Before the
FEDERAL COMMUNICATIONS COMMISSION
Washington, D.C. 20554

In the Matter of					)
							)
Implementation of Section 255 of the			)
Telecommunications Act of 1996			)
							)	WT Docket No. 96-198
Access to Telecommunications Services,		)
Telecommunications Equipment, and			)
Customer Premises Equipment by			)
Persons with Disabilities				)



REPLY COMMENTS OF BELL ATLANTIC ON NOTICE OF INQUIRY1


	The record here demonstrates that Commission action is not needed to ensure that voice-grade services (including such capabilities as TTY and fax services) using Internet protocol technology and/or carried over the Internet are and will continue to be accessible to persons with disabilities.
	Instead, the comments show that the industry is very sensitive to the needs of persons with disabilities and will voluntarily make their services accessible, if readily achievable, without being prodded by additional regulatory requirements.  For example, the Voice On the Net coalition relates a number of fora and standards initiatives, as well an individual company efforts, designed to make packet-based telephony applications accessible to persons with disabilities.  Comments of the VON Coalition at 5-12.  See also Comments of iBasis, Inc. In the Further Notice of Inquiry at 3-4 (citing voluntary efforts to achieve accessibility), Comments of Level 3 Communications, LLC at 5-6 (citing the industry's commitment to providing access by persons with disabilities to next generation services), MCI WorldCom, Inc. Comments at 2-4 (showing how Internet protocol networks will be compatible with devices used by persons with disabilities).
	As a result, it is premature for the Commission to consider any regulatory action in this area, because the industry appears to be well on its way to meeting the needs of the disabled community on its own.2  In the unlikely event that the voluntary actions cited in the comments fail to provide the needed access, the Commission can quickly revisit the issue.
						Respectfully Submitted,

		
					            ____________________________
						Lawrence W. Katz
Michael E. Glover
    Of Counsel						1320 North Court House Road
						8th Floor
						Arlington, Virginia  22201
						(703) 974-4862

						Attorney for the Bell Atlantic
							telephone companies
February 14, 2000
1  The Bell Atlantic telephone companies ("Bell Atlantic") are Bell Atlantic-Delaware, Inc.; Bell Atlantic-Maryland, Inc.; Bell Atlantic-New Jersey, Inc.; Bell Atlantic-Pennsylvania, Inc.; Bell Atlantic-Virginia, Inc.; Bell Atlantic-Washington, D.C., Inc.; Bell Atlantic-West Virginia, Inc.; New York Telephone Company; and New England Telephone and Telegraph Company.
           2  Similarly, the Commission need not consider here whether telephony services using Internet protocol should be classified as telecommunications or information services.  Such classification has regulatory implications well beyond section 255, such as for universal service and payment of access charges, and this narrow proceeding is not the appropriate place to address these issues.  In addition, given the lack of notice, the Commission cannot lawfully address here the regulatory status of electronic mail and other text-based services, as the American Foundation for the Blind requests.  See 5 U.S.C. ( 553(b).
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