FCC Seeks Comment on New HAC Rules

The Commission released a Notice of Proposed Rulemaking (“NPRM”) on the Revisions to Reporting Requirements Governing Hearing Aid-Compatible Mobile Handsets, adopted at the September Open Meeting on Tuesday, September 26.  The NPRM seeks comment on revising the hearing aid compatibility reporting requirements for non-nationwide service providers to reduce regulatory burdens, and on whether the benefits of requiring an annual status report filing continues to outweigh the burdens of this information collection.

The NPRM seeks comment on the following proposals:

  • FCC Form 655 Exemption:  whether to exempt a service provider that is not a Tier 1 carrier (“Non-Tier 1 Service Provider”) from the annual FCC Form 655 reporting requirements, and whether those requirements are still necessary to meet overall goals and deployment benchmarks.  For example, it seeks comment on the extent to which consumers rely on those reports, if consumers can obtain that information via third parties, and potential cost benefits of the proposed exemptions.  Additionally, the NPRM inquires into what materials and reports the Commission should rely on in helping to ensure Non-Tier 1 Service providers meet deployment benchmarks and other requirements, and to gauge the success of HAC models.
  • Alternative Size Standard:  whether the scope of any exemption should be based on an alternative definition of carrier and size standard.  A Non-Tier 1 Service Provider exemption would cover all non-nationwide providers, but under an alternative definition, it could instead be based on the number of subscribers.
  • Alternative Reporting Period or Certification:  alternative methods to reduce burdens associated with reporting requirements, if the Commission finds it is not in the public interest to eliminate the requirements completely.
  • Timing:  when a reporting exemption or modified reporting requirement would become effective if the Commission were to adopt such an approach, i.e., at a certain point in time, or once a provider has met a certain threshold.
  • Related Changes:  whether any changes to other aspects of the HAC requirements would be necessary or appropriate to accommodate or reflect a reporting exemption or modified requirement for Non-Tier 1 Service Providers.  For example, whether the FCC should retain the de minimis exception rule, and any other subsequent changes to Section 20.19 if the rules depend on variable factors.
  • Other Updates:  additional ways to streamline or update HAC reporting for all service providers, considering less costly ways to meet current and future deployment benchmarks, handset reporting, compliance tracking, and any other proposed changes with a cost benefit analysis of current and proposed collections.

The comment dates, pursuant to the Federal Register are as follows:

Comments are due November 13, 2017. Reply Comments are due November 27, 2017.

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