under the 2011 ANSI Standard.'' Accordingly, a transition period will ease the burden on handset
manufacturers that are close to introducing handsets that would have met hearing aid compatibility
requirements under the old rules, but that without an accommodation would require retesting, or in some
cases redesign, to be hearing aid-compatible under the new rules.
16. Most commenters that address the issue support the 12-month transition period proposed
in the Second Further Notice as sufficient to meet manufacturers' needs.43 TIA argues that a 24-month
transition period is needed to allow sufficient time for laboratory equipment to be developed and tested,
as well as to accommodate possible parts shortages and other unexpected developments.44 In its
comments, TIA does not distinguish clearly between the transition period for multi-band and multi-mode
testing and the transition period for applying deployment benchmarks, and to the extent it is concerned
about uncertainties that may affect when models can be introduced to or withdrawn from the market, its
arguments appear to pertain only to the separate transition for applying existing deployment benchmarks.
To the extent TIA is concerned about the availability of testing equipment, we note that nearly 10 months
have already passed since the 2011 ANSI Standard was published, and that manufacturers have had the
opportunity to use that time to develop such equipment. We are not persuaded that an additional 24
months is needed, particularly in light of the other comments from manufacturers and service providers
indicating that 12 months is sufficient.
17. We clarify that during the 12-month transition period, manufacturers that choose to test a
multi-band and/or multi-mode handset model only for those operations covered under the 2007 ANSI
Standard must use the 2007 ANSI Standard for such testing. Conversely, if manufacturers choose to use
the 2011 ANSI Standard, they must test all operations in the handset that fall within the 2011 ANSI
Standard, subject only to an accommodation for VoLTE transmissions. We find that permitting use of the
2011 ANSI Standard to test only those operations covered under the 2007 ANSI Standard would be
confusing and would discourage early testing of newly covered air interfaces and frequency bands.5
Some commenters express concern that, given the lack of guidance for testing the inductive coupling
capability of VoLTE transmissions, a simple choice between these two alternatives would make it
impossible to test any handset with VoLTE capability under the 2011 ANSI Standard for any of its
operations.46 In recognition of this concern, until such guidance is issued during the 12-month transition
period, OET will permit handsets to be certified for inductive coupling under the 2011 ANSI Standard if
they meet at least a T3 rating for all operations covered under that standard other than for VoLTE.47
Manufacturers and service providers will be required to disclose that such handsets have not been tested
for all their operations as discussed below.48 We expect that during the next 12 months, industry
members will work with the standards bodies to finalize all guidance necessary to facilitate full
application of the 2011 ANSI Standard, and we will provide all possible support to this endeavor. In the
42 See Second Further Notice, 26 FCC Rcd at 14996 9 ("We understand that most handsets are expected to have
little difficulty meeting the hearing aid compatibility rating criteria over Wi-Fi and other currently existing or
imminently expected air interfaces that are outside the 2007 ANSI Standard.")
43 See CTIA Reply Comments at 6-7; HIA Comments at 2, 3-4; Samsung Comments at 4.
44 TIA Comments at 4; TIA Reply Comments at 2-3.
4 Accordingly, we revise Section 20.19(b)(3)(ii) of our proposed rule to clarify that the 2007 ANSI Standard must
be used for these tests during the 12-month transition period. See infra App. B.
46 See AT&T Reply Comments at 3-4; CTIA Reply Comments at 7-10; Samsung Comments at 4-5.
47 Alternatively, to the extent a manufacturer is able to test inductive coupling capability for VoLTE transmissions
under the 2011 ANSI Standard prior to the issuance of general guidance, OET will accept such testing if it meets
OET's standards under 47 C.F.R. 2.1033(d).
4 See infra note 48.
Federal Communications Commission
United States. Federal Communications Commission. FCC Record, Volume 27, No. 5, Pages 3728 to 4696, April 9-April 27, 2012. Washington D.C.. UNT Digital Library. http://digital.library.unt.edu/ark:/67531/metadc102307/. Accessed August 30, 2014.