FCC Record, Volume 27, No. 5, Pages 3728 to 4696, April 9 - April 27, 2012 Page: 3,737
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12. While supporting adoption of the 2011 ANSI Standard, some commenters ask the
Commission to provide additional guidance on certain testing techniques under the standard so that test
equipment can be developed and the relevant tests applied. In particular, Samsung states that guidelines
are required to facilitate use of the Modulation Interference Factor (MIF) testing technique.28 Similarly,
some commenters contend that guidance is necessary to enable hearing aid compatibility testing under the
2011 ANSI Standard for Voice over Long Term Evolution (VoLTE) transmissions.29 We anticipate that
the manufacturers and standards bodies working with OET will be able quickly to develop guidance for
the MIF testing techniques and for determination of the M rating for VoLTE transmissions. To the extent
such guidance has not been issued, OET will work with manufacturers to the extent of its authority so that
the manufacturers can provide test reports that sufficiently demonstrate compliance with the rules as
required by Section 2.1033(d) of the rules.30 We recognize, however, that it may take longer to develop
guidance for testing the inductive coupling capability of VoLTE transmissions under the 2011 ANSI
Standard. Accordingly, as discussed below, until such guidance is issued, OET will adapt its certification
procedures so that manufacturers can use the 2011 ANSI Standard for these handsets during a 12-month
transition period.3" We further note that under the rules we adopt today, as an alternative to using the
2011 ANSI Standard, handsets introduced during the 12-month transition period may be tested under the
2007 ANSI Standard for their operations that are covered under that standard and treated as hearing aid-
compatible only for those operations.32 Finally, because Section 2.1033(d) currently refers to the U-
ratings that were used in early versions of ANSI Standard C63.19,33 we also take this opportunity to
conform this rule to the terminology used in the 2007 and 2011 ANSI Standards. We find good cause not
to provide public notice and an opportunity for comment on this rule change under Section 553(b)(3)(B)
of the Administrative Procedure Act because the change is purely ministerial and necessary to conform
the Commission's written rules to ANSI Standard C63.19.3'
13. In addition to the need for technical guidance, commenters raise two other issues related
to the 2011 ANSI Standard. While it supports the standard's adoption, HIA is concerned that certain low
power devices that are deemed M4 without testing under the 2011 ANSI Standard because they are
unlikely to cause interference may in fact cause interference to hearing aids.35 As HIA suggests, we will
work with ASC C63 to monitor how these handsets perform and will consider future action if needed.
28 See Samsung Comments at 4-5: see also TIA Comments at 4 (stating that additional transition time is necessary
so that the Commission can issue guidance and MIF testing equipment can be developed).
29 See AT&T Reply Comments at 3; CTIA Reply Comments at 9-10; Samsung Comments at 5. VoLTE is a
technology that will enable LTE systems, which were originally designed for data, to be used for voice
communications. Because VoLTE has not yet been implemented, handsets that include LTE capability currently
rely on other air interfaces for voice transmissions. VoLTE refers to the native voice capability of an LTE system,
and it is distinguished from Voice over Internet Protocol capability that may be provided over LTE through a third-
party application. Questions regarding hearing aid compatibility testing for voice capabilities offered through third-
party applications will be addressed separately by the Commission. See Second R&O and Further Notice, 25 FCC
Rcd at 11198-99 89 (seeking comment on how rules should address circumstances where voice capability may be
enabled by a party other than the manufacturer).
30 47 C.F.R. 2.1033(d).
*3 See infra para. 17.
32 See infra paras. 14-20.
33 See 47 C.F.R. 2.1033(d).
34 5 U.S.C. 553(b)(3)(B); see also 47 C.F.R. 0.241 l(a)(1) (delegating authority to OET to make editorial changes
3 HIA Comments at 4.
Federal Communications Commission
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United States. Federal Communications Commission. FCC Record, Volume 27, No. 5, Pages 3728 to 4696, April 9 - April 27, 2012, book, April 2012; Washington D.C.. (digital.library.unt.edu/ark:/67531/metadc102307/m1/26/: accessed June 18, 2018), University of North Texas Libraries, Digital Library, digital.library.unt.edu; crediting UNT Libraries Government Documents Department.