Telecom Report 2007-03-12
From TEITAC
Proposed report format template for TEITAC subcommittee reports, 3/12/07
Reports should address each of the following categories.
I. Material which can be described as “Changes to Existing Provisions”
- Modification – Material which modifies existing provisions.
- Rationale – Why is this change suggested?
| Current provision | Keep current language | Change in Jurisdiction? | Modification | Rationale: Why is this change suggested? |
|---|---|---|---|---|
| 1194.23(a) | no | (a) Telecommunications products or systems that provide a function allowing voice communication and do not themselves provide TTY or other text conversation functionality:
| ||
| 1194.23(b) | no | (b) Telecommunications products, which include voice communication functionality, shall support the EIA/TIA 825 Baudot | ||
| 1194.23(c) | no | (c) Voice mail, messaging, auto-attendant, and interactive voice response telecommunications systems shall:
| ||
| 1194.23(d) | (d) Voice mail, messaging, auto-attendant, and interactive voice response telecommunications systems that require a response from a user within a time interval, shall give an alert when the time interval is about to run out, and shall provide sufficient time for the user to indicate more time is required. | |||
| 1194.23(e) | (e) Where provided, visual interfaces for telecommunications status information such as caller identification and similar telecommunications functions as part of interactive voice response systems or equivalents shall also be available for users of TTYs or other text conversation systems, and for users who cannot see displays and shall meet all accessibility provisions for software and content. | |||
| 1194.23(f) | (f) For receive transmitted voice signals,
| We need to decide how to address the difference between the gain level in HAC and 508. Do we want to differentiate between line-powered products and externally powered? We need to decide on a gain level.
1* There is a problem is measurement of gain from variable floor. Recommend standard for the floor from which the adjustable gain is measured by developed by TIA. | ||
| 1194.23(g) | (g) If the telecommunications product allows a user to adjust the receive volume, a function shall be provided to automatically reset the volume to the default level after every use if the volume is capable of greater than 18 dB of gain along with an option for user override of that automatic default. | Is there a need to have a max output specified to prevent the gain from exceeding that level? | ||
| 1194.23(h) | (h) Where a telecommunications product delivers output by an audio transducer which is normally held up to the ear, a means for effective magnetic wireless coupling to hearing technologies shall be provided that allows the user of such technologies to effectively utilize the telecommunication product. This guideline shall apply to wireless, wireline, cordless and Bluetooth ?? applications.. | |||
| 1194.23(i) | (i) Interference to hearing technologies (including hearing aids, cochlear implants, and assistive listening devices) shall be reduced to the lowest possible level that allows a user of hearing technologies to utilize the telecommunications product. | Should metrics be added like the TIA cordless standards?? or a reference to ANSI/IEEE?? or other standards?
Do we want to reference FCC regs for wireless technologies? | ||
| 1194.23(j) | (j) Products that transmit or conduct information or communication shall pass through cross-manufacturer, non-proprietary, industry-standard codes, translation protocols, formats or other information necessary to provide the information or communication in a usable format.
Technologies which use encoding, signal compression, format transformation, or similar techniques shall not remove information needed for access or shall restore it upon delivery. | |||
| 1194.23(k) | (k) Telecommunications products or systems which have the capacity to transmit video, text and voice communications shall support internet protocol text and voice communications in X format and have sufficient transmission bandwidth capacity to support video communication such as video relay and point to point video communications. | What did we decide to do about firewall problems? | ||
| | Move to Closed Products |
|
ALTERNATE PROPOSAL FOR ENTRIES (SO THE ABOVE ONE WAS NOT DESTROYED
| Current provision | Keep current language | Change in Jurisdiction? | Modification | Rationale: Why is this change suggested? |
|---|---|---|---|---|
| 1194.23(a) | no | 1194.23(a1) Telecommunications products or systems that provide a function allowing voice communication and do not themselves provide TTY for PSTN or the standard real-time IP text format for IP systems:
1194.23(a2) Telecommunications products or systems that provide a function allowing voice communication and have sufficient bandwidth to support real-time video signing but do not themselves provide real-time video communication sufficient to support signing:
| 1) We need to change the TTY provisions to reflect the new IP networks. If we don't want to call IP Telephones as ‘telecom’ then we can change the name of this group. But I think this group needs to be the one that talks about VoIP phones.
2) The TTY provisions should be rewritten to say something like “TTY for PSTN system and IPText for IP systems” 3) “other text conversation functionality” it too vague. People converse on email and SMS even thought turn around times of 7 min are not unusual for SMS. Suggest we add ‘real-time’ 4) Having “a text conversation’ function is not sufficient. There has to be a standard one that is supported by all or transcoded to a standard one or you can't have end to end conversation. WE can punt as to what it is maybe (probably not a good idea but….) but we need to specify that the standard is used. 5) We need to treat video as separate because video cannot substitute for text. Although it is so much faster when people on both ends sign, it will not work for the majority of people who cannot sign. | |
| 1194.23(b) | no | 1194.23(b) Telecommunications products, which include voice communication functionality, shall support the standard real-time text protocol for that medium:
(1) on PSTN they shall support EIA/TIA 825 Baudot standard TTY signal protocol. (2) on IP networks they shall support ITU T-140 and RFC 4103 or shall be capable of converting to this. | ||
| 1194.23(c) | no | (c) Voice mail, messaging, auto-attendant, and interactive voice response telecommunications systems shall:
| ||
| 1194.23(d) | (d) Voice mail, messaging, auto-attendant, and interactive voice response telecommunications systems that require a response from a user within a time interval, shall give an alert when the time interval is about to run out, and shall provide at least 10 seconds for the user to indicate more time is required by hitting any key (if a specific key is required then 20 seconds shall be provided). | |||
| 1194.23(e) | (e) Where provided, caller identification and similar telecommunications functions shall also be available for users of real-time text communication systems specified in 1194.23(b), and for users who cannot see displays. | |||
| 1194.23(f) | (f) For receive transmitted voice signals,
| We need to decide how to address the difference between the gain level in HAC and 508. Do we want to differentiate between line-powered products and externally powered? We need to decide on a gain level.
1* There is a problem is measurement of gain from variable floor. Recommend standard for the floor from which the adjustable gain is measured by developed by TIA. | ||
| 1194.23(g) | (g) If the telecommunications product allows a user to adjust the receive volume above 80 Db SPL , a function shall be provided to automatically reset the volume down to 80 Db SPL | "no need to reset volume unless it is very loud. very frustrating if you do for all users. Is there a need to have a max output specified to prevent the gain from exceeding that level? {Don't think so. already regs against going over 120 db spl arent there? } | ||
| 1194.23(h) | (h) Where a telecommunications product delivers output by an audio transducer which is normally held up to the ear, a means for effective magnetic wireless coupling to hearing technologies shall be provided that allows the user of such technologies to effectively utilize the telecommunication product. This guideline shall apply to wireless, wireline, and cordless applications.. | No need for 'bluetooth' it is a peripheral technology - not a telecom technology. we dont want to require that every bluetooth headset conform to this. | ||
| 1194.23(i) | (i) Interference to hearing technologies (including hearing aids, cochlear implants, and assistive listening devices) shall be reduced to the lowest possible level that allows a user of hearing technologies to utilize the telecommunications product. | Need to specify metrics like the TIA cordless standards?? or a reference to ANSI/IEEE?? or other standards?
Do we want to reference FCC regs for wireless technologies? | ||
| 1194.23(j) | (j) Products that transmit or conduct information or communication shall pass through cross-manufacturer, non-proprietary, industry-standard codes, translation protocols, formats or other information necessary to provide the information or communication in a usable format.
Technologies which use encoding, signal compression, format transformation, or similar techniques shall not remove information needed for access or shall restore it upon delivery. | |||
| 1194.23(k) | (k) “All of the information that is presented visually by a telephone must be available via a non-visual mechanism to blind or visually impaired users of that telephone.” | |||
| 1194.23(k) | (l) Telecommunications products or systems which have the capacity to transmit video, text and voice communications shall support internet protocol text and voice communications in X format and have sufficient transmission bandwidth capacity to support video communication such as video relay and point to point video communications. | What did we decide to do about firewall problems? | ||
| | Move to HARDWARE |
|
ALL OF THE 255 PROVISIONS ALSO NEED TO BE PUT IN HERE SOMEWHERE. WE ARE ALSO SUPPOSED TO REVIEW THOSE REGULATIONS.
NOTE: On the last call there was some confusion about the 255 regs. The 255 regulations are regulations just like 508. They both are in the CFR (Code of federal regulations).
- 508 is part 1194 of Chapter X1 of title 36 of the Code of Federal Regulations (CFR)
- 255 regs are parts 6 and 7 of title 47 of the Code of Federal Regulations (CFR)
- The 255 regulations were adopted by the FCC and added to the other FCC regulations via Clause 194 of the FCC report and order (the 3rd ORDER CLAUSE in the Report and Order) which reads:
- " 194. IT IS FURTHER ORDERED that 47 C.F.R. Parts 6 and 7 ARE ADOPTED as set forth in Appendix B, effective seventy (70) days after publication of the text thereof in the Federal Register. "
- The 255 regulations were adopted by the FCC and added to the other FCC regulations via Clause 194 of the FCC report and order (the 3rd ORDER CLAUSE in the Report and Order) which reads:
If we believe in harmonization, we certainly want 255 and 508 (Both parts of the CFR) to be harmonized with each other !
Lots of work to do.
II. Entirely New Provisions
| New provision | Rationale: What issue does this provision address? |
|---|---|
