Telecom Report 2007-04-18

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Template for TEITAC subcommittee reports, 2nd drafts (due 4/18/07)

Please submit this draft as cumulative – show the complete draft to date, not just changes from the first draft.

Contents

I.  Material which can be described as “Changes to Existing Provisions”

  1. Modification – Material which modifies existing provisions.
  2. Rationale – Why is this change suggested?
  3. Estimate Economic Assessment.  This field should contain the Subcommittee’s rough guess of expense to implement a revised provision.  These changes should be measured from the current 508 standard only.  For example, if the provision is not different, there is no net economic impact.  Code as:
    • “0” for negligible economic impact;
    • “+” for minor economic impact;
    • “++” for significant economic impact.


Current provision Keep current language? Change in jurisdiction? Modification Rationale:  Why is this change suggested? Economic Assessment
1194.23(a) no no (a) Telecommunications products and other products capable of providing real-time voice communications and do not themselves provide TTY or other real-time text conversation functionality:
  1. shall provide a standard non-acoustic connection point for TTYs all analog and TDM-digital wired telephones must be equipped with an RJ11 jack or have built in capability to support an RJ11 module that can provide a connection point for TTYs;
  2. A terminal that does not have send and receive capability for real-time text shall support the connection of real-time text capable devices in conjunction with the voice call capability in the same location and the same permissions for use as the terminal.  NOTE: Terminals can be hardware or software based.
  3. shall be capable of allowing simultaneous speech and text without interference or its microphone shall be capable of being turned on and off to allow the user to intermix speech with text [TTY] use.
Is there a legal def of real-time comm?  Proposed Definition:  Two-way communcations that employ transmission of conversational, remote interactions wherein the characters are transmitted w/in 1 sec. of time created.  
1194.23(b) no no (b) Products that provide real-time voice conversation text functionality shall do so in the standard format that is supported for that transport medium.
  1. products that connect directly to the PSTN shall support TIA 825 Baudot where they interface to the PSTN;
  2. Products that connect directly to the Internet via SIP shall support RFC 4103 where they interface to the Internet via SIP
  3. All other Products (including PBX, cellular, and peer to peer Internet phones) that do not connect to PSTN or use SIP over the Internet shall support the standard real-time text format for that system.  These systems only need to support TIA 825 Baudot at the juncture to the PSTN (if any) and only need to support RFC 4103 at the point where they connect to public SIP systems (if any).
   
1194.23(c) no no (c) Voice mail, messaging, auto-attendant, and interactive voice response telecommunications systems shall:
  1. be usable by TTY users with their TTYs and by individuals using relay services including voice carry over, hearing carry over, video relay, and speech-to-speech relay services,
  2. have audio capability sufficient for high intelligibility,
  3. have highly intelligible recorded messages and prompts without any background sounds that would reduce intelligibility,
  4. provide full player controls that allow users to pause, rewind, slow down and repeat all messages and prompts, and adjust volume,
  5. include menus that contain no more than 6 items,
  6. provide easy to understand and act upon menu items and other navigational messages,
  7. provide controls that are consistent throughout the application,
  8. allow the user to correct any errors or confirm any input that would lead to permanent changes in their account or profile
  9. Have an “easy out” to reach a live customer service representative.
   
1194.23(d) yes no (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. n/a 0
1194.23(e) no no (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. Issue:  Does mute have to be its own button, not a function softkey?  
1194.23(f) no no (f) For receive transmitted voice signals,
  1. line powered telecommunications products shall comply with FCC regulation §68.317 for volume control,

OR

  1. * telecommunications products shall provide a built in gain adjustable up to a minimum of 20 dB.  For incremental volume control, at least one intermediate step of 12 dB of gain shall be provided.
  2. all other telecommunications products or systems that provide a function allowing voice communication shall provide a gain adjustable up to a minimum of 20? dB with [.For] incremental volume control of at least one intermediate step of 12 dB of gain [shall be] provided as measured and documented in accordance with the provisions of the FCC regulation &sect68.317 for volume control.
   
1194.23(g) no no (g) If the telecommunications product allows a user to adjust the receive volume, a function shall be provided to automatically reset the volume to a safe 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.    
1194.23(h) no no (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) yes no (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.   0
1194.23(j) yes no (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.  Firewalls, routers, gateways and other products that pass real-time voice communication shall also pass real-time text communication signals (including mixed voice & real-time text) that are standard for that technology platform without distortion or error beyond 1%.
  1. for PSTN this would be TIA/EIA 825 Baudot.

NOTE:  Only phones that are passing text signals onto another device, e.g. TTY, would be subject to this provision.

   
1194.24(k)   YES (k) Products which have mechanically operated controls or keys, shall comply with the following... Moved to HARDWARE  

 

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II.  New Provisions

New provision Rationale:  What issue does this provision address? Economic Assessment
(x)  The user interface of IP terminals that provide real-time voice communication shall meet the following provisions:
  1. IP terminal user interfaces that have a multiline display shall display any real-time text that is received in the standard format for that platform;
  2. IP terminal user interfaces that have the ability to generate text shall allow sending real-time text in the standard real-time text format for that platform;
  3. Such real time text send and receive capabilities shall be synchronized with voice as part of the same communication session.
IP version of 1194.23(a) Cheaper, easier to do than hardware to t/c products.
(x) Systems that support real-time voice communication shall support at least one standard (for the system) means for real time text communication that is supported by all terminal, router, gateway and other products on that system, and that meets the following requirements:
  1. Provides transmission of character with less than 1 second delay from entry;
  2. Provides transmission with less than 1% character error under normal but heavy network traffic;
  3. Support intermixing of speech and text in both directions (simultaneously if and only if IP based).
  4. IP systems cannot rely upon audio channels for transmission of real-time text.
IP version of 1194.23(b)  


 

III.  Other Material

A.  Recommendations on organization of the provisions

 


B1.  Issues this subcommittee has not yet addressed, but which should be addressed.

  • the 255 provisions. They overlap with 508 almost exactly but we have not yet looked at them specifically. Need to if we are to have harmonization. Access Board and US Gov should at least harmonize with itself.

B2.  Issues this subcommittee is not addressing, but which should be addressed.

 


C.  Recommendations regarding process: the work of the subcommittees, the whole Committee, liaison with the Access Board, etc.

 

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