Thread Subject: Re: FW: TIA Request for Guidance(TEITACDiscussionsof 2006.11.13)
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From: Diane Golden
Date: Sun, Nov 19 2006 3:45 PM
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I'm still not following what has happened with federal procurements related to the gain/volume control requirement. There are products commercially available that deliver the 20 dB gain. They are just not the typical business phone set (especially in terms of cost). The gain/VC standard could be met with a different handset or with a phone set that is built to deliver the required gain/VC. Both are commercially available yet if I understand correctly, none have been purchased under a federal soliciation. Paul indicates that Avaya has bid on phone solicitations with the substitute handset but the phone configured that way is not procured due to cost --even though that configuration meets the 508 standard. So this doesn't appear to be an issue of commercial availability. Instead it appears cost considerations are over-riding conformance to this particular access standard in the decision making process. Is there another explanation?
----- Original Message ----
From: " = EMAIL ADDRESS REMOVED = " < = EMAIL ADDRESS REMOVED = >
To: = EMAIL ADDRESS REMOVED = ; TEITAC Telecommunications Subcommittee < = EMAIL ADDRESS REMOVED = >
Sent: Wednesday, November 15, 2006 3:06:15 PM
Subject: Re: [teitac-telecom] FW: TIA Request for Guidance (TEITACDiscussionsof 2006.11.13)
The federal procurement process involves requirements definition followed by market research followed by (possibly) refinement of requirements and the development of the actual solicitation document.
So, if I am looking to acquire a phone system and I have my business requirements (number of sets, features, service, etc) and my accessibility requirements (mostly 1194.23 plus a few additional provisions) I need to find out if what I want (and I am going to ask to have proposals submitted for) actually is commercially available. If not, I have to either refine my requirements before my RFP/Q/I is posted or run the risk of modifying my solicitation during the actual procurement process. If there are not products that fully meet the Standard, I need to define my requirements accordingly.
An agency complies with Section 508 when it follows the entire process - including exceptions. Fully complying with all of the applicable provisions is a high bar and most products have some area where they won't fully meet. I, as a federal buyer, need to acquire the product that best meets my requirements (which include business needs and accessibility). If there are additional accessibility features that are not commercially available (or not by enough vendors to comply with the Competition in Contracting Act requirements), then my agency may chose to award extra value to products that give me more accessibility.
"Diane Golden" < = EMAIL ADDRESS REMOVED = >
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11/15/2006 03:04 PM Please respond to
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"TEITAC Telecommunications Subcommittee" < = EMAIL ADDRESS REMOVED = >
To"TEITAC Telecom listserv (E-mail)" < = EMAIL ADDRESS REMOVED = >
SubjectRe: [teitac-telecom] FW: TIA Request for Guidance (TEITACDiscussionsof 2006.11.13)
Thanks for the VPAT narrative example. So as a rater/reviewer, I would have
to say the base product bid does NOT conform to that standard. The base
product does not provide 20 dB of gain as is required by the standard so it
does not conform. Is that how federal procurement reviewers have been
rating conformance to that standard? Does a phone with 15 dB of gain
"better conform" using the "best meets" language of 508?
From: John Combs (jcombs) [mailto: = EMAIL ADDRESS REMOVED = ]
Sent: Wednesday, November 15, 2006 1:50 PM
To: = EMAIL ADDRESS REMOVED = ; TEITAC Telecommunications Subcommittee
Subject: RE: [teitac-telecom] FW: TIA Request for Guidance
Speaking from a manufacturer's standpoint, on our ITI-format Voluntary
Product Accessibility Template (VPAT) for the 20 dB amplification
requirement, we state:
"Supports when combined with compatible Assistive Technology"
"Cisco IP Phones meets the FCC 68 requirements for volume gain of
minimum of 12dB of gain from default factor setting. To achieve 20dB or
greater, Cisco recommends using an inline amplifier, such as Walker
Clarity CE-125, or Ameriphone Clarity HA-30. The Plantronics Clarity
EC225/ECE225* inline amplifier is an example of a manufacturer selling
3rd party handset and headset amplifiers. Recommended headset
amplifiers can be viewed through the following URL:
Most of our IP phones actually have 15 dB of gain, but for some reason
no one wrote that into our VPAT!
- John Combs
P.S.: Web link to info about the HA-30 & CE-125 inline handset cord
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Diane
Sent: Wednesday, November 15, 2006 10:21 AM
To: 'TEITAC Telecommunications Subcommittee'
Subject: Re: [teitac-telecom] FW: TIA Request for Guidance
So if in reality the phones coming to federal procurers or looked at
during market research do NOT meet the 20dB gain standard - how have
those products been reviewed/rated in terms of conformance to that
access requirement? What is the thinking in the purchase decision
making process? Do the phones with 15 get some sort of bonus over those
with just 12? Can any of the federal purchasers on this listserv
Diane Cordry Golden, Ph.D.
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ]On Behalf Of Rebecca
Sent: Wednesday, November 15, 2006 9:14 AM
To: TEITAC Telecommunications Subcommittee
Subject: [teitac-telecom] FW: TIA Request for Guidance (TEITAC
Hi, all, this is Steve Whitesell's response to the question raised on
Monday's conference call as to whether there are phones capable of
exceeding 12 db gain without significant battery drain. The short
answer is no, but please read his entire response.
Rebecca Schwartz, Esq.
Manager, Regulatory and Government Affairs TIA 2500 Wilson Blvd. Ste.
300 Arlington, VA 22201
From: Steve Whitesell [mailto: = EMAIL ADDRESS REMOVED = ]
Sent: Wednesday, November 15, 2006 1:42 AM
To: Rebecca Schwartz
Cc: John Derr; Bill Belt
Subject: TIA Request for Guidance (TEITAC Discussions of 2006.11.13)
I am responding to John Derr's request below.
I believe most mass market telephones provide receive volume controls
a gain in the 12 to 15 dB range. There may be some that provide more,
I am not aware of specific models that I can point to. If you want, I
could contact representatives of Uniden, Panasonic, and Thomson (GE
to ask that question. I can tell you that VTech phones (VTech and AT&T
brands) have gains in the 12 to 15 dB range.
If there are any mass market phones providing greater gain, they are
likely ac powered corded telephones. Simple telephone-line-powered
telephones like the basic 500 set and the Trimline(R) simply do not have
enough power available to them from the telephone line to provide gains
the order of 20 dB. Likewise, most cordless handsets do not have the
voltage swing capability to provide that much gain without introducing
severe distortion. I would think that corded telephones operating on
provided from a plug in wall transformer could be designed to provide
higher receive gain levels, but there are not that many of them in the
It is probably worth pointing out that the FCC rules on volume control
specify gain with respect to a "nominal" starting value that has to be
within certain limits on loudness. It is possible to create a larger
"range" by having low volume settings below the nominal value in
to having high volume settings above it. But to meet the FCC
requirements, a product has to have at least 12 dB of gain above the
nominal value. Additional "range" achieved by having volume settings
the nominal value does not count from the viewpoint of FCC compliance.
Please feel free to contact me if you have further questions on this
subject or at any time you feel I can be of help.
Stephen R Whitesell
Chair, TIA TR-41
Senior Technical Consultant
Standards, Regulatory, and
Intellectual Property Matters
2 Shannon Ct
Howell, NJ 07731
Tel: 732 751 1079
Email: = EMAIL ADDRESS REMOVED =
----- Forwarded by Steve Whitesell/ENG/VTNCAN/VTECH on 11/15/2006 12:11
<JDerr@tiaonline. To: "Steve
Whitesell" < = EMAIL ADDRESS REMOVED = >
org> cc: "Bill Belt"
< = EMAIL ADDRESS REMOVED = >, "Rebecca
< = EMAIL ADDRESS REMOVED = >
11/14/2006 12:44 Subject: TIA Request for
Guidance (TEITAC Discussions
PM of 2006.11.13)
Good Afternoon Steve,
Hope all going well for you as we start to head into Thanksgiving
season. You may be aware that TIA just added a new attorney to our
External Affairs Department, Rebecca Schwartz. Becky was on yesterday's
TEITAC Telecom call where the group was having discussions regarding,
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