Thread Subject: Re: VoIP enabled cell phones
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From: Owen Rachal
Date: Fri, Dec 15 2006 7:15 PM
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Tenacity is currently researching this very issue. I am compiling the info that we have gathered and will get it out to the Subcommittee early next week. In the meantime, any input anybody else would like to offer would of course be appreciated. In particular, I am interested in what Dr. Michaelis and John Combs have to say about the subject. They may be able to save us some time.
But David: was the request for VOIP enabled CELL phones or just VOIP? The two are pretty significantly different as I understand it, though I am just now researching the wireless industry. VOIP systems actually have to convert information from cell phones to enable users within the VOIP network to talk to cell phone users, much like what happens with analog users. I will consult with our development team, but I am unaware of any VOIP cell phone trends with regard to TTY. Now, I do know that many cellular manufacturers are making cell phones that also make wifi calls over VOIP networks, and many VOIP manufacturers are working on mobile wifi phones for use similar to cell phones within covered areas. Additionally, it is possible to install a SIP phone on a smart phone and thus have a DIY VOIP cell phone. Is one of these what you are describing? If not, hopefully the info I am compiling will shed some light on the subject.
Of course, VOIP and TTY is a significant enough issue without the wireless component. Currently, a number of text standards are being pushed, both by noncommercial sources as well as telecomm manufacturers. I believe it is safe to say that VOIP in general cannot be said to be TTY-accessible, but rather certain VOIP systems have the competitive advantage of additional (analog?) technologies that make them TTY-accessible.
It is Tenacity's very strong belief that explicit mention of VOIP should be included throughout accessibility legislation - or at the very least, it should be explicitly mentioned that when a technology such as telephony is mentioned, it includes ALL permutations of that technology. While we feel that including VOIP within the broader subjects of "telephony" and "telecommunications" should be a simple and intuitive concepts for anyone reading the letter of the law, evidently that interpretation has not been shared by many VOIP stakeholders. Users perceive VOIP telephones to be just like any other phone and are equally angry when they find that they have in fact LOST accessibility when their empoyer switches to a "more powerful and functional" hi-tech VOIP phone system. While telephony has moved forward, accessibility with regards to telephony has not done so with some manufacturers -- although not all.
Finally - and I have been trying to figure out how to explain this model perfectly, so this may come out kind of muddled - but can we not include language sggesting that the core functionality of a product is what must be made accessible, instead of telling developers HOW to make things accessible? As one example, instead of saying "phones must be accessible to TTYs", why not say that "a user dependent upon text communication must be able to utilize text to communicate with other text-based communications devices, including TTYs." It seems to me that text communication from the phone to another TTY is as good as or better than installing a jack and an audio codec that enables a user to attach a TTY to an otherwise inaccessible phone. Additionally, the TTY-accessible model phone has the disadvantage of requiring additonal technology from the user, which prevents 1) the TTY-dependent user from being able to simply walk up to any phone and use it, such as when you borrow somebody else's phone to place a call, 2) the TTY dependent user from communicating if they do not have a functional TTY, such as if it breaks, is lost or stolen, etc., and 3) the TTY-independent user from being able to freely communicate with a TTY-dependent user. This seems to me to be a form of discrimination itself -- the TTY dependent user cannot freely talk in every situation nor with anyone they would want to talk with. Why not say that every phone should be able to send text to any other phone, which would allow for precisely that kind of freedom? It seems to me that approaching accessibility from a functional perspective (as in functional accessibility) would be more comprehensive and useful than addressing the techniques used by developers. When you address development techniques instead of user experiences, you can miss the forest for the trees, making a product that is COMPLIANT without being ACCESSIBLE, and ACCESSIBLE without being USABLE.
I welcome any thoughts on any of these points.
Director of Marketing and communications
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From: = EMAIL ADDRESS REMOVED = on behalf of Baquis David
Sent: Fri 12/15/2006 03:42 PM
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Subject: [teitac-telecom] VoIP enabled cell phones
I received a technical assistance inquiry today from someone who asked
if there are TTY-accessible VoIP (Voice of Internet Protocol) enabled
Beyond my days in the TTY Forum, I was uncertain if there are new
wireless VoIP accessibility barriers that I might not be aware of.
Perhaps the wireless industry can offer expert input on this. I would
need a basic primer as to how a regular digital cell phone differs from
a VoIP cell phone.
Related to that, I wonder if the subcommittee has considered
recommending whether VoIP should be addressed *explicitly* in the
refresh. We get that yes/no question about whether VoIP products are
covered. We have people who specifically look for the term, VoIP, in
Perhaps you can address this point specifically, in your upcoming status
report to the plenary about your subcommittee discussions. Some people
are of the opinion that the standards apply to telecom functionality and
that it should not matter whether a phone is analog, digital or VoIP -
that they are all covered. On the other hand, others are uneasy about
appearing to preempt the FCC by saying VoIP products are telecom covered
by accessibility regulations, before they say so. We cut VoIP out of
the current published telecom technical assistance for that reason. The
flip side of this question is how would you feel about refreshed
standards that said absolutely nothing about VoIP. I can tell you that
it would not serve the needs of federal customers who want clarity on
that subject of how to know with confidence that the new VoIP system
they want to buy is fully accessible.
U.S. Access Board
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