Thread Subject: Re: July 30 language of 2.2-A Magnetic Coupling

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From: Gregg Vanderheiden
Date: Fri, Aug 10 2007 10:40 AM

Good point.



Also - VoIP isn't telecomm. (per FCC who these guidelines will be sent to)



I note that we use Telecommunication in







We also include the definition of Telecom from the communication act.
Unfortunately that definition also describes the Internet which has been
declared as NOT telecomm.





I would suggest that we



1) Don't include the telecom definition because it is confusing. (we would
have to note that the Internet is not telecom because the FCC declared it an
information service - but then said that VoIP has to follow the section 255
telecom rules even though it still isn't telecom -- which is too complicated
and confusing.



2) We keep the term telecom around because people look for it - but we
always use it in a phrase like "voice communication including
telecommunication". In this form, its definition is not critical so we can
avoid the definition issue above. It also avoids having to keep explaining
that VoIP isn't telecom but is covered. Also as we move to 'phone calls'
being made over all sorts of technologies we don't have to keep re-defining
'phone call'.



3) Substitute "real-time voice conversation" for 'telecom'










Here are the places where telecom currently exists.


With each I have placed the same provision with telecom replaces with
?real-time voice conversation? and sometimes including ?including
telecommunication?.




Telecommunications


The transmission, between or among points specified by the user, of
information of the user's choosing, without change in the form or content of
the information as sent and received. (Telecommunications Act of 1996)



SUGGEST: Delete this








2.2-A - Magnetic Coupling


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 must 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.

Discussion: TIA alternate for last sentence:

"This guideline shall apply to wireline and wireless technologies."

EWG proposed edit for clarity Telecommunications products that deliver
output with an audio transducer, which is normally held up to the ear, must
provide a means for effective magnetic wireless coupling to hearing
technologies that allows a user to effectively utilize the product. This
guideline applies to wireless, wireline, cordless and Bluetooth
applications. (or TIA alternate)

SUGGEST: Products that deliver output with an audio transducer, which is
normally held up to the ear, must provide a means for effective magnetic
wireless coupling to hearing technologies that allows a user to effectively
utilize the product. This guideline applies to wired and wireless
applications.




2.2-B - Interference with Hearing Device


Interference to hearing technologies (including hearing aids, cochlear
implants, and assistive listening devices) must be reduced to the lowest
possible level that allows a user of hearing technologies to utilize the
telecommunications product.

Discussion: This comes from Telecom SC and must be reconciled Hardware SC

Suggestion: (from Mary B) Interference to hearing technologies (including
hearing aids, cochlear implants, and assistive listening devices) must be
reduced to the lowest possible level. The interface level must allow a user
of hearing technologies to utilize the telecommunications product.

SUGGEST: Where a product delivers output by an audio transducer which is
normally held up to the ear, interference with hearing technologies
(including hearing aids, cochlear implants, and assistive listening devices)
must be reduced to the lowest possible level. The interface level must allow
a user of hearing technologies to utilize the product. [Same as MARY?s
but ?interference to? is changed to ?interference with? and removed
?telecommunication?. Also added ?when held up to the ear to eliminate
people having to evaluate this for every piece of technology when the
problem is with items held to the ear.






2.2-E - Volume (Gain)


For incoming voice signals:

1. Analog line-powered telecommunications products, wireline, and all
cordless telephones (wireline or VoIP) must comply with FCC regulation
§68.317 for volume control
2. All cellular phones - TBD
3. All other telecommunications products or systems that provide a
function allowing voice communication must provide a gain adjustable from
the normal unamplified level to at least 20 dB above the normal unamplified
level as measured in accordance with the provisions of the FCC regulation
§68.317 for volume control. The volume at the normal unamplified level
setting must also meet the requirement in FCC regulation 68.317.



SUGGEST: First use of ?telecommunication? is OK since this is clearly
limited to the old phone system and everyone will know what it means.



#3 has a number of problems. First ? it covers a wide range of products
including laptops etc. It is meant to apply to handsets held to the ear but
it is not specified except if you read 68.317.



Suggest changing it to:



All other products that delivers output by an audio transducer which is
normally held up to the ear, and that provide a function allowing voice
communication must provide a gain adjustable from the normal unamplified
level to at least 20 dB above the normal unamplified level as measured in
accordance with the provisions of the FCC regulation §68.317 for volume
control. The volume at the normal unamplified level setting must also meet
the requirement in FCC regulation 68.317.






5-A - Accessibility Configuration


In complying with this subpart, each agency must:

1. Activate accessibility features and configure telecommunications
products so that they are accessible to and usable by people with
disabilities.
2. Ensure access to and use of all telecommunications relay services as
approved by the Federal Communications Commission pursuant to its authority
under 47 U.S.C. Sec. 225, for incoming and outgoing calls, as needed to
achieve functionally equivalent communication access by people with
disabilities.



SUGGEST: Deleting ?telecommunication? in #1 to make this generic -- and
in #2 to make it apply to IP relay services. So that it reads:

1. Activate accessibility features and configure products so that they
are accessible to and usable by people with disabilities.
2. Ensure access to and use of all relay services as approved by the
Federal Communications Commission pursuant to its authority under 47 U.S.C.
Sec. 225, for incoming and outgoing calls, as needed to achieve functionally
equivalent communication access by people with disabilities.






5-E - Voice Terminals without Real-Time Text


There are 3 proposed provisions, not settled within Telecom SC:

Version 1: Telecommunications terminals and other terminals capable of
providing real-time voice communications which do not themselves provide TTY
or other real-time text conversation functionality must comply with the
following:

1. All analog and TDM-digital wired terminals must support the
connection of a TTY in the same location and with the permissions for use as
the telephone. This must be accomplished by:

* Providing an RJ-11 jack on the telephone, or
* For an analog telephone, by the use of a Y-adapter that allows both
the analog telephone and the TTY to be plugged into the same line outlet, or

* Having built-in capability to support an RJ11 module that can
provide a connection point for TTYs.

2. Other types of terminals covered by this section must 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.
3. These products must either:

* Be capable of allowing simultaneous speech and text conversation
without interference or
* Its microphone must be capable of being turned on and off to allow
the user to intermix speech with text use.





SUGGEST:

This one has lots of discussion and 3 version so I won't pick one to edit.
But we should remove telecommunication and just talk about ?Terminals
capable of providing real-time voice communications?








5-F - IVR, Auto-Attendant and Messaging


Voice mail, messaging, auto-attendant, and interactive voice response
telecommunications systems must provide access in the following manner:

1. All functions that are accessible to voice users must also be
directly accessible to users of real-time text.
2. Use the ITU-T G.711 recommendation for encoding and storing audio
information. If an audio encoder other than G711 is employed, the vendor
must provide evidence that the intelligibility is equal to or better than
that provided by G.711;
3. Provide full player controls that allow users to pause, rewind, slow
down and repeat all messages and prompts;
4. Provide prompts (either as provided by the vendor, or by the agency
or customer) without any background sounds that would reduce
intelligibility.

NOTE: Relay services are not considered to be "directly accessible".



SUGGEST: ?Voice mail, messaging, auto-attendant, and interactive voice
response systems must provide access in the following manner: ?






5-G - Caller and Status Information


Products with visual interfaces that display telecommunications status
information (such as caller identification and similar telecommunications
functions) must also make this information available for:

* Users of TTYs,
* Users of other text conversation systems, and
* Users who cannot see displays.

These products must also meet all accessibility provisions for software and
content.



SUGGEST: Products with visual interfaces that display call status
information (such as caller identification and similar functions) must also
make this information available for:






5-H - Video Support


Telecommunications products or systems which have the capacity to transmit
video, text, and voice communications must support internet protocol text
and voice communications in X format, and they must have sufficient
transmission bandwidth capacity to support video communication such as video
relay and point to point video communications.



SUGGEST: This one is still in progress so specific language is not
proposed other than to remove telecommunication and add IP near the front
somewhere.









Gregg

-- ------------------------------

Gregg C Vanderheiden Ph.D.







> -----Original Message-----

> From: = EMAIL ADDRESS REMOVED =

> [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of

> Jim Tobias

> Sent: Friday, August 10, 2007 10:16 AM

> To: 'TEITAC desktop/portable (hardware) subcommittee';

> 'TEITAC Telecommunications Subcommittee'

> Cc: = EMAIL ADDRESS REMOVED =

> Subject: Re: [teitac-hardware] July 30 language of 2.2-A

> Magnetic Coupling

>

> As forwarded to the Hardware SC, this provision reads:

>

> "Telecommunications products that deliver output with an

> audio transducer, which is normally held up to the ear, must

> provide a means for effective magnetic wireless coupling to

> hearing technologies that allows a user to effectively

> utilize the product. This guideline shall apply to wireline

> and wireless technologies."

>

> Didn't we agree to remove "Telecommunications" at the July

> plenary, because this provision should also apply to

> intercoms, ATMs, museum audio systems, etc., any of which

> deliver output via a transducer, but none of which are

> "telecommunications" as defined by the FCC?

>

> ***

> Jim Tobias

> Inclusive Technologies

> +1.732.441.0831 v/tty

> +1.908.907.2387 mobile

> skype jimtobias

>

>

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