Thread Subject: Re: Services

Note

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From: Pam Ransom
Date: Tue, Oct 31 2006 9:40 AM

Hi David - As you noted in your email, people may have different definitions
of "telecommunications services". Just for a point of clarification (and I
may have just misinterpreted your email below, and if I did, others may have
also... smile...)...

The Access Board Telecommunications Guidelines for Section 255 does not
cover "telecommunications services" (as defined in the Telecom Act). I
would guess that the lawyers would say that requirements for telecom
services would not be incorporated into the Access Board's final rule
requirements, refreshing its Telecommunications Guidelines for 255. You also
mentioned "voice mail" - legally VM is defined as an "information service"
and would be covered by 508, and the FCC included both voice mail and IVRs
as the only two information services covered by Section 255 ("information
service" is also defined in the Telecom Act). Indeed, as you mentioned,
Section 508 covers both telecom CPE and telecom services...

I'd suggest that a clarification ( 1. re telecom services no being covered
by the AB Telecom Guidelines for 255 and 2. the legal definitions for
"telecommunications servcies" and "information services") would be helpful
for the subcommittee so that members don't get distracted from the areas
where we can work together to have a real positive impact... Thanks for
"listening".. smile.. Pam Ransom




----- Original Message -----
From: "Baquis David " < = EMAIL ADDRESS REMOVED = >
To: < = EMAIL ADDRESS REMOVED = >
Sent: Monday, October 30, 2006 2:34 PM
Subject: [teitac-telecom] Services


> On today's conference call, it sounded to me like the subcom
> participants were discussing the scope of technology that falls within
> the standards/guidelines. Specifically the issue of "services" came up.
> It seemed obvious to me that this term means different things to
> different people. This has come up many times in federal sector
> meetings.
>
> There was a question about whether 508 doesn't cover services. The
> group was reminded by Terry Weaver that the term "services", is in fact
> listed in the definition of Information Technology. The definition of
> Electronic and Information Technology includes the definition of IT.
> See: http://www.access-board.gov/sec508/standards.htm#Subpart_a. That
> comes from Clinger Cohen.
>
> Generally, the 508 Standards have not addressed services. However,
> consider that Subpart D certainly addresses support services. In
> addition, is "voice mail" a service? That is definitely covered by 508.
>
> You can't have a clear discussion on this term until you clarify which
> specific meaning you want your discussion to be based on. It's ok to
> have several discussions based on separate interpretations, but I think
> it would be less confusing if you were not talking apples and oranges.
> If you mean local/long distance/cellular and other carrier services,
> that is another ballgame altogether.
>
> One very outspoken company wants 508 to cover "integrator services".
> That is a completely different animal. Should the 508 standards address
> those? And how about accessibility consultants that are also considered
> 508-related services. See:
> http://www.ittatc.org/technical/ACC/i_ACC_Intro_Page.php
>
> In summary, with regard to this "services issue", what the Access Board
> needs from the Committee is an answer to:
>
> 1.) What kinds of services are covered or should be covered by the 508
> Standards and 255 Guidelines? (And would you like a Clinger Cohen expert
> to explain to you what was meant in the definition of IT?)
>
> 2.) What specific provisions exist or need to be added or changed to
> address accessibility of those services? Or another way of approaching
> that is to identify accessibility barriers with respect to those
> services, if you believe that such services are covered. Why don't you
> check back with us before going too far down that path?
>
> 3.) In addition, can you recommend advisory notes, technical assistance
> or needed research related to this subject? Remember that your
> recommendations needn't be limited solely to the design requirements.
>
> 4.) Don't forget that for each of your recommendations we would like
> your comments regarding economic impact. It is best that we receive
> this information from all of you - as experts, so we don't have to
> figure it out on our own after the Committee disbands. It is important
> for you to understand that the economic impact analysis could make a
> difference in whether a Committee recommendation ends up making it into
> the final rule.
>
> David Baquis
> Accessibility Specialist
> U.S. Access Board
> 1331 F Street, NW, #1000
> Washington, DC 20004
> 800-USA-ABLE; (202) 272-0013 (voice)
> www.access-board.gov; = EMAIL ADDRESS REMOVED = "Leading the way to
> excellence in accessibility"
>
> "Thank you for your questions concerning section 508 of the
> Rehabilitation Act Amendments of 1998. Section 508 authorizes the
> Access Board to provide technical assistance to individuals and Federal
> departments and agencies concerning the requirements of this section.
> This technical assistance is intended solely as informal guidance; it is
> not a determination of the legal rights or responsibilities of entities
> subject to section 508."
> *****
>
>

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