Thread Subject: Re: Background on what is covered by Sec. 255 Rules

Note

This archival content is maintained by WebAIM and NCDAE on behalf of TEITAC and the U.S. Access Board . Additional details on the updates to section 508 and section 255 can be found at the Access Board web site.

From: Aapdjenifer@aol.com
Date: Tue, Dec 11 2007 10:25 AM

In regard to the last item in the list below:

3. âIn connection with multipurpose equipment, we adopt our tentative
conclusion that
CPE is covered by section 255 only to the extent that it provides a
telecommunications
function.â (September 1999 255 Order, paragraph 87)."

I think it is important to note that in this Order it says
"telecommunications" function and not "telecommunications service" function here.

Telecommunications in the Act is defined as "..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."
Sec. 3 (43)

So the issue would be what is a "telecommunications function".

Note that in the same Order the FCC defined "usability" as "access to the
full functionality
of ... the product or service." See Paras 12 and 23 and regs at 47 CFR
6.3(k) and 7.3(m).

Jenifer
AAPD

In a message dated 12/10/2007 11:58:06 PM Eastern Standard Time,
= EMAIL ADDRESS REMOVED = writes:

Dear All,

During our teleconference last Thursday, there
was a request that we send around a list of what
is currently covered by Sec. 255, so that we
would all have access to that background. Thanks
to Ellen for preparing the following information.

PLEASE READ this background, and if you have any
questions, comments, or suggestions, please
discuss on the mailing list. The more discussion
we can get through on the mailing list, the more
quickly we should be able to move through our task force teleconferences.

Thank you,

- Judy


Background on things covered by Section 255 Rules


I. Entities Covered by Section 255

1. Any provider of telecommunications Services (47 CFR 6.1)

- Definition of Telecommunications Service
is from the 1996 Telecom Act ­ essentially it is
âoffering telecommunications for a fee to the publicâ

2. Any manufacturer of telecommunications
equipment or customer premises equipment ( 47 CFR 6.1)

- Definition of Telecommunications
equipment­ telecommunications equip is equipment
used by a carrier to provide telecommunication service
- CPE ­ equipment employed on the premises
of a person other than a carrier to originate,
route or terminate telecommunications.

3. Any telecommunications carrier (47 CFR 6.1)

4. Any provider of interconnected VOIP service (47 CFR 6.1)

5. Any manufacturer of equipment or CPE
specifically designed to provide VOIP (47 CFR 6.1)

6. Any provider of voicemail or interactive menu service (part 7.1)

7. Any manufacturer of telecommunications
equipment or CPE which performs a voicemail or
interactive menu function (part 7.1)


II. Covered Functions

1. Part 6.11 and 7.11 Information, documentation and training

- âManufacturers and service providers shall
ensure access to information and documentation it
provides to its customers, if readily
achievable. Such information and documentation
included user guides, bills, installation guides
for end-user installable devices, and product
support communications, regarding both the
product in general and the accessibility featuresâ¦â¦â

2. âAn entity that provides both
telecommunications services and
non-telecommunications services, however, is
subject to section 255 only to the extent that it
provides a telecommunications
serviceâ (September 1999 255 Order, paragraph 80.)

3. âIn connection with multipurpose
equipment, we adopt our tentative conclusion that
CPE is covered by section 255 only to the extent
that it provides a telecommunications
function.â (September 1999 255 Order, paragraph 87)

###

WebAIM is an initiative of:
Center for Persons with Disabilities (CPD) Utah State University