Thread Subject: Please Read: Recap of Dec 13 call
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From: BLACKLER, ELLEN (ATTSI)
Date: Tue, Dec 18 2007 1:50 PM
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Team - Below (and attached) is the recap of the Dec 13 call. Please
review before the Dec 20th call.
Recap of December 13 Task Force Call
1. The Task Force discussed the service and equipment that is covered
by the FCC's Section 255 rules, and reached a general understanding on
what is covered today. In addition, the Task Force agreed that it was
not necessary for its work to identify the communications products that
are covered or not with great precision. Instead, the Task Force
agreed that if we could identify some examples of products covered by
Section 255 for which the technical standards would be relevant that
would be enough for the group to evaluate how the standard should be
treated for Section 255.
2. General Provisions regarding Purpose and Application of the
a. The Task Force agreed to recommend to the TEITAC the
inclusion of the language of the current November 27 EWG draft in
Section 1194.1 Purpose, describing the 255 related purpose of the
guidelines. This language closely tracks the current rules regarding
the coverage of the section 255 rules and gives context to the rest of
the draft and clarifies the difference in scope between section 508
(procurement) and section 255 guidelines (design and manufacture).
b. The Task Force agreed to recommend to the TEITAC the following in
Section 1194.2 Application:
* Add a subheading, "Section 508", at the beginning of this
section to denote the current provisions are for Section 508 purposes.
* Add a second section, "Section 255", followed by the language
currently entitled Version 4 and Version 5. This language is from the
current 255 guidelines modified to include interconnected VOIP. The
Application section would then have two subsections, one generally
describing the obligations under section 508 and the other generally
describing the obligations under 255.
3. Technical Provisions
a. Accessibility Configuration (previously in 1.2 A of General
Technical Requirements, now in Subpart D, 5.2.3 2-C.)
* The Task Force noted that the provision changed materially
between the October 26 draft and the November 27 draft when it was
moved. The October language placed an affirmative obligation on
agencies to activate features and configure products to be accessible.
The November draft 26 requires 2 things: 1) "Products procured must be
capable of being configured to be accessible to and usable by people
with disabilities while simultaneously meeting the products function.";
and 2) accessibility features should not disable any function.
* Language in November draft. The Task Force recommends to the
TEITAC that the requirements in the November draft should be included in
the 255 guidelines and should be moved into the "General Technical
Requirements" section modified as follows:
"Products procured must be capable of being configured to be accessible
to [and usable by] people with disabilities while simultaneously meeting
the product's function. The accessibility features should not disable
Note: For purposes of Section 255, "products" are the
telecommunications equipment, voicemail and interactive menu equipment,
interconnected VOIP equipment and CPE covered by the FCC's rules
implementing section 255."
o "usable to" is bracketed, because the Task Force wanted the
TEITAC to discuss the inclusion of usable, as defined in the November
draft, in provisions that would apply to Section 508 as well as Section
255. The Task Force would like the TEITAC to discuss whether to leave
usable to in, take it out or keep usable to for section 255 only.
* October draft language. The Task Force also recommends that
the agency obligation in the October draft should be reinstated and
included in the "Implementation, Operation and Maintenance" Section
modified as follows.
"In complying with this subpart, each [agency or entity covered by
section 255] must activate accessibility features and configure products
so that they are accessible to and usable by people with disabilities.
Note: For section 508 the agency would have the obligation. For
section 255 it is the service provider or manufacturer covered by
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