Thread Subject: Re: Telecom Subcomm. Discussion: Audio Output

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: Jim Tobias
Date: Mon, Nov 06 2006 4:18 PM

Thanks, Terry, for reminding us of this -- agencies buy voice mail service
sometimes, not the hardware and software to provide their own voice mail
service. They certainly don't build their own wireless networks!

May I ask you (and the legal-beagles also on this list) 2 questions? At the
time that the 508 Standards were being drafted, it might not have been clear
that Section 255 enforcement would as sparse as it has been, and that 508
was going to be a more effective method of motivating improvements in
accessibility. So perhaps the assumption was, let's not raise the same
issues in 508 that have been settled in 255 (with the exception of the level
of phone amplification.)

1. Could the 508 Standards have incorporated the 255 Guidelines explicitly,
and added the 1194.23 provisions? That is, is it an acceptable practice in
the regulatory world to repeat regulations found elsewhere, or at least to
refer to them?

2. Would this have been an effective way to make sure that 508 compliance
efforts met all the relevant accessibility needs? That is, instead of
having to train procurement folks on 1194.23 and hope that they also knew
about and cared about 255, if both of those sets of provisions were
incorporated in 1194.23, would it have "worked", or would the stylistic and
structural differences between 255 and 508 been too confusing?


***********
Jim Tobias
Inclusive Technologies
= EMAIL ADDRESS REMOVED =
+1.732.441.0831 v/tty
skype jimtobias
www.inclusive.com





_____

From: = EMAIL ADDRESS REMOVED = [mailto: = EMAIL ADDRESS REMOVED = ]
Sent: Monday, November 06, 2006 1:29 PM
To: TEITAC Telecommunications Subcommittee
Cc: TEITAC Telecommunications Subcommittee;
= EMAIL ADDRESS REMOVED =
Subject: Re: [teitac-telecom] Telecom Subcomm. Discussion: Audio Output



However, 508 does cover services that the Federal agencies' purchase. By
purchasing inaccessible service, a Federal agency cannot comply with the
tech provisions of Sec508, no matter what handset is on the desktop.





"Karen Peltz Strauss" < = EMAIL ADDRESS REMOVED = >
Sent by: = EMAIL ADDRESS REMOVED =


11/06/2006 01:23 PM


Please respond to
"TEITAC Telecommunications Subcommittee"
< = EMAIL ADDRESS REMOVED = >



To
"TEITAC Telecommunications Subcommittee" < = EMAIL ADDRESS REMOVED = >,
"'Pam Ransom'" < = EMAIL ADDRESS REMOVED = >

cc

Subject
Re: [teitac-telecom] Telecom Subcomm. Discussion: Audio Output






Section 255 does cover both manufacturers and service providers, but under
Section 255, the Access Board was only given authority to develop guidelines
for the accessibility of telecommunications equipment and CPE. This is why
the original TAAC guidelines only covered equipment and not services. Then
the FCC used its own jurisdiction to extend the guidelines to services as
well.

So our task here is only limited to what the Access Board can do - and that
is to revise the equipment guidelines.

Karen
----- Original Message -----
From: <mailto: = EMAIL ADDRESS REMOVED = > Jim Tobias
To: <mailto: = EMAIL ADDRESS REMOVED = > 'Pam Ransom' ;
<mailto: = EMAIL ADDRESS REMOVED = > 'TEITAC Telecommunications
Subcommittee'
Sent: Monday, November 06, 2006 12:29 PM
Subject: Re: [teitac-telecom] Telecom Subcomm. Discussion: Audio Output



_____

From: Pam Ransom [mailto: = EMAIL ADDRESS REMOVED = ]
Sent: Monday, November 06, 2006 12:13 PM
To: TEITAC Telecommunications Subcommittee
Subject: Re: [teitac-telecom] Telecom Subcomm. Discussion: Audio Output

Dear Mary, Brenda and All - I have a clarification and suggested correction
within the "Process" paragraph of the email that was sent to the telecom
subcommittee.

"Process: Overall, the task of the Telecommunications subcommittee is to
provide recommendations for refreshing 508 Standards and 255 Guidelines. As
a reminder, the laws and implementing regulations have distinct purposes.

(1) Section 255 guidelines apply to all manufacturers of Terminal
Telecommunications equipment and to all Telecommunications Service providers
in the United States. [ Correction: The Section 255 Access Board 255
Guidelines ONLY apply to manufacturers of customer premises equipment not
telecom services. This process is to refresh the Access Board guidelines. ]


I don't understand your correction. I thought that the Section 255 language
specifically included both manufacturers and service providers. Also,
Doesn't Section 251(a) forbid service providers from installing any network
equipment that would undercut 255?



_____

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