Thread Subject: Telecom Subcomm. Discussion: Audio Output

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From: Brooner Mary-AMB004
Date: Mon, Nov 06 2006 4:09 PM
Subject: Telecom Subcomm. Discussion: Audio Output

AUDIO OUTPUT DISCUSSION

Overview: The following 508 standards and 255 Guidelines relate to the
sending and receiving of speech integral to the use of a
telecommunications product for voice communication and access to other
acoustic information critical to the use of a telecommunications
product. A number of questions have already been identified as points of
consideration and these are set below the relevant Guideline and
Standard text and in italics.

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. Section 255 guidelines apply to all manufacturers of Terminal
Telecommunications equipment and to all Telecommunications Service
providers in the United States. Section 255 guidelines do not apply to
product made in the US or by a US manufacturers but sold outside the
United States. Section 508 standards are directed to the procurement of
telecommunications and IT equipment by US Government procurement
officers. Manufacturers and service providers may choose to participate
in Section 508 federal procurement opportunities.

As a working committee, we have agreed to address the 508 Standards and
255 Guidelines together where there is similarity. One of our members,
Diane Golden, took on the task of pairing existing standards and
guidelines and pulling out relevant questions from resources on the
Access Board website.

Your role: There are many and we will not name them all, but again, to
get started:

1) provide comment on your analysis of what may be needed to
refresh the guidelines. If you have relevant information for the
questions, please contribute. If you have additional questions, please
raise them up. If you are aware of possibly relevant technical
standards please note with reference information, if possible.

2) when commenting, try to remember to cut and paste into a new
email with a Subject header that reflects the discussion topic. This
will may it much easier to summarize.

3) remember, we all offer different perspectives and skills.
This is our chance to learn, share our expertise and perspectives. Be
as clear as you can, understanding we all get confused about some
things. The goal is to refresh the standards and guidelines. We are
not re-writing law and we are not in the playoffs to the Super Bowl.

Mary Brooner/Brenda Battat - co-chairs



(508) 1194.23(f) For transmitted voice signals, telecommunications
products shall provide a gain adjustable up to a minimum of 20 dB. For
incremental volume control, at least one intermediate step of 12 dB of
gain shall be provided.

(255) 1193.43(e) Provide audio or acoustic information, including any
auditory feedback tones that are important for the use of the product,
through at least one mode in enhanced auditory fashion (i.e., increased
amplification, increased signal-to-noise ratio, or combination). For
transmitted voice signals, provide a gain adjustable up to a minimum of
20 dB. For incremental volume control, provide at least one intermediate
step of 12 dB of gain.

Is there a conflict with OSHA standards?

Is there a need to have a maximum output specified to prevent
the gain from exceeding that level?

Does the application to "transmitted voice signals" apply to
both outgoing and incoming?

Was 20 db of gain established as a universal design feature to
meet the needs of individuals with mild hearing loss and to overcome
ambient noise issues? Without establishment of a default level or range
does the 20 db gain deliver access? What about individuals who need
greater gain assuming the default is adequate? Does the built-in
amplification eliminate options for add on amplification through in-line
amplifiers, etc.?

Is gain the most critical factor in understanding speech?

Does this or should system side gain be required (versus
consumer premises product gain or in software based telecommunications
products)?

(508) 1194.23 (g) If the telecommunications product allows a user to
adjust the receive volume, a function shall be provided to automatically
reset the volume to the default level after every use.

Is this necessary if the gain is very small?

Should the standard align with the FCC rule which requires reset
only when the volume exceeds 18 dB gain?

Should the language of this standard be revised to align with
the FCC waiver provisions related to override of the volume reset?

(508) 1194.23(h) 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 shall be
provided.

(255) 1193.43(i) Where a product delivers output by an audio transducer
which is normally held up to the ear, provide a means for effective
wireless coupling to hearing aids.

(508) 1194.23(i) Interference to hearing technologies (including hearing
aids, cochlear implants, and assistive listening devices) shall be
reduced to the lowest possible level that allows a user of hearing
technologies to utilize the telecommunications product.

(255) 1193.43(h) Reduce interference to hearing technologies (including
hearing aids, cochlear implants, and assistive listening devices) to the
lowest possible level that allows a user to utilize the product.

Should metrics be added or a reference to ANSI/IEEE or other
standards?

(255) 1193.43 (g) Where a product delivers audio output through an
external speaker, provide an industry standard connector for headphones
or personal listening devices (e.g., phone-like handset or earcup) which
cuts off the speaker(s) when used.

(508) 1194.25 (e) When products provide auditory output, the audio
signal shall be provided at a standard signal level through an industry
standard connector that will allow for private listening. The product
must provide the ability to interrupt, pause, and restart the audio at
anytime.

(255) 1193.51(b) Products providing auditory output shall provide the
auditory signal at a standard signal level through an industry standard
connector.

From: Pam Ransom
Date: Mon, Nov 06 2006 4:16 PM
Subject: Re: 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. ]

(2) Section 255 guidelines do not apply to product made in the US or by a US manufacturers but sold outside the United States. ..." [ Clarification: The Section 255 Access Board 255 Guidelines do not apply to US manufacturers' telecommunications products that are sold outside the U.S. ]

Thanks... Pam Ransom
----- Original Message -----
From: Brooner Mary-AMB004
To: = EMAIL ADDRESS REMOVED =
Sent: Thursday, November 02, 2006 7:55 AM
Subject: [teitac-telecom] Telecom Subcomm. Discussion: Audio Output


AUDIO OUTPUT DISCUSSION

Overview: The following 508 standards and 255 Guidelines relate to the sending and receiving of speech integral to the use of a telecommunications product for voice communication and access to other acoustic information critical to the use of a telecommunications product. A number of questions have already been identified as points of consideration and these are set below the relevant Guideline and Standard text and in italics.

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. Section 255 guidelines apply to all manufacturers of Terminal Telecommunications equipment and to all Telecommunications Service providers in the United States. Section 255 guidelines do not apply to product made in the US or by a US manufacturers but sold outside the United States. Section 508 standards are directed to the procurement of telecommunications and IT equipment by US Government procurement officers. Manufacturers and service providers may choose to participate in Section 508 federal procurement opportunities.

As a working committee, we have agreed to address the 508 Standards and 255 Guidelines together where there is similarity. One of our members, Diane Golden, took on the task of pairing existing standards and guidelines and pulling out relevant questions from resources on the Access Board website.

Your role: There are many and we will not name them all, but again, to get started:

1) provide comment on your analysis of what may be needed to refresh the guidelines. If you have relevant information for the questions, please contribute. If you have additional questions, please raise them up. If you are aware of possibly relevant technical standards please note with reference information, if possible.

2) when commenting, try to remember to cut and paste into a new email with a Subject header that reflects the discussion topic. This will may it much easier to summarize.

3) remember, we all offer different perspectives and skills. This is our chance to learn, share our expertise and perspectives. Be as clear as you can, understanding we all get confused about some things. The goal is to refresh the standards and guidelines. We are not re-writing law and we are not in the playoffs to the Super Bowl.

Mary Brooner/Brenda Battat - co-chairs



(508) 1194.23(f) For transmitted voice signals, telecommunications products shall provide a gain adjustable up to a minimum of 20 dB. For incremental volume control, at least one intermediate step of 12 dB of gain shall be provided.

(255) 1193.43(e) Provide audio or acoustic information, including any auditory feedback tones that are important for the use of the product, through at least one mode in enhanced auditory fashion (i.e., increased amplification, increased signal-to-noise ratio, or combination). For transmitted voice signals, provide a gain adjustable up to a minimum of 20 dB. For incremental volume control, provide at least one intermediate step of 12 dB of gain.

Is there a conflict with OSHA standards?

Is there a need to have a maximum output specified to prevent the gain from exceeding that level?

Does the application to "transmitted voice signals" apply to both outgoing and incoming?

Was 20 db of gain established as a universal design feature to meet the needs of individuals with mild hearing loss and to overcome ambient noise issues? Without establishment of a default level or range does the 20 db gain deliver access? What about individuals who need greater gain assuming the default is adequate? Does the built-in amplification eliminate options for add on amplification through in-line amplifiers, etc.?

Is gain the most critical factor in understanding speech?

Does this or should system side gain be required (versus consumer premises product gain or in software based telecommunications products)?

(508) 1194.23 (g) If the telecommunications product allows a user to adjust the receive volume, a function shall be provided to automatically reset the volume to the default level after every use.

Is this necessary if the gain is very small?

Should the standard align with the FCC rule which requires reset only when the volume exceeds 18 dB gain?

Should the language of this standard be revised to align with the FCC waiver provisions related to override of the volume reset?

(508) 1194.23(h) 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 shall be provided.

(255) 1193.43(i) Where a product delivers output by an audio transducer which is normally held up to the ear, provide a means for effective wireless coupling to hearing aids.

(508) 1194.23(i) Interference to hearing technologies (including hearing aids, cochlear implants, and assistive listening devices) shall be reduced to the lowest possible level that allows a user of hearing technologies to utilize the telecommunications product.

(255) 1193.43(h) Reduce interference to hearing technologies (including hearing aids, cochlear implants, and assistive listening devices) to the lowest possible level that allows a user to utilize the product.

Should metrics be added or a reference to ANSI/IEEE or other standards?

(255) 1193.43 (g) Where a product delivers audio output through an external speaker, provide an industry standard connector for headphones or personal listening devices (e.g., phone-like handset or earcup) which cuts off the speaker(s) when used.

(508) 1194.25 (e) When products provide auditory output, the audio signal shall be provided at a standard signal level through an industry standard connector that will allow for private listening. The product must provide the ability to interrupt, pause, and restart the audio at anytime.

(255) 1193.51(b) Products providing auditory output shall provide the auditory signal at a standard signal level through an industry standard connector.



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

From: Jim Tobias
Date: Mon, Nov 06 2006 4:16 PM
Subject: Re: 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?

From: Karen Peltz Strauss
Date: Mon, Nov 06 2006 4:17 PM
Subject: Re: 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: Jim Tobias
To: 'Pam Ransom' ; '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?


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

From: terry.weaver@gsa.gov
Date: Mon, Nov 06 2006 4:17 PM
Subject: Re: 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: Jim Tobias
To: 'Pam Ransom' ; '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?

From: Karen Peltz Strauss
Date: Mon, Nov 06 2006 4:17 PM
Subject: Re: Telecom Subcomm. Discussion: Audio Output

Right - I was only talking about Section 255.
----- Original Message -----
From: = EMAIL ADDRESS REMOVED =
To: TEITAC Telecommunications Subcommittee
Cc: TEITAC Telecommunications Subcommittee ; = EMAIL ADDRESS REMOVED =
Sent: Monday, November 06, 2006 1:28 PM
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: Jim Tobias
To: 'Pam Ransom' ; '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?


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

From: Jim Tobias
Date: Mon, Nov 06 2006 4:18 PM
Subject: Re: Telecom Subcomm. Discussion: Audio Output

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?



_____

From: Brett, Thomas F
Date: Mon, Nov 06 2006 4:18 PM
Subject: Re: Telecom Subcomm. Discussion: Audio Output

The captioner was scheduled for 1 hour..2-3pm



Tom Brett,

Section 508 Coordinator

US Office of Personnel Management

Rm 6H34A

2026061206 (v)

2026062582 (tty)

Disabled does not mean Unable

= EMAIL ADDRESS REMOVED = <mailto: = EMAIL ADDRESS REMOVED = >

-----Original Message-----
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Jim Tobias
Sent: Monday, November 06, 2006 2:57 PM
To: 'TEITAC Telecommunications Subcommittee'
Subject: Re: [teitac-telecom] Telecom Subcomm. Discussion: Audio Output



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