Thread Subject: More questions/discussion on gain

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From: Diane Golden
Date: Sun, Nov 12 2006 4:15 PM
Subject: More questions/discussion on gain

First -- thank you, thank you, thank you, John for the info you provided. I
really needed much of that years ago when we began procurement reviews, but
it is still extremely helpful now (smile.)

So in reference to the issue of gain or volume control it appears all phones
have about 12 dB of gain/volume control built into the product to conform to
HAC 68.317. However, the current 508 requirement, 1194.23(f), for 20 dB is
not being met as a built-in feature which was the intent of the standard.
(I can say this is accurate from the procurements I'm familiar with at a
state level, but would be interesting to see if it is an accurate reflection
of what federal procurement officials are seeing also.)

So to follow up on Jim's questions, it would seem not a problem to continue
to require the 12 dB gain as a baseline for built-in gain (provided there
was a better definition of how gain is measured to ensure consistency.) But
clearly this will do nothing to increase accessibility -- in fact it will
appear to be a lessening of the current 508 standard since that standard has
not been met as intended.

When you described the distortion and shift to amplifying the high
frequencies for gain significantly over 12 dB, were you talking about just
"add-on" amplifiers to a base phone product (e.g. in-line amplifiers or
substituted handsets) or were you also talking about stand alone amplified
phones? I would think this would influence Jim's second option for a
standard that requires more than 12 dB of gain but allows that to be "high
frequency amplification". Specifically, how much of that "shifted" gain
could/should be delivered as a built-in feature to every phone purchased?

And last, maybe it is just our experience in Missouri, but we find very few
folks who go to "add-on" AT with reference to telephone access. In fact
over the years, in-line amplifiers and other add-on AT products have really
faded from the market. Almost everything now is a substituted product
assumedly because of all the factors John described, power issues, frequency
shifting, default override options, etc. Or folks go to hearing aid
coupling (more direct boot connections, cochlear links, etc.) So I'm not
sure how helpful it would be to add a telecom standard that requires
compatibility with add-on products when there are so few such AT products on
the market any more.

Diane

Diane Cordry Golden, Ph.D.
National Association of State Chief Information Officers
Missouri Assistive Technology Office

From: Michael Byington
Date: Mon, Nov 13 2006 1:45 AM
Subject: Re: More questions/discussion on gain

Diane, John, Jim, and others

I am new to this list, and like John, I want to introduce myself and
tell a little bit about my background. I was asked to participate on
this list by the President of the Council of Citizens with Low Vision
International (CCLVI) , Bernice Candarian. I am a past President of
CCLVI. I am legally blind and am a heavy user of visual aids for
information access although i also quite often choose to use screen
readers as well.

In terms of my professional background, I have a Master's in
Communications, and I have worked for many years, in a combination of
human service, disability rights advocacy, and telecommunications access
positions. I served as Section 504 Coordinator for the City of Wichita
just after graduating from college, and long before the ADA. I have
worked for two centers for independent living in direct service and
administrative positions, have served as the Technical Consultant for
the Kansas Affiliate Program to the Helen Keller National Center for
Deafblind Youths and Adults, and have worked as a professional lobbyist
representing several human service interests. For two and a half years,
I served as Contract Administrator for Telecommunications Relay Services
for the State of Kansas, and also as a part of that job, I had overall
responsibility for our telecommunications equipment distribution program
in Kansas. I left that position three years ago and returned to direct
service; I currently serve as a Shift Manager in a residential training
facility for people who are newly blind or visually impaired. In my
current position, I do quite a bit of teaching and independent living
training with people who are sensory impaired, but who are not at the
expert or even semi-skilled level of competence when it comes to the use
of telecommunications accommodations such as screenreaders, enlarging
software, etc.

I do not begin to have the technical background that John does, and I
thank him for his insightful posting. What I want to share, however, are
some practical thoughts as to what may work for the broad plethora of
people with sensory disabilities who need telecommunications
accommodations on the job, and what needs to be fleshed out in the
regulatory process for 508 and 255. I am going to address more of 508.
With regard to 255, I never have been fond of the "readily achievable"
level of compliance and enforcement built into the statute, and I will
leave the line of demarcation as to what is readily achievable to build
in as opposed to make compatible for add-on to those with engineering
skills superior to mine, and to those who have more experience with
telecommunications and "readily achievable" based case law.

The central issue being discussed in the postings I have read on this
list and its parent website, however, relate to what standards of
universal design may be required by regulation to accommodate all of
those with disabilities who may need accommodation in the 508 covered
workplace. The first thing I want to caution is that universal design in
developing parameters for telecommunications access for sensory impaired
is a much less exacting science than it is to place physical standards
for the built environment in an operational document such as the ADAAG.
It is easier, and less personalized or individualized to determine the
minimum requirements for width, slope, height of truncated domes, etc.,
than it is to determine how much gain, or what font size or
screenreading hierarchy will work best for individual users in order for
them to work competitively and efficiently.

I am not going to mention specific brands of equipment because I have
been our of the telecommunications equipment distribution day to day
operations for nearly three years now, so I know that brands, models,
and company alliances have all changed, and I have not really kept up. I
will say, however, that when giving out amplified telephone equipment in
Kansas, our program would not fund equipment with less than about 25 db
of amplification, and some thpes of amplification equipment we funded
had a gain of up to 60 db. This kind of technology could not be built in
to a telephone system as a feature of universal design. One of many
reasons is that the level of very high amplification needed by some
severely hearing impaired individuals could actually be injurous to the
hearing of a normally hearing individual, or individual with a less
severe loss. Yet, I would contend that the worker who has a very severe
impairment, requiring, for example, 55 db of gain, should still have the
option to choose to use their hearing for telephone communication rather
that a traditional TTY, Cap-Tel, or other text based technology.

The same is true for accommodations for people who are blind and
visually impaired. Certainly a certain degree of enlargement
capabilities, and speech access can be built into a universal system,
but for the professional, well-trained user of such software as JAWS,
Window Eyes, or Zoomtext, the features of these particular pieces of
software configured specifically for the individual user, can make the
difference as to whether the person can work at a competitive level of
quality and productivity.

Thus, while I think a certain amount of the required minimum standards
to be built into systems as universal design features are important for
overall, universal accessibility, most people who have significant
degrees of sensory disabilities are going to need more powerful and
personalized solutions. The ability to add on, and compatibility with,
individualized modifications therefore remains paramount.

It is becoming increasingly possible to in fact make access features
portable so that the worker moving from system to system or place to
place may have full access even if all access features are not built
into each system, terminal, or other linked equipment. For example, two
very functional brands of screenreaders can now be loaded onto any
system without going through installation procedures, and through simply
plugging a jump drive into a USB port. I think regulatory changes have
to be firm in providing for such needed individualized accommodations,
but I also think we make a regulatory mistake if we promulgate
regulatory language that relies on the state of current science. There
is every reason to believe that the progression of assistive technology
is moving more and more toward situations where personally customized
access for people with specific and severe disabilities will be provided
universally through personally carried add on devices attached to
systems in-line, through USB ports, and in other evolving ways.

I hope this is helpful. I look forwarding to hearing from many of you
on the call later today.

Michael Byington


>>> "Diane Golden" < = EMAIL ADDRESS REMOVED = > 11/12/2006 5:18 PM >>>
First -- thank you, thank you, thank you, John for the info you
provided. I
really needed much of that years ago when we began procurement reviews,
but
it is still extremely helpful now (smile.)

So in reference to the issue of gain or volume control it appears all
phones
have about 12 dB of gain/volume control built into the product to
conform to
HAC 68.317. However, the current 508 requirement, 1194.23(f), for 20
dB is
not being met as a built-in feature which was the intent of the
standard.
(I can say this is accurate from the procurements I'm familiar with at
a
state level, but would be interesting to see if it is an accurate
reflection
of what federal procurement officials are seeing also.)

So to follow up on Jim's questions, it would seem not a problem to
continue
to require the 12 dB gain as a baseline for built-in gain (provided
there
was a better definition of how gain is measured to ensure consistency.)
But
clearly this will do nothing to increase accessibility -- in fact it
will
appear to be a lessening of the current 508 standard since that
standard has
not been met as intended.

When you described the distortion and shift to amplifying the high
frequencies for gain significantly over 12 dB, were you talking about
just
"add-on" amplifiers to a base phone product (e.g. in-line amplifiers
or
substituted handsets) or were you also talking about stand alone
amplified
phones? I would think this would influence Jim's second option for a
standard that requires more than 12 dB of gain but allows that to be
"high
frequency amplification". Specifically, how much of that "shifted"
gain
could/should be delivered as a built-in feature to every phone
purchased?

And last, maybe it is just our experience in Missouri, but we find very
few
folks who go to "add-on" AT with reference to telephone access. In
fact
over the years, in-line amplifiers and other add-on AT products have
really
faded from the market. Almost everything now is a substituted product
assumedly because of all the factors John described, power issues,
frequency
shifting, default override options, etc. Or folks go to hearing aid
coupling (more direct boot connections, cochlear links, etc.) So I'm
not
sure how helpful it would be to add a telecom standard that requires
compatibility with add-on products when there are so few such AT
products on
the market any more.

Diane

Diane Cordry Golden, Ph.D.
National Association of State Chief Information Officers
Missouri Assistive Technology Office

From: Jagbell
Date: Mon, Nov 13 2006 6:50 AM
Subject: Re: More questions/discussion on gain

Hi Everyone-

I have been away for the last week but I have been following the
dialogue. Michael, am I correct in my reading that you feel that
people should carry their equipment with them or am I
misunderstanding this? I have highlighted this section in red below.

Also, I thought it might be helpful to give some background on me so
I am attaching a profile piece on me from The New York Times.

http://www.nytimes.com/2005/04/05/arts/05hear.html?
ex=1163566800&en=0fc70c5b64ec04ca&ei=5070

Also, for some of us that are not familiar with some of the people on
the committee, can we each submit bios to our names on the wikki?

Thanks,

Janice



On Nov 13, 2006, at 3:39 AM, Michael Byington wrote:

> Diane, John, Jim, and others
>
> I am new to this list, and like John, I want to introduce myself and
> tell a little bit about my background. I was asked to participate on
> this list by the President of the Council of Citizens with Low Vision
> International (CCLVI) , Bernice Candarian. I am a past President of
> CCLVI. I am legally blind and am a heavy user of visual aids for
> information access although i also quite often choose to use screen
> readers as well.
>
> In terms of my professional background, I have a Master's in
> Communications, and I have worked for many years, in a combination of
> human service, disability rights advocacy, and telecommunications
> access
> positions. I served as Section 504 Coordinator for the City of Wichita
> just after graduating from college, and long before the ADA. I have
> worked for two centers for independent living in direct service and
> administrative positions, have served as the Technical Consultant for
> the Kansas Affiliate Program to the Helen Keller National Center for
> Deafblind Youths and Adults, and have worked as a professional
> lobbyist
> representing several human service interests. For two and a half
> years,
> I served as Contract Administrator for Telecommunications Relay
> Services
> for the State of Kansas, and also as a part of that job, I had overall
> responsibility for our telecommunications equipment distribution
> program
> in Kansas. I left that position three years ago and returned to direct
> service; I currently serve as a Shift Manager in a residential
> training
> facility for people who are newly blind or visually impaired. In my
> current position, I do quite a bit of teaching and independent living
> training with people who are sensory impaired, but who are not at the
> expert or even semi-skilled level of competence when it comes to
> the use
> of telecommunications accommodations such as screenreaders, enlarging
> software, etc.
>
> I do not begin to have the technical background that John does, and I
> thank him for his insightful posting. What I want to share,
> however, are
> some practical thoughts as to what may work for the broad plethora of
> people with sensory disabilities who need telecommunications
> accommodations on the job, and what needs to be fleshed out in the
> regulatory process for 508 and 255. I am going to address more of 508.
> With regard to 255, I never have been fond of the "readily achievable"
> level of compliance and enforcement built into the statute, and I will
> leave the line of demarcation as to what is readily achievable to
> build
> in as opposed to make compatible for add-on to those with engineering
> skills superior to mine, and to those who have more experience with
> telecommunications and "readily achievable" based case law.
>
> The central issue being discussed in the postings I have read on this
> list and its parent website, however, relate to what standards of
> universal design may be required by regulation to accommodate all of
> those with disabilities who may need accommodation in the 508 covered
> workplace. The first thing I want to caution is that universal
> design in
> developing parameters for telecommunications access for sensory
> impaired
> is a much less exacting science than it is to place physical standards
> for the built environment in an operational document such as the
> ADAAG.
> It is easier, and less personalized or individualized to determine the
> minimum requirements for width, slope, height of truncated domes,
> etc.,
> than it is to determine how much gain, or what font size or
> screenreading hierarchy will work best for individual users in
> order for
> them to work competitively and efficiently.
>
> I am not going to mention specific brands of equipment because I have
> been our of the telecommunications equipment distribution day to day
> operations for nearly three years now, so I know that brands, models,
> and company alliances have all changed, and I have not really kept
> up. I
> will say, however, that when giving out amplified telephone
> equipment in
> Kansas, our program would not fund equipment with less than about
> 25 db
> of amplification, and some thpes of amplification equipment we funded
> had a gain of up to 60 db. This kind of technology could not be
> built in
> to a telephone system as a feature of universal design. One of many
> reasons is that the level of very high amplification needed by some
> severely hearing impaired individuals could actually be injurous to
> the
> hearing of a normally hearing individual, or individual with a less
> severe loss. Yet, I would contend that the worker who has a very
> severe
> impairment, requiring, for example, 55 db of gain, should still
> have the
> option to choose to use their hearing for telephone communication
> rather
> that a traditional TTY, Cap-Tel, or other text based technology.
>
> The same is true for accommodations for people who are blind and
> visually impaired. Certainly a certain degree of enlargement
> capabilities, and speech access can be built into a universal system,
> but for the professional, well-trained user of such software as JAWS,
> Window Eyes, or Zoomtext, the features of these particular pieces of
> software configured specifically for the individual user, can make the
> difference as to whether the person can work at a competitive level of
> quality and productivity.
>
> Thus, while I think a certain amount of the required minimum standards
> to be built into systems as universal design features are important
> for
> overall, universal accessibility, most people who have significant
> degrees of sensory disabilities are going to need more powerful and
> personalized solutions. The ability to add on, and compatibility with,
> individualized modifications therefore remains paramount.
>
> It is becoming increasingly possible to in fact make access features
> portable so that the worker moving from system to system or place to
> place may have full access even if all access features are not built
> into each system, terminal, or other linked equipment. For example,
> two
> very functional brands of screenreaders can now be loaded onto any
> system without going through installation procedures, and through
> simply
> plugging a jump drive into a USB port. I think regulatory changes have
> to be firm in providing for such needed individualized accommodations,
> but I also think we make a regulatory mistake if we promulgate
> regulatory language that relies on the state of current science. There
> is every reason to believe that the progression of assistive
> technology
> is moving more and more toward situations where personally customized
> access for people with specific and severe disabilities will be
> provided
> universally through personally carried add on devices attached to
> systems in-line, through USB ports, and in other evolving ways.
>
> I hope this is helpful. I look forwarding to hearing from many of you
> on the call later today.
>
> Michael Byington
>
>
>>>> "Diane Golden" < = EMAIL ADDRESS REMOVED = > 11/12/2006 5:18 PM >>>
> First -- thank you, thank you, thank you, John for the info you
> provided. I
> really needed much of that years ago when we began procurement
> reviews,
> but
> it is still extremely helpful now (smile.)
>
> So in reference to the issue of gain or volume control it appears all
> phones
> have about 12 dB of gain/volume control built into the product to
> conform to
> HAC 68.317. However, the current 508 requirement, 1194.23(f), for 20
> dB is
> not being met as a built-in feature which was the intent of the
> standard.
> (I can say this is accurate from the procurements I'm familiar with at
> a
> state level, but would be interesting to see if it is an accurate
> reflection
> of what federal procurement officials are seeing also.)
>
> So to follow up on Jim's questions, it would seem not a problem to
> continue
> to require the 12 dB gain as a baseline for built-in gain (provided
> there
> was a better definition of how gain is measured to ensure
> consistency.)
> But
> clearly this will do nothing to increase accessibility -- in fact it
> will
> appear to be a lessening of the current 508 standard since that
> standard has
> not been met as intended.
>
> When you described the distortion and shift to amplifying the high
> frequencies for gain significantly over 12 dB, were you talking about
> just
> "add-on" amplifiers to a base phone product (e.g. in-line amplifiers
> or
> substituted handsets) or were you also talking about stand alone
> amplified
> phones? I would think this would influence Jim's second option for a
> standard that requires more than 12 dB of gain but allows that to be
> "high
> frequency amplification". Specifically, how much of that "shifted"
> gain
> could/should be delivered as a built-in feature to every phone
> purchased?
>
> And last, maybe it is just our experience in Missouri, but we find
> very
> few
> folks who go to "add-on" AT with reference to telephone access. In
> fact
> over the years, in-line amplifiers and other add-on AT products have
> really
> faded from the market. Almost everything now is a substituted product
> assumedly because of all the factors John described, power issues,
> frequency
> shifting, default override options, etc. Or folks go to hearing aid
> coupling (more direct boot connections, cochlear links, etc.) So I'm
> not
> sure how helpful it would be to add a telecom standard that requires
> compatibility with add-on products when there are so few such AT
> products on
> the market any more.
>
> Diane
>
> Diane Cordry Golden, Ph.D.
> National Association of State Chief Information Officers
> Missouri Assistive Technology Office
>

From: Rebecca Schwartz
Date: Mon, Nov 13 2006 10:42 AM
Subject: Re: More questions/discussion on gain

I am new to this group, as of the past month, as well. I am a
regulatory attorney and a member of the Public Policy Committee at TIA.
I am very new to accessibility issues, and any knowledge I have comes
from the regulatory perspective. I have a BA in Communications and a BA
in Political Science. I also have a law degree and a certificate in
Communications Law. I look forward to working with you all.

Rebecca Schwartz, Esq.
Manager, Regulatory and Government Affairs
TIA
2500 Wilson Blvd. Ste. 300
Arlington, VA 22201
703.907.7477 (OFFICE)
703.395.7511 (CELL)
703.907.7727 (FAX)

-----Original Message-----
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Michael
Byington
Sent: Monday, November 13, 2006 3:40 AM
To: = EMAIL ADDRESS REMOVED =
Subject: Re: [teitac-telecom] More questions/discussion on gain

Diane, John, Jim, and others

I am new to this list, and like John, I want to introduce myself and
tell a little bit about my background. I was asked to participate on
this list by the President of the Council of Citizens with Low Vision
International (CCLVI) , Bernice Candarian. I am a past President of
CCLVI. I am legally blind and am a heavy user of visual aids for
information access although i also quite often choose to use screen
readers as well.

In terms of my professional background, I have a Master's in
Communications, and I have worked for many years, in a combination of
human service, disability rights advocacy, and telecommunications access
positions. I served as Section 504 Coordinator for the City of Wichita
just after graduating from college, and long before the ADA. I have
worked for two centers for independent living in direct service and
administrative positions, have served as the Technical Consultant for
the Kansas Affiliate Program to the Helen Keller National Center for
Deafblind Youths and Adults, and have worked as a professional lobbyist
representing several human service interests. For two and a half years,
I served as Contract Administrator for Telecommunications Relay Services
for the State of Kansas, and also as a part of that job, I had overall
responsibility for our telecommunications equipment distribution program
in Kansas. I left that position three years ago and returned to direct
service; I currently serve as a Shift Manager in a residential training
facility for people who are newly blind or visually impaired. In my
current position, I do quite a bit of teaching and independent living
training with people who are sensory impaired, but who are not at the
expert or even semi-skilled level of competence when it comes to the use
of telecommunications accommodations such as screenreaders, enlarging
software, etc.

I do not begin to have the technical background that John does, and I
thank him for his insightful posting. What I want to share, however, are
some practical thoughts as to what may work for the broad plethora of
people with sensory disabilities who need telecommunications
accommodations on the job, and what needs to be fleshed out in the
regulatory process for 508 and 255. I am going to address more of 508.
With regard to 255, I never have been fond of the "readily achievable"
level of compliance and enforcement built into the statute, and I will
leave the line of demarcation as to what is readily achievable to build
in as opposed to make compatible for add-on to those with engineering
skills superior to mine, and to those who have more experience with
telecommunications and "readily achievable" based case law.

The central issue being discussed in the postings I have read on this
list and its parent website, however, relate to what standards of
universal design may be required by regulation to accommodate all of
those with disabilities who may need accommodation in the 508 covered
workplace. The first thing I want to caution is that universal design in
developing parameters for telecommunications access for sensory impaired
is a much less exacting science than it is to place physical standards
for the built environment in an operational document such as the ADAAG.
It is easier, and less personalized or individualized to determine the
minimum requirements for width, slope, height of truncated domes, etc.,
than it is to determine how much gain, or what font size or
screenreading hierarchy will work best for individual users in order for
them to work competitively and efficiently.

I am not going to mention specific brands of equipment because I have
been our of the telecommunications equipment distribution day to day
operations for nearly three years now, so I know that brands, models,
and company alliances have all changed, and I have not really kept up. I
will say, however, that when giving out amplified telephone equipment in
Kansas, our program would not fund equipment with less than about 25 db
of amplification, and some thpes of amplification equipment we funded
had a gain of up to 60 db. This kind of technology could not be built in
to a telephone system as a feature of universal design. One of many
reasons is that the level of very high amplification needed by some
severely hearing impaired individuals could actually be injurous to the
hearing of a normally hearing individual, or individual with a less
severe loss. Yet, I would contend that the worker who has a very severe
impairment, requiring, for example, 55 db of gain, should still have the
option to choose to use their hearing for telephone communication rather
that a traditional TTY, Cap-Tel, or other text based technology.

The same is true for accommodations for people who are blind and
visually impaired. Certainly a certain degree of enlargement
capabilities, and speech access can be built into a universal system,
but for the professional, well-trained user of such software as JAWS,
Window Eyes, or Zoomtext, the features of these particular pieces of
software configured specifically for the individual user, can make the
difference as to whether the person can work at a competitive level of
quality and productivity.

Thus, while I think a certain amount of the required minimum standards
to be built into systems as universal design features are important for
overall, universal accessibility, most people who have significant
degrees of sensory disabilities are going to need more powerful and
personalized solutions. The ability to add on, and compatibility with,
individualized modifications therefore remains paramount.

It is becoming increasingly possible to in fact make access features
portable so that the worker moving from system to system or place to
place may have full access even if all access features are not built
into each system, terminal, or other linked equipment. For example, two
very functional brands of screenreaders can now be loaded onto any
system without going through installation procedures, and through simply
plugging a jump drive into a USB port. I think regulatory changes have
to be firm in providing for such needed individualized accommodations,
but I also think we make a regulatory mistake if we promulgate
regulatory language that relies on the state of current science. There
is every reason to believe that the progression of assistive technology
is moving more and more toward situations where personally customized
access for people with specific and severe disabilities will be provided
universally through personally carried add on devices attached to
systems in-line, through USB ports, and in other evolving ways.

I hope this is helpful. I look forwarding to hearing from many of you
on the call later today.

Michael Byington


>>> "Diane Golden" < = EMAIL ADDRESS REMOVED = > 11/12/2006 5:18 PM >>>
First -- thank you, thank you, thank you, John for the info you
provided. I
really needed much of that years ago when we began procurement reviews,
but
it is still extremely helpful now (smile.)

So in reference to the issue of gain or volume control it appears all
phones
have about 12 dB of gain/volume control built into the product to
conform to
HAC 68.317. However, the current 508 requirement, 1194.23(f), for 20
dB is
not being met as a built-in feature which was the intent of the
standard.
(I can say this is accurate from the procurements I'm familiar with at
a
state level, but would be interesting to see if it is an accurate
reflection
of what federal procurement officials are seeing also.)

So to follow up on Jim's questions, it would seem not a problem to
continue
to require the 12 dB gain as a baseline for built-in gain (provided
there
was a better definition of how gain is measured to ensure consistency.)
But
clearly this will do nothing to increase accessibility -- in fact it
will
appear to be a lessening of the current 508 standard since that
standard has
not been met as intended.

When you described the distortion and shift to amplifying the high
frequencies for gain significantly over 12 dB, were you talking about
just
"add-on" amplifiers to a base phone product (e.g. in-line amplifiers
or
substituted handsets) or were you also talking about stand alone
amplified
phones? I would think this would influence Jim's second option for a
standard that requires more than 12 dB of gain but allows that to be
"high
frequency amplification". Specifically, how much of that "shifted"
gain
could/should be delivered as a built-in feature to every phone
purchased?

And last, maybe it is just our experience in Missouri, but we find very
few
folks who go to "add-on" AT with reference to telephone access. In
fact
over the years, in-line amplifiers and other add-on AT products have
really
faded from the market. Almost everything now is a substituted product
assumedly because of all the factors John described, power issues,
frequency
shifting, default override options, etc. Or folks go to hearing aid
coupling (more direct boot connections, cochlear links, etc.) So I'm
not
sure how helpful it would be to add a telecom standard that requires
compatibility with add-on products when there are so few such AT
products on
the market any more.

Diane

Diane Cordry Golden, Ph.D.
National Association of State Chief Information Officers
Missouri Assistive Technology Office

From: John Combs (jcombs)
Date: Mon, Nov 13 2006 12:20 PM
Subject: Re: More questions/discussion on gain

Michael,

Nice to meet you online.

One thing you mention in your text below -- an audio amplifier which
claims to have 60 dB of gain. This is another thing we should address
in the TEITAC discussions, lack of a testing standard for measuring true
amplifier gain. Many manufacturers claims very high gain numbers, but
don't deliver anything close to what they say.

Let's consider 60 dB of audio gain. If the initial maximum audio level
on an analog phone receiver is 1 Watt of sound power, a 60 dB boost of
this gives us 1 million Watts!

Regardless of claims, I've never found an inline handset amplifier that
actually exceeded 30 dB of true gain.


- John Combs


-----Original Message-----
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Michael
Byington
Sent: Monday, November 13, 2006 12:40 AM
To: = EMAIL ADDRESS REMOVED =
Subject: Re: [teitac-telecom] More questions/discussion on gain

Diane, John, Jim, and others

I am new to this list, and like John, I want to introduce myself and
tell a little bit about my background. I was asked to participate on
this list by the President of the Council of Citizens with Low Vision
International (CCLVI) , Bernice Candarian. I am a past President of
CCLVI. I am legally blind and am a heavy user of visual aids for
information access although i also quite often choose to use screen
readers as well.

In terms of my professional background, I have a Master's in
Communications, and I have worked for many years, in a combination of
human service, disability rights advocacy, and telecommunications access
positions. I served as Section 504 Coordinator for the City of Wichita
just after graduating from college, and long before the ADA. I have
worked for two centers for independent living in direct service and
administrative positions, have served as the Technical Consultant for
the Kansas Affiliate Program to the Helen Keller National Center for
Deafblind Youths and Adults, and have worked as a professional lobbyist
representing several human service interests. For two and a half years,
I served as Contract Administrator for Telecommunications Relay Services
for the State of Kansas, and also as a part of that job, I had overall
responsibility for our telecommunications equipment distribution program
in Kansas. I left that position three years ago and returned to direct
service; I currently serve as a Shift Manager in a residential training
facility for people who are newly blind or visually impaired. In my
current position, I do quite a bit of teaching and independent living
training with people who are sensory impaired, but who are not at the
expert or even semi-skilled level of competence when it comes to the use
of telecommunications accommodations such as screenreaders, enlarging
software, etc.

I do not begin to have the technical background that John does, and I
thank him for his insightful posting. What I want to share, however, are
some practical thoughts as to what may work for the broad plethora of
people with sensory disabilities who need telecommunications
accommodations on the job, and what needs to be fleshed out in the
regulatory process for 508 and 255. I am going to address more of 508.
With regard to 255, I never have been fond of the "readily achievable"
level of compliance and enforcement built into the statute, and I will
leave the line of demarcation as to what is readily achievable to build
in as opposed to make compatible for add-on to those with engineering
skills superior to mine, and to those who have more experience with
telecommunications and "readily achievable" based case law.

The central issue being discussed in the postings I have read on this
list and its parent website, however, relate to what standards of
universal design may be required by regulation to accommodate all of
those with disabilities who may need accommodation in the 508 covered
workplace. The first thing I want to caution is that universal design in
developing parameters for telecommunications access for sensory impaired
is a much less exacting science than it is to place physical standards
for the built environment in an operational document such as the ADAAG.
It is easier, and less personalized or individualized to determine the
minimum requirements for width, slope, height of truncated domes, etc.,
than it is to determine how much gain, or what font size or
screenreading hierarchy will work best for individual users in order for
them to work competitively and efficiently.

I am not going to mention specific brands of equipment because I have
been our of the telecommunications equipment distribution day to day
operations for nearly three years now, so I know that brands, models,
and company alliances have all changed, and I have not really kept up. I
will say, however, that when giving out amplified telephone equipment in
Kansas, our program would not fund equipment with less than about 25 db
of amplification, and some thpes of amplification equipment we funded
had a gain of up to 60 db. This kind of technology could not be built in
to a telephone system as a feature of universal design. One of many
reasons is that the level of very high amplification needed by some
severely hearing impaired individuals could actually be injurous to the
hearing of a normally hearing individual, or individual with a less
severe loss. Yet, I would contend that the worker who has a very severe
impairment, requiring, for example, 55 db of gain, should still have the
option to choose to use their hearing for telephone communication rather
that a traditional TTY, Cap-Tel, or other text based technology.

The same is true for accommodations for people who are blind and
visually impaired. Certainly a certain degree of enlargement
capabilities, and speech access can be built into a universal system,
but for the professional, well-trained user of such software as JAWS,
Window Eyes, or Zoomtext, the features of these particular pieces of
software configured specifically for the individual user, can make the
difference as to whether the person can work at a competitive level of
quality and productivity.

Thus, while I think a certain amount of the required minimum standards
to be built into systems as universal design features are important for
overall, universal accessibility, most people who have significant
degrees of sensory disabilities are going to need more powerful and
personalized solutions. The ability to add on, and compatibility with,
individualized modifications therefore remains paramount.

It is becoming increasingly possible to in fact make access features
portable so that the worker moving from system to system or place to
place may have full access even if all access features are not built
into each system, terminal, or other linked equipment. For example, two
very functional brands of screenreaders can now be loaded onto any
system without going through installation procedures, and through simply
plugging a jump drive into a USB port. I think regulatory changes have
to be firm in providing for such needed individualized accommodations,
but I also think we make a regulatory mistake if we promulgate
regulatory language that relies on the state of current science. There
is every reason to believe that the progression of assistive technology
is moving more and more toward situations where personally customized
access for people with specific and severe disabilities will be provided
universally through personally carried add on devices attached to
systems in-line, through USB ports, and in other evolving ways.

I hope this is helpful. I look forwarding to hearing from many of you on
the call later today.

Michael Byington


>>> "Diane Golden" < = EMAIL ADDRESS REMOVED = > 11/12/2006 5:18 PM >>>
First -- thank you, thank you, thank you, John for the info you
provided. I really needed much of that years ago when we began
procurement reviews, but it is still extremely helpful now (smile.)

So in reference to the issue of gain or volume control it appears all
phones have about 12 dB of gain/volume control built into the product to
conform to HAC 68.317. However, the current 508 requirement,
1194.23(f), for 20 dB is not being met as a built-in feature which was
the intent of the standard.
(I can say this is accurate from the procurements I'm familiar with at a
state level, but would be interesting to see if it is an accurate
reflection of what federal procurement officials are seeing also.)

So to follow up on Jim's questions, it would seem not a problem to
continue to require the 12 dB gain as a baseline for built-in gain
(provided there was a better definition of how gain is measured to
ensure consistency.) But clearly this will do nothing to increase
accessibility -- in fact it will appear to be a lessening of the current
508 standard since that standard has not been met as intended.

When you described the distortion and shift to amplifying the high
frequencies for gain significantly over 12 dB, were you talking about
just "add-on" amplifiers to a base phone product (e.g. in-line
amplifiers or substituted handsets) or were you also talking about stand
alone amplified phones? I would think this would influence Jim's second
option for a standard that requires more than 12 dB of gain but allows
that to be "high frequency amplification". Specifically, how much of
that "shifted"
gain
could/should be delivered as a built-in feature to every phone
purchased?

And last, maybe it is just our experience in Missouri, but we find very
few folks who go to "add-on" AT with reference to telephone access. In
fact over the years, in-line amplifiers and other add-on AT products
have really faded from the market. Almost everything now is a
substituted product assumedly because of all the factors John described,
power issues, frequency shifting, default override options, etc. Or
folks go to hearing aid coupling (more direct boot connections, cochlear
links, etc.) So I'm not sure how helpful it would be to add a telecom
standard that requires compatibility with add-on products when there are
so few such AT products on the market any more.

Diane

Diane Cordry Golden, Ph.D.
National Association of State Chief Information Officers Missouri
Assistive Technology Office

From: Diane Golden
Date: Mon, Nov 13 2006 2:40 PM
Subject: Re: More questions/discussion on gain

While I have no idea exactly how the dB gain is figured -- and obviously we
need some consistency -- I believe the numbers used are an attempt to align
gain with hearing loss levels in audiograms. The dB in an audiogram is
hearing level (HL) not SPL or any other true acoustic or electronic measure.
The decibels in HL is a normative number, with zero indicating threshold
hearing level for young adult males at each of the frequencies tested when
doing an audiogram. An individual with hearing thresholds at 50-60 dB for
250 to 8000 Hz on an audiogram has a hearing loss that would typically be
matched with an amplified phone that claims to have 30-40dB of gain. That
amount of "gain" when laid over the audiogram would improve the hearing
threshold level back to about 20 dB which is considered to be is within
normal limits. I think the convolusion of the concept of gain has occured
as folks tried to match a "gain number" to level of hearing loss measured in
HL dB.

Diane

Diane Cordry Golden, Ph.D., Director
Missouri Assistive Technology
816/350-5280 (direct voice)
= EMAIL ADDRESS REMOVED =
www.at.mo.gov


-----Original Message-----
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ]On Behalf Of John Combs
(jcombs)
Sent: Monday, November 13, 2006 1:16 PM
To: TEITAC Telecommunications Subcommittee
Subject: Re: [teitac-telecom] More questions/discussion on gain


Michael,

Nice to meet you online.

One thing you mention in your text below -- an audio amplifier which
claims to have 60 dB of gain. This is another thing we should address
in the TEITAC discussions, lack of a testing standard for measuring true
amplifier gain. Many manufacturers claims very high gain numbers, but
don't deliver anything close to what they say.

Let's consider 60 dB of audio gain. If the initial maximum audio level
on an analog phone receiver is 1 Watt of sound power, a 60 dB boost of
this gives us 1 million Watts!

Regardless of claims, I've never found an inline handset amplifier that
actually exceeded 30 dB of true gain.


- John Combs


-----Original Message-----
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Michael
Byington
Sent: Monday, November 13, 2006 12:40 AM
To: = EMAIL ADDRESS REMOVED =
Subject: Re: [teitac-telecom] More questions/discussion on gain

Diane, John, Jim, and others

I am new to this list, and like John, I want to introduce myself and
tell a little bit about my background. I was asked to participate on
this list by the President of the Council of Citizens with Low Vision
International (CCLVI) , Bernice Candarian. I am a past President of
CCLVI. I am legally blind and am a heavy user of visual aids for
information access although i also quite often choose to use screen
readers as well.

In terms of my professional background, I have a Master's in
Communications, and I have worked for many years, in a combination of
human service, disability rights advocacy, and telecommunications access
positions. I served as Section 504 Coordinator for the City of Wichita
just after graduating from college, and long before the ADA. I have
worked for two centers for independent living in direct service and
administrative positions, have served as the Technical Consultant for
the Kansas Affiliate Program to the Helen Keller National Center for
Deafblind Youths and Adults, and have worked as a professional lobbyist
representing several human service interests. For two and a half years,
I served as Contract Administrator for Telecommunications Relay Services
for the State of Kansas, and also as a part of that job, I had overall
responsibility for our telecommunications equipment distribution program
in Kansas. I left that position three years ago and returned to direct
service; I currently serve as a Shift Manager in a residential training
facility for people who are newly blind or visually impaired. In my
current position, I do quite a bit of teaching and independent living
training with people who are sensory impaired, but who are not at the
expert or even semi-skilled level of competence when it comes to the use
of telecommunications accommodations such as screenreaders, enlarging
software, etc.

I do not begin to have the technical background that John does, and I
thank him for his insightful posting. What I want to share, however, are
some practical thoughts as to what may work for the broad plethora of
people with sensory disabilities who need telecommunications
accommodations on the job, and what needs to be fleshed out in the
regulatory process for 508 and 255. I am going to address more of 508.
With regard to 255, I never have been fond of the "readily achievable"
level of compliance and enforcement built into the statute, and I will
leave the line of demarcation as to what is readily achievable to build
in as opposed to make compatible for add-on to those with engineering
skills superior to mine, and to those who have more experience with
telecommunications and "readily achievable" based case law.

The central issue being discussed in the postings I have read on this
list and its parent website, however, relate to what standards of
universal design may be required by regulation to accommodate all of
those with disabilities who may need accommodation in the 508 covered
workplace. The first thing I want to caution is that universal design in
developing parameters for telecommunications access for sensory impaired
is a much less exacting science than it is to place physical standards
for the built environment in an operational document such as the ADAAG.
It is easier, and less personalized or individualized to determine the
minimum requirements for width, slope, height of truncated domes, etc.,
than it is to determine how much gain, or what font size or
screenreading hierarchy will work best for individual users in order for
them to work competitively and efficiently.

I am not going to mention specific brands of equipment because I have
been our of the telecommunications equipment distribution day to day
operations for nearly three years now, so I know that brands, models,
and company alliances have all changed, and I have not really kept up. I
will say, however, that when giving out amplified telephone equipment in
Kansas, our program would not fund equipment with less than about 25 db
of amplification, and some thpes of amplification equipment we funded
had a gain of up to 60 db. This kind of technology could not be built in
to a telephone system as a feature of universal design. One of many
reasons is that the level of very high amplification needed by some
severely hearing impaired individuals could actually be injurous to the
hearing of a normally hearing individual, or individual with a less
severe loss. Yet, I would contend that the worker who has a very severe
impairment, requiring, for example, 55 db of gain, should still have the
option to choose to use their hearing for telephone communication rather
that a traditional TTY, Cap-Tel, or other text based technology.

The same is true for accommodations for people who are blind and
visually impaired. Certainly a certain degree of enlargement
capabilities, and speech access can be built into a universal system,
but for the professional, well-trained user of such software as JAWS,
Window Eyes, or Zoomtext, the features of these particular pieces of
software configured specifically for the individual user, can make the
difference as to whether the person can work at a competitive level of
quality and productivity.

Thus, while I think a certain amount of the required minimum standards
to be built into systems as universal design features are important for
overall, universal accessibility, most people who have significant
degrees of sensory disabilities are going to need more powerful and
personalized solutions. The ability to add on, and compatibility with,
individualized modifications therefore remains paramount.

It is becoming increasingly possible to in fact make access features
portable so that the worker moving from system to system or place to
place may have full access even if all access features are not built
into each system, terminal, or other linked equipment. For example, two
very functional brands of screenreaders can now be loaded onto any
system without going through installation procedures, and through simply
plugging a jump drive into a USB port. I think regulatory changes have
to be firm in providing for such needed individualized accommodations,
but I also think we make a regulatory mistake if we promulgate
regulatory language that relies on the state of current science. There
is every reason to believe that the progression of assistive technology
is moving more and more toward situations where personally customized
access for people with specific and severe disabilities will be provided
universally through personally carried add on devices attached to
systems in-line, through USB ports, and in other evolving ways.

I hope this is helpful. I look forwarding to hearing from many of you on
the call later today.

Michael Byington


>>> "Diane Golden" < = EMAIL ADDRESS REMOVED = > 11/12/2006 5:18 PM >>>
First -- thank you, thank you, thank you, John for the info you
provided. I really needed much of that years ago when we began
procurement reviews, but it is still extremely helpful now (smile.)

So in reference to the issue of gain or volume control it appears all
phones have about 12 dB of gain/volume control built into the product to
conform to HAC 68.317. However, the current 508 requirement,
1194.23(f), for 20 dB is not being met as a built-in feature which was
the intent of the standard.
(I can say this is accurate from the procurements I'm familiar with at a
state level, but would be interesting to see if it is an accurate
reflection of what federal procurement officials are seeing also.)

So to follow up on Jim's questions, it would seem not a problem to
continue to require the 12 dB gain as a baseline for built-in gain
(provided there was a better definition of how gain is measured to
ensure consistency.) But clearly this will do nothing to increase
accessibility -- in fact it will appear to be a lessening of the current
508 standard since that standard has not been met as intended.

When you described the distortion and shift to amplifying the high
frequencies for gain significantly over 12 dB, were you talking about
just "add-on" amplifiers to a base phone product (e.g. in-line
amplifiers or substituted handsets) or were you also talking about stand
alone amplified phones? I would think this would influence Jim's second
option for a standard that requires more than 12 dB of gain but allows
that to be "high frequency amplification". Specifically, how much of
that "shifted"
gain
could/should be delivered as a built-in feature to every phone
purchased?

And last, maybe it is just our experience in Missouri, but we find very
few folks who go to "add-on" AT with reference to telephone access. In
fact over the years, in-line amplifiers and other add-on AT products
have really faded from the market. Almost everything now is a
substituted product assumedly because of all the factors John described,
power issues, frequency shifting, default override options, etc. Or
folks go to hearing aid coupling (more direct boot connections, cochlear
links, etc.) So I'm not sure how helpful it would be to add a telecom
standard that requires compatibility with add-on products when there are
so few such AT products on the market any more.

Diane

Diane Cordry Golden, Ph.D.
National Association of State Chief Information Officers Missouri
Assistive Technology Office

From: Michael Byington
Date: Mon, Nov 13 2006 7:55 PM
Subject: Re: More questions/discussion on gain

John, I agree with your points. The most powerful amplified telephone on
the market, and also the one which had the best and most adjustable
clarity circuitry, when I was doing equipment distribution was
manufactured by Williams Sound. It claimed to feature up to 55 db of
gain, and it was considerably more powerful than the phones that claimed
to achieve 60 db. I agree that none of these measurements are probably
accurate. Generally, however, it was true that 30, 40, 50, and 60 db all
meant something in that the 50 db phones were more powerful than the 30
db ones, etc. If you want to tell me that the gain was really more
between 20 db and 30 db, however, from an engineering standpoint, I will
not express surprise at this. The concern, quite obviously, however, is
that, we also may have similar difficulty believing that the current 12
db requirement is really being met with equipment that is truly 12 db.
If I understand your post correctly, I believe that this is the point
you are making about the lack of testing standards. Thanks.

>>> "John Combs (jcombs)" < = EMAIL ADDRESS REMOVED = > 11/13/2006 1:16 PM >>>
Michael,

Nice to meet you online.

One thing you mention in your text below -- an audio amplifier which
claims to have 60 dB of gain. This is another thing we should address
in the TEITAC discussions, lack of a testing standard for measuring
true
amplifier gain. Many manufacturers claims very high gain numbers, but
don't deliver anything close to what they say.

Let's consider 60 dB of audio gain. If the initial maximum audio
level
on an analog phone receiver is 1 Watt of sound power, a 60 dB boost of
this gives us 1 million Watts!

Regardless of claims, I've never found an inline handset amplifier
that
actually exceeded 30 dB of true gain.


- John Combs


-----Original Message-----
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Michael
Byington
Sent: Monday, November 13, 2006 12:40 AM
To: = EMAIL ADDRESS REMOVED =
Subject: Re: [teitac-telecom] More questions/discussion on gain

Diane, John, Jim, and others

I am new to this list, and like John, I want to introduce myself and
tell a little bit about my background. I was asked to participate on
this list by the President of the Council of Citizens with Low Vision
International (CCLVI) , Bernice Candarian. I am a past President of
CCLVI. I am legally blind and am a heavy user of visual aids for
information access although i also quite often choose to use screen
readers as well.

In terms of my professional background, I have a Master's in
Communications, and I have worked for many years, in a combination of
human service, disability rights advocacy, and telecommunications
access
positions. I served as Section 504 Coordinator for the City of Wichita
just after graduating from college, and long before the ADA. I have
worked for two centers for independent living in direct service and
administrative positions, have served as the Technical Consultant for
the Kansas Affiliate Program to the Helen Keller National Center for
Deafblind Youths and Adults, and have worked as a professional
lobbyist
representing several human service interests. For two and a half
years,
I served as Contract Administrator for Telecommunications Relay
Services
for the State of Kansas, and also as a part of that job, I had overall
responsibility for our telecommunications equipment distribution
program
in Kansas. I left that position three years ago and returned to direct
service; I currently serve as a Shift Manager in a residential
training
facility for people who are newly blind or visually impaired. In my
current position, I do quite a bit of teaching and independent living
training with people who are sensory impaired, but who are not at the
expert or even semi-skilled level of competence when it comes to the
use
of telecommunications accommodations such as screenreaders, enlarging
software, etc.

I do not begin to have the technical background that John does, and I
thank him for his insightful posting. What I want to share, however,
are
some practical thoughts as to what may work for the broad plethora of
people with sensory disabilities who need telecommunications
accommodations on the job, and what needs to be fleshed out in the
regulatory process for 508 and 255. I am going to address more of 508.
With regard to 255, I never have been fond of the "readily achievable"
level of compliance and enforcement built into the statute, and I will
leave the line of demarcation as to what is readily achievable to
build
in as opposed to make compatible for add-on to those with engineering
skills superior to mine, and to those who have more experience with
telecommunications and "readily achievable" based case law.

The central issue being discussed in the postings I have read on this
list and its parent website, however, relate to what standards of
universal design may be required by regulation to accommodate all of
those with disabilities who may need accommodation in the 508 covered
workplace. The first thing I want to caution is that universal design
in
developing parameters for telecommunications access for sensory
impaired
is a much less exacting science than it is to place physical standards
for the built environment in an operational document such as the
ADAAG.
It is easier, and less personalized or individualized to determine the
minimum requirements for width, slope, height of truncated domes,
etc.,
than it is to determine how much gain, or what font size or
screenreading hierarchy will work best for individual users in order
for
them to work competitively and efficiently.

I am not going to mention specific brands of equipment because I have
been our of the telecommunications equipment distribution day to day
operations for nearly three years now, so I know that brands, models,
and company alliances have all changed, and I have not really kept up.
I
will say, however, that when giving out amplified telephone equipment
in
Kansas, our program would not fund equipment with less than about 25
db
of amplification, and some thpes of amplification equipment we funded
had a gain of up to 60 db. This kind of technology could not be built
in
to a telephone system as a feature of universal design. One of many
reasons is that the level of very high amplification needed by some
severely hearing impaired individuals could actually be injurous to
the
hearing of a normally hearing individual, or individual with a less
severe loss. Yet, I would contend that the worker who has a very
severe
impairment, requiring, for example, 55 db of gain, should still have
the
option to choose to use their hearing for telephone communication
rather
that a traditional TTY, Cap-Tel, or other text based technology.

The same is true for accommodations for people who are blind and
visually impaired. Certainly a certain degree of enlargement
capabilities, and speech access can be built into a universal system,
but for the professional, well-trained user of such software as JAWS,
Window Eyes, or Zoomtext, the features of these particular pieces of
software configured specifically for the individual user, can make the
difference as to whether the person can work at a competitive level of
quality and productivity.

Thus, while I think a certain amount of the required minimum standards
to be built into systems as universal design features are important
for
overall, universal accessibility, most people who have significant
degrees of sensory disabilities are going to need more powerful and
personalized solutions. The ability to add on, and compatibility with,
individualized modifications therefore remains paramount.

It is becoming increasingly possible to in fact make access features
portable so that the worker moving from system to system or place to
place may have full access even if all access features are not built
into each system, terminal, or other linked equipment. For example,
two
very functional brands of screenreaders can now be loaded onto any
system without going through installation procedures, and through
simply
plugging a jump drive into a USB port. I think regulatory changes have
to be firm in providing for such needed individualized accommodations,
but I also think we make a regulatory mistake if we promulgate
regulatory language that relies on the state of current science. There
is every reason to believe that the progression of assistive
technology
is moving more and more toward situations where personally customized
access for people with specific and severe disabilities will be
provided
universally through personally carried add on devices attached to
systems in-line, through USB ports, and in other evolving ways.

I hope this is helpful. I look forwarding to hearing from many of you
on
the call later today.

Michael Byington


>>> "Diane Golden" < = EMAIL ADDRESS REMOVED = > 11/12/2006 5:18 PM >>>
First -- thank you, thank you, thank you, John for the info you
provided. I really needed much of that years ago when we began
procurement reviews, but it is still extremely helpful now (smile.)

So in reference to the issue of gain or volume control it appears all
phones have about 12 dB of gain/volume control built into the product
to
conform to HAC 68.317. However, the current 508 requirement,
1194.23(f), for 20 dB is not being met as a built-in feature which was
the intent of the standard.
(I can say this is accurate from the procurements I'm familiar with at
a
state level, but would be interesting to see if it is an accurate
reflection of what federal procurement officials are seeing also.)

So to follow up on Jim's questions, it would seem not a problem to
continue to require the 12 dB gain as a baseline for built-in gain
(provided there was a better definition of how gain is measured to
ensure consistency.) But clearly this will do nothing to increase
accessibility -- in fact it will appear to be a lessening of the
current
508 standard since that standard has not been met as intended.

When you described the distortion and shift to amplifying the high
frequencies for gain significantly over 12 dB, were you talking about
just "add-on" amplifiers to a base phone product (e.g. in-line
amplifiers or substituted handsets) or were you also talking about
stand
alone amplified phones? I would think this would influence Jim's
second
option for a standard that requires more than 12 dB of gain but allows
that to be "high frequency amplification". Specifically, how much of
that "shifted"
gain
could/should be delivered as a built-in feature to every phone
purchased?

And last, maybe it is just our experience in Missouri, but we find
very
few folks who go to "add-on" AT with reference to telephone access.
In
fact over the years, in-line amplifiers and other add-on AT products
have really faded from the market. Almost everything now is a
substituted product assumedly because of all the factors John
described,
power issues, frequency shifting, default override options, etc. Or
folks go to hearing aid coupling (more direct boot connections,
cochlear
links, etc.) So I'm not sure how helpful it would be to add a telecom
standard that requires compatibility with add-on products when there
are
so few such AT products on the market any more.

Diane

Diane Cordry Golden, Ph.D.
National Association of State Chief Information Officers Missouri
Assistive Technology Office