Thread Subject: VoIP enabled cell phones

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From: Baquis David
Date: Fri, Dec 15 2006 2:45 PM
Subject: VoIP enabled cell phones

I received a technical assistance inquiry today from someone who asked
if there are TTY-accessible VoIP (Voice of Internet Protocol) enabled
cell phones.

Beyond my days in the TTY Forum, I was uncertain if there are new
wireless VoIP accessibility barriers that I might not be aware of.
Perhaps the wireless industry can offer expert input on this. I would
need a basic primer as to how a regular digital cell phone differs from
a VoIP cell phone.

Related to that, I wonder if the subcommittee has considered
recommending whether VoIP should be addressed *explicitly* in the
refresh. We get that yes/no question about whether VoIP products are
covered. We have people who specifically look for the term, VoIP, in
the standards.

Perhaps you can address this point specifically, in your upcoming status
report to the plenary about your subcommittee discussions. Some people
are of the opinion that the standards apply to telecom functionality and
that it should not matter whether a phone is analog, digital or VoIP -
that they are all covered. On the other hand, others are uneasy about
appearing to preempt the FCC by saying VoIP products are telecom covered
by accessibility regulations, before they say so. We cut VoIP out of
the current published telecom technical assistance for that reason. The
flip side of this question is how would you feel about refreshed
standards that said absolutely nothing about VoIP. I can tell you that
it would not serve the needs of federal customers who want clarity on
that subject of how to know with confidence that the new VoIP system
they want to buy is fully accessible.

David Baquis
Accessibility Specialist
U.S. Access Board
1331 F Street, NW, #1000
Washington, DC 20004
800-USA-ABLE; (202) 272-0013 (voice)
www.access-board.gov; = EMAIL ADDRESS REMOVED =

From: Owen Rachal
Date: Fri, Dec 15 2006 7:15 PM
Subject: Re: VoIP enabled cell phones

Tenacity is currently researching this very issue. I am compiling the info that we have gathered and will get it out to the Subcommittee early next week. In the meantime, any input anybody else would like to offer would of course be appreciated. In particular, I am interested in what Dr. Michaelis and John Combs have to say about the subject. They may be able to save us some time.

But David: was the request for VOIP enabled CELL phones or just VOIP? The two are pretty significantly different as I understand it, though I am just now researching the wireless industry. VOIP systems actually have to convert information from cell phones to enable users within the VOIP network to talk to cell phone users, much like what happens with analog users. I will consult with our development team, but I am unaware of any VOIP cell phone trends with regard to TTY. Now, I do know that many cellular manufacturers are making cell phones that also make wifi calls over VOIP networks, and many VOIP manufacturers are working on mobile wifi phones for use similar to cell phones within covered areas. Additionally, it is possible to install a SIP phone on a smart phone and thus have a DIY VOIP cell phone. Is one of these what you are describing? If not, hopefully the info I am compiling will shed some light on the subject.

Of course, VOIP and TTY is a significant enough issue without the wireless component. Currently, a number of text standards are being pushed, both by noncommercial sources as well as telecomm manufacturers. I believe it is safe to say that VOIP in general cannot be said to be TTY-accessible, but rather certain VOIP systems have the competitive advantage of additional (analog?) technologies that make them TTY-accessible.

It is Tenacity's very strong belief that explicit mention of VOIP should be included throughout accessibility legislation - or at the very least, it should be explicitly mentioned that when a technology such as telephony is mentioned, it includes ALL permutations of that technology. While we feel that including VOIP within the broader subjects of "telephony" and "telecommunications" should be a simple and intuitive concepts for anyone reading the letter of the law, evidently that interpretation has not been shared by many VOIP stakeholders. Users perceive VOIP telephones to be just like any other phone and are equally angry when they find that they have in fact LOST accessibility when their empoyer switches to a "more powerful and functional" hi-tech VOIP phone system. While telephony has moved forward, accessibility with regards to telephony has not done so with some manufacturers -- although not all.

Finally - and I have been trying to figure out how to explain this model perfectly, so this may come out kind of muddled - but can we not include language sggesting that the core functionality of a product is what must be made accessible, instead of telling developers HOW to make things accessible? As one example, instead of saying "phones must be accessible to TTYs", why not say that "a user dependent upon text communication must be able to utilize text to communicate with other text-based communications devices, including TTYs." It seems to me that text communication from the phone to another TTY is as good as or better than installing a jack and an audio codec that enables a user to attach a TTY to an otherwise inaccessible phone. Additionally, the TTY-accessible model phone has the disadvantage of requiring additonal technology from the user, which prevents 1) the TTY-dependent user from being able to simply walk up to any phone and use it, such as when you borrow somebody else's phone to place a call, 2) the TTY dependent user from communicating if they do not have a functional TTY, such as if it breaks, is lost or stolen, etc., and 3) the TTY-independent user from being able to freely communicate with a TTY-dependent user. This seems to me to be a form of discrimination itself -- the TTY dependent user cannot freely talk in every situation nor with anyone they would want to talk with. Why not say that every phone should be able to send text to any other phone, which would allow for precisely that kind of freedom? It seems to me that approaching accessibility from a functional perspective (as in functional accessibility) would be more comprehensive and useful than addressing the techniques used by developers. When you address development techniques instead of user experiences, you can miss the forest for the trees, making a product that is COMPLIANT without being ACCESSIBLE, and ACCESSIBLE without being USABLE.

I welcome any thoughts on any of these points.

Thanks,
Owen Rachal
Director of Marketing and communications
Tenacity, Inc
337-735-9513
= EMAIL ADDRESS REMOVED =

-----Original Message-----
From: = EMAIL ADDRESS REMOVED = on behalf of Baquis David
Sent: Fri 12/15/2006 03:42 PM
To: = EMAIL ADDRESS REMOVED =
Subject: [teitac-telecom] VoIP enabled cell phones

I received a technical assistance inquiry today from someone who asked
if there are TTY-accessible VoIP (Voice of Internet Protocol) enabled
cell phones.

Beyond my days in the TTY Forum, I was uncertain if there are new
wireless VoIP accessibility barriers that I might not be aware of.
Perhaps the wireless industry can offer expert input on this. I would
need a basic primer as to how a regular digital cell phone differs from
a VoIP cell phone.

Related to that, I wonder if the subcommittee has considered
recommending whether VoIP should be addressed *explicitly* in the
refresh. We get that yes/no question about whether VoIP products are
covered. We have people who specifically look for the term, VoIP, in
the standards.

Perhaps you can address this point specifically, in your upcoming status
report to the plenary about your subcommittee discussions. Some people
are of the opinion that the standards apply to telecom functionality and
that it should not matter whether a phone is analog, digital or VoIP -
that they are all covered. On the other hand, others are uneasy about
appearing to preempt the FCC by saying VoIP products are telecom covered
by accessibility regulations, before they say so. We cut VoIP out of
the current published telecom technical assistance for that reason. The
flip side of this question is how would you feel about refreshed
standards that said absolutely nothing about VoIP. I can tell you that
it would not serve the needs of federal customers who want clarity on
that subject of how to know with confidence that the new VoIP system
they want to buy is fully accessible.

David Baquis
Accessibility Specialist
U.S. Access Board
1331 F Street, NW, #1000
Washington, DC 20004
800-USA-ABLE; (202) 272-0013 (voice)
www.access-board.gov; = EMAIL ADDRESS REMOVED =

From: Pam Ransom
Date: Tue, Dec 19 2006 1:50 PM
Subject: Re: VoIP enabled cell phones

David - There is always a challenge of working on two completely different
laws in one "refresh', and keeping the parameters of the two different laws
separate.

Speaking only about Section 255 of the Telecom Act - VoIP is not covered. In
fact the FCC's 255 Report and Order included a Further Notice of Inquiry
asking whether VoIP should be covered by 255 - and since that time (1999)
the FCC hasn't taken any action on that Further Notice of Inquiry.

Our subcommittee can certainly discuss and make suggestions about VoIP in
the 255 context, however the Advisory Subcommittee doesn't have the
authority to determine that VoIP is covered by 255, only the FCC has that
authority.

Pam Ransom


----- Original Message -----
From: "Baquis David " < = EMAIL ADDRESS REMOVED = >
To: < = EMAIL ADDRESS REMOVED = >
Sent: Friday, December 15, 2006 3:42 PM
Subject: [teitac-telecom] VoIP enabled cell phones


> I received a technical assistance inquiry today from someone who asked
> if there are TTY-accessible VoIP (Voice of Internet Protocol) enabled
> cell phones.
>
> Beyond my days in the TTY Forum, I was uncertain if there are new
> wireless VoIP accessibility barriers that I might not be aware of.
> Perhaps the wireless industry can offer expert input on this. I would
> need a basic primer as to how a regular digital cell phone differs from
> a VoIP cell phone.
>
> Related to that, I wonder if the subcommittee has considered
> recommending whether VoIP should be addressed *explicitly* in the
> refresh. We get that yes/no question about whether VoIP products are
> covered. We have people who specifically look for the term, VoIP, in
> the standards.
>
> Perhaps you can address this point specifically, in your upcoming status
> report to the plenary about your subcommittee discussions. Some people
> are of the opinion that the standards apply to telecom functionality and
> that it should not matter whether a phone is analog, digital or VoIP -
> that they are all covered. On the other hand, others are uneasy about
> appearing to preempt the FCC by saying VoIP products are telecom covered
> by accessibility regulations, before they say so. We cut VoIP out of
> the current published telecom technical assistance for that reason. The
> flip side of this question is how would you feel about refreshed
> standards that said absolutely nothing about VoIP. I can tell you that
> it would not serve the needs of federal customers who want clarity on
> that subject of how to know with confidence that the new VoIP system
> they want to buy is fully accessible.
>
> David Baquis
> Accessibility Specialist
> U.S. Access Board
> 1331 F Street, NW, #1000
> Washington, DC 20004
> 800-USA-ABLE; (202) 272-0013 (voice)
> www.access-board.gov; = EMAIL ADDRESS REMOVED =
>
>

From: Jim Tobias
Date: Tue, Dec 19 2006 3:05 PM
Subject: Re: VoIP enabled cell phones

I think we can address VoIP and all other platforms, present or future, if
we focus on the function being performed; "voice conversation". We can be
explicit about the platform independence by using phrases like "these
standards apply regardless of the platform on which the product or service
is built".


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


> -----Original Message-----
> From: Pam Ransom [mailto: = EMAIL ADDRESS REMOVED = ]
> Sent: Tuesday, December 19, 2006 3:47 PM
> To: TEITAC Telecommunications Subcommittee
> Subject: Re: [teitac-telecom] VoIP enabled cell phones
>
> David - There is always a challenge of working on two
> completely different laws in one "refresh', and keeping the
> parameters of the two different laws separate.
>
> Speaking only about Section 255 of the Telecom Act - VoIP is
> not covered. In fact the FCC's 255 Report and Order included
> a Further Notice of Inquiry asking whether VoIP should be
> covered by 255 - and since that time (1999) the FCC hasn't
> taken any action on that Further Notice of Inquiry.
>
> Our subcommittee can certainly discuss and make suggestions
> about VoIP in the 255 context, however the Advisory
> Subcommittee doesn't have the authority to determine that
> VoIP is covered by 255, only the FCC has that authority.
>
> Pam Ransom
>
>
> ----- Original Message -----
> From: "Baquis David " < = EMAIL ADDRESS REMOVED = >
> To: < = EMAIL ADDRESS REMOVED = >
> Sent: Friday, December 15, 2006 3:42 PM
> Subject: [teitac-telecom] VoIP enabled cell phones
>
>
> > I received a technical assistance inquiry today from
> someone who asked
> > if there are TTY-accessible VoIP (Voice of Internet
> Protocol) enabled
> > cell phones.
> >
> > Beyond my days in the TTY Forum, I was uncertain if there are new
> > wireless VoIP accessibility barriers that I might not be aware of.
> > Perhaps the wireless industry can offer expert input on
> this. I would
> > need a basic primer as to how a regular digital cell phone differs
> > from a VoIP cell phone.
> >
> > Related to that, I wonder if the subcommittee has considered
> > recommending whether VoIP should be addressed *explicitly* in the
> > refresh. We get that yes/no question about whether VoIP
> products are
> > covered. We have people who specifically look for the
> term, VoIP, in
> > the standards.
> >
> > Perhaps you can address this point specifically, in your upcoming
> > status report to the plenary about your subcommittee
> discussions. Some
> > people are of the opinion that the standards apply to telecom
> > functionality and that it should not matter whether a phone
> is analog,
> > digital or VoIP - that they are all covered. On the other
> hand, others
> > are uneasy about appearing to preempt the FCC by saying
> VoIP products
> > are telecom covered by accessibility regulations, before
> they say so.
> > We cut VoIP out of the current published telecom technical
> assistance
> > for that reason. The flip side of this question is how
> would you feel
> > about refreshed standards that said absolutely nothing
> about VoIP. I
> > can tell you that it would not serve the needs of federal customers
> > who want clarity on that subject of how to know with
> confidence that
> > the new VoIP system they want to buy is fully accessible.
> >
> > David Baquis
> > Accessibility Specialist
> > U.S. Access Board
> > 1331 F Street, NW, #1000
> > Washington, DC 20004
> > 800-USA-ABLE; (202) 272-0013 (voice)
> > www.access-board.gov; = EMAIL ADDRESS REMOVED =
> >
> >

From: Gregg Vanderheiden
Date: Thu, Dec 21 2006 9:55 AM
Subject: Re: VoIP enabled cell phones

You might treat PSTN and VoIP products as separate, with a separate set of
rules for each (which may be mostly - but not all- the same). You can then
say what rules apply to each (for 508 which covers both) yet make it easy to
separate the requirements for 255 (for as long as it only covers one). In
the future if congress says that VoIP should be under the same or separate
rules we would be all set.


Gregg
-- ------------------------------
Gregg C Vanderheiden Ph.D.



> -----Original Message-----
> From: = EMAIL ADDRESS REMOVED =
> [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of
> Pam Ransom
> Sent: Tuesday, December 19, 2006 2:47 PM
> To: TEITAC Telecommunications Subcommittee
> Subject: Re: [teitac-telecom] VoIP enabled cell phones
>
> David - There is always a challenge of working on two
> completely different laws in one "refresh', and keeping the
> parameters of the two different laws separate.
>
> Speaking only about Section 255 of the Telecom Act - VoIP is
> not covered. In fact the FCC's 255 Report and Order included
> a Further Notice of Inquiry asking whether VoIP should be
> covered by 255 - and since that time (1999) the FCC hasn't
> taken any action on that Further Notice of Inquiry.
>
> Our subcommittee can certainly discuss and make suggestions
> about VoIP in the 255 context, however the Advisory
> Subcommittee doesn't have the authority to determine that
> VoIP is covered by 255, only the FCC has that authority.
>
> Pam Ransom
>
>
> ----- Original Message -----
> From: "Baquis David " < = EMAIL ADDRESS REMOVED = >
> To: < = EMAIL ADDRESS REMOVED = >
> Sent: Friday, December 15, 2006 3:42 PM
> Subject: [teitac-telecom] VoIP enabled cell phones
>
>
> > I received a technical assistance inquiry today from
> someone who asked
> > if there are TTY-accessible VoIP (Voice of Internet
> Protocol) enabled
> > cell phones.
> >
> > Beyond my days in the TTY Forum, I was uncertain if there are new
> > wireless VoIP accessibility barriers that I might not be aware of.
> > Perhaps the wireless industry can offer expert input on
> this. I would
> > need a basic primer as to how a regular digital cell phone differs
> > from a VoIP cell phone.
> >
> > Related to that, I wonder if the subcommittee has considered
> > recommending whether VoIP should be addressed *explicitly* in the
> > refresh. We get that yes/no question about whether VoIP
> products are
> > covered. We have people who specifically look for the
> term, VoIP, in
> > the standards.
> >
> > Perhaps you can address this point specifically, in your upcoming
> > status report to the plenary about your subcommittee
> discussions. Some
> > people are of the opinion that the standards apply to telecom
> > functionality and that it should not matter whether a phone
> is analog,
> > digital or VoIP - that they are all covered. On the other
> hand, others
> > are uneasy about appearing to preempt the FCC by saying
> VoIP products
> > are telecom covered by accessibility regulations, before
> they say so.
> > We cut VoIP out of the current published telecom technical
> assistance
> > for that reason. The flip side of this question is how
> would you feel
> > about refreshed standards that said absolutely nothing
> about VoIP. I
> > can tell you that it would not serve the needs of federal customers
> > who want clarity on that subject of how to know with
> confidence that
> > the new VoIP system they want to buy is fully accessible.
> >
> > David Baquis
> > Accessibility Specialist
> > U.S. Access Board
> > 1331 F Street, NW, #1000
> > Washington, DC 20004
> > 800-USA-ABLE; (202) 272-0013 (voice)
> > www.access-board.gov; = EMAIL ADDRESS REMOVED =
> >
> >

From: Gregg Vanderheiden
Date: Thu, Dec 21 2006 10:00 AM
Subject: Re: VoIP enabled cell phones

You might treat PSTN and VoIP products as separate, with a separate set of
rules for each (which may be mostly - but not all- the same). You can then
say what rules apply to each (for 508 which covers both) yet make it easy to
separate the requirements for 255 (for as long as it only covers one). In
the future if congress says that VoIP should be under the same or separate
rules we would be all set.


Gregg
-- ------------------------------
Gregg C Vanderheiden Ph.D.



> -----Original Message-----
> From: = EMAIL ADDRESS REMOVED =
> [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of
> Pam Ransom
> Sent: Tuesday, December 19, 2006 2:47 PM
> To: TEITAC Telecommunications Subcommittee
> Subject: Re: [teitac-telecom] VoIP enabled cell phones
>
> David - There is always a challenge of working on two
> completely different laws in one "refresh', and keeping the
> parameters of the two different laws separate.
>
> Speaking only about Section 255 of the Telecom Act - VoIP is
> not covered. In fact the FCC's 255 Report and Order included
> a Further Notice of Inquiry asking whether VoIP should be
> covered by 255 - and since that time (1999) the FCC hasn't
> taken any action on that Further Notice of Inquiry.
>
> Our subcommittee can certainly discuss and make suggestions
> about VoIP in the 255 context, however the Advisory
> Subcommittee doesn't have the authority to determine that
> VoIP is covered by 255, only the FCC has that authority.
>
> Pam Ransom
>
>
> ----- Original Message -----
> From: "Baquis David " < = EMAIL ADDRESS REMOVED = >
> To: < = EMAIL ADDRESS REMOVED = >
> Sent: Friday, December 15, 2006 3:42 PM
> Subject: [teitac-telecom] VoIP enabled cell phones
>
>
> > I received a technical assistance inquiry today from
> someone who asked
> > if there are TTY-accessible VoIP (Voice of Internet
> Protocol) enabled
> > cell phones.
> >
> > Beyond my days in the TTY Forum, I was uncertain if there are new
> > wireless VoIP accessibility barriers that I might not be aware of.
> > Perhaps the wireless industry can offer expert input on
> this. I would
> > need a basic primer as to how a regular digital cell phone differs
> > from a VoIP cell phone.
> >
> > Related to that, I wonder if the subcommittee has considered
> > recommending whether VoIP should be addressed *explicitly* in the
> > refresh. We get that yes/no question about whether VoIP
> products are
> > covered. We have people who specifically look for the
> term, VoIP, in
> > the standards.
> >
> > Perhaps you can address this point specifically, in your upcoming
> > status report to the plenary about your subcommittee
> discussions. Some
> > people are of the opinion that the standards apply to telecom
> > functionality and that it should not matter whether a phone
> is analog,
> > digital or VoIP - that they are all covered. On the other
> hand, others
> > are uneasy about appearing to preempt the FCC by saying
> VoIP products
> > are telecom covered by accessibility regulations, before
> they say so.
> > We cut VoIP out of the current published telecom technical
> assistance
> > for that reason. The flip side of this question is how
> would you feel
> > about refreshed standards that said absolutely nothing
> about VoIP. I
> > can tell you that it would not serve the needs of federal customers
> > who want clarity on that subject of how to know with
> confidence that
> > the new VoIP system they want to buy is fully accessible.
> >
> > David Baquis
> > Accessibility Specialist
> > U.S. Access Board
> > 1331 F Street, NW, #1000
> > Washington, DC 20004
> > 800-USA-ABLE; (202) 272-0013 (voice)
> > www.access-board.gov; = EMAIL ADDRESS REMOVED =
> >
> >

From: Pam Ransom
Date: Thu, Dec 21 2006 10:50 AM
Subject: Re: VoIP enabled cell phones

Just for clarification.... I would anticipate that the subcommittees will be
discussing VoIP. However, for those Advisory Council and Subcommittee
members who may be newer to the issues of Section 255, I wouldn't want them
to get the wrong impression - Section 255 does not cover VoIP. The Advisory
Council does not have the authority to change that - only the FCC or
Congress does.
Pam Ransom


----- Original Message -----
From: "Jim Tobias" < = EMAIL ADDRESS REMOVED = >
To: "'Pam Ransom'" < = EMAIL ADDRESS REMOVED = >; "'TEITAC Telecommunications
Subcommittee'" < = EMAIL ADDRESS REMOVED = >
Sent: Tuesday, December 19, 2006 4:02 PM
Subject: Re: [teitac-telecom] VoIP enabled cell phones


> I think we can address VoIP and all other platforms, present or future, if
> we focus on the function being performed; "voice conversation". We can be
> explicit about the platform independence by using phrases like "these
> standards apply regardless of the platform on which the product or service
> is built".
>
>
> ***********
> Jim Tobias
> Inclusive Technologies
> = EMAIL ADDRESS REMOVED =
> +1.732.441.0831 v/tty
> skype jimtobias
> www.inclusive.com
>
>
> > -----Original Message-----
> > From: Pam Ransom [mailto: = EMAIL ADDRESS REMOVED = ]
> > Sent: Tuesday, December 19, 2006 3:47 PM
> > To: TEITAC Telecommunications Subcommittee
> > Subject: Re: [teitac-telecom] VoIP enabled cell phones
> >
> > David - There is always a challenge of working on two
> > completely different laws in one "refresh', and keeping the
> > parameters of the two different laws separate.
> >
> > Speaking only about Section 255 of the Telecom Act - VoIP is
> > not covered. In fact the FCC's 255 Report and Order included
> > a Further Notice of Inquiry asking whether VoIP should be
> > covered by 255 - and since that time (1999) the FCC hasn't
> > taken any action on that Further Notice of Inquiry.
> >
> > Our subcommittee can certainly discuss and make suggestions
> > about VoIP in the 255 context, however the Advisory
> > Subcommittee doesn't have the authority to determine that
> > VoIP is covered by 255, only the FCC has that authority.
> >
> > Pam Ransom
> >
> >
> > ----- Original Message -----
> > From: "Baquis David " < = EMAIL ADDRESS REMOVED = >
> > To: < = EMAIL ADDRESS REMOVED = >
> > Sent: Friday, December 15, 2006 3:42 PM
> > Subject: [teitac-telecom] VoIP enabled cell phones
> >
> >
> > > I received a technical assistance inquiry today from
> > someone who asked
> > > if there are TTY-accessible VoIP (Voice of Internet
> > Protocol) enabled
> > > cell phones.
> > >
> > > Beyond my days in the TTY Forum, I was uncertain if there are new
> > > wireless VoIP accessibility barriers that I might not be aware of.
> > > Perhaps the wireless industry can offer expert input on
> > this. I would
> > > need a basic primer as to how a regular digital cell phone differs
> > > from a VoIP cell phone.
> > >
> > > Related to that, I wonder if the subcommittee has considered
> > > recommending whether VoIP should be addressed *explicitly* in the
> > > refresh. We get that yes/no question about whether VoIP
> > products are
> > > covered. We have people who specifically look for the
> > term, VoIP, in
> > > the standards.
> > >
> > > Perhaps you can address this point specifically, in your upcoming
> > > status report to the plenary about your subcommittee
> > discussions. Some
> > > people are of the opinion that the standards apply to telecom
> > > functionality and that it should not matter whether a phone
> > is analog,
> > > digital or VoIP - that they are all covered. On the other
> > hand, others
> > > are uneasy about appearing to preempt the FCC by saying
> > VoIP products
> > > are telecom covered by accessibility regulations, before
> > they say so.
> > > We cut VoIP out of the current published telecom technical
> > assistance
> > > for that reason. The flip side of this question is how
> > would you feel
> > > about refreshed standards that said absolutely nothing
> > about VoIP. I
> > > can tell you that it would not serve the needs of federal customers
> > > who want clarity on that subject of how to know with
> > confidence that
> > > the new VoIP system they want to buy is fully accessible.
> > >
> > > David Baquis
> > > Accessibility Specialist
> > > U.S. Access Board
> > > 1331 F Street, NW, #1000
> > > Washington, DC 20004
> > > 800-USA-ABLE; (202) 272-0013 (voice)
> > > www.access-board.gov; = EMAIL ADDRESS REMOVED =
> > >
> > >

From: Jim Tobias
Date: Thu, Dec 21 2006 11:45 AM
Subject: Re: VoIP enabled cell phones

Why would we want to create separate accessibility rules for VoIP and
non-VoIP? Just because the FCC has purely historical difficulties
regulating VoIP doesn't mean that we have to. Frankly, we've been waiting 6
years for an answer to the VoIP question -- why wait longer when we have the
opportunity and are in fact being asked to press forward?

It seems better for everyone if we bite the bullet and create a single voice
telephony accessibility framework. It may be that manufacturers and service
providers will actually benefit from this simplicity and clarity.


> -----Original Message-----
> From: Gregg Vanderheiden [mailto: = EMAIL ADDRESS REMOVED = ]
> Sent: Thursday, December 21, 2006 11:53 AM
> To: 'TEITAC Telecommunications Subcommittee'
> Cc: 'TEITAC General Interface Accessibility Subcommittee'
> Subject: Re: [teitac-telecom] VoIP enabled cell phones
>
> You might treat PSTN and VoIP products as separate, with a
> separate set of
> rules for each (which may be mostly - but not all- the same).
> You can then
> say what rules apply to each (for 508 which covers both) yet
> make it easy to
> separate the requirements for 255 (for as long as it only
> covers one). In
> the future if congress says that VoIP should be under the
> same or separate rules we would be all set.
>
>
> Gregg
> -- ------------------------------
> Gregg C Vanderheiden Ph.D.
>
>
>
> > -----Original Message-----
> > From: = EMAIL ADDRESS REMOVED =
> > [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Pam
> > Ransom
> > Sent: Tuesday, December 19, 2006 2:47 PM
> > To: TEITAC Telecommunications Subcommittee
> > Subject: Re: [teitac-telecom] VoIP enabled cell phones
> >
> > David - There is always a challenge of working on two completely
> > different laws in one "refresh', and keeping the parameters
> of the two
> > different laws separate.
> >
> > Speaking only about Section 255 of the Telecom Act - VoIP is not
> > covered. In fact the FCC's 255 Report and Order included a Further
> > Notice of Inquiry asking whether VoIP should be covered by
> 255 - and
> > since that time (1999) the FCC hasn't taken any action on
> that Further
> > Notice of Inquiry.
> >
> > Our subcommittee can certainly discuss and make suggestions
> about VoIP
> > in the 255 context, however the Advisory Subcommittee
> doesn't have the
> > authority to determine that VoIP is covered by 255, only
> the FCC has
> > that authority.
> >
> > Pam Ransom
> >
> >
> > ----- Original Message -----
> > From: "Baquis David " < = EMAIL ADDRESS REMOVED = >
> > To: < = EMAIL ADDRESS REMOVED = >
> > Sent: Friday, December 15, 2006 3:42 PM
> > Subject: [teitac-telecom] VoIP enabled cell phones
> >
> >
> > > I received a technical assistance inquiry today from
> > someone who asked
> > > if there are TTY-accessible VoIP (Voice of Internet
> > Protocol) enabled
> > > cell phones.
> > >
> > > Beyond my days in the TTY Forum, I was uncertain if there are new
> > > wireless VoIP accessibility barriers that I might not be aware of.
> > > Perhaps the wireless industry can offer expert input on
> > this. I would
> > > need a basic primer as to how a regular digital cell
> phone differs
> > > from a VoIP cell phone.
> > >
> > > Related to that, I wonder if the subcommittee has considered
> > > recommending whether VoIP should be addressed *explicitly* in the
> > > refresh. We get that yes/no question about whether VoIP
> > products are
> > > covered. We have people who specifically look for the
> > term, VoIP, in
> > > the standards.
> > >
> > > Perhaps you can address this point specifically, in your upcoming
> > > status report to the plenary about your subcommittee
> > discussions. Some
> > > people are of the opinion that the standards apply to telecom
> > > functionality and that it should not matter whether a phone
> > is analog,
> > > digital or VoIP - that they are all covered. On the other
> > hand, others
> > > are uneasy about appearing to preempt the FCC by saying
> > VoIP products
> > > are telecom covered by accessibility regulations, before
> > they say so.
> > > We cut VoIP out of the current published telecom technical
> > assistance
> > > for that reason. The flip side of this question is how
> > would you feel
> > > about refreshed standards that said absolutely nothing
> > about VoIP. I
> > > can tell you that it would not serve the needs of federal
> customers
> > > who want clarity on that subject of how to know with
> > confidence that
> > > the new VoIP system they want to buy is fully accessible.
> > >
> > > David Baquis
> > > Accessibility Specialist
> > > U.S. Access Board
> > > 1331 F Street, NW, #1000
> > > Washington, DC 20004
> > > 800-USA-ABLE; (202) 272-0013 (voice) www.access-board.gov;
> > > = EMAIL ADDRESS REMOVED =
> > >
> > >

From: Jim Tobias
Date: Thu, Dec 21 2006 11:50 AM
Subject: Re: VoIP enabled cell phones

Why would we want to create separate accessibility rules for VoIP and
non-VoIP? Just because the FCC has purely historical difficulties
regulating VoIP doesn't mean that we have to. Frankly, we've been waiting 6
years for an answer to the VoIP question -- why wait longer when we have the
opportunity and are in fact being asked to press forward?

It seems better for everyone if we bite the bullet and create a single voice
telephony accessibility framework. It may be that manufacturers and service
providers will actually benefit from this simplicity and clarity.


> -----Original Message-----
> From: Gregg Vanderheiden [mailto: = EMAIL ADDRESS REMOVED = ]
> Sent: Thursday, December 21, 2006 11:53 AM
> To: 'TEITAC Telecommunications Subcommittee'
> Cc: 'TEITAC General Interface Accessibility Subcommittee'
> Subject: Re: [teitac-telecom] VoIP enabled cell phones
>
> You might treat PSTN and VoIP products as separate, with a
> separate set of
> rules for each (which may be mostly - but not all- the same).
> You can then
> say what rules apply to each (for 508 which covers both) yet
> make it easy to
> separate the requirements for 255 (for as long as it only
> covers one). In
> the future if congress says that VoIP should be under the
> same or separate rules we would be all set.
>
>
> Gregg
> -- ------------------------------
> Gregg C Vanderheiden Ph.D.
>
>
>
> > -----Original Message-----
> > From: = EMAIL ADDRESS REMOVED =
> > [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Pam
> > Ransom
> > Sent: Tuesday, December 19, 2006 2:47 PM
> > To: TEITAC Telecommunications Subcommittee
> > Subject: Re: [teitac-telecom] VoIP enabled cell phones
> >
> > David - There is always a challenge of working on two completely
> > different laws in one "refresh', and keeping the parameters
> of the two
> > different laws separate.
> >
> > Speaking only about Section 255 of the Telecom Act - VoIP is not
> > covered. In fact the FCC's 255 Report and Order included a Further
> > Notice of Inquiry asking whether VoIP should be covered by
> 255 - and
> > since that time (1999) the FCC hasn't taken any action on
> that Further
> > Notice of Inquiry.
> >
> > Our subcommittee can certainly discuss and make suggestions
> about VoIP
> > in the 255 context, however the Advisory Subcommittee
> doesn't have the
> > authority to determine that VoIP is covered by 255, only
> the FCC has
> > that authority.
> >
> > Pam Ransom
> >
> >
> > ----- Original Message -----
> > From: "Baquis David " < = EMAIL ADDRESS REMOVED = >
> > To: < = EMAIL ADDRESS REMOVED = >
> > Sent: Friday, December 15, 2006 3:42 PM
> > Subject: [teitac-telecom] VoIP enabled cell phones
> >
> >
> > > I received a technical assistance inquiry today from
> > someone who asked
> > > if there are TTY-accessible VoIP (Voice of Internet
> > Protocol) enabled
> > > cell phones.
> > >
> > > Beyond my days in the TTY Forum, I was uncertain if there are new
> > > wireless VoIP accessibility barriers that I might not be aware of.
> > > Perhaps the wireless industry can offer expert input on
> > this. I would
> > > need a basic primer as to how a regular digital cell
> phone differs
> > > from a VoIP cell phone.
> > >
> > > Related to that, I wonder if the subcommittee has considered
> > > recommending whether VoIP should be addressed *explicitly* in the
> > > refresh. We get that yes/no question about whether VoIP
> > products are
> > > covered. We have people who specifically look for the
> > term, VoIP, in
> > > the standards.
> > >
> > > Perhaps you can address this point specifically, in your upcoming
> > > status report to the plenary about your subcommittee
> > discussions. Some
> > > people are of the opinion that the standards apply to telecom
> > > functionality and that it should not matter whether a phone
> > is analog,
> > > digital or VoIP - that they are all covered. On the other
> > hand, others
> > > are uneasy about appearing to preempt the FCC by saying
> > VoIP products
> > > are telecom covered by accessibility regulations, before
> > they say so.
> > > We cut VoIP out of the current published telecom technical
> > assistance
> > > for that reason. The flip side of this question is how
> > would you feel
> > > about refreshed standards that said absolutely nothing
> > about VoIP. I
> > > can tell you that it would not serve the needs of federal
> customers
> > > who want clarity on that subject of how to know with
> > confidence that
> > > the new VoIP system they want to buy is fully accessible.
> > >
> > > David Baquis
> > > Accessibility Specialist
> > > U.S. Access Board
> > > 1331 F Street, NW, #1000
> > > Washington, DC 20004
> > > 800-USA-ABLE; (202) 272-0013 (voice) www.access-board.gov;
> > > = EMAIL ADDRESS REMOVED =
> > >
> > >

From: Owen Rachal
Date: Thu, Dec 21 2006 1:30 PM
Subject: Re: VoIP enabled cell phones

I agree. As I mentioned during the subcommittee meeting, it seems to me
that addressing accessibility is really a User Interface issue - much
like usability is a UI issue. The technology behind the UI can change as
much as it wants, as long as the UI accessibility issues are handled
according to a common benchmark. I realize that there are statutes
dictating what can and cannot be done by a given regulatory or advisory
body, but surely within that body and its sphere of influence it can
treat issues any way it likes!

If the Access Board decides to address technologies by function, for
example, when making its recommendations and dictates accessibility
standards for Voice Telecommunications, Text Telecommunications and
Video Telecommunications (a technology which may or may not even be
recognized yet, but is foreseeable and still identifiable by its
function), I would assume that it would be within its rights do so. Am I
wrong in thinking this way?

It would seem to me that the FCC (or whoever else) could simply look at
the Access Board standards and decide if it wants to follow suit or not.
If the standards also refer to a separate set of definitions external to
the standards (such as a new section which defines Video, Text and Voice
Telecommunications), then any agency which wants to consider adopting
the standards can simply accept the accessibility standards and rewrite
the definitions if they see fit.

Owen Rachal
Tenacity, Inc.
= EMAIL ADDRESS REMOVED =

-----Original Message-----
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Jim Tobias
Sent: Thursday, December 21, 2006 12:41 PM
To: 'TEITAC Telecommunications Subcommittee'
Cc: 'TEITAC General Interface Accessibility Subcommittee'
Subject: Re: [teitac-telecom] VoIP enabled cell phones

Why would we want to create separate accessibility rules for VoIP and
non-VoIP? Just because the FCC has purely historical difficulties
regulating VoIP doesn't mean that we have to. Frankly, we've been
waiting 6
years for an answer to the VoIP question -- why wait longer when we have
the
opportunity and are in fact being asked to press forward?

It seems better for everyone if we bite the bullet and create a single
voice
telephony accessibility framework. It may be that manufacturers and
service
providers will actually benefit from this simplicity and clarity.


> -----Original Message-----
> From: Gregg Vanderheiden [mailto: = EMAIL ADDRESS REMOVED = ]
> Sent: Thursday, December 21, 2006 11:53 AM
> To: 'TEITAC Telecommunications Subcommittee'
> Cc: 'TEITAC General Interface Accessibility Subcommittee'
> Subject: Re: [teitac-telecom] VoIP enabled cell phones
>
> You might treat PSTN and VoIP products as separate, with a
> separate set of
> rules for each (which may be mostly - but not all- the same).
> You can then
> say what rules apply to each (for 508 which covers both) yet
> make it easy to
> separate the requirements for 255 (for as long as it only
> covers one). In
> the future if congress says that VoIP should be under the
> same or separate rules we would be all set.
>
>
> Gregg
> -- ------------------------------
> Gregg C Vanderheiden Ph.D.
>
>
>
> > -----Original Message-----
> > From: = EMAIL ADDRESS REMOVED =
> > [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Pam
> > Ransom
> > Sent: Tuesday, December 19, 2006 2:47 PM
> > To: TEITAC Telecommunications Subcommittee
> > Subject: Re: [teitac-telecom] VoIP enabled cell phones
> >
> > David - There is always a challenge of working on two completely
> > different laws in one "refresh', and keeping the parameters
> of the two
> > different laws separate.
> >
> > Speaking only about Section 255 of the Telecom Act - VoIP is not
> > covered. In fact the FCC's 255 Report and Order included a Further
> > Notice of Inquiry asking whether VoIP should be covered by
> 255 - and
> > since that time (1999) the FCC hasn't taken any action on
> that Further
> > Notice of Inquiry.
> >
> > Our subcommittee can certainly discuss and make suggestions
> about VoIP
> > in the 255 context, however the Advisory Subcommittee
> doesn't have the
> > authority to determine that VoIP is covered by 255, only
> the FCC has
> > that authority.
> >
> > Pam Ransom
> >
> >
> > ----- Original Message -----
> > From: "Baquis David " < = EMAIL ADDRESS REMOVED = >
> > To: < = EMAIL ADDRESS REMOVED = >
> > Sent: Friday, December 15, 2006 3:42 PM
> > Subject: [teitac-telecom] VoIP enabled cell phones
> >
> >
> > > I received a technical assistance inquiry today from
> > someone who asked
> > > if there are TTY-accessible VoIP (Voice of Internet
> > Protocol) enabled
> > > cell phones.
> > >
> > > Beyond my days in the TTY Forum, I was uncertain if there are new
> > > wireless VoIP accessibility barriers that I might not be aware of.
> > > Perhaps the wireless industry can offer expert input on
> > this. I would
> > > need a basic primer as to how a regular digital cell
> phone differs
> > > from a VoIP cell phone.
> > >
> > > Related to that, I wonder if the subcommittee has considered
> > > recommending whether VoIP should be addressed *explicitly* in the
> > > refresh. We get that yes/no question about whether VoIP
> > products are
> > > covered. We have people who specifically look for the
> > term, VoIP, in
> > > the standards.
> > >
> > > Perhaps you can address this point specifically, in your upcoming
> > > status report to the plenary about your subcommittee
> > discussions. Some
> > > people are of the opinion that the standards apply to telecom
> > > functionality and that it should not matter whether a phone
> > is analog,
> > > digital or VoIP - that they are all covered. On the other
> > hand, others
> > > are uneasy about appearing to preempt the FCC by saying
> > VoIP products
> > > are telecom covered by accessibility regulations, before
> > they say so.
> > > We cut VoIP out of the current published telecom technical
> > assistance
> > > for that reason. The flip side of this question is how
> > would you feel
> > > about refreshed standards that said absolutely nothing
> > about VoIP. I
> > > can tell you that it would not serve the needs of federal
> customers
> > > who want clarity on that subject of how to know with
> > confidence that
> > > the new VoIP system they want to buy is fully accessible.
> > >
> > > David Baquis
> > > Accessibility Specialist
> > > U.S. Access Board
> > > 1331 F Street, NW, #1000
> > > Washington, DC 20004
> > > 800-USA-ABLE; (202) 272-0013 (voice) www.access-board.gov;
> > > = EMAIL ADDRESS REMOVED =
> > >
> > >

From: Karen Peltz Strauss
Date: Thu, Dec 21 2006 1:45 PM
Subject: Re: VoIP enabled cell phones

I agree as well. In fact, it is only a matter of time before VoIP providers
are covered by Section 255-type rules, either by the FCC or Congress.
Extending these accessibility obligations already came before Congress in
this past legislative session and had bi-partisan support. At the FCC,
VoIP providers are now required to provide emergency access, allow access to
their facilities for law enforcement purposes (CALEA), and pay into the
universal service fund. The FCC used its ancillary jurisdiction under Title
I of the Communications Act to apply these Title II obligations to these
providers. The only thing left in the social obligation arena is for the FCC
to extend its disability rules to VoIP providers. This is more than likely
to occur at some point in the not-so-distant future. Given that the TEITAC
has convened experts to refresh the accessibility rules, it makes sense to
offer guidance in this area at this point. In fact, this could be what is
needed to push the FCC to finish its proceedings on the social obligations
of VoIP providers.

Karen Peltz Strauss
CSD

----- Original Message -----
From: "Owen Rachal" < = EMAIL ADDRESS REMOVED = >
To: "TEITAC Telecommunications Subcommittee"
< = EMAIL ADDRESS REMOVED = >
Cc: "TEITAC General Interface Accessibility Subcommittee"
< = EMAIL ADDRESS REMOVED = >
Sent: Thursday, December 21, 2006 3:25 PM
Subject: Re: [teitac-telecom] VoIP enabled cell phones


>I agree. As I mentioned during the subcommittee meeting, it seems to me
> that addressing accessibility is really a User Interface issue - much
> like usability is a UI issue. The technology behind the UI can change as
> much as it wants, as long as the UI accessibility issues are handled
> according to a common benchmark. I realize that there are statutes
> dictating what can and cannot be done by a given regulatory or advisory
> body, but surely within that body and its sphere of influence it can
> treat issues any way it likes!
>
> If the Access Board decides to address technologies by function, for
> example, when making its recommendations and dictates accessibility
> standards for Voice Telecommunications, Text Telecommunications and
> Video Telecommunications (a technology which may or may not even be
> recognized yet, but is foreseeable and still identifiable by its
> function), I would assume that it would be within its rights do so. Am I
> wrong in thinking this way?
>
> It would seem to me that the FCC (or whoever else) could simply look at
> the Access Board standards and decide if it wants to follow suit or not.
> If the standards also refer to a separate set of definitions external to
> the standards (such as a new section which defines Video, Text and Voice
> Telecommunications), then any agency which wants to consider adopting
> the standards can simply accept the accessibility standards and rewrite
> the definitions if they see fit.
>
> Owen Rachal
> Tenacity, Inc.
> = EMAIL ADDRESS REMOVED =
>
> -----Original Message-----
> From: = EMAIL ADDRESS REMOVED =
> [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Jim Tobias
> Sent: Thursday, December 21, 2006 12:41 PM
> To: 'TEITAC Telecommunications Subcommittee'
> Cc: 'TEITAC General Interface Accessibility Subcommittee'
> Subject: Re: [teitac-telecom] VoIP enabled cell phones
>
> Why would we want to create separate accessibility rules for VoIP and
> non-VoIP? Just because the FCC has purely historical difficulties
> regulating VoIP doesn't mean that we have to. Frankly, we've been
> waiting 6
> years for an answer to the VoIP question -- why wait longer when we have
> the
> opportunity and are in fact being asked to press forward?
>
> It seems better for everyone if we bite the bullet and create a single
> voice
> telephony accessibility framework. It may be that manufacturers and
> service
> providers will actually benefit from this simplicity and clarity.
>
>
>> -----Original Message-----
>> From: Gregg Vanderheiden [mailto: = EMAIL ADDRESS REMOVED = ]
>> Sent: Thursday, December 21, 2006 11:53 AM
>> To: 'TEITAC Telecommunications Subcommittee'
>> Cc: 'TEITAC General Interface Accessibility Subcommittee'
>> Subject: Re: [teitac-telecom] VoIP enabled cell phones
>>
>> You might treat PSTN and VoIP products as separate, with a
>> separate set of
>> rules for each (which may be mostly - but not all- the same).
>> You can then
>> say what rules apply to each (for 508 which covers both) yet
>> make it easy to
>> separate the requirements for 255 (for as long as it only
>> covers one). In
>> the future if congress says that VoIP should be under the
>> same or separate rules we would be all set.
>>
>>
>> Gregg
>> -- ------------------------------
>> Gregg C Vanderheiden Ph.D.
>>
>>
>>
>> > -----Original Message-----
>> > From: = EMAIL ADDRESS REMOVED =
>> > [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Pam
>> > Ransom
>> > Sent: Tuesday, December 19, 2006 2:47 PM
>> > To: TEITAC Telecommunications Subcommittee
>> > Subject: Re: [teitac-telecom] VoIP enabled cell phones
>> >
>> > David - There is always a challenge of working on two completely
>> > different laws in one "refresh', and keeping the parameters
>> of the two
>> > different laws separate.
>> >
>> > Speaking only about Section 255 of the Telecom Act - VoIP is not
>> > covered. In fact the FCC's 255 Report and Order included a Further
>> > Notice of Inquiry asking whether VoIP should be covered by
>> 255 - and
>> > since that time (1999) the FCC hasn't taken any action on
>> that Further
>> > Notice of Inquiry.
>> >
>> > Our subcommittee can certainly discuss and make suggestions
>> about VoIP
>> > in the 255 context, however the Advisory Subcommittee
>> doesn't have the
>> > authority to determine that VoIP is covered by 255, only
>> the FCC has
>> > that authority.
>> >
>> > Pam Ransom
>> >
>> >
>> > ----- Original Message -----
>> > From: "Baquis David " < = EMAIL ADDRESS REMOVED = >
>> > To: < = EMAIL ADDRESS REMOVED = >
>> > Sent: Friday, December 15, 2006 3:42 PM
>> > Subject: [teitac-telecom] VoIP enabled cell phones
>> >
>> >
>> > > I received a technical assistance inquiry today from
>> > someone who asked
>> > > if there are TTY-accessible VoIP (Voice of Internet
>> > Protocol) enabled
>> > > cell phones.
>> > >
>> > > Beyond my days in the TTY Forum, I was uncertain if there are new
>> > > wireless VoIP accessibility barriers that I might not be aware of.
>> > > Perhaps the wireless industry can offer expert input on
>> > this. I would
>> > > need a basic primer as to how a regular digital cell
>> phone differs
>> > > from a VoIP cell phone.
>> > >
>> > > Related to that, I wonder if the subcommittee has considered
>> > > recommending whether VoIP should be addressed *explicitly* in the
>> > > refresh. We get that yes/no question about whether VoIP
>> > products are
>> > > covered. We have people who specifically look for the
>> > term, VoIP, in
>> > > the standards.
>> > >
>> > > Perhaps you can address this point specifically, in your upcoming
>> > > status report to the plenary about your subcommittee
>> > discussions. Some
>> > > people are of the opinion that the standards apply to telecom
>> > > functionality and that it should not matter whether a phone
>> > is analog,
>> > > digital or VoIP - that they are all covered. On the other
>> > hand, others
>> > > are uneasy about appearing to preempt the FCC by saying
>> > VoIP products
>> > > are telecom covered by accessibility regulations, before
>> > they say so.
>> > > We cut VoIP out of the current published telecom technical
>> > assistance
>> > > for that reason. The flip side of this question is how
>> > would you feel
>> > > about refreshed standards that said absolutely nothing
>> > about VoIP. I
>> > > can tell you that it would not serve the needs of federal
>> customers
>> > > who want clarity on that subject of how to know with
>> > confidence that
>> > > the new VoIP system they want to buy is fully accessible.
>> > >
>> > > David Baquis
>> > > Accessibility Specialist
>> > > U.S. Access Board
>> > > 1331 F Street, NW, #1000
>> > > Washington, DC 20004
>> > > 800-USA-ABLE; (202) 272-0013 (voice) www.access-board.gov;
>> > > = EMAIL ADDRESS REMOVED =
>> > >
>> > >

From: Gregg Vanderheiden
Date: Thu, Dec 21 2006 1:50 PM
Subject: Re: VoIP enabled cell phones

I know it seems to be the opposite direction from what are trying to do but
I think there are two reasons for having separate guideline sets for PSTN
and VoIP(with many features common)

1) We are charged with doing something that applies to both 508 and 255.
Whether we think it is logical or not - the FCC is treating VoIP differently
than PSTN. And we need to create rules they can use.

2) They are different in some ways. Things you can ask for on one you
cannot ask for on the other. (IPText and simultaneous text and voice for
example are not possible on PSTN.) On the other hand there are some
strategies that we know don't work (e.g. all the TTY provisions work great
on PSTN but do not work well - and we don't want to carry over to- IP
networks.)


Gregg
-- ------------------------------
Gregg C Vanderheiden Ph.D.



> -----Original Message-----
> From: = EMAIL ADDRESS REMOVED =
> [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of
> Jim Tobias
> Sent: Thursday, December 21, 2006 12:41 PM
> To: 'TEITAC Telecommunications Subcommittee'
> Cc: 'TEITAC General Interface Accessibility Subcommittee'
> Subject: Re: [teitac-telecom] VoIP enabled cell phones
>
> Why would we want to create separate accessibility rules for
> VoIP and non-VoIP? Just because the FCC has purely
> historical difficulties regulating VoIP doesn't mean that we
> have to. Frankly, we've been waiting 6 years for an answer
> to the VoIP question -- why wait longer when we have the
> opportunity and are in fact being asked to press forward?
>
> It seems better for everyone if we bite the bullet and create
> a single voice telephony accessibility framework. It may be
> that manufacturers and service providers will actually
> benefit from this simplicity and clarity.
>
>
> > -----Original Message-----
> > From: Gregg Vanderheiden [mailto: = EMAIL ADDRESS REMOVED = ]
> > Sent: Thursday, December 21, 2006 11:53 AM
> > To: 'TEITAC Telecommunications Subcommittee'
> > Cc: 'TEITAC General Interface Accessibility Subcommittee'
> > Subject: Re: [teitac-telecom] VoIP enabled cell phones
> >
> > You might treat PSTN and VoIP products as separate, with a separate
> > set of rules for each (which may be mostly - but not all- the same).
> > You can then
> > say what rules apply to each (for 508 which covers both)
> yet make it
> > easy to separate the requirements for 255 (for as long as it only
> > covers one). In
> > the future if congress says that VoIP should be under the same or
> > separate rules we would be all set.
> >
> >
> > Gregg
> > -- ------------------------------
> > Gregg C Vanderheiden Ph.D.
> >
> >
> >
> > > -----Original Message-----
> > > From: = EMAIL ADDRESS REMOVED =
> > > [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Pam
> > > Ransom
> > > Sent: Tuesday, December 19, 2006 2:47 PM
> > > To: TEITAC Telecommunications Subcommittee
> > > Subject: Re: [teitac-telecom] VoIP enabled cell phones
> > >
> > > David - There is always a challenge of working on two completely
> > > different laws in one "refresh', and keeping the parameters
> > of the two
> > > different laws separate.
> > >
> > > Speaking only about Section 255 of the Telecom Act - VoIP is not
> > > covered. In fact the FCC's 255 Report and Order included
> a Further
> > > Notice of Inquiry asking whether VoIP should be covered by
> > 255 - and
> > > since that time (1999) the FCC hasn't taken any action on
> > that Further
> > > Notice of Inquiry.
> > >
> > > Our subcommittee can certainly discuss and make suggestions
> > about VoIP
> > > in the 255 context, however the Advisory Subcommittee
> > doesn't have the
> > > authority to determine that VoIP is covered by 255, only
> > the FCC has
> > > that authority.
> > >
> > > Pam Ransom
> > >
> > >
> > > ----- Original Message -----
> > > From: "Baquis David " < = EMAIL ADDRESS REMOVED = >
> > > To: < = EMAIL ADDRESS REMOVED = >
> > > Sent: Friday, December 15, 2006 3:42 PM
> > > Subject: [teitac-telecom] VoIP enabled cell phones
> > >
> > >
> > > > I received a technical assistance inquiry today from
> > > someone who asked
> > > > if there are TTY-accessible VoIP (Voice of Internet
> > > Protocol) enabled
> > > > cell phones.
> > > >
> > > > Beyond my days in the TTY Forum, I was uncertain if
> there are new
> > > > wireless VoIP accessibility barriers that I might not
> be aware of.
> > > > Perhaps the wireless industry can offer expert input on
> > > this. I would
> > > > need a basic primer as to how a regular digital cell
> > phone differs
> > > > from a VoIP cell phone.
> > > >
> > > > Related to that, I wonder if the subcommittee has considered
> > > > recommending whether VoIP should be addressed
> *explicitly* in the
> > > > refresh. We get that yes/no question about whether VoIP
> > > products are
> > > > covered. We have people who specifically look for the
> > > term, VoIP, in
> > > > the standards.
> > > >
> > > > Perhaps you can address this point specifically, in
> your upcoming
> > > > status report to the plenary about your subcommittee
> > > discussions. Some
> > > > people are of the opinion that the standards apply to telecom
> > > > functionality and that it should not matter whether a phone
> > > is analog,
> > > > digital or VoIP - that they are all covered. On the other
> > > hand, others
> > > > are uneasy about appearing to preempt the FCC by saying
> > > VoIP products
> > > > are telecom covered by accessibility regulations, before
> > > they say so.
> > > > We cut VoIP out of the current published telecom technical
> > > assistance
> > > > for that reason. The flip side of this question is how
> > > would you feel
> > > > about refreshed standards that said absolutely nothing
> > > about VoIP. I
> > > > can tell you that it would not serve the needs of federal
> > customers
> > > > who want clarity on that subject of how to know with
> > > confidence that
> > > > the new VoIP system they want to buy is fully accessible.
> > > >
> > > > David Baquis
> > > > Accessibility Specialist
> > > > U.S. Access Board
> > > > 1331 F Street, NW, #1000
> > > > Washington, DC 20004
> > > > 800-USA-ABLE; (202) 272-0013 (voice) www.access-board.gov;
> > > > = EMAIL ADDRESS REMOVED =
> > > >
> > > >

From: Gregg Vanderheiden
Date: Thu, Dec 21 2006 1:55 PM
Subject: Re: VoIP enabled cell phones

I know it seems to be the opposite direction from what are trying to do but
I think there are two reasons for having separate guideline sets for PSTN
and VoIP(with many features common)

1) We are charged with doing something that applies to both 508 and 255.
Whether we think it is logical or not - the FCC is treating VoIP differently
than PSTN. And we need to create rules they can use.

2) They are different in some ways. Things you can ask for on one you
cannot ask for on the other. (IPText and simultaneous text and voice for
example are not possible on PSTN.) On the other hand there are some
strategies that we know don't work (e.g. all the TTY provisions work great
on PSTN but do not work well - and we don't want to carry over to- IP
networks.)


Gregg
-- ------------------------------
Gregg C Vanderheiden Ph.D.



> -----Original Message-----
> From: = EMAIL ADDRESS REMOVED =
> [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of
> Jim Tobias
> Sent: Thursday, December 21, 2006 12:41 PM
> To: 'TEITAC Telecommunications Subcommittee'
> Cc: 'TEITAC General Interface Accessibility Subcommittee'
> Subject: Re: [teitac-telecom] VoIP enabled cell phones
>
> Why would we want to create separate accessibility rules for
> VoIP and non-VoIP? Just because the FCC has purely
> historical difficulties regulating VoIP doesn't mean that we
> have to. Frankly, we've been waiting 6 years for an answer
> to the VoIP question -- why wait longer when we have the
> opportunity and are in fact being asked to press forward?
>
> It seems better for everyone if we bite the bullet and create
> a single voice telephony accessibility framework. It may be
> that manufacturers and service providers will actually
> benefit from this simplicity and clarity.
>
>
> > -----Original Message-----
> > From: Gregg Vanderheiden [mailto: = EMAIL ADDRESS REMOVED = ]
> > Sent: Thursday, December 21, 2006 11:53 AM
> > To: 'TEITAC Telecommunications Subcommittee'
> > Cc: 'TEITAC General Interface Accessibility Subcommittee'
> > Subject: Re: [teitac-telecom] VoIP enabled cell phones
> >
> > You might treat PSTN and VoIP products as separate, with a separate
> > set of rules for each (which may be mostly - but not all- the same).
> > You can then
> > say what rules apply to each (for 508 which covers both)
> yet make it
> > easy to separate the requirements for 255 (for as long as it only
> > covers one). In
> > the future if congress says that VoIP should be under the same or
> > separate rules we would be all set.
> >
> >
> > Gregg
> > -- ------------------------------
> > Gregg C Vanderheiden Ph.D.
> >
> >
> >
> > > -----Original Message-----
> > > From: = EMAIL ADDRESS REMOVED =
> > > [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Pam
> > > Ransom
> > > Sent: Tuesday, December 19, 2006 2:47 PM
> > > To: TEITAC Telecommunications Subcommittee
> > > Subject: Re: [teitac-telecom] VoIP enabled cell phones
> > >
> > > David - There is always a challenge of working on two completely
> > > different laws in one "refresh', and keeping the parameters
> > of the two
> > > different laws separate.
> > >
> > > Speaking only about Section 255 of the Telecom Act - VoIP is not
> > > covered. In fact the FCC's 255 Report and Order included
> a Further
> > > Notice of Inquiry asking whether VoIP should be covered by
> > 255 - and
> > > since that time (1999) the FCC hasn't taken any action on
> > that Further
> > > Notice of Inquiry.
> > >
> > > Our subcommittee can certainly discuss and make suggestions
> > about VoIP
> > > in the 255 context, however the Advisory Subcommittee
> > doesn't have the
> > > authority to determine that VoIP is covered by 255, only
> > the FCC has
> > > that authority.
> > >
> > > Pam Ransom
> > >
> > >
> > > ----- Original Message -----
> > > From: "Baquis David " < = EMAIL ADDRESS REMOVED = >
> > > To: < = EMAIL ADDRESS REMOVED = >
> > > Sent: Friday, December 15, 2006 3:42 PM
> > > Subject: [teitac-telecom] VoIP enabled cell phones
> > >
> > >
> > > > I received a technical assistance inquiry today from
> > > someone who asked
> > > > if there are TTY-accessible VoIP (Voice of Internet
> > > Protocol) enabled
> > > > cell phones.
> > > >
> > > > Beyond my days in the TTY Forum, I was uncertain if
> there are new
> > > > wireless VoIP accessibility barriers that I might not
> be aware of.
> > > > Perhaps the wireless industry can offer expert input on
> > > this. I would
> > > > need a basic primer as to how a regular digital cell
> > phone differs
> > > > from a VoIP cell phone.
> > > >
> > > > Related to that, I wonder if the subcommittee has considered
> > > > recommending whether VoIP should be addressed
> *explicitly* in the
> > > > refresh. We get that yes/no question about whether VoIP
> > > products are
> > > > covered. We have people who specifically look for the
> > > term, VoIP, in
> > > > the standards.
> > > >
> > > > Perhaps you can address this point specifically, in
> your upcoming
> > > > status report to the plenary about your subcommittee
> > > discussions. Some
> > > > people are of the opinion that the standards apply to telecom
> > > > functionality and that it should not matter whether a phone
> > > is analog,
> > > > digital or VoIP - that they are all covered. On the other
> > > hand, others
> > > > are uneasy about appearing to preempt the FCC by saying
> > > VoIP products
> > > > are telecom covered by accessibility regulations, before
> > > they say so.
> > > > We cut VoIP out of the current published telecom technical
> > > assistance
> > > > for that reason. The flip side of this question is how
> > > would you feel
> > > > about refreshed standards that said absolutely nothing
> > > about VoIP. I
> > > > can tell you that it would not serve the needs of federal
> > customers
> > > > who want clarity on that subject of how to know with
> > > confidence that
> > > > the new VoIP system they want to buy is fully accessible.
> > > >
> > > > David Baquis
> > > > Accessibility Specialist
> > > > U.S. Access Board
> > > > 1331 F Street, NW, #1000
> > > > Washington, DC 20004
> > > > 800-USA-ABLE; (202) 272-0013 (voice) www.access-board.gov;
> > > > = EMAIL ADDRESS REMOVED =
> > > >
> > > >

From: Gregg Vanderheiden
Date: Thu, Dec 21 2006 2:00 PM
Subject: Re: VoIP enabled cell phones

We still need to differentiate things like text communication on PSTN and
VoIP. Yes?


Gregg
-- ------------------------------
Gregg C Vanderheiden Ph.D.



> -----Original Message-----
> From: = EMAIL ADDRESS REMOVED =
> [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of
> Karen Peltz Strauss
> Sent: Thursday, December 21, 2006 2:42 PM
> To: TEITAC Telecommunications Subcommittee
> Subject: Re: [teitac-telecom] VoIP enabled cell phones
>
> I agree as well. In fact, it is only a matter of time before
> VoIP providers are covered by Section 255-type rules, either
> by the FCC or Congress.
> Extending these accessibility obligations already came before
> Congress in
> this past legislative session and had bi-partisan support.
> At the FCC,
> VoIP providers are now required to provide emergency access,
> allow access to their facilities for law enforcement purposes
> (CALEA), and pay into the universal service fund. The FCC
> used its ancillary jurisdiction under Title I of the
> Communications Act to apply these Title II obligations to
> these providers. The only thing left in the social obligation
> arena is for the FCC to extend its disability rules to VoIP
> providers. This is more than likely to occur at some point
> in the not-so-distant future. Given that the TEITAC has
> convened experts to refresh the accessibility rules, it makes
> sense to offer guidance in this area at this point. In fact,
> this could be what is needed to push the FCC to finish its
> proceedings on the social obligations of VoIP providers.
>
> Karen Peltz Strauss
> CSD
>
> ----- Original Message -----
> From: "Owen Rachal" < = EMAIL ADDRESS REMOVED = >
> To: "TEITAC Telecommunications Subcommittee"
> < = EMAIL ADDRESS REMOVED = >
> Cc: "TEITAC General Interface Accessibility Subcommittee"
> < = EMAIL ADDRESS REMOVED = >
> Sent: Thursday, December 21, 2006 3:25 PM
> Subject: Re: [teitac-telecom] VoIP enabled cell phones
>
>
> >I agree. As I mentioned during the subcommittee meeting, it
> seems to me
> > that addressing accessibility is really a User Interface
> issue - much
> > like usability is a UI issue. The technology behind the UI
> can change as
> > much as it wants, as long as the UI accessibility issues are handled
> > according to a common benchmark. I realize that there are statutes
> > dictating what can and cannot be done by a given regulatory
> or advisory
> > body, but surely within that body and its sphere of influence it can
> > treat issues any way it likes!
> >
> > If the Access Board decides to address technologies by function, for
> > example, when making its recommendations and dictates accessibility
> > standards for Voice Telecommunications, Text Telecommunications and
> > Video Telecommunications (a technology which may or may not even be
> > recognized yet, but is foreseeable and still identifiable by its
> > function), I would assume that it would be within its
> rights do so. Am I
> > wrong in thinking this way?
> >
> > It would seem to me that the FCC (or whoever else) could
> simply look at
> > the Access Board standards and decide if it wants to follow
> suit or not.
> > If the standards also refer to a separate set of
> definitions external to
> > the standards (such as a new section which defines Video,
> Text and Voice
> > Telecommunications), then any agency which wants to
> consider adopting
> > the standards can simply accept the accessibility standards
> and rewrite
> > the definitions if they see fit.
> >
> > Owen Rachal
> > Tenacity, Inc.
> > = EMAIL ADDRESS REMOVED =
> >
> > -----Original Message-----
> > From: = EMAIL ADDRESS REMOVED =
> > [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf
> Of Jim Tobias
> > Sent: Thursday, December 21, 2006 12:41 PM
> > To: 'TEITAC Telecommunications Subcommittee'
> > Cc: 'TEITAC General Interface Accessibility Subcommittee'
> > Subject: Re: [teitac-telecom] VoIP enabled cell phones
> >
> > Why would we want to create separate accessibility rules
> for VoIP and
> > non-VoIP? Just because the FCC has purely historical difficulties
> > regulating VoIP doesn't mean that we have to. Frankly, we've been
> > waiting 6
> > years for an answer to the VoIP question -- why wait longer
> when we have
> > the
> > opportunity and are in fact being asked to press forward?
> >
> > It seems better for everyone if we bite the bullet and
> create a single
> > voice
> > telephony accessibility framework. It may be that manufacturers and
> > service
> > providers will actually benefit from this simplicity and clarity.
> >
> >
> >> -----Original Message-----
> >> From: Gregg Vanderheiden [mailto: = EMAIL ADDRESS REMOVED = ]
> >> Sent: Thursday, December 21, 2006 11:53 AM
> >> To: 'TEITAC Telecommunications Subcommittee'
> >> Cc: 'TEITAC General Interface Accessibility Subcommittee'
> >> Subject: Re: [teitac-telecom] VoIP enabled cell phones
> >>
> >> You might treat PSTN and VoIP products as separate, with a
> >> separate set of
> >> rules for each (which may be mostly - but not all- the same).
> >> You can then
> >> say what rules apply to each (for 508 which covers both) yet
> >> make it easy to
> >> separate the requirements for 255 (for as long as it only
> >> covers one). In
> >> the future if congress says that VoIP should be under the
> >> same or separate rules we would be all set.
> >>
> >>
> >> Gregg
> >> -- ------------------------------
> >> Gregg C Vanderheiden Ph.D.
> >>
> >>
> >>
> >> > -----Original Message-----
> >> > From: = EMAIL ADDRESS REMOVED =
> >> > [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Pam
> >> > Ransom
> >> > Sent: Tuesday, December 19, 2006 2:47 PM
> >> > To: TEITAC Telecommunications Subcommittee
> >> > Subject: Re: [teitac-telecom] VoIP enabled cell phones
> >> >
> >> > David - There is always a challenge of working on two completely
> >> > different laws in one "refresh', and keeping the parameters
> >> of the two
> >> > different laws separate.
> >> >
> >> > Speaking only about Section 255 of the Telecom Act - VoIP is not
> >> > covered. In fact the FCC's 255 Report and Order included
> a Further
> >> > Notice of Inquiry asking whether VoIP should be covered by
> >> 255 - and
> >> > since that time (1999) the FCC hasn't taken any action on
> >> that Further
> >> > Notice of Inquiry.
> >> >
> >> > Our subcommittee can certainly discuss and make suggestions
> >> about VoIP
> >> > in the 255 context, however the Advisory Subcommittee
> >> doesn't have the
> >> > authority to determine that VoIP is covered by 255, only
> >> the FCC has
> >> > that authority.
> >> >
> >> > Pam Ransom
> >> >
> >> >
> >> > ----- Original Message -----
> >> > From: "Baquis David " < = EMAIL ADDRESS REMOVED = >
> >> > To: < = EMAIL ADDRESS REMOVED = >
> >> > Sent: Friday, December 15, 2006 3:42 PM
> >> > Subject: [teitac-telecom] VoIP enabled cell phones
> >> >
> >> >
> >> > > I received a technical assistance inquiry today from
> >> > someone who asked
> >> > > if there are TTY-accessible VoIP (Voice of Internet
> >> > Protocol) enabled
> >> > > cell phones.
> >> > >
> >> > > Beyond my days in the TTY Forum, I was uncertain if
> there are new
> >> > > wireless VoIP accessibility barriers that I might not
> be aware of.
> >> > > Perhaps the wireless industry can offer expert input on
> >> > this. I would
> >> > > need a basic primer as to how a regular digital cell
> >> phone differs
> >> > > from a VoIP cell phone.
> >> > >
> >> > > Related to that, I wonder if the subcommittee has considered
> >> > > recommending whether VoIP should be addressed
> *explicitly* in the
> >> > > refresh. We get that yes/no question about whether VoIP
> >> > products are
> >> > > covered. We have people who specifically look for the
> >> > term, VoIP, in
> >> > > the standards.
> >> > >
> >> > > Perhaps you can address this point specifically, in
> your upcoming
> >> > > status report to the plenary about your subcommittee
> >> > discussions. Some
> >> > > people are of the opinion that the standards apply to telecom
> >> > > functionality and that it should not matter whether a phone
> >> > is analog,
> >> > > digital or VoIP - that they are all covered. On the other
> >> > hand, others
> >> > > are uneasy about appearing to preempt the FCC by saying
> >> > VoIP products
> >> > > are telecom covered by accessibility regulations, before
> >> > they say so.
> >> > > We cut VoIP out of the current published telecom technical
> >> > assistance
> >> > > for that reason. The flip side of this question is how
> >> > would you feel
> >> > > about refreshed standards that said absolutely nothing
> >> > about VoIP. I
> >> > > can tell you that it would not serve the needs of federal
> >> customers
> >> > > who want clarity on that subject of how to know with
> >> > confidence that
> >> > > the new VoIP system they want to buy is fully accessible.
> >> > >
> >> > > David Baquis
> >> > > Accessibility Specialist
> >> > > U.S. Access Board
> >> > > 1331 F Street, NW, #1000
> >> > > Washington, DC 20004
> >> > > 800-USA-ABLE; (202) 272-0013 (voice) www.access-board.gov;
> >> > > = EMAIL ADDRESS REMOVED =
> >> > >
> >> > >

From: Pam Ransom
Date: Thu, Dec 21 2006 2:35 PM
Subject: Re: VoIP enabled cell phones

All that's being stated is the fact that Section 255 doesn't cover VoIP.
Advisory Council members, through the subcommittee process and its
deliberations will figure out how to best address VoIP in its
recommendations to the Access Board.

----- Original Message -----
From: "Jim Tobias" < = EMAIL ADDRESS REMOVED = >
To: "'TEITAC Telecommunications Subcommittee'"
< = EMAIL ADDRESS REMOVED = >
Cc: "'TEITAC General Interface Accessibility Subcommittee'"
< = EMAIL ADDRESS REMOVED = >
Sent: Thursday, December 21, 2006 12:41 PM
Subject: Re: [teitac-telecom] VoIP enabled cell phones


> Why would we want to create separate accessibility rules for VoIP and
> non-VoIP? Just because the FCC has purely historical difficulties
> regulating VoIP doesn't mean that we have to. Frankly, we've been waiting
6
> years for an answer to the VoIP question -- why wait longer when we have
the
> opportunity and are in fact being asked to press forward?
>
> It seems better for everyone if we bite the bullet and create a single
voice
> telephony accessibility framework. It may be that manufacturers and
service
> providers will actually benefit from this simplicity and clarity.
>
>
> > -----Original Message-----
> > From: Gregg Vanderheiden [mailto: = EMAIL ADDRESS REMOVED = ]
> > Sent: Thursday, December 21, 2006 11:53 AM
> > To: 'TEITAC Telecommunications Subcommittee'
> > Cc: 'TEITAC General Interface Accessibility Subcommittee'
> > Subject: Re: [teitac-telecom] VoIP enabled cell phones
> >
> > You might treat PSTN and VoIP products as separate, with a
> > separate set of
> > rules for each (which may be mostly - but not all- the same).
> > You can then
> > say what rules apply to each (for 508 which covers both) yet
> > make it easy to
> > separate the requirements for 255 (for as long as it only
> > covers one). In
> > the future if congress says that VoIP should be under the
> > same or separate rules we would be all set.
> >
> >
> > Gregg
> > -- ------------------------------
> > Gregg C Vanderheiden Ph.D.
> >
> >
> >
> > > -----Original Message-----
> > > From: = EMAIL ADDRESS REMOVED =
> > > [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Pam
> > > Ransom
> > > Sent: Tuesday, December 19, 2006 2:47 PM
> > > To: TEITAC Telecommunications Subcommittee
> > > Subject: Re: [teitac-telecom] VoIP enabled cell phones
> > >
> > > David - There is always a challenge of working on two completely
> > > different laws in one "refresh', and keeping the parameters
> > of the two
> > > different laws separate.
> > >
> > > Speaking only about Section 255 of the Telecom Act - VoIP is not
> > > covered. In fact the FCC's 255 Report and Order included a Further
> > > Notice of Inquiry asking whether VoIP should be covered by
> > 255 - and
> > > since that time (1999) the FCC hasn't taken any action on
> > that Further
> > > Notice of Inquiry.
> > >
> > > Our subcommittee can certainly discuss and make suggestions
> > about VoIP
> > > in the 255 context, however the Advisory Subcommittee
> > doesn't have the
> > > authority to determine that VoIP is covered by 255, only
> > the FCC has
> > > that authority.
> > >
> > > Pam Ransom
> > >
> > >
> > > ----- Original Message -----
> > > From: "Baquis David " < = EMAIL ADDRESS REMOVED = >
> > > To: < = EMAIL ADDRESS REMOVED = >
> > > Sent: Friday, December 15, 2006 3:42 PM
> > > Subject: [teitac-telecom] VoIP enabled cell phones
> > >
> > >
> > > > I received a technical assistance inquiry today from
> > > someone who asked
> > > > if there are TTY-accessible VoIP (Voice of Internet
> > > Protocol) enabled
> > > > cell phones.
> > > >
> > > > Beyond my days in the TTY Forum, I was uncertain if there are new
> > > > wireless VoIP accessibility barriers that I might not be aware of.
> > > > Perhaps the wireless industry can offer expert input on
> > > this. I would
> > > > need a basic primer as to how a regular digital cell
> > phone differs
> > > > from a VoIP cell phone.
> > > >
> > > > Related to that, I wonder if the subcommittee has considered
> > > > recommending whether VoIP should be addressed *explicitly* in the
> > > > refresh. We get that yes/no question about whether VoIP
> > > products are
> > > > covered. We have people who specifically look for the
> > > term, VoIP, in
> > > > the standards.
> > > >
> > > > Perhaps you can address this point specifically, in your upcoming
> > > > status report to the plenary about your subcommittee
> > > discussions. Some
> > > > people are of the opinion that the standards apply to telecom
> > > > functionality and that it should not matter whether a phone
> > > is analog,
> > > > digital or VoIP - that they are all covered. On the other
> > > hand, others
> > > > are uneasy about appearing to preempt the FCC by saying
> > > VoIP products
> > > > are telecom covered by accessibility regulations, before
> > > they say so.
> > > > We cut VoIP out of the current published telecom technical
> > > assistance
> > > > for that reason. The flip side of this question is how
> > > would you feel
> > > > about refreshed standards that said absolutely nothing
> > > about VoIP. I
> > > > can tell you that it would not serve the needs of federal
> > customers
> > > > who want clarity on that subject of how to know with
> > > confidence that
> > > > the new VoIP system they want to buy is fully accessible.
> > > >
> > > > David Baquis
> > > > Accessibility Specialist
> > > > U.S. Access Board
> > > > 1331 F Street, NW, #1000
> > > > Washington, DC 20004
> > > > 800-USA-ABLE; (202) 272-0013 (voice) www.access-board.gov;
> > > > = EMAIL ADDRESS REMOVED =
> > > >
> > > >

From: Jim Tobias
Date: Thu, Dec 21 2006 2:55 PM
Subject: Re: VoIP enabled cell phones

Regarding PSTN and VoIP, 255 and 508, Gregg wrote:

> We still need to differentiate things like text communication
> on PSTN and VoIP. Yes?

How about if at the "top level" text commmunication is considered as a unit
(or perhaps divided into "stored" and "realtime")? Don't SMS, email,
web-based chat, etc. share most of their accessibility issues? Then
dropping down to the platform level, add the proper amount of "sufficient
techniques" guidance.

From: Jim Tobias
Date: Thu, Dec 21 2006 3:00 PM
Subject: Re: VoIP enabled cell phones

Gregg wrote:
> I know it seems to be the opposite direction from what are
> trying to do but I think there are two reasons for having
> separate guideline sets for PSTN and VoIP(with many features common)
>
> 1) We are charged with doing something that applies to both
> 508 and 255.
> Whether we think it is logical or not - the FCC is treating
> VoIP differently than PSTN. And we need to create rules they
> can use.

We are charged with harmonizing 255 and 508, not perpetuating the
distinction. And although we can't force the FCC to adopt our attempt at
harmonization, we shouldn't have to wait for their permission to make
reasonable, technologically sound improvements in the regs.

Gregg wrote:
> 2) They are different in some ways. Things you can ask for
> on one you cannot ask for on the other. (IPText and
> simultaneous text and voice for
> example are not possible on PSTN.) On the other hand there are some
> strategies that we know don't work (e.g. all the TTY
> provisions work great on PSTN but do not work well - and we
> don't want to carry over to- IP
> networks.)

I would be willing to argue these points. Voice and text can indeed be
mixed on the PSTN (consider VCO/HCO). Just because they can't be done in
the same microsecond is irrelevant to the user experience. And even Baudot
performance over IP can be tweaked if need be. Beyond these, of course, we
can't require something that's not feasible, and there's always the "undue
burden" dodge.

I think the key to progess here is what we all have been converging on, and
Hajime really crystallized a few days ago: regulations drafted with an
integrated functional view that starts at a high level ("voice
conversation"), then specifies the various elements of that ("audio
quality", "volume and gain", "hearing aid compatibility", etc.), and then,
for each element, indicates both requirements and "sufficient techniques"
for all platforms, or by platform when necessary.

From: Jim Tobias
Date: Thu, Dec 21 2006 3:05 PM
Subject: Re: VoIP enabled cell phones

Regarding PSTN and VoIP, 255 and 508, Gregg wrote:

> We still need to differentiate things like text communication
> on PSTN and VoIP. Yes?

How about if at the "top level" text commmunication is considered as a unit
(or perhaps divided into "stored" and "realtime")? Don't SMS, email,
web-based chat, etc. share most of their accessibility issues? Then
dropping down to the platform level, add the proper amount of "sufficient
techniques" guidance.

From: Jim Tobias
Date: Thu, Dec 21 2006 3:15 PM
Subject: Re: VoIP enabled cell phones

Pam wrote:
> All that's being stated is the fact that Section 255 doesn't
> cover VoIP.

This raises a question for me. Was VoIP excluded from consideration in the
text of the Telecom Act, or only by how the FCC chose to regulate? So, for
example, could the FCC now rule that 255 *does* apply to VoIP, with or
without making a large decision about VoIP? I know it's a different kettle
of fish, but I remember Judge Green ruling that, for the sake of
accessibility only (TRS), that the Baby Bells could carry telephone traffic
across LATA boundaries, something they were forbidden to do for other
purposes. Sorry if this makes no sense.

From: BLACKLER, ELLEN (SBCSI)
Date: Thu, Dec 21 2006 3:30 PM
Subject: Re: VoIP enabled cell phones

In the Telecom Act, section 255 applies explicitly to
"telecommunications services", which do not include VOIP. The FCC has
not yet determined that VOIP is a telecommunication service. If they
make such a determination, then 255 would apply. The FCC could also
determine they can extend accessibility requirements to VOIP using some
other jurisdictional basis as they did with voicemail, which is also not
a telecommunication service. But they have not done that yet either.
Or congress could do it with a change in law.

Regardless, AT&T would support development of standards for
accessibility for VOIP. They would be immediately relevant for 508 and
they would be useful for the FCC in considering the issue. I think it
would be easier for the FCC to consider it if they had something
concrete before them. Having said that, it seems to me there are
technical reasons that different standards might be necessary for VOIP
versus traditional telephony - not because consumers needs are
different, but because the way the needs are achieved might be different
for the different platforms.

-----Original Message-----
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Jim Tobias
Sent: Thursday, December 21, 2006 5:13 PM
To: 'Pam Ransom'; 'TEITAC Telecommunications Subcommittee'
Subject: Re: [teitac-telecom] VoIP enabled cell phones




Pam wrote:
> All that's being stated is the fact that Section 255 doesn't
> cover VoIP.

This raises a question for me. Was VoIP excluded from consideration in
the
text of the Telecom Act, or only by how the FCC chose to regulate? So,
for
example, could the FCC now rule that 255 *does* apply to VoIP, with or
without making a large decision about VoIP? I know it's a different
kettle
of fish, but I remember Judge Green ruling that, for the sake of
accessibility only (TRS), that the Baby Bells could carry telephone
traffic
across LATA boundaries, something they were forbidden to do for other
purposes. Sorry if this makes no sense.

From: Karen Peltz Strauss
Date: Thu, Dec 21 2006 3:55 PM
Subject: Re: VoIP enabled cell phones

Ellen is right - the FCC could decide that 255 covers VoIP - just like they
decided that 2 other information services (voice mail and IVR services) are
covered under 255. VoIP was not under consideration by the 1996 because it
did not exist back then.

----- Original Message -----
From: "BLACKLER, ELLEN (SBCSI)" < = EMAIL ADDRESS REMOVED = >
To: "TEITAC Telecommunications Subcommittee"
< = EMAIL ADDRESS REMOVED = >; "Pam Ransom" < = EMAIL ADDRESS REMOVED = >
Sent: Thursday, December 21, 2006 5:24 PM
Subject: Re: [teitac-telecom] VoIP enabled cell phones


> In the Telecom Act, section 255 applies explicitly to
> "telecommunications services", which do not include VOIP. The FCC has
> not yet determined that VOIP is a telecommunication service. If they
> make such a determination, then 255 would apply. The FCC could also
> determine they can extend accessibility requirements to VOIP using some
> other jurisdictional basis as they did with voicemail, which is also not
> a telecommunication service. But they have not done that yet either.
> Or congress could do it with a change in law.
>
> Regardless, AT&T would support development of standards for
> accessibility for VOIP. They would be immediately relevant for 508 and
> they would be useful for the FCC in considering the issue. I think it
> would be easier for the FCC to consider it if they had something
> concrete before them. Having said that, it seems to me there are
> technical reasons that different standards might be necessary for VOIP
> versus traditional telephony - not because consumers needs are
> different, but because the way the needs are achieved might be different
> for the different platforms.
>
> -----Original Message-----
> From: = EMAIL ADDRESS REMOVED =
> [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Jim Tobias
> Sent: Thursday, December 21, 2006 5:13 PM
> To: 'Pam Ransom'; 'TEITAC Telecommunications Subcommittee'
> Subject: Re: [teitac-telecom] VoIP enabled cell phones
>
>
>
>
> Pam wrote:
>> All that's being stated is the fact that Section 255 doesn't
>> cover VoIP.
>
> This raises a question for me. Was VoIP excluded from consideration in
> the
> text of the Telecom Act, or only by how the FCC chose to regulate? So,
> for
> example, could the FCC now rule that 255 *does* apply to VoIP, with or
> without making a large decision about VoIP? I know it's a different
> kettle
> of fish, but I remember Judge Green ruling that, for the sake of
> accessibility only (TRS), that the Baby Bells could carry telephone
> traffic
> across LATA boundaries, something they were forbidden to do for other
> purposes. Sorry if this makes no sense.
>
>

From: Jagbell
Date: Thu, Dec 21 2006 5:00 PM
Subject: Re: VoIP enabled cell phones

I agree. The goal of this group is to converge items where possible
and not to perpetuate artificial distinctions. People will
understand the issues if we simplify the rules. As it is now, these
artificial distinctions only confuse people.

Janice


On Dec 21, 2006, at 5:53 PM, Karen Peltz Strauss wrote:

> Ellen is right - the FCC could decide that 255 covers VoIP - just
> like they
> decided that 2 other information services (voice mail and IVR
> services) are
> covered under 255. VoIP was not under consideration by the 1996
> because it
> did not exist back then.
>
> ----- Original Message -----
> From: "BLACKLER, ELLEN (SBCSI)" < = EMAIL ADDRESS REMOVED = >
> To: "TEITAC Telecommunications Subcommittee"
> < = EMAIL ADDRESS REMOVED = >; "Pam Ransom"
> < = EMAIL ADDRESS REMOVED = >
> Sent: Thursday, December 21, 2006 5:24 PM
> Subject: Re: [teitac-telecom] VoIP enabled cell phones
>
>
>> In the Telecom Act, section 255 applies explicitly to
>> "telecommunications services", which do not include VOIP. The FCC
>> has
>> not yet determined that VOIP is a telecommunication service. If they
>> make such a determination, then 255 would apply. The FCC could also
>> determine they can extend accessibility requirements to VOIP using
>> some
>> other jurisdictional basis as they did with voicemail, which is
>> also not
>> a telecommunication service. But they have not done that yet either.
>> Or congress could do it with a change in law.
>>
>> Regardless, AT&T would support development of standards for
>> accessibility for VOIP. They would be immediately relevant for
>> 508 and
>> they would be useful for the FCC in considering the issue. I
>> think it
>> would be easier for the FCC to consider it if they had something
>> concrete before them. Having said that, it seems to me there are
>> technical reasons that different standards might be necessary for
>> VOIP
>> versus traditional telephony - not because consumers needs are
>> different, but because the way the needs are achieved might be
>> different
>> for the different platforms.
>>
>> -----Original Message-----
>> From: = EMAIL ADDRESS REMOVED =
>> [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Jim
>> Tobias
>> Sent: Thursday, December 21, 2006 5:13 PM
>> To: 'Pam Ransom'; 'TEITAC Telecommunications Subcommittee'
>> Subject: Re: [teitac-telecom] VoIP enabled cell phones
>>
>>
>>
>>
>> Pam wrote:
>>> All that's being stated is the fact that Section 255 doesn't
>>> cover VoIP.
>>
>> This raises a question for me. Was VoIP excluded from
>> consideration in
>> the
>> text of the Telecom Act, or only by how the FCC chose to
>> regulate? So,
>> for
>> example, could the FCC now rule that 255 *does* apply to VoIP,
>> with or
>> without making a large decision about VoIP? I know it's a different
>> kettle
>> of fish, but I remember Judge Green ruling that, for the sake of
>> accessibility only (TRS), that the Baby Bells could carry telephone
>> traffic
>> across LATA boundaries, something they were forbidden to do for other
>> purposes. Sorry if this makes no sense.
>>
>>

From: Gregg Vanderheiden
Date: Thu, Dec 21 2006 5:20 PM
Subject: Re: VoIP enabled cell phones

Jim Wrote:
"I would be willing to argue these points. Voice and text can indeed be
mixed on the PSTN (consider VCO/HCO). Just because they can't be done in
the same microsecond is irrelevant to the user experience. And even Baudot
performance over IP can be tweaked if need be. Beyond these, of course, we
can't require something that's not feasible, and there's always the "undue
burden" dodge."


Voice and text simultaneously is required for Captel, and the inability to
interrupt is one of the most cited problem with TTY by people who use it -
and it caused by non-simultaneity problem (text and text). And Baudot has
problems on the Internet and no-one wants to perpetuate it.

Not sure of your "not feasible" comment. What were you referring to as
requiring something non-feasible?


I like your suggestion on how to work off common guidelines at high level
and differentiate only at specific technology level (PSTN and IP)


Gregg
-- ------------------------------
Gregg C Vanderheiden Ph.D.



> -----Original Message-----
> From: = EMAIL ADDRESS REMOVED =
> [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of
> Jim Tobias
> Sent: Thursday, December 21, 2006 3:47 PM
> To: 'TEITAC General Interface Accessibility Subcommittee';
> 'TEITAC Telecommunications Subcommittee'
> Subject: Re: [teitac-general] [teitac-telecom] VoIP enabled
> cell phones
>
> Gregg wrote:
> > I know it seems to be the opposite direction from what are
> trying to
> > do but I think there are two reasons for having separate guideline
> > sets for PSTN and VoIP(with many features common)
> >
> > 1) We are charged with doing something that applies to both
> > 508 and 255.
> > Whether we think it is logical or not - the FCC is treating VoIP
> > differently than PSTN. And we need to create rules they can use.
>
> We are charged with harmonizing 255 and 508, not perpetuating
> the distinction. And although we can't force the FCC to
> adopt our attempt at harmonization, we shouldn't have to wait
> for their permission to make reasonable, technologically
> sound improvements in the regs.
>
> Gregg wrote:
> > 2) They are different in some ways. Things you can ask for
> on one you
> > cannot ask for on the other. (IPText and simultaneous text
> and voice
> > for
> > example are not possible on PSTN.) On the other hand
> there are some
> > strategies that we know don't work (e.g. all the TTY
> provisions work
> > great on PSTN but do not work well - and we don't want to
> carry over
> > to- IP
> > networks.)
>
> I would be willing to argue these points. Voice and text can
> indeed be mixed on the PSTN (consider VCO/HCO). Just because
> they can't be done in the same microsecond is irrelevant to
> the user experience. And even Baudot performance over IP can
> be tweaked if need be. Beyond these, of course, we can't
> require something that's not feasible, and there's always the
> "undue burden" dodge.
>
> I think the key to progess here is what we all have been
> converging on, and Hajime really crystallized a few days ago:
> regulations drafted with an integrated functional view that
> starts at a high level ("voice conversation"), then specifies
> the various elements of that ("audio quality", "volume and
> gain", "hearing aid compatibility", etc.), and then, for each
> element, indicates both requirements and "sufficient techniques"
> for all platforms, or by platform when necessary.
>
>

From: Gregg Vanderheiden
Date: Thu, Dec 21 2006 5:25 PM
Subject: Re: VoIP enabled cell phones

I like that - if we can implement such a structure (which I favor).


Gregg
-- ------------------------------
Gregg C Vanderheiden Ph.D.



> -----Original Message-----
> From: = EMAIL ADDRESS REMOVED =
> [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf
> Of Jim Tobias
> Sent: Thursday, December 21, 2006 3:53 PM
> To: 'TEITAC Telecommunications Subcommittee';
> = EMAIL ADDRESS REMOVED =
> Subject: Re: [teitac-websoftware] [teitac-telecom] VoIP
> enabled cell phones
>
> Regarding PSTN and VoIP, 255 and 508, Gregg wrote:
>
> > We still need to differentiate things like text
> communication on PSTN
> > and VoIP. Yes?
>
> How about if at the "top level" text commmunication is
> considered as a unit (or perhaps divided into "stored" and
> "realtime")? Don't SMS, email, web-based chat, etc. share
> most of their accessibility issues? Then dropping down to
> the platform level, add the proper amount of "sufficient
> techniques" guidance.
>
>