WORKING Report

1. Activate accessibility features and configure telecommunications products so that they are accessible to and usable by people with disabilities.
2. Ensure access to and use of all telecommunications relay services for incoming and outgoing calls as approved by the Federal Communications Commission pursuant to its authority under 47 U.S.C. Sec. 225, as needed to achieve functionally equivalent communication access by people with disabilities.

1. In using such systems agencies shall: IF A GENERAL SETUP PROVISION FOR AGENCIES EXISTS - THIS SHOULD PROBABLY MOVE THERE
   1. Preferably present the system user with 4, but no more than 6, menu choices at one time unless the user requests to hear more options;
   2. provide easy to understand and act upon menu items and other navigational messages;

1. All analog and TDM-digital wired terminals shall support the connection of a TTY in the same location and with the permissions for use as the telephone.  This shall be accomplished by providing an RJ-11 jack on the telephone, or, in the case of an analog telephone, by the use of a Y-adapter that allows both the analog telephone and the TTY to be plugged into the same line outlet, or have built in capability to support an RJ11 module that can provide a connection point for TTYs;
2. Other types of terminals covered by this section shall support the connection of real-time text capable devices in conjunction with the voice call capability in the same location and the same permissions for use as the terminal.
3. Shall be capable of allowing simultaneous speech and text conversation without interference or its microphone shall be capable of being turned on and off to allow the user to intermix speech with text use.

OR NEW TIA PROPOSAL

Telecommunications products or systems [terminals and other terminals capable of providing real-time voice communications which do not themselves] that provide TTY or other real-time text conversation functionality shall comply with the following:

1. All analog and TDM-digital wired terminals shall support the connection of a TTY in the same location and with the permissions for use as the telephone. This may [shall] be accomplished by providing an RJ-11 jack on the telephone, or, in the case of an analog telephone, by the use of a Y-adapter that allows both the analog telephone and the TTY to be plugged into the same line outlet, or by having [have] built in capability to support an RJ11 module that can provide a connection point for TTYs;
2. Packet based telecommunication systems shall support the addition of terminals and terminal peripheral equipment that support [Other types of terminals covered by this section shall support the connection of] real-time text functionality [capable devices] in conjunction with the voice call functionality [capability] in the same location and with the same permissions for use as the terminal.
3. Shall be capable of allowing simultaneous speech and text conversation without interference or its microphone shall be capable of being turned on and off to allow the user to intermix speech with text use.

Definition: 

Terminal:

device or devices with which the end user directly interacts and that provide the user interface.

Real-Time Text:

Communications that employ the transmission of text wherein the characters are transmitted by a terminal w/in a maximum of 1 sec. of character input. This would typically be for conversational purposes but also may be used in voicemail, IVR and other similar applications.

• softTTY cheap to productize but significant security issues.  Sec’ty fix very costly.
• does CPE include Info Srvc?
• Incoming text on screen can be supported, but to support another text stream wld be challenge.

For cellphone, New s/w needed to rd text as you go.  Add’l to current phone s/w Yes.  Trade off w/ tty to head phone prblm, connector on side.  Allows IP phones to be vco/hco enabled.

SUGGESTED EDITS TO TIA PROPOSAL (See list serve email from GreggVan on 6/24/07 for rationale

Telecommunications products or systems that Terminals capable of providing real-time voice communications that do not themselves provide TTY or other real-time text conversation functionality shall comply with the following:

1. All analog and TDM-digital wired terminals shall support the connection of a TTY in the same location and with the permissions for use as the telephone. This may must be accomplished by providing an RJ-11 jack on the telephone, or, in the case of an analog telephone, by the use of a Y-adapter that allows both the analog telephone and the TTY to be plugged into the same line outlet, or by having built in capability to support an RJ11 module that can provide a connection point for TTYs;
2. Packet based telecommunication All other real-time voice communication systems shall support the ad hoc addition of terminals and terminal peripheral equipment that support real-time text functionality in conjunction with the voice call functionality in the same location andwith the same permissions for use as their voice terminal.
3. Shall be capable of allowing simultaneous speech and text conversation without interference or its microphone shall be capable of being turned on and off to allow the user to intermix speech with text use.

Definition

ad hoc addition

addition by user without requiring system administrator intervention

(We may want to limit ad hoc addition requirement to public or shared-use phones rather than personal workstation phones although people often share common desks or desks at remote offices etc.)

1. IP terminal user interfaces that have a multi-line display shall display any real-time text that is received in the standard format for that platform;
2. IP terminal user interfaces that have the ability to generate text shall allow sending real-time text in the standard real-time text format for that platform;
3. Such real time text send and receive capabilities shall be synchronized with voice as part of the same communication session.

Response to TIA Comment: TIA proposal for (a) does not cover this topic. TIA proposal for (a) is about how to connect devices if you don't support Real-time text directly, which is a different topic than this provision. (a) is about AT compatibility, this one is about building access into a product. 255 says build in first. Use AT if not readily achievable. So we should include provisions to allow people with disabilities to user mainstream products where readily achievable.
RE TIA Note: the purpose is not to drive endpoints to support TTY. It is to allow people who are hard of hearing and deaf to not need to use TTY. TTY is an AT approach rather than an 'accessible mainstream technology' approach. This provision is about providing 'real-time' text functionality. (a) is about what to do if you don't. ||  

1. Products that connect directly to the PSTN shall support TIA 825 Baudot where they interface to the PSTN;
2. Products that connect directly to the Internet via SIP shall support RFC 4103 where they interface to the Internet via SIP;
3. All other Products (including PBX, cellular, and peer to peer Internet phones) that do not connect to PSTN or use SIP over the Internet shall support the standard real-time text format for that system.  These systems only need to support TIA 825 Baudot at the juncture to the PSTN (if any) and only need to support RFC 4103 at the point where they connect to public SIP systems (if any).

OR - NEW Trace Proposal

Real-time Text Interoperability
Products that provide real-time text conversation functionality must

1. provide real-time text functionality in the standard real-time text format that is specified for that system.
2. use TIA 825 Baudot where they interface to the PSTN;
3. support both RFC-4103 and RFC-4351 where they interface to other VoIP systems or to the Internet via SIP;
   

Note: Closed systems, where the real-time text format of all the components is controlled and identical, may use any real-time text format that meets provision W (Real-time Text Reliability) and this provision X (Real-time Text Interoperability).

OR- NEW TIA PROPOSAL

1194.23(b) Products that provide real-time text conversation functionality shall do so in the standard format that is supported for that transport medium and provide level of service that does not exceed 1% Total Character Error Rate under normal network conditions..

1. Products that connect directly to the PSTN ,including packet based systems, shall support TIA 825 Baudot where they interface to the PSTN;
2. Packet based systems shall support real-time text communication between text capable terminals.

s/w is available over the air; reqmt is for gateway vendor to support this.

Comments of TIA:Reference to RFC 4103 and TIA - 1001 raises several concerns... reference to specific standards that are proprietary and early stage development is premature. Reference to SIP is problematic because not all SIP is the same and further may not be the defact protocol in the future. Govt.should not mandate 4103 or 1001 in 508. If mandated, should occur via PSAP interoperability or TRS because if the PSAP can only support TTY via PSTN it doesn't matter.
Push to talk that does not connect to PSTN is not covered.

COMMENTS IN RESPONSE: This provision is about interoperability. Without a common connection format there cant be interoperability. Standards are not proprietary though they can include proprietary formats. 4103 and 1001 are both in products. 4103 is not premature and is cited in numerous international standards and reports for use for this purpose.

Note: RFC-4103 and RFC-4351 are very similar except 4103 uses two channels (audio and text) and 4351 uses one channel (audio - text is sent as data packets on audio channel). RFC-4351 is provided to facilitate conversation with PSTN gateways.

1. Provides transmission of characters with less than 1 second delay from entry;
2. Provides transmission with less than 1% Total Character Error Rate under peak non-crisis network traffic;
3. Support alternating speech and text in both directions on non-packet based systems and simultaneously speech and text in both directions on packet based systems.
4. IP systems cannot rely upon audio channels for transmission of real-time text. {can delete 5 if interop provision and peak traffic clause are retained.

OR - Trace Alternate Proposal (Allows use of audio channel for text data -- and clarifies that

Real-time Text Reliability
Real-time voice communication systems must support at least one means for real time text communication that:

1. is standard for the system and supported by all terminal, router, gateway and other products on that system, and
2. Provides transmission of characters with less than 1 second delay from entry; and
3. Provides transmission with less than 1% Total Character Error Rate under peak non-crisis network traffic; and
4. Supports intermixing of speech and text in both directions (simultaneously if and only if IP based), and
5. If it is an IP based system, it does no rely upon audio signals for transmission of real-time text.

NOTE: a system may be standard or proprietary but it includes all products that use that system.

Definition

peak non-crisis network traffic – peak measured network traffic excluding disasters and other crises – or the peak traffic the system is designed to handle.

• what is “systems?”
• system perf. Reqmts are net roll up;  How does this play w/ component vendor?
• req robust protocols rather than a metric.

“system as delivered must be reliable” shld be:  System as purchased should use a reliable text transport format.

TIA Comment: TIA suggests we discuss deleting this. it is largely redundant of (b).

TIA note

Note: with regards to #4 - TIA1001 specifically allows transmission of real-time text through the audio channel as a means optimally conveying text between two PSTN gateways

Response to TIA comment: This is quite different than (b). b is about alternate terminals. This is the performance guideline that industry has been asking for to allow future innovation. Alternate forms can be proposed as long as they meet these performance requirements. It also governs all new systems as they are established. there is no coverage for these provisions in (b).
RE use of voice channel for data: Good comment. See Trace Proposal which includes changes to accommodate this (it only prevents us of tones rather than data to convey text data on IP networks).

1. Voice mail, messaging, auto-attendant, and interactive voice response telecommunications systems shall make information available and be capable of recording Baudot TTY signals and shall:
   1. Use the ITU-T G.711 standard for encoding and storing audio information.  If an audio encoder other than G711 is employed, the vendor must provide evidence that the intelligibility is equal to or better than that provided by G.711;
   2. Provide full player controls that allow users to pause, rewind, slow down and repeat all messages and prompts, and adjust volume;
   3. Provide prompts (either as provided by the vendor or by the user) without any background sounds that would reduce intelligibility.
2. In using such systems agencies shall: IF A GENERAL SETUP PROVISION FOR AGENCIES EXISTS - THIS SHOULD PROBABLY MOVE THERE
   1. Preferably present the system user with 4, but no more than 6, menu choices at one time unless the user requests to hear more options;
   2. provide easy to understand and act upon menu items and other navigational messages;

ALTERNATE PROPOSAL (from 7/2/07 call)

Voice mail, messaging, auto-attendant, and interactive voice response telecommunications systems must comply with the following:

1. All functions that are accessible to voice users must also be directly accessible to users of real-time text.
2. Use the ITU-T G.711 standard for encoding and storing audio information.  If an audio encoder other than G711 is employed, the vendor must provide evidence that the intelligibility is equal to or better than that provided by G.711;
3. Provide full player controls that allow users to pause, rewind, [slow down] and repeat all messages and prompts;
4. Provide prompts (either as provided by the vendor or by the user) without any background sounds that would reduce intelligibility.

NOTE: Relay services are not considered to be "directly accessible".

DEFINITION OF MENU

Set of selectable options (from HFES 200

NOTE: This issue should now be addressed by the 7/2/07 revision

TIA COMMENT REGARDING #2

(TIA Comment: Adjustable volume over a PSTN call is forbidden by TIA-968).

NOTE: This issue should now be addressed by the 7/2/07 revision

May require s/w in product. Set-up issue.

Provisions for product.  Provisions for set up.

• define menu somewhere.

Based on committee members’ opinion; not backed by research.

TIA recommends returning to original text

Where provided, caller identification and similar telecommunications functions shall also be available for users of TTYs and for users who cannot see displays.

Issue:  Does mute have to be its own button, not a function softkey?

1. line powered telecommunications products shall comply with FCC regulation §68.317 for volume control,

OR

1. * telecommunications products shall provide a built in gain adjustable up to a minimum of 20 dB.   For incremental volume control, at least one intermediate step of 12 dB of gain shall be provided.
2. all other telecommunications products or systems that provide a function allowing voice communication shall provide a gain adjustable up to a minimum of 20? dB with incremental volume control of at least one intermediate step of 12 dB of gain provided as measured and documented in accordance with the provisions of the FCC regulation §68.317 for volume control.

OR- NEW TIA PROPOSAL as amended by Working Group on 6/25 conference call

1. Analog line-powered telecommunications products and wireline all cordless telephones (wireline or VoIP) shall comply with FCC regulation §68.317 for volume control
2. All cellular phones - (language pending outcome of ATIS study group 11 work).
3. all other telecommunications products or systems that provide a function allowing voice communication shall provide a gain adjustable from the normal unamplified level to at least 20 dB above the normal unamplified level as measured in accordance with the provisions of the FCC regulation §68.317 for volume control. The volume at the normal unamplified level setting shall also meet the requirement in FCC regulation 68.317.

1* There is a problem is measurement of gain from variable floor.  Recommend standard for the floor from which the adjustable gain is measured by developed by TIA.


Two options for intro phrase to TIA proposal:

1. “PSTN telephone-line-powered telecommunication products etc.”
2. “PSTN phone-line-powered wireline telephones and wireline cordless telephones”

OR NEW TIA PROPOSAL as amended by Working Group on 6/25 conference call

If the product allows a user to adjust the receive volume to a level greater than 18 dB above normal unamplified level, a function shall be provided to automatically reset the volume to a level not greater than 18 dB above normal unamplified level after every use. A manual override switch may be provided to prevent the automatic reset subject to the conditions specified in FCC Memorandum Opinion and Order DA 01-578.

oLD PROPOSAL

(g) If the telecommunications product allows a user to adjust the receive volume, a function shall be provided to automatically reset the volume to a safe level after every use if the volume is capable of greater than 18 dB of gain along with an option for user override of that automatic default.

Also – do we want to say anything about distortion? There was discussion about this in the Closed group and research from the Hearing Enhancement project that was funded by the Access Board was cited. Said that 12 db of symmetrical clipping was ok but not more. Not sure what that is in THD.

TIA alternate for last sentence

This guideline shall apply to wireline and wireless technologies.

Do we want to reference FCC regs for wireless technologies?

1. for PSTN this would be TIA/EIA 825 Baudot.

NOTE:  Only phones that are passing text signals onto another device, e.g. TTY, would be subject to this provision.

Don’t want to do Bell 103 and 202. Concern:  What if passing voice but need to translate text?  Want to take 4103 and put it own format for closed network.

1. The caller must always be able to dial 0 or to say “operator” to queue for a human.
2. An accurate estimated wait-time, based on call traffice at time of call, should always be given when caller arrives in the queue
3. Callers should never be asked to repeat info provided to a human or an automated system during a call.
4. When human not available, callers should be offered option to be called back or to leave a message.
5. Speech applications should provide touch-tone (DTMF) fall-back.
6. Long prompts should be avoided.
7. Callers should be able to interrupt t prompts via DTMS tones or barge-in software.
8. System must not disconnect for user erros, but instead queue for human operator.
9. Primary language should be assumed with option for caller to change language.