To:       Consumer Contact List
From:  Karen Peltz Strauss
Re:      VoIP Accessibility Order, Analog Service Sunset Upheld
Date:   June 18, 2007

The launching of the Coalition of Organizations for Accessible Technology and the work of the Telecommunications and Electronic and Information Technology Advisory Committee has caused these consumer contact list updates to take a back seat this spring.  This is the first in a series of updates that will now bring you up to date.
 
1.  FCC extends requirements of Sections 255 (product and service accessibility mandates) and 225 (telecommunications relay service (TRS) mandates) to interconnected VoIP providers and manufacturers.
 
 In an order released on June 15, 2007, the FCC issued new rules requiring interconnected VoIP service providers and manufacturers of equipment and CPE that is specially designed to provide interconnected VoIP service (and "needed to effectively use an interconnected VoIP service") to comply with the accessibility obligations of Section 255 and the relay obligations of Section 225 of the Communications Act.  The FCC explained that there is a "gap between emerging technologies and the implementation of features needed to render those technologies accessible" and that as an increasing number of consumers with disabilities replace their traditional circuit-switched phone service with interconnected VoIP service, the health, safety and livelihood of these individuals may be at risk without reliable access to interconnected VoIP service.  The Commission concluded that "where interconnected VoIP service substitutes for traditional phone service, the same disability access protections that currently apply to telecommunications services and equipment must apply to interconnected VoIP service and equipment".  This is because consumers have a reasonable expectation that interconnected VoIP services are replacements for traditional phone service.
 
The FCC went on to note that the Access Board has convened the Telecommunications and Electronic and Information Technology Advisory Committee (TEITAC) for the purpose of recommending updated guidelines for Section 255 of the Act, and that the FCC will review those to determine whether amendments to its own Section 255 rules are appropriate.  Finally, the FCC made a particular point of noting that "as we move from the PSTN to VoIP, we need reliable, real-time text capability that is supported throughout the VoIP system so that people who rely on text and text intermixed with speech in order to converse can use the next generation phone system.  The FCC said it may convene an advisory body to figure out how this can be achieved.
 
Finally, as is required for PSTN-based providers and manufacturers currently covered under Section 255, each manufacturer and interconnected VoIP provider must designate an agent for the receipt and handling of accessibility complaints and inquiries, and must send this information to the Commission’s Consumer & Governmental Affairs Bureau (within 30 days after the effective date of the rules, which will be published in the Federal Register).
 
As for the TRS requirements, the FCC made clear that interconnected VoIP providers must contribute to the Interstate TRS Fund and offer 711 abbreviated dialing for access to relay services.  The Commission explained that this fulfills its universal service obligation to make available to "all" persons "rapid, efficient [nationwide] communication service.”  The FCC went on to conclude that its action will increase the utility of the telephone system and "serve the core objectives of section 225 and our TRS rules by making TRS widely available and by providing functionally equivalent services for the benefit of individuals with hearing or speech disabilities."
 
The FCC's order and PN on this issue are attached and noted below.
 
IP-ENABLED SERVICES; IMPLEMENTATION OF SECTIONS 255 AND 251(A)(2): ACCESS TO TELECOMMUNICATIONS SERVICE, TELECOMMUNICATIONS EQUIPMENT AND CUSTOMER PREMISES EQUIPMENT BY PERSONS WITH DISABILITIES; ET AL.
Extended the disability access requirements that currently apply to telecommunications service providers and equipment manufacturers under Section 255 of the Communications Act of 1934. (Dkt No.  92-105, 96-198). Action by:  the Commission. Adopted:  05/31/2007 by R&O. (FCC No. 07-110).  CGB
<http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-07-110A1.doc>
<http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-07-110A2.doc>
<http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-07-110A3.doc>
<http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-07-110A4.doc>
<http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-07-110A5.doc>
<http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-07-110A6.doc>
<http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-07-110A1.pdf>
<http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-07-110A2.pdf>
<http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-07-110A3.pdf>
<http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-07-110A4.pdf>
<http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-07-110A5.pdf>
<http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-07-110A6.pdf>
<http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-07-110A1.txt>
<http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-07-110A2.txt>
<http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-07-110A3.txt>
<http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-07-110A4.txt>
<http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-07-110A5.txt>
<http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-07-110A6.txt>
 

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