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IP: FCC NOI Section 255 Requirements for IP Telephony
From: David Farber <farber () cis upenn edu>
Date: Fri, 1 Oct 1999 13:07:28 -0400
Press Release with Links to Report and Order http://www.fcc.gov/Bureaus/Common_Carrier/News_Releases/1999/nrcc9075.html In the Matter of Implementation of Sections 255 and 251(a)(2) of the Communications Act of 1934, as Enacted by the Telecommunications Act of 1996 Access to Telecommunications Service, Telecommunications Equipment and Customer Premises Equipment by Persons with Disabilities WT Docket No. 96-198 REPORT AND ORDER AND FURTHER NOTICE OF INQUIRY Adopted: July 14, 1999; Released: September 29, 1999 a. Internet Telephony 177. Internet Protocol telephony ("Internet" or "IP" telephony) services enable real-time voice transmission using the Internet Protocol (IP), a packet-switched communications protocol. The services can be provided in two basic ways: computer-to-computer IP telephony conducted through special software and hardware at an end user's premises; or phone-to-phone IP telephony conducted through "gateways" that enable applications originating and/or terminating on the public switched network. Phone-to-phone IP telephony is provided through computer gateways that allow end users to make and receive calls using their traditional telephones. Gateways translate the circuit-switched voice signal into IP packets, and vice versa, and perform associated signalling, control, and address translation functions. The voice communications can then be transmitted along with other data on the "public" Internet, or can be routed through intranets or other private data networks for improved performance. 178. Many commenters urged that we apply the requirements of Section 255 to Internet telephony ("IP telephony") in general or phone-to-phone IP telephony, specifically. They pointed out that, given the evolutions in communications and the rapid pace of technological innovation, we need to ensure that as new services and networks are developed they are designed to provide access to persons with disabilities. They noted that it is during the development stage that accessibility can be most effectively included. We are concerned that consumers who are simply attempting to place or receive a call using standard CPE not have their accessibility disappear or diminished because the call is being transmitted using a new, developing technology. In addition, commenters stated that if persons with disabilities cannot participate in communications over these newly developing networks, they risk becoming further marginalized from society. 179. We ask commenters to provide any further information as to the extent to which phone-to-phone IP telephony services might impact the disability community, and the steps, we should take to address any adverse impacts in order to fulfill the goals of section 255, or otherwise promote the accessibility of this technology. Commenting parties should offer specific suggestions as to the appropriate role for the Commission in guaranteeing access and the statutory basis for that role. For example, commenters should address ways in which phone to phone IP telephony may be interpreted as falling within the purview of section 255. Commenters should provide specific definitions of the services or equipment to which the statute might apply, and the appropriate means of limiting its application to only those services and equipment. Commenters should address the ways, if any, in which industry bodies can ensure access without regulatory action. Commenters should also describe the specific access issues or experiences that might arise with IP telephony. For example, will TTY tones be adequately transmitted in a packet-switched environment? Will persons with speech disabilities whose speech patterns and voice outputs from alternative and augmentative communications devices may fall outside of traditional voice patterns, face additional communications barriers with packetized voice services? 180. We further ask commenters to address what efforts manufacturers of equipment that performs phone-to-phone IP telephony functions and providers of phone-to-phone IP telephony services are currently making to ensure that such equipment and services are accessible. What improvements in accessibility may be possible through the use of phone-to-phone IP telephony? Are there natural opportunities for incorporating accessibility into IP telephony? can greater accessibility be achieved if requirements are adopted early in the development of IP Telephony? Is it possible that greater levels of accessibility will be readily achievable with IP telephony than conventional telephony? How will compatibility with assistive technology affect the use of IP telephony? 181. Commenters should also address the extent to which IP telephony is now, or soon will be, an effective substitute for conventional circuit-switched telephony. As Internet usage grows, phone-to-phone voice IP telephony may be used with increasing frequency as an alternative to more traditional telephone service. How extensive is Internet telephony usage today? What is the projected usage of Internet telephony in the near future? What is the projected use of various kinds of IP telephony by persons with disabilities? 182. Commenters are asked to describe differences in characteristics between computer-based and phone-based IP telephony, and whether such differences merit different treatment by the Commission. Given the rapid pace of technological change in the telecommunications marketplace, we also ask commenters to apprise us of any new technologies that may impact the availability of accessible services and equipment. b. Computer Based Equipment 183. We also seek comment on another aspect of the network of the future -- the movement of telecommunications and information service functions from the network, or the terminal equipment which connects directly to the network, into computer equipment which does not connect to the network directly. This computer hardware and software is not typically regarded as CPE, but may, in fact, deliver the same functions we seek to make accessible. For instance, voicemail, interactive menus, or phone-to-phone IP telephony in current network topologies can reside in equipment located on the service provider's premises, but such functionalities are also available in several forms to end users on their own premises. For example, voicemail can be purchased from a carrier, can be provided via software and a private branch exchange (PBX), or can be provided through a computer that connects with the PBX, but is not generally regarded as part of the PBX. It is this latter application as to which we seek comment. 184. These software applications shift the potential for accessibility solutions from the core of the network to the end user's premises. We therefore ask commenters to address whether equipment that provides these capabilities, but which does not connect directly into the public network (or otherwise directly receive the transmission of the telecommunications), should be considered to be CPE subject to the requirements of section 255. We note, for example, that this Order does not currently reach a software telephone or the personal computer on which it resides, even though it performs the same functions as the traditional telephone. 185. We ask commenters to address the need to include this computer-based equipment as CPE or otherwise apply the provisions of these rules to that equipment in order to ensure access. We also ask commenters to address whether failure to bring such equipment within the scope of section 255 would create a serious gap in coverage that would interfere with our ability to effectively implement its provisions. Commenters should offer suggestions as to the appropriate role for the Commission in ensuring access for this kind of equipment and the statutory basis for that role. We also ask about the potential for this kind of equipment for improving accessibility and its compatibility with assistive technology. Is it possible that greater levels of accessibility will be readily achievable if this kind of equipment has accessibility requirements? ______________________________________________________ Get Your Private, Free Email at http://www.hotmail.com
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