Via Electronic Filing (http://apps.fcc.gov/ecfs/) November 8, 2013 Marlene H. Dortch Secretary Federal Communications Commission 445 Twelfth St., S.W. Washington, DC 20554

Re: CG Docket No. 13-46 Dear Ms. Dortch: On Wednesday, November 6, 2013, the Telecommunications Industry Association (“TIA”) met with Federal Communications Commission’s (“Commission”) Consumer and Governmental Affairs Bureau (“CGB”) Disability Rights Office (“DRO”), at TIA headquarters (1320 North Courthouse Road, Suite 200, Arlington, VA 22201). The purpose of this meeting was for TIA to share information with the Commission on its existing standardization efforts that impact accessibility and to discuss these and other TIA standardization efforts’ role in improving disability access. In attendance were: Stephen Whitesell, Whitesell Consulting LLC and TIA TR-41 (Performance and Accessibility for Communications Products) Engineering Committee1 Chair; James Bress, AST Technology Labs, Inc. and TR-41.3.14 Accessibility Working Group2 Chair; Rafi Rahamim, Broadcom; Tim Lawler, Cisco; Hazim Dawood and Jason Nixon, Industry Canada; Tony Jasionowski, Panasonic North America; Randy Ivans, Underwriters Laboratory; Terrien Thomas, VXi Corporation; and Marianna Kramarikova, Brian Scarpelli, and Doug Spoerl

1 TIA Engineering Committee TR-41 develops and maintains voluntary standards for the performance and accessibility of communications products. The products addressed by these standards include telephones with handsets, headsets, and speakerphones, communications gateways, and other products that are typically installed at the user’s premises. TR-41’s standards may include performance requirements for voice, video, and other features that are associated with communications services. They cover requirements for a product’s performance related to signal transmission, environmental impacts, interfacing to networks and other equipment, accessibility, and usability. TR-41 addresses issues pertaining to administrative aspects of regulatory product approval processes and develops criteria for preventing harm to the telephone network, which become mandatory when adopted by the Administrative Council for Terminal Attachments (ACTA). TR-41 is a point of contact for expert technical opinions, advice, and actions for standards development for government agencies that deal with communications including the FCC. It also provides input to other organizations that develop and publish product safety standards. See http://tiaonline.org/all-standards/committees/tr-41. 2 TR-41.3.14, a working group of TR-41, develops standards for telephone devices, including handsets, headsets, and speakerphones, for performance pertaining to features used by persons with hearing impairments and other disabilities. See www.tiaonline.org/all-standards/committees/tr-41.3.14.

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of TIA. Attendees from the Commission were Cheryl King, DRO Associate Chief; and Elaine Gardner, DRO Attorney Advisor. Christian Volger and Linda Kozma-Spytek from Gallaudet Unversity were also in attendance. During this meeting, TR-41 presented and discussed with Commission attendees the topics in TIA’s attached materials. Specifically, in regard to the ANSI/TIA-4965 standard for Conversational Gain,3 TIA TR-41 members noted for the Commission that their work on an associated guidance document providing test procedures for showing compliance with the Conversational Gain requirements has been completed.4 As of November 6, 2013, the testing guidance document titled TIA TSB-31-D-2, Telecommunications - Telephone Terminal Equipment - Rationale and Measurement Guidelines for U.S. Network Protection - Addendum 2, has been approved for adoption and publication. TIA’s TR-41 urged the Commission to move forward as quickly as possible based on this development and consistent with TIA’s pending Petition for Rulemaking.5 TIA supports the Commission taking the next step towards improving the access and experience of hard-of-hearing users of terminal equipment (“TE”), such as analog and digital wireline telephones, by undertaking a rulemaking to update references in Part 68 of the FCC’s rules to TIA standards which set hearing aid compatibility (“HAC”) volume control requirements. TR-41 participants also discussed the following topics with Commission attendees and the Gallaudet University representatives:

• The Commission’s informal complaint procedure pertaining to communications products.

• The Commission’s “Clearinghouse” website6 which could be a place to publicize TR-41’s accessibility standards work and possibly products which meet TR-41’s accessibility standards.

• The Section 508 and Section 255 refresh which is a current United States Access Board project,7 and how TR-41 may develop voluntary performance standards related to these documents.

3 See ANSI/TIA-4965, Receive Volume Control Requirements for Digital and Analog Wireline Terminals (October 24, 2012) available at http://global.ihs.com/search_res.cfm?RID=TIA&INPUT_DOC_NUMBER=ANSI/TIA-4965. 4 In a recent submission on this matter, TIA noted for the Commission that in the process of amending TIA’s TSB-31-D to add Conversational Gain test procedures to these testing guidelines for showing compliance with Part 68 and TIA-968-B, a technical referencing error was discovered during the initial ballot on the amendment. While this error is not directly related to the test procedures, it has since been corrected and the resulting addendum to TSB-31-D has been balloted and approved by TR-41. See Reply Comments of TIA, CG Docket No. 13-46 (filed Sept. 9, 2013). 5 TIA, Access to Telecommunications Equipment and Services by Persons with Disabilities, RM-11682, Petition for Rulemaking (filed Oct. 25, 2012) (“TIA Petition”). 6 See http://apps.fcc.gov/accessibilityclearinghouse/.

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• Pursuing Commission’s Office of Engineering Technology (“OET”) participation in TR-41’s accessibility standards development.

• TR-41 doing more work with Rehabilitation Engineering Research Centers (RERCs) including Gallaudet, Georgia Tech, and TRACE Research and Development Center at the University Wisconsin.

Pursuant to the Commission’s rules,8 this letter is being electronically filed via ECFS and a copy of this submission is being provided electronically to the meeting attendees.

Respectfully submitted,

TELECOMMUNICATIONS INDUSTRY ASSOCIATION

By: /s/ Brian Scarpelli__ Brian Scarpelli Senior Manager, Government Affairs TELECOMMUNICATIONS INDUSTRY ASSOCIATION 1320 North Courthouse Road Suite 200 Arlington, VA 22201 703.907.7700

November 8, 2013 cc: Cheryl King, DRO Associate Chief

Elaine Gardner, DRO Attorney Advisor

7 See http://www.access-board.gov/guidelines-and-standards/communications-and-it/about-the-ict-refresh. 8 47 C.F.R. § 1.1206.

Telecommunications Industry

Association Presentation:

Developing

Standards for Accessibility

November 6, 2013

TIA Government Affairs

Brian Scarpelli Sr. Manager, Government Affairs +1-703-907-7714 bscarpelli@tiaonline.org http://www.tiaonline.org/policy/accessibility

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Agenda ￭ Introductions ￭ TR-41’s New Name and Increased Focus on

Accessibility ￭ TR-41 and FCC Collaboration ￭ Brief Review of TR-41 Accessibility Related

Standards TIA-504 ANSI/TIA-1083-A ANSI/TIA-4965 ANSI/TIA-4953

￭ Questions and Discussion ￭ Adjournment

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About the Telecommunications Industry Association (TIA)

￭ Represents over 500 information and communication technology (ICT) companies

￭ Activities Include: Technology and standards development Policy and advocacy leadership Networking Business opportunity development Access to cutting edge market intelligence Sustainability practices U.S. and international Advocacy and Lobbying Industry Trade Events …and much more

￭ American National Standards (ANSI) accredited standards development organization with 11 engineering committees and 12 international advisory groups

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TIA’s Accessibility Mission ￭ Encourage collaboration among stakeholders

Development of voluntary, consensus-based standards Increase the accessibility of technology for those with

disabilities Encourage innovation Harness technology to open up new communications

opportunities ￭ Proactive consultation with the disability community

Understand the needs related to ICT products Encourage accessibility solutions into member companies’

product development processes ￭ Work with government regulatory agencies

Develop technical standards for use in government rules when needed

Encourage the use of voluntary, consensus-based, industry standards to address accessibility needs

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TIA TR-41 PERFORMANCE AND ACCESSIBILITY FOR COMMUNICATIONS PRODUCTS Steve Whitesell President, Whitesell Consulting LLC TIA TR-41 Chair +1-732-751-1079 (voice) swhitesell@ieee.org

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TIA TR-41 PERFORMANCE AND ACCESSIBILITY FOR COMMUNICATIONS PRODUCTS ￭ TR-41’s New Name ￭ Develop and maintain standards:

Covering voluntary requirements for communications products’ performance

Addressing newly identified performance issues For reference in FCC regulations

￭ Strong focus on equipment used for voice services, integrated voice and data services, and Internet protocol (IP) applications

￭ Intent to increase focus on standards related to communications products’ accessibility

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TIA TR-41.3.14 “Accessibility Working Group”

￭ Standards for telephone devices, including handsets, headsets, and speakerphones

￭ Performance of features used by persons with hearing impairments and other disabilities

￭ Participants from across the industry including accessibility consumer interests (such as Gallaudet University)

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Summary of Current TR-41 Related Accessibility Standards

￭ TIA-504 (EIA RS-504) Adopted as the FCC 68.316 rules

￭ ANSI/TIA-1083-A In response to complaints of cordless telephones

“buzzing” for some hearing aid tele-coils (voluntary standard)

￭ ANSI/TIA-4965 In response to outdated references in FCC 68.317

￭ ANSI/TIA-4953 In response to amplified telephone industry

request for a standard for measurement and performance of “high gain amplified telephones” (voluntary standard)

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TR-41 Working With The FCC Example: ANSI/TIA-631

￭ FCC received complaints of “voices, radio stations, and noise” heard on telephone handsets (early 1990s) The FCC requested technical assistance from TIA TR-41

￭ TR-41 found the issue was poor telephone design for “Radio Frequency Immunity” Well known design criteria in the AT&T/WE days Can be a major problem for telephone users

￭ TR-41 developed ANSI/TIA-631 “Radio Frequency Immunity Requirements” (voluntary standard)

￭ FCC has reported the complaints have decreased dramatically and that TIA-631 as a voluntary standard is a great success (paraphrased from Catherine Deaton from the FCC Los Angeles field office) 10

TR-41 Working With The FCC Other Examples

￭ TIA standards and FCC Part-68 rules Used as the text for FCC rules (TIA-504) Referenced in FCC rules (TIA-470 and TIA-579) Address changes needed based on consumer or

telephone equipment industry needs (TIA-4965)

￭ In response to consumer complaints Raise awareness in the telephone equipment industry Voluntary standards (TIA-631 and TIA-1083)

￭ In response to accessibility groups needs Provide guidance to the telephone equipment

industry Voluntary standards (TIA-4953)

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FCC Part-68 Rules for “Hearing Aid Compatibility”

￭ The FCC associates the phrase “hearing aid compatibility” with both magnetic (t-coil) and acoustic (volume control) requirements

￭ CFR FCC 68.316 “Hearing aid compatibility: Technical requirements”

￭ CFR FCC 68.317 “Hearing aid compatibility volume control: technical standards”

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What is Telephone Hearing Aid Compatibility?

￭ All telephones manufactured or imported for use in the U.S. are required to be hearing aid compatible (HAC) since 1988.

￭ “HAC” means providing a magnetic field that complies with the FCC's adopted technical standard (TIA-504).

￭ Improved performance for hearing aid users The telephone’s magnetic field is used by hearing

aids equipped with a telecoil. Use of a hearing aid’s tele-coil reduces background

noise heard by the hearing aid user.

Source: FCC 13

CFR FCC 68.316 “Hearing aid compatibility:

Technical requirements” ￭ “A telephone handset is hearing aid compatible for

the purposes of this section if it complies with the following standard, published by the Telecommunications Industry Association, copyright 1983, and reproduced by permission of the Telecommunications Industry Association: ELECTRONIC INDUSTRIES ASSOCIATION RECOMMENDED STANDARD RS–504 MAGNETIC FIELD INTENSITY CRITERIA FOR TELEPHONE COMPATIBILITY WITH HEARING AIDS”

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Telephone Volume Control ￭ Volume control requirements address the acoustic

output from the telephone handset coupled to the microphone of a hearing aid, or directly to the ear HAC magnetic coupling telecoil (T) mode HAC volume control microphone (M) mode or

use without hearing aid

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CFR FCC 68.317 “Hearing aid compatibility volume control:

technical standards”

￭ References outdated TIA standards for: Measurement methods Establishing the “normal unamplified level”

￭ ANSI/EIA–470–A–1987 (Analog Telephones) ￭ ANSI/EIA/TIA–579–1991 (Digital Telephones)

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HAC Related Issues ￭ Consumer complaints of hearing aid tele-coil

“buzzing” from cordless telephones Addressed by ANSI/TIA-1083

(voluntary standard)

￭ Telephone design performance often compromised to comply with FCC 68.317 rules (“HAC Volume Control”) Addressed by ANSI/TIA-4965 which is proposed to be the

new reference in the CFR FCC 68.317 rules Current rules encourage manufacturers to trade-off better

performance for “meeting the rules”

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TIA-504

￭ TIA-504 HAC Performance Categories 4.2 Axial Field Intensity 4.3 Radial Field Intensity 4.4 Induced Voltage Frequency Response

￭ OK for standard analog corded telephones ￭ Technology advancements not addressed

Digital telephones Different testing methods

Cordless telephones Potential for magnetic noise

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ANSI/TIA-1083-A Handset Magnetic Measurement

Procedures and Performance Requirements

Tony Jasionowski Panasonic – North America Senior Group Manager, Accessibility 201-348-7777 (voice) Tony.Jasionowski@us.panasonic.com http://www.panasonic.com/about/accessibility/

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ANSI/TIA-1083-A Handset Magnetic Measurement

Procedures and Performance Requirements

￭ Why is ANSI/TIA-1083 needed? ￭ How should / could ANSI/TIA-1083 affect

FCC Part-68 rules?

￭ What does ANSI/TIA-1083 mean to the telephone public?

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Enhanced HAC Magnetic Coupling Requirements

￭ The FCC’s HAC magnetic coupling requirements FCC 47 CFR 68.316 (is the same as TIA-504) Only addresses the desired signal related to speech and

does not consider possible impact of magnetically coupled noise

￭ ANSI/TIA-1083 (March 2007) Voluntary standard developed by TIA TR-41.3 Addresses complaints of “buzz” noise interference often

caused by cordless telephones

￭ ANSI/TIA-1083-A (November 2010) Voluntary standard revised by TIA TR-41.3 Added requirements for telephones with digital network

interfaces, such as VoIP telephones

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ANSI/TIA-1083 and FCC Regulations ￭ ANSI/TIA-1083-A is not directly included as part

of the FCC rules (voluntary standard)

￭ FCC complaints for hearing aid tele-coil buzzing due to cordless telephones have decreased dramatically since ANSI/TIA-1083 was published

￭ FCC took an active role in getting telephone equipment manufacturer “buy-in” to compliance with ANSI/TIA-1083 early in the development of the standard

￭ New regulations are not needed due to the success of the ANSI/TIA-1083 voluntary standard 22

How ANSI/TIA-1083 Affects The Telephone Using Public

￭ When purchasing a new wireline telephone look for the following logo to ensure HAC magnetic compatibility

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ANSI/TIA-4965 Receive Volume Control Requirements for

Digital and Analog Wireline Handset Terminals

￭ Why is ANSI/TIA-4965 needed? ￭ Why should the FCC update the CFR FCC

68.317 rules to reference TIA-4965 ? ￭ How will adopting TIA-4965 improve

telephones for consumers?

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Wireline Telephones Volume Control Requirements NOW

￭ Currently, the FCC CFR. 68.317 rules reference older TIA standards: Minimum 12 dB gain relative to “normal unamplified level” Automatic reset if gain exceeds 18 dB Gain is specified as change in Receive Objective Loudness

Rating (ROLR) level and refers to two outdated TIA standards. Normal unamplified level must also meet ROLR

requirements specified in these two outdated standards. ROLR and associated testing requirements have been

replaced by newer TIA standards with an improved method of measuring volume control which is applicable to newer telephone handset designs

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Conversational Gain ￭ A new, more rational and intuitive way to

measure volume control ￭ The reference:

Two people talking face-to-face, 1 meter apart Conversational Gain = How loud a voice is compared

to a typical face-to-face conversation

￭ 0dB conversational gain means the speech heard from the telephone is the same level as would be heard if speaking face-to-face about 1 meter apart

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Conversational Gain Reference Level

￭ Face-to-face conversation at a distance of 1 meter produces an average level of 64 dBSPL at each ear.

￭ The level needs to be increased by 6 dB to sound equally loud when listening with only one ear.

￭ The 0 dB Conversational Gain reference is: 64 dBSPL for two-ear listening (i.e., speakerphone) 70 dBSPL for one-ear listening (i.e., handset)

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How is Conversational Gain Measured?

￭ Using commercially available testing equipment

ITU P.57 Type-3.3 Ear Simulator Head And Torso Simulator (HATS)

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The Transition from ROLR to Conversational Gain

￭ A standard unamplified telephone (the Western Electric 500-type telephone and equivalent models by other manufacturers) provides about 6 dB of Conversational Gain even though it has no volume control.

￭ The current FCC ROLR-based requirement for at least 12 dB of gain above the normal unamplified level thus becomes a minimum of 18 dB of Conversational Gain.

￭ The requirement to automatically reset if the ROLR-based gain exceeds 18 dB becomes 24 dB of Conversational Gain.

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How Conversational Gain Affects Consumers

￭ Uses a more relevant reference 20dB gain means hearing speech 20dB louder than

if speaking face-to-face

￭ A better way to compare consumer products Permits a valid comparison to the sound levels

produced by different devices

￭ Telephone equipment volume control claims easier to verify Brings fairness to the marketplace for equipment

manufacturers

￭ Telephone equipment designs do not need to be “compromised” just to meet the old and outdated rule

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TIA’s Conversational Gain Proposal to the FCC

￭ ANSI/TIA-4965, Receive Volume Control Requirements for Digital and Analog Wireline Terminals, was developed by TIA TR-41.3 and published publicly on October 24, 2012.

￭ October 25, 2012: TIA filed a Petition for Rulemaking with the FCC requesting that it update outdated references to TIA standards (see http://bit.ly/10ah86B). Would effectively shift wireline telephone volume control

from ROLR to Conversational Gain

￭ In mid-March 2013, the FCC gave TIA’s Petition a formal rulemaking number (CG Docket No. 13-46).

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TIA’s Conversational Gain Proposal to the FCC

￭ Public Notice on TIA’s Petition released on July 19, 2013.

￭ Comments were due August 19, 2013 and reply comments were due September 9, 2013.

￭ The record shows support from two stakeholder groups impacted by TIA’s request and the hearing aid industry, and notably contains no opposition to TIA’s request of the Commission.

￭ Held ex parte meeting with representatives from FCC Disability Rights Office on October 25, 2013.

￭ Awaiting FCC action.

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Performance Standard for Amplified Telephones

(ANSI/TIA-4953) James Bress President, AST Technology Labs Chair, TIA TR-41.3 +1-321-254-8118 x100 (voice) jrbress@asttechlabs.com www.asttechlabs.com

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What was the problem?

￭ No standard method to measure and evaluate a telephone’s acoustic gain related to hearing loss needs

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Who Asked for TIA-4953? ￭ TEDPA

(Telecommunications Equipment Distribution Programs Assoc.) State programs that buy and distribute equipment to

people with disabilities Collectively the largest purchasers of high-gain amplified

telephones in the US

￭ Amplified telephone manufacturers Managing claims of “gain” from competitors Bring sanity to telephone RFP requirements

￭ Amplified telephone consumers Need to know if an amplified telephone will meet the

needs of their hearing loss level Need to know if an amplified telephone will work well

when used with a hearing aid

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Who Needs an Amplified Telephone?

￭ People with varying degrees of hearing loss Mild Moderate Severe

￭ People with hearing aids Telephone to hearing aid coupling issues

(microphone mode) Magnetic signal performance for t-coil use (HAC)

(TIA-4953 requires telephones to meet TIA-1083)

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ANSI/TIA-4953 Amplified Telephone Measurement

Procedures and Performance Requirements

￭ Developed by TIA TR-41.3 Published in May 2012 Adopted by ANSI in August of 2012

￭ TIA-4953 Requirements Summary Conversational Gain Tone Control Acoustic ringer level and tone Acoustic and magnetic performance for hearing-

aid users Noise, distortion, stability (no howling), transmit

levels

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Why is Tone Control Important?

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TIA-4953 Summary

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How ANSI/TIA-4953 Affects Consumers

￭ When purchasing an amplified telephone, consumers will be able to use the following to make the most informed decision

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TR41’s Current Activities Related to Accessibility Standards

￭ Current projects open: Revise ANSI/TIA-1083A:

Include wideband digital (VoIP) Use real speech test signals

￭ Possible new projects to revise current TIA TR-41 standards to address specific issues: Revise ANSI/TIA-1083-A to inform of the need to

meet the requirements included in FCC 68.316? Revise TIA-4953 (high-gain amplified telephones

with tone control): Include digital telephones (VoIP) Speakerphones Mobile handsets?

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Where Do We Go From Here?

￭ FCC, DRO, Access Board participation in TIA TR-41’s development of voluntary standards for accessibility?

￭ Identify FCC accessibility rules for which TIA TR-41 could develop voluntary standards?

￭ Input and participation from industry accessibility groups?

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Questions?

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Thank you!

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