Telecommunications Access Advisory Committee
August 14-16, 1996

Wednesday, August 14

Members present:

	Jo-Anne Basile, Cellular Telecommunications Industry    
          Association
	Brenda Battat, Self Help for Hard of Hearing People
	Stephen Berger, Siemens Rolm Communications
	Roberta Breden, Telecommunications Industry Association
	Judy Brewer, Massachusetts Assistive Technology                     
          Partnership Center
	Nolan Crabb*, American Council of the Blind
	Tim Cranmer, National Federation of the Blind
	Steven Crosby, Lucent Technologies
	Michael Delcasino, AT&T
	Alexandra Enders, RESNA
	James Fruchterman, Arkenstone
	Mark Golden, Personal Communications Industry   
          Association
	George Hanover, Consumer Electronics Manufacturers 
          Association
	Judith Harkins, Gallaudet
	Steven Jacobs, NCR Corp.
	David Jatlow*, Ericsson
	June Isaacson Kailes, Access Board liaison
	Holly Kaplan, American Speech-Language & Hearing 
          Association
	Al Lucas, Motorola
	Willis Mann, National Association for State Relay 
          Administration
	Paul Schroeder, American Foundation for the Blind
	Jenifer Simpson, United Cerebral Palsy Association
	Al Sonnenstrahl, Consumer Action Network, A. G. Bell 
          Association
	Susan Palmer*, Pacific Bell
	Karen Peltz Strauss, Council of Organizational 
          Representatives
	Leigh Thorpe, Northern Telecom
	Jim Tobias, Inclusive Technologies
	Gregg Vanderheiden, Trace R & D Center
	Ann Whelehan*, NYNEX
	Kathy Woods*, United States Telephone Association

	*alternate  (listed only when substituting for a member)

Members absent:

	Betsy Bayha, World Institute on Disability [proxy to 
          Karen Peltz Strauss]
	Shelley Bergum, Deaf & Disabled Telecommunications 
          Program
	Neal Chandra, Broad Alliance for Multimedia Technology & 
          Applications
	Jack O'Keeffe, Pennsylvania Citizens Consumer Council
	Robert Segalman, US Society for Augmentative & 
          Alternative Communication

	The second meeting of the Telecommunications Access 
Advisory Committee (TAAC) was convened at 9:30 am, Wednesday, 
August 14, 1996, at the Association of American Railroads 
conference center in Washington, DC.

	After a welcome by Roberta Breden Chair, the Committee 
ratified the minutes of the June meeting, as amended.  
Members, or alternates, each signed a copy of the revised 
protocols.  All members were urged to subscribe to the 
listserv provided through the Trace Center and some time was 
devoted to answering questions on the process.

	In its discussion of guideline definitions and scope, 
the Committee agreed to the following points:

-    In customer premises equipment (CPE), it is not always 
possible to separate the effects of software from hardware 
and one manufacturer may choose to perform the same function 
with one or the other.  Therefore, the guidelines must cover 
both.

-    It is not always possible to determine whether a 
particular function resides with the CPE, the 
telecommunications carrier or the source material.  
Therefore, the guidelines will be developed with the 
assumption that the function resides in the CPE and urge the 
FCC to apply the same guidelines to entities and services 
under its jurisdiction.

-    The Committee also agreed that the existing definitions 
of CPE (including both the hardware and software that allows 
it to function as such) and telecommunications equipment are 
sufficient.

	The discussion focused next on criteria for a "readily 
achievable" determination.  An ad hoc group was appointed to 
further discuss the issues.  The group reported back as 
follows:

1.   TAAC cannot change the definition of "readily 
achievable," as it was drafted by Congress.  Accordingly, we 
propose that any interpretation of readily achievable be 
contained in the technical assistance section of the Access 
Board's guidelines, rather than in the actual guidelines 
themselves.

2.  The technical assistance section will contain various 
factors to be considered in determining whether making a 
particular piece of equipment accessible is readily 
achievable.  Among these factors will be whether 
accessibility is "technologically feasible."  We chose this 
term (rather than technically possible) because it has been 
used elsewhere, specifically in the Hearing Aid Accessibility 
(HAC) Act.  The concept of access being "feasible"  or not 
also was used by the FCC in its determination that it was not 
feasible for relay centers to provide coin sent-paid service 
(i.e. handle relay calls with coins from pay telephones).  

3.  The Access Board should make very clear in its guidelines 
that the factors considered for a finding of readily 
achievable in the context of making telecommunications 
equipment accessible are limited to an interpretation of 
readily achievable under the Telecommunications Act of 1996
only.  More specifically, the Board should specify that 
factors employed in this determination should in no way be 
transferred to other readily achievable determinations under 
the Americans with Disabilities Act.  This will be especially 
important if we list the marketability of a piece of
equipment as a permissible factor in these determinations.

	During the public comment portion of the meeting, a 
member of the public expressed the opinion that ATMs and 
certain information kiosks were not telecommunications within 
the meaning of the Act.

Thursday, August 15 and Friday, August 16

	The Chair appointed two subcommittees, one on Guideline 
Content, co-chaired by Steve Crosby and Paul Schroeder, and 
one on Compliance Procedures, co-chaired by Steve Berger and 
Judy Brewer.  The subcommittees met separately to develop 
objectives and timelines for further work.  FCC staff members 
made presentations to each subcommittee on that agency's 
proposed activities.  The full Committee reconvened Friday 
afternoon for reports from the subcommittees:

	The Compliance Subcommittee discussed both process and 
performance.  Some members proposed using a declaration of 
conformity (DoC) process, whereby manufacturers would self-
certify, but other members expressed some concerns about this 
approach.  Subcommittee members agreed to circulate 
background materials on compliance measures; to articulate 
specific concerns with the DoC process, and to consider 
potential alternative proposals if they arise.  Subcommittee 
members agreed that compliance measures would need to address 
the product support systems (documentation, technical 
support, etc.) as well as the product/service.  Specific 
proposals would be circulated by e-mail prior to the next 
meeting.

	The Guidelines subcommittee discussed various principles 
to be included, including the trial balloon proposal 
circulated prior to the meeting.  Some members suggested that 
guidelines developed for other topics may provide useful 
formats for these guidelines.  Examples of such would be 
posted to the subcommittee listserv in time for discussion 
prior to the next meeting.

	No comments were received during the public comment 
period.