The TR41.11 VoIP Phone FCC Part 68 Certification Working Group Report

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1 The TR41.11 VoIP Phone FCC Part 68 Certification Working Group Report 1. Working Group Members Cliff Chamney Sprint. Anh Nguyen UL. Julio Posse Sony Electronics Inc. John Shinn Nortel Networks. Tailey Tung Siemens. - (Working Group Chair) Victor Van Cisco Systems. 2. Issues concerning VoIP phone FCC Part 68 certification The VoIP phones initially designed for private LAN and Internets are now capable of providing access via front-end gateways to public network. The existing FCC Part 68 rules established more than 20 years ago have not clearly identified the applicability of the rules to VoIP phones. As FCC Part 68 rules and the HAC Act require accessibility including HAC and Volume control for the disabled to all phones, the industry is confused and unsure of what VoIP phone products should do for FCC Part 68 certification. The other issue concerning VoIP phone FCC Part 68 certification is the lack of standardized test methods for the test houses to evaluate the conformity of the VoIP phone with the Part HAC and Part volume control requirements. One fundamental parameter needing definition is the IP equivalent of the analog HAC and volume control test signal levels, as set forth in Part and (b). There may or may not be other issues. FCC is not currently preventing the marketing of the VoIP phones without HAC and volume control certification. This situation is likely to continue until FCC receives public complaints requesting for clarification or the industry can help FCC to establish administrative and test procedures for HAC and volume control of VoIP phones. 3. Working Group Mission The mission of this working group is to: a. Recommend applicability of the existing FCC Part 68 rules to VoIP phone products. b. Recommend application guidelines to TR41.11 sub-committee for the FCC Part 68 certification of the VoIP phone products.

2 4. Working Group Recommendations The following three recommendations from the working group are based on and referenced to the FCC rules and TIA standards summarized in the Annex to this report: 4.1 FCC Part Waivers rule not applicable to VoIP phone products The working group considers the FCC Part Waivers rule is technically not applicable to VoIP phone products for the reason the compliance with the requirements of 68.4(a)(1) is technologically feasible and there is a TIA/EIA-IS-810 standard for VoIP phones. 4.2 Guidelines for FCC Part 68 certification of VoIP phone products The working group recommends the following three guidelines for the FCC Part 68 certification of VoIP phone products: a. VoIP product with no direct connection & communication with the public network The VoIP phone product with no direct connection and no communication with the public network functions like private network (e.g. LAN) data / voice terminal. This product would be differentiated by not having a public network-compatible connector, to provide some assurance it will not be connected to the public network. It will not cause harm to the public network. No FCC Part 68 certification is required for private network products. b. VoIP product with no direct connection but communicate with the public network This kind of VoIP phone product generally communicates with the public network via the front-end gateways. It functions like the proprietary digital telephones connect behind PBX systems. As is true for the category above, this product would not have a public network-compatible connector. Limited FCC Part 68 certification is required to confirm compliance with the following Part 68 requirements: - Part signal power limitation; - Part HAC; - Part volume control; and - Part additional limitation (e.g. Automatic re-dial) requirements. TR41.11 should request TR41.9 to develop test methods for evaluating the conformity of the VoIP phone products with the FCC Part HAC and volume control requirements. c. VoIP product with direct connection to the public network This kind of VoIP product (e.g. VoIP PBX systems with VoIP phones, in-built network gateway and Ethernet connections) functions like customer premises equipment / systems for direct connection to public network. Any VoIP product with a public network-compatible connector must have full Part 68 approval. Full FCC Part 68 certification is required to confirm compliance with the following FCC Part 68 requirements applicable to the system:

3 - Part network surge protection; - Part leakage current limitations; - Part hazardous voltage limitations; - Part signal power limitations; - Part transverse balance; - Part On-hook impedance limitations; - Part Billing protection; - Part Hearing aid compatibility; - Part volume control; and the - Part additional limitations. 4.3 New equipment classification for VoIP phone products Document Number: TR-41.11/ The working group also recommends the creation of the following new equipment classification "Section for VoIP equipment" capable of accessing and telecommunicating with the PSTN: a. IP - VoIP phones and VoIP devices with handset or headset capable of providing access and telecommunication via front-end gateways with the PSTN. b. IS - VoIP systems (e.g. VoIP PBX) with gateways to PSTN. c. IT - VoIP terminal adapters (e.g. terminal adapters for the connection of analog or digital telephones to IP networks) capable of providing access and telecommunication via front-end gateways with the PSTN.

4 Annex HAC and Volume Control Regulatory and Industry Requirement References The recommendations from the working group are based on and referenced to the following FCC rules and TIA standards. A1. HAC Act The United States Congress has legislated that persons using hearing aids with magnetic pickups shall have reasonable access to the National Telephone Network. The HAC Act required the FCC to establish regulations that would ensure reasonable access to telephone service by persons with hearing disabilities. Hearing aid compatible telephones must offer both electro-magnetic coil compatibility and volume control. As of January 1, 2000, all telephones, including cordless telephones, manufactured in the United States or imported for use in the United States, must have volume control in accordance with Mobile telephones are exempt, except in business applications. A2. FCC Part Purpose The purpose of the rules and regulations in this part is to provide for uniform standards for the protection of the telephone network from harms caused by the connection of terminal equipment and associated wiring thereto, and for the compatibility of hearing aids and telephones so as to ensure that persons with hearing aids have reasonable access to the telephone network. A3. FCC Part Scope (a) General. Except as provided for in paragraphs (b), (c), (d), (e), (f), (g), (h), (i), (j) and (k) of this section for grandfathered and national defense and security terminal equipment, the rules and regulations apply to direct connection: (1) Of all terminal equipment to the public switched telephone network, for use in conjunction with all services other than party line service; (2) Of all terminal equipment to channels furnished in connection with foreign exchange lines (customer-premises end), the station end of off-premises stations associated with PBX and Centrex services, trunk-to-station tie lines (trunk end only) and switched service network station lines (CCSA and EPSCS); and (3) Of all PBX (or similar) systems to private line services for tie trunk type interfaces and off premises station lines. Services may only be added to this section as a result of rulemaking proceedings and equipment connected to such added services is afforded a reasonable transition period. (4) Of all customer premises wiring associated with one and two-line (non-system) residential and business telephone service.

5 (5) Of all terminal equipment to subrate and Mbps digital services. (6) of registered terminal equipment or registered protective circuitry to Local Area Data Channels and to channels which are similar to Local Area Data Channels that are obtained as special assemblies. (7) of all terminal equipment or systems to voiceband private line channels for 2-point and multipoint private line services (excluding those identified in Category II, A.T.&T. Tariff F.C.C. No. 260 or subsequent revisions) that utilize loop start, ringdown or inband signaling; or voiceband metallic channels. (8) of the types of test equipment specified in Section 68.3, Definitions. (9) Of all terminal equipment to Public Switched Digital Service (PSDS) Type I, II or III. (10) Of all terminal equipment to the Integrated Services Digital Network (ISDN) Basic Rate Access (BRA) or Primary Rate Access (PRA). A4. FCC Part 68.4 Hearing aid-compatible telephones (a)(1) Except for telephones used with public mobile services, telephones used with private radio services, and cordless and secure telephones, every telephone manufactured in the United States (other than for export) or imported for use in the United States after August 16, 1989, must be hearing aid compatible, as defined in Every cordless telephone manufactured in the United States (other than for export) or imported into the United States after August 16, 1991, must be hearing aid compatible, as defined in (2) Unless otherwise stated and except for telephones used with public mobile services, telephones used with private radio services and secure telephones, every telephone listed in must be hearing aid compatible, as defined in (3) A telephone is hearing aid-compatible if it provides internal means for effective use with hearing aids that are designed to be compatible with telephones which meet established technical standards for hearing aid compatibility. (4) The Commission shall revoke or otherwise limit the exemptions of paragraph (a)(1) of this section for telephones used with public mobile services or telephones used with private radio services if it determines that [i] such revocation or limitation is in the public interest; [ii] continuation of the exemption without such revocation or limitation would have an adverse effect on hearingimpaired individuals; [iii] compliance with the requirements of 68.4(a)(1) is technologically feasible for the telephones to which the exemption applies; and [iv] compliance with the requirements of 68.4(a)(1) would not increase costs to such an extent that the telephones to which the exemption applies could not be successfully marketed. A5. FCC Part 68.5 Waivers The Commission may, upon the application of any interested person, initiate a proceeding to waive the requirements of 68.4(a)(1) with respect to new telephones, or telephones associated with a new technology or service. The Commission shall not grant such a waiver unless it determines, on the basis of evidence in the record of such proceeding, that such telephones, or such technology or service, are in the public interest, and that (a) compliance with the requirements of 68.4(a)(1) is

6 technologically infeasible, or (b) compliance with such requirements would increase the costs of the telephones, or of the technology or service, to such an extent that such telephones, technology, or service could not be successfully marketed. In any proceeding under this section to grant a waiver from the requirements of 68.4(a)(1), the Commission shall consider the effect on hearing-impaired individuals of granting the waiver. The Commission shall periodically review and determine the continuing need for any waiver granted pursuant to this section. A6. FCC Part 68.6 Telephones with volume control As of January 1, 2000, all telephones, including cordless telephones, as defined in 15.3(j) of this chapter, manufactured in the United States (other than for export) or imported for use in the United States, must have volume control in accordance with Secure telephones, as defined by 68.3 are exempt from this section, as are telephones used with public mobile services or private radio services. A7. FCC Part Hearing aid-compatibility (a) Coin telephones. All new and existing coin-operated telephones, whether located on public property or in a semi-public location (e.g. drugstore, gas station, private club). (b) Emergency use telephones. Telephones "provided for emergency use" include the following: (1) Telephones, except headsets, in places where a person with a hearing disability might be isolated in an emergency, including, but not limited to, elevators, highways, and tunnels for automobile, railway or subway, and workplace common areas. Note to paragraph (b)(1): Examples of workplace common areas include libraries, reception areas and similar locations where employees are reasonably expected to congregate. (2) Telephones specifically installed to alert emergency authorities, including, but not limited to, police or fire departments or medical assistance personnel. (3) Telephones, except headsets, in workplace non-common areas. Note: Examples of workplace non-common areas include private enclosed offices, open area individual work stations and mail rooms. Such non-common area telephones are required to be hearing aid compatible, as defined in , by January 1, 2000, except for those telephones located in establishments with fewer than fifteen employees; and those telephones purchased between January 1, 1985 through December 31, 1989, which are not required to be hearing aid compatible, as defined in , until January 1, (i) Telephones, including headsets, made available to an employee with a hearing disability for use by that employee in his or her employment duty, shall, however, be hearing aid compatible, as defined in (ii) As of January 1, 2000 or January 1, 2005, whichever date is applicable, there shall be a rebuttable presumption that all telephones located in the workplace are hearing aid compatible, as defined in Any person who identifies a telephone as non-hearing aid-compatible, as defined in , may rebut this presumption. Such telephone must be replaced within fifteen working days with a hearing aid compatible telephone, as defined in , including, on or after January 1, 2000, with volume control, as defined in

7 (iii) Telephones, not including headsets, except those headsets furnished under paragraph (b)(3)(i) of this section, that are purchased, or replaced with newly acquired telephones, must be: (A) Hearing aid compatible, as defined in , after October 23, 1996; and (B) Include volume control, as defined in , on or after January 1, (iv) When a telephone under paragraph (b)(3)(iii) of this section is replaced with a telephone from inventory existing before October 23, 1996, any person may make a bona fide request that such telephone be hearing aid compatible, as defined in If the replacement occurs on or after January 1, 2000, the telephone must have volume control, as defined in The telephone shall be provided within fifteen working days. (v) During the period from October 23, 1996, until the applicable date of January 1, 2000 or January 1, 2005, workplaces of fifteen or more employees also must provide and designate telephones for emergency use by employees with hearing disabilities through one or more of the following means: (A) By having at least one coin-operated telephone, one common area telephone or one other designated hearing aid compatible telephone within a reasonable and accessible distance for an individual searching for a telephone from any point in the workplace; or (B) By providing wireless telephones that meet the definition for hearing aid compatible for wireline telephones, as defined in , for use by employees in their employment duty outside common areas and outside the offices of employees with hearing disabilities. (4) All credit card operated telephones, whether located on public property or in a semipublic location (e.g. drugstore, gas station, private club), unless a hearing aid compatible (as defined in ) coin-operated telephone providing similar services is nearby and readily available. However, regardless of coin-operated telephone availability, all credit card operated telephones must be made hearing aid-compatible, as defined in , when replaced, or by May 1, 1991, which ever comes sooner. (5) Telephones needed to signal life threatening or emergency situations in confined settings, including but not limited to, rooms in hospitals, residential health care facilities for senior citizens, and convalescent homes: (i) A telephone that is hearing aid compatible, as defined in , is not required until: (A) November 1, 1997, for establishments with fifty or more beds, unless replaced before that time; and (B) November 1, 1998, for all other establishments with fewer than fifty beds, unless replaced before that time. (ii) Telephones that are purchased, or replaced with newly acquired telephones, must be: (A) Hearing aid compatible, as defined in , after October 23, 1996; and (B) Include volume control, as defined in , on or after January 1, 2000.

8 (iii) Unless a telephone in a confined setting is replaced pursuant to paragraph (b)(5)(ii) of this section, a hearing aid compatible telephone shall not be required if: (A) A telephone is both purchased and maintained by a resident for use in that resident's room in the establishment; or (B) The confined setting has an alternative means of signalling life-threatening or emergency situations that is available, working and monitored. A8. FCC Report and Order and Further Notice of Enquiry - WT Docket No The section concerning HAC and VC copied from the FCC Report and Order and Further Notice of Enquiry - WT Docket No released on September 29, 1999 in the matter of implementation of Sections 255 and 251(a)(2) of the Telecommunications Act of Introduction 1. In this Report and Order (Order) we adopt rules and policies to implement sections 255 and 251(a)(2) of the Communications Act of 1934, as amended (Act). These provisions, which were added by the Telecommunications Act of 1996 (1996 Act), are the most significant opportunity for the advancement of people with disabilities since the passage of the Americans with Disabilities Act (ADA) in These provisions require manufacturers of telecommunications equipment and providers of telecommunications services to ensure that such equipment and services are accessible to persons with disabilities, if readily achievable. Congress has recognized that, although we are moving into the information age with increasing dependence on telecommunications tools, people with disabilities remain unable to access many products and services that are vital to full participation in our society. The purpose of sections 255 and 251(a)(2) of the Act is to amend this situation by bringing the benefits of the telecommunications revolution to all Americans, including those who face accessibility barriers to telecommunications products and services. The rules we adopt in this Order will have an historic effect on the ability of Americans with disabilities to access and utilize telecommunications technologies and services. þ Section 255(b) requires a manufacturer of telecommunications equipment or customer premises equipment (CPE) to ensure that the equipment is designed, developed, and fabricated to be accessible to and usable by individuals with disabilities, if readily achievable. * TR41.11 working group comment - However, it was intended that Part 68 HAC and VC requirements would continue to stand alone, and not be subject to vendor readily achievable determinations. A9. TIA/EIA IS-810 Transmission requirements for narrowband VoIP and voice over PCM digital wireline telephones The receive frequency response shall be below the upper limit and above the lower limit defined in Table 3 and shown in Figure 6. The RLR shall be calculated from the 1/3 octave sensitivity data collected from the receive frequency response measurement. The terminal should be designed to have a nominal RLR value of 2 db, with a tolerance of +/- 4.0 db. The test method and acoustic output requirements for telephone handset receive volume control are documented in ANSI/TIA/EIA-504-A. This standard includes the magnetic output requirements for handset telephones intended for use by the hard of hearing.

9 * TR41.11 working group comment - The ANSI/TIA/EIA-504-A standard uses a different measurement method from that adopted by the FCC in ANSI/TIA/EIA-504, but the end results are the same. A10. TIA/EIA IS-811 Performance & Interoperability requirements for VoIP feature telephones The acoustic performance requirements in Section VoIP feature telephones with handset shall support the handset technical requirements set out by section 5 in TIA/EIA/IS-810A and the handset volume control and magnetic output requirements specified by ANSI/TIA/EIA 504-A. * TR41.11 working group comment - The ANSI/TIA/EIA-504-A standard uses a different measurement method from that adopted by the FCC in ANSI/TIA/EIA-504, but the end results are the same.