Addressing Technology Evolution and Accessibility

1. Addressing Technology Evolution and Accessibility Disability Subcommittee FCC Technological Advisory CouncilSept 18, 2002

2. Objective • To explore the issues around technology evolution and its impact on people with disabilities and those who are older. • Not to create solutions (thoughany proposed externally will be listed) • Rather to explore the issuesand how they relate to • Facilitating safe technical innovation • Better methods for handling legacy • FCC’s roles and options

3. The Problem • People with disabilities use special “assistive technologies” (AT) in order to access and use telecommunication technologies • These couple to standard telecommunication technologies in various ways • Standard ways • RJ11 phone jack • Special ways to current design or common features • T-coil, • Headphone jack –TTY coupling, • Data over voice line using unique FSK tones

4. Problem cont’d • Evolving technologies may cause the connection methods used by AT to disappear or no longer work. • The connection point physically disappears with New Tech • e.g. Telephone speaker coils • e.g. RJ 11 as we move to VoIP • If design of new technologies does nottake the AT into account – the new technologies may not work with existing AT • New Tech interferes with existing AT • e.g. Digital cell and Hearing aids • New Tech is introduced thatdoes not accommodate AT signals or format • e.g. TTY and Voice Compression/Transmission (DigitalWireless) (VoIP??) • e.g. DVR and Captions (One of the two DVR formats) • e.g. Satellite

5. Solution Strategies • Change the New Mainstream Technology to work with AT a) Change design of the Mainstream Technology so it works with the AT • Lower EM from Cell Phone • Fix Network to carry TTY Tones • Fix DVR to capture and record captionsl b) Create patches / adapters that allow the New Mainstream Tech to work with AT • Network gateways • Special Cables (smart cables) • Neck Loops • Change the technology Used by People with Disabilities a) Migrate people with disabilities to new Mainstream Technology whenit provides the same functionality (won’t or can’t always happen) For example • ??? Instead of hearing aids? • ??? Instead of captions?? • ??? instead of TTY b) Migrate people with disabilities to new AT to access New Mainstream Technology • (in IT area -- Create a new kind of screen reader) • Create a NEW KIND of Hearing Aid ?? • Create a NEW KIND of TTY ??

6. Solutions (cont’d) • Each approach has constraints • Each puts the burden on different player(s) • Some common elements

7. Proposed Plan is to Examine via Two Case Studies / Problems • Cases • Hearing aid Compatibility with Phones • VOIP • Objective • To explore the issues around technology evolution and its impact on people with disabilities and those who are older. • Not to create solutions (though any proposed externally will be listed) • Rather to explore the issues and how they relate to • Facilitating safe technical innovation • Better methods for handling legacy • FCC’s roles and options

8. Some Initial Observations and Complications • Solutions often reside in multiple locations / companies / industry sectors. Creates coordination, timing, and accountability issues. • e.g. Lucent TTY solution involves Handset manufacturers and Carriers • Part of solution may reside inside of regulated industry and partoutside (or inside of another agency). Creates different coordination, timing, and accountability issues. • e.g. Handset manufacturers (FCC) and Hearing Aids (in FDA scope ?) • Network solutions that can use a single gateway (or set of them)are more popular with carriers than ones that require implementation at every PSTN / New-Tech interface. • e.g. a gateway at each interface between PSTN and wireless or VoIP network. • Functional Equivalence of Alternatives must be kept in mind • Email or instant messaging not same as TTY (Voicemail or voice messaging not the same as conversation)

9. More Initial Observations and Complications • Solutions must work under network stress (emergencies, disasters) • Real world stress situations are difficult to simulate. • Installed base is a big problem (with Mainstream and Assistive Tech) • All solutions must work with all combinations of new and old technology unless there is national move to swap all old for new or it is reasonable to just cut off users of old technology and require them to buy new. This latter assumes cost of new is low and new is available. (biggest cost for swap is locating tech? And training?) • Assistive Tech lifetime is longer than mainstream CPE • Often lower income, AT is more expensive, paid for by third party, or all 3 • Must be a transition path from today to tomorrow • Compatibility with old and new technologies? • Solutions should not just postpone the problem. • Solutions must work (guaranteed) over time • Phone and TTY systems are guaranteed. If another system is proposed to replace a system with guaranteed support – will support for it be guaranteed? • Phone systems all interoperate – as do TTYs over phone systems. Will future text conversation systems all interoperate – and work wherever voice works?

10. Observations (cont’d) • There seems to be some themes here • spatial problems (location) • temporal problems (indep timelines) • logistical problems (coordinating…) • conditional problems (regulated or not)

11. QUESTIONS • Are there underlying principles? • Are there basic strategies or models for addressing this class of problem? • Does a solution scale (scale in what dimension)? • How do we think about functional equivalence / flexibility / innovation? • should we encourage flexibility at the expense of equiv? • (this needs to be parsed and examined) • Should backwards compatibility be thought of as a patch (part of the transition) or a product (with a market) or a mandate? • Regarding swap – is there a mechanism to find out where the old tech resides?

12. QUESTIONS (cont’d) • How cheap can AT become? How does this impact “lifetime” • Are there non-regulatory strategies or approaches? • If regulation is needed, are there approaches that • Minimize industry load? • Maximize innovative freedom? • Maximize mainstream integration? • Minimize transition problems, cost, pain? • Was it / should it have been possible to predict these problems?

13. If possible to predict….. • What are the next areas these will appear in? • Is it possible to avoid them? How? Do What? • Is it possible to make them easier to solve if action taken earlier? • Can R & D by Industry or others help? • What action could FCC take to help? • Is regulatory necessary? • Are there effective non-regulatory approaches or actions?