A Celebration of Usability in Civic Life: Access and Usability by People with Disabilities

1. A Celebration of Usability in Civic Life: Access and Usability by People with Disabilities Karen Peltz Strauss Rehabilitation Engineering Research Center on Telecommunications Access Baltimore, Maryland June 17, 2008

2. Access to Telecommunications and Technology Means: • Jobs • Education • Information • Recreation • Marketplace • Transportation • Independence • Civic duties

3. U.S. Telecommunications Policy People with Disabilities • Telecommunications for the Disabled Act of 1982 • Telecommunications Accessibility Enhancement Act of 1988 • Hearing Aid Compatibility Act of 1988 • Section 508 of the Rehabilitation Act • Sections 255 and 251 of the Communications Act • Americans with Disabilities Act • Captioning mandates – Communications Act and Decoder Circuitry Act

4. Telecommunications Issues • Access to equipment • Access to services • Telecommunications Relay Services • Captioning • Video Description • Emergency Access • Spectrum • Hearing Aid Compatibility and Volume Control

5. U.S. Telecommunications Policy People with Disabilities • Use of “universal service” obligation to mandate telephone access • Recognition of limitations of a competitive marketplace for people with disabilities • Small market sizes of individual disability populations • Generally lower incomes • Need for adaptive equipment • Recognition of costs to society of “lost access” • Recognition of pervasiveness of the telephone and television for maintaining connections and acquiring information

7. The Early Years • 1960s – UPI, Western Union, AT&T – discard Baudot-dependent teletypewriters • 3 pioneers: Robert Weitbrecht, Dr. James Masters and Andrew Saks teamed to develop and support the TTY • Early TTYs: • 75 – 200 pounds • 4 feet high by 2 feet wide • Noisy, slow communication • Half duplex mode • Keys stuck together!

8. Hearing Aid Compatibility Laws • Telecommunications for the Disabled Act of 1982 • All essential telephones must be hearing aid compatible • Right of people with disabilities to have access to telecommunications established as national policy • Hearing Aid Compatibility Act of 1988 • Wireline and cordless phones must be HAC • Many wireless phones must be HAC

9. HAC and Volume Control Usability Issues • Wireless Phones – Inductive or acoustic coupling and reduced electromagnetic interference • Volume Control – FCC rule allowing phone to default to higher volume to facilitate use by senior citizens • Cordless Phones – must activate HAC feature – adjust hearing aid and phone to work together – difficult for senior citizens?

10. Telecommunications Relay Services

11. Telecommunications Relay ServicesAmericans with Disabilities Act of 1990 Goals of Functional Equivalency: • No restrictions based on frequency, length, hours, or content of calls • Standard blockage rate • Qualified relay staff • Complete confidentiality • Equivalent call pricing

12. Relay Service Flavors What is usable for you? • Text to Voice Relay • Voice Carryover and Hearing Carryover • Video Relay Service (sign language) • IP Relay Services (IM feature) • Speech-to-Speech Relay • Spanish Relay • CART relay • Captioned Telephone Relay Services

13. Video Relay Services • Remote sign language interpreters used to interpret conversations • Web cams – allow VRS user to access relay from home, office • Enables natural conversation with emotional context in primary language – American Sign Language • Facilitates conference calling • Facilitates IVR calls

14. IP Relay Service • User connects to relay service via Internet service provider • Connection made via computer, web phone, personal digital assistant or other portable device – TTY not needed • Promotes independence • Faster, more efficient communication • Multiple or conference calls possible • Can browse Internet while on relay call

15. Captioned Telephone Relay Service: Relay Usability for People who are Hard of Hearing

16. Other Relay Features • Fast speed of answer • Call release • Message retrieval • Video mail • Conference calling • IVR calling • Bend in rules on recording calls for STS • Speed dialing • Future: 10 digit dialing for IP/VRS users

17. Section 255 of the Communications Act47 CFR Parts 6 and 7 • Accessibility: Telecommunications products and services must be accessible to and usable by individuals with disabilities, if readily achievable. • Compatibility: When it is not readily achievable to make products and services accessible, must make them compatible with peripheral devices or specialized customer premises equipment commonly used by people with disabilities • Applies to VoIP: For consumers, thecontent and form of VoIP messages are not changed between sender and recipient • Two information services covered – voice mail and interactive voice response systems

18. Usability under Section 255 Individuals with disabilities must have access to the full functionality of and documentation for the product or service: • Instructions and user guides • Product information (including accessible features) • Billing • Technical support services • Service and repair centers

19. Section 255 – Universal Design Design products and services to be usable by people with the widest range of functional abilities • Evaluate and incorporate access throughout the design, development and fabrication stages • Design to meet user needs • Flexibility in products to accommodate wide variety of functional differences • Design to work in conjunction with other products that make it usable • Include people with disabilities in market research, product testing and trials, and pilot demonstrations to achieve above

20. Section 255 Readily Achievable – case by case analysis: easily accomplishable without much difficulty or expense • Balance costs and nature of access required with available resources, including the available resources of parent companies • No fundamental alteration or technically infeasible changes required • Examples: nibs, ability to change color, font, background lighting, addition of volume or vibrating features, inclusion of TTY jacks, etc.

21. Case Example: Interactive Voice Response Systems • Automated telephone systems that provide menu options for callers to select messages and to make communications choices (e.g., press 1 for location, 2 for a reservation, etc.) • Usability Problems: • Poor audio • Fast time-outs – too fast for TRS, people who are hard of hearing • Complicated menu options for people with cognitive disabilities • Lack of access to TTYs, other text-based communications

22. Section 508 of the Rehabilitation ActAccess Board Rules: 36 CFR Part 1194 Federal agencies must develop, procure, maintain, and use electronic and information technology that is accessible to federal employees with disabilities and members of the public with disabilities: Telecommunications equipment Computers – hardware and software Web-based information and applications Office equipment Multimedia applications – CDs, videos TEITAC: Federal Advisory Committee production of guidelines for Section 508 and 255

23. Television Decoder Circuitry Act of 1990 All televisions with screens greater than 13 inches must receive and display closed captions: replaced old, stand alone decoders that were expensive and difficult to install. Also: • PC TVs – PCs with television cards or chips must display captions if sold with monitors larger than 13 inches • Digital Television Receivers – ability to control print type, color, size, and background of captions

24. Federal Closed Captioning Rules Making Television Usable • English • New Programming: – 100% non-exempt programming • Pre-rule Programming (first shown before January 1, 1998): 75% of non-exempt programming • Spanish • New Programming • Current – 75% • January 1, 2010 – 100% • Pre-rule Programming • Current – 30% • January 1, 2012 – 75% • Exemptions for commercials, certain overnight programming, certain local (“one time”) programs

25. 21st Century Communicationsand Video Accessibility Act of 2008 • Coalition of Organizations for Accessible Technology : “COAT” • >200 local, regional and national advocacy and governmental organizations • Bill to be introduced by Congressman Edward Markey (D-MA) • Objectives: • Bring current federal accessibility laws on communications and video programming into the 21st century • Close accessibility gaps

26. 21st Century Access: Communications • Expand Section 255-type accessibility protections to Internet-enabled communications services • Add improved accountability and enforcement measures for accessibility • Clearinghouse of accessible products and services • Reporting obligations by companies • Reports to Congress by FCC • Better outreach and education • Improved complaint procedures

27. IP Advantages • Select from among text, video or voice conversational modes • Video communications for ASL users • Two-way, real time text • In-service and conferencing calls • Enhancements to telephony audio • Alter phone features through software on server or downloaded to the phone

28. IP Accessibility and Usability • IP accessibility regardless of • Form: text, video or voice • Transmission media – PSTN, IP, wireless, cable, satellite or combination • Avoid artificial separations that can create • Serious accessibility gaps and consumer confusion • Uneven playing field for companies that follow different rules for similar services • Accessibility solutions – easy at the design and development stages. Expensive and burdensome if retrofitted later on.

29. 21st Century Act – Communications • Relay Services • Expand relay obligations to Internet-enabled communications services • Clarify scope of Section 225 of the Communications Act to include calls using multiple forms of relay services between and among people with disabilities (in addition to calls between people with disabilities and individuals without disabilities) • Hearing Aid Compatibility: Expand federal mandates to devices used for Internet-enabled communications

30. Communications Access Universal Service Reform Lifeline and Link-up Subsidies for Broadband • Current law: Lifeline and Link-up programs offer low income discounts for telephone (PSTN) installation and service • Proposal: Allow low income consumers with disabilities to apply these USF subsidies to broadband fees • Would encourage broadband use among low income persons with hearing and speech disabilities to acquire access to IP-based video communication services

31. Communications Access Universal Service Reform Telecommunications Equipment for People who are Deaf-Blind • Current: Some state programs distribute free or discounted specialized customer premises equipment • Problem: Little or no equipment for people who are deaf-blind in these programs because of high costs • Proposal: Allocate up to $10 million/year from the Universal Service Fund for communications equipment for people who are deaf-blind • Provide incentives to develop new equipment capable of enhancing independence and productivity of this population

32. 21st Century Access: Video Programming Closed Captioning • Expand Television Decoder Circuitry Act to all video programming devices that are designed to receive or display analog, digital, and Internet programming, including video devices of all sizes and recording and playback devices: PDAs, MP3 players, VCRs, DVRs, battery-operated TVs, etc. • Extend FCC’s closed captioning obligations to “television-type” video programming distributed over the Internet (not user-generated content)

33. 21st Century Access: Video Programming Video Description • Restore FCC’s video description rules (for people who are blind or who have low vision) and extend rules to digital TV • Require non-visual access to on-screen emergency warnings and information • Ensure that the new DTV standard includes the capacity to deliver video description

34. 21st Century Act: Usability Accessible user interfaces Individuals with sensory, motor, and cognitive disabilities, as well as older Americans, struggle to operate common electronic devices • Require access by people who are blind or who have low vision to television controls (volume, channel selection, etc.) • Require easy access to closed captioning features (e.g., button on remote, first level menu access) • Require access (e.g., audio output) by people who are blind or who have low vision to electronic program guides and navigational on-screen menus

35. On the Horizon • Leveling the Playing Field: Achieve independence and autonomy with full access • Good business sense: industry benefits when it incorporates access • Avoid expensive and burdensome retrofits: incorporate access during design and development phases • Inclusion, not exclusion: upgrades should not remove access – e.g. voice recognition technology – avoid a repeat of the “talkies” effect • Access benefits everyone: examples: closed captioning, vibrating pagers and cell phones, slower IVR recordings, cell phones with audio output, talking caller ID devices, etc

36. Learn More COAT: www.COATaccess.org Questions? info@coataccess.org Good bedtime reading: “A New Civil Right: Telecommunications Equality for Deaf and Hard of Hearing Americans” (by Karen Peltz Strauss): Gallaudet University Press (2006)