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

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

 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

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

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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

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

 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

 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?

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

What is usable for you?
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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

 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

 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

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

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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

Section 255 of the Communications Act
47 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, the content and form of VoIP messages are not changed between sender and recipient
 Two information services covered – voice mail and interactive voice response systems

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

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

Readily Achievable – case by case analysis: easily accomplishable without much difficulty or expense
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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.

 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

Section 508 of the Rehabilitation Act
Access 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:
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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

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

Federal Closed Captioning Rules
Making Television Usable
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English
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New Programming: – 100% non-exempt programming
Pre-rule Programming (first shown before January 1, 1998): 75% of non-exempt programming
Spanish
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New Programming
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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

21st Century Communications and 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:
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Bring current federal accessibility laws on communications and video programming into the 21 st century
Close accessibility gaps

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 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
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Reports to Congress by FCC
 Better outreach and education
 Improved complaint procedures

 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

 IP accessibility regardless of
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Form: text, video or voice
Transmission media – PSTN, IP, wireless, cable, satellite or combination
 Avoid artificial separations that can create
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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.

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 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

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 IPbased video communication services

Telecommunications Equipment for
People who are Deaf-Blind
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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

21 st 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.
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Extend FCC’s closed captioning obligations to
“television-type” video programming distributed over the Internet (not user-generated content)

21 st Century Access: Video Programming
Video Description
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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

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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.)
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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

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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

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)