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

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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

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Access to Telecommunications and Technology Means

• Jobs
• Education
• Information
• Recreation
• Marketplace
• Transportation
• Independence
• Civic duties

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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

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Telecommunications Issues

• 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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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

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The Early Years

• 1960s UPI, Western Union, ATT 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!

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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

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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?

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Telecommunications Relay Services
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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

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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

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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

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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

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

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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, 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

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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

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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

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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.

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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

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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

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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

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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
  

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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

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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

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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

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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.

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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

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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

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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

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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 FCCs closed captioning obligations to
  television-type video programming distributed
  over the Internet (not user-generated content)

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21st Century Access Video Programming

• Video Description
• Restore FCCs 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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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

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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

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Learn More

• COAT www.COATaccess.org
• Questions? info_at_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)