A Celebration of Usability in Civic Life: Access and Usability

by People with Disabilities

Karen Peltz StraussKaren Peltz StraussRehabilitation Engineering Research Rehabilitation Engineering Research

Center on Telecommunications AccessCenter on Telecommunications Access

Baltimore, Maryland Baltimore, Maryland June 17, 2008 June 17, 2008

Access to Telecommunications and Access to Telecommunications and Technology Means:Technology Means:

• JobsJobs• EducationEducation• InformationInformation• RecreationRecreation• MarketplaceMarketplace• TransportationTransportation• IndependenceIndependence• Civic dutiesCivic duties

U.S. Telecommunications Policy People with Disabilities Telecommunications for the Disabled Act of 1982 Telecommunications for the Disabled Act of 1982 Telecommunications Accessibility Enhancement Act of Telecommunications Accessibility Enhancement Act of

19881988 Hearing Aid Compatibility Act of 1988Hearing Aid Compatibility Act of 1988

Section 508 of the Rehabilitation ActSection 508 of the Rehabilitation Act Sections 255 and 251 of the Communications ActSections 255 and 251 of the Communications Act Americans with Disabilities ActAmericans with Disabilities Act Captioning mandates – Communications Act and Captioning mandates – Communications Act and

Decoder Circuitry ActDecoder Circuitry Act

Telecommunications Issues Access to equipmentAccess to equipment Access to servicesAccess to services Telecommunications Telecommunications

Relay Services Relay Services CaptioningCaptioning Video DescriptionVideo Description Emergency AccessEmergency Access SpectrumSpectrum Hearing Aid Hearing Aid

Compatibility and Volume Compatibility and Volume ControlControl

U.S. Telecommunications Policy People with Disabilities

Use of “universal service” obligation to mandate telephone Use of “universal service” obligation to mandate telephone accessaccess

Recognition of limitations of a competitive marketplace Recognition of limitations of a competitive marketplace for people with disabilitiesfor people with disabilities Small market sizes of individual disability populations Small market sizes of individual disability populations Generally lower incomesGenerally lower incomes Need for adaptive equipmentNeed for adaptive equipment

Recognition of costs to society of “lost access”Recognition of costs to society of “lost access” Recognition of pervasiveness of the telephone and Recognition of pervasiveness of the telephone and

television for maintaining connections and acquiring television for maintaining connections and acquiring informationinformation

The Early Years

1960s – UPI, Western Union, AT&T – discard Baudot-1960s – UPI, Western Union, AT&T – discard Baudot-dependent teletypewritersdependent teletypewriters

3 pioneers: Robert Weitbrecht, Dr. James Masters and 3 pioneers: Robert Weitbrecht, Dr. James Masters and Andrew Saks teamed to develop and support the TTY Andrew Saks teamed to develop and support the TTY

Early TTYs: Early TTYs:

75 – 200 pounds75 – 200 pounds 4 feet high by 2 feet wide4 feet high by 2 feet wide Noisy, slow communication Noisy, slow communication Half duplex mode Half duplex mode Keys stuck together!Keys stuck together!

Hearing Aid Compatibility Laws

Telecommunications for the Disabled Act of 1982 Telecommunications for the Disabled Act of 1982 All essential telephones must be hearing aid All essential telephones must be hearing aid

compatiblecompatible Right of people with disabilities to have access Right of people with disabilities to have access

to telecommunications established as national to telecommunications established as national policypolicy

Hearing Aid Compatibility Act of 1988 Hearing Aid Compatibility Act of 1988 Wireline and cordless phones must be HACWireline and cordless phones must be HAC Many wireless phones must be HAC Many wireless phones must be HAC

HAC and Volume Control Usability Issues

Wireless Phones – Inductive or acoustic coupling Wireless Phones – Inductive or acoustic coupling andand reduced electromagnetic interference reduced electromagnetic interference

Volume Control – FCC rule allowing phone to Volume Control – FCC rule allowing phone to default to higher volume to facilitate use by senior default to higher volume to facilitate use by senior citizens citizens

Cordless Phones – must activate HAC feature – Cordless Phones – must activate HAC feature – adjust hearing aid and phone to work together – adjust hearing aid and phone to work together – difficult for senior citizens?difficult for senior citizens?

Telecommunications Relay Services

Telecommunications Relay ServicesAmericans with Disabilities Act of 1990

Goals of Functional Equivalency:Goals of Functional Equivalency: No restrictions based on frequency, No restrictions based on frequency,

length, hours, or content of callslength, hours, or content of calls Standard blockage rateStandard blockage rate Qualified relay staffQualified relay staff Complete confidentialityComplete confidentiality Equivalent call pricing Equivalent call pricing

Relay Service Flavors

What is usable for you?What is usable for you? Text to Voice RelayText to Voice Relay Voice Carryover and Hearing CarryoverVoice Carryover and Hearing Carryover Video Relay Service (sign language)Video Relay Service (sign language) IP Relay Services (IM feature) IP Relay Services (IM feature) Speech-to-Speech RelaySpeech-to-Speech Relay Spanish RelaySpanish Relay CART relay CART relay Captioned Telephone Relay Services Captioned Telephone Relay Services

Video Relay Services

Remote sign language interpreters used to Remote sign language interpreters used to interpret conversationsinterpret conversations

Web cams – allow VRS user to access relay from Web cams – allow VRS user to access relay from home, officehome, office

Enables natural conversation with emotional Enables natural conversation with emotional context in primary language – American Sign context in primary language – American Sign Language Language

Facilitates conference callingFacilitates conference calling Facilitates IVR callsFacilitates IVR calls

IP Relay Service

User connects to relay service via Internet service User connects to relay service via Internet service providerprovider

Connection made via computer, web phone, Connection made via computer, web phone, personal digital assistant or other portable device – personal digital assistant or other portable device – TTY not neededTTY not needed

Promotes independencePromotes independence Faster, more efficient communication Faster, more efficient communication Multiple or conference calls possibleMultiple or conference calls possible Can browse Internet while on relay callCan browse Internet while on relay call

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

Other Relay Features

Fast speed of answerFast speed of answer Call releaseCall release Message retrievalMessage retrieval Video mail Video mail Conference calling Conference calling IVR callingIVR calling Bend in rules on recording calls for STSBend in rules on recording calls for STS Speed dialingSpeed dialing Future: 10 digit dialing for IP/VRS usersFuture: 10 digit dialing for IP/VRS users

Section 255 of the Communications Act47 CFR Parts 6 and 7

AccessibilityAccessibility: Telecommunications products and services must be : Telecommunications products and services must be accessible to and usable by individuals with disabilities, if readily accessible to and usable by individuals with disabilities, if readily achievable.achievable.

CompatibilityCompatibility: When it is not readily achievable to make products : When it is not readily achievable to make products and services accessible, must make them compatible with peripheral and services accessible, must make them compatible with peripheral devices or specialized customer premises equipment commonly used devices or specialized customer premises equipment commonly used by people with disabilities by people with disabilities

Applies to VoIPApplies to VoIP: For consumers, the: For consumers, the content and form of VoIP content and form of VoIP messages are not changed between sender and recipientmessages are not changed between sender and recipient

Two information services covered – voice mail and interactive voice Two information services covered – voice mail and interactive voice response systems response systems

Usability under Section 255

Individuals with disabilities must have access to the Individuals with disabilities must have access to the full functionality of and documentation for the product full functionality of and documentation for the product or service: or service:

Instructions and user guidesInstructions and user guides Product information (including accessible features)Product information (including accessible features) Billing Billing Technical support services Technical support services Service and repair centers Service and repair centers

Section 255 – Universal DesignDesign products and services to be usable by people with the Design products and services to be usable by people with the

widest range of functional abilities widest range of functional abilities

Evaluate and incorporate access throughout the design, Evaluate and incorporate access throughout the design, development and fabrication stages development and fabrication stages

Design to meet user needsDesign to meet user needs Flexibility in products to accommodate wide variety of Flexibility in products to accommodate wide variety of

functional differencesfunctional differences Design to work in conjunction with other products that Design to work in conjunction with other products that

make it usablemake it usable

Include people with disabilities in market research, product Include people with disabilities in market research, product testing and trials, and pilot demonstrations to achieve testing and trials, and pilot demonstrations to achieve aboveabove

Section 255Readily Achievable – case by case analysis: easily Readily Achievable – case by case analysis: easily

accomplishable without much difficulty or expenseaccomplishable without much difficulty or expense

Balance costs and nature of access required with Balance costs and nature of access required with available resources, including the available resources available resources, including the available resources of parent companies of parent companies

No fundamental alteration or technically infeasible No fundamental alteration or technically infeasible changes requiredchanges required

Examples: nibs, ability to change color, font, Examples: nibs, ability to change color, font, background lighting, addition of volume or vibrating background lighting, addition of volume or vibrating features, inclusion of TTY jacks, etc.features, inclusion of TTY jacks, etc.

Case Example: Interactive Voice Response Systems

Automated telephone Automated telephone systems that provide menu options for systems that provide menu options for callers to select messages and to make communications choices callers to select messages and to make communications choices (e.g., press 1 for location, 2 for a reservation, etc.)(e.g., press 1 for location, 2 for a reservation, etc.)

Usability ProblUsability Problems: ems: Poor audioPoor audio Fast time-outs – too fast for TRS, people who are hard of Fast time-outs – too fast for TRS, people who are hard of

hearing hearing Complicated menu options for people with cognitive Complicated menu options for people with cognitive

disabilities disabilities Lack of access to TTYs, other text-based communicationsLack of access to TTYs, other text-based communications

Section 508 of the Rehabilitation ActAccess Board Rules: 36 CFR Part 1194

Federal agencies must develop, procure, maintain, and use Federal agencies must develop, procure, maintain, and use electronic and information technology that is accessible to electronic and information technology that is accessible to federal employees with disabilities and members of the federal employees with disabilities and members of the public with disabilities:public with disabilities:

Telecommunications equipmentTelecommunications equipment Computers – hardware and softwareComputers – hardware and software Web-based information and applicationsWeb-based information and applications Office equipmentOffice equipment Multimedia applications – CDs, videosMultimedia applications – CDs, videos

TEITAC: Federal Advisory Committee production ofTEITAC: Federal Advisory Committee production of guidelines for Section 508 and 255guidelines for Section 508 and 255

Television Decoder Circuitry Act of 1990

All televisions with screens greater than 13 inches All televisions with screens greater than 13 inches must receive and display closed captions: must receive and display closed captions: replaced old, stand alone decoders that were replaced old, stand alone decoders that were expensive and difficult to install. Also: expensive and difficult to install. Also:

PC TVs – PCs with television cards or chips must PC TVs – PCs with television cards or chips must display captions if sold with monitors larger than 13 display captions if sold with monitors larger than 13 inchesinches

Digital Television Receivers – ability to control print Digital Television Receivers – ability to control print type, color, size, and background of captionstype, color, size, and background of captions

Federal Closed Captioning Rules Making Television Usable

English English New Programming: – 100% non-exempt programming New Programming: – 100% non-exempt programming Pre-rule Programming (first shown before January 1, 1998): 75% Pre-rule Programming (first shown before January 1, 1998): 75%

of non-exempt programmingof non-exempt programming Spanish Spanish

New ProgrammingNew Programming Current – 75% Current – 75% January 1, 2010 – 100%January 1, 2010 – 100%

Pre-rule ProgrammingPre-rule Programming Current – 30%Current – 30% January 1, 2012 – 75%January 1, 2012 – 75%

Exemptions for commercials, certain overnight Exemptions for commercials, certain overnight programming, certain local (“one time”) programs programming, certain local (“one time”) programs

21st Century Communicationsand Video Accessibility Act of 2008

Coalition of Organizations for Accessible Coalition of Organizations for Accessible Technology : “COAT”Technology : “COAT”

>200 local, regional and national advocacy and >200 local, regional and national advocacy and governmental organizations governmental organizations

Bill to be introduced by Congressman Edward Bill to be introduced by Congressman Edward Markey (D-MA)Markey (D-MA)

Objectives:Objectives: Bring current federal accessibility laws on communications Bring current federal accessibility laws on communications

and video programming into the 21and video programming into the 21stst century century Close accessibility gaps Close accessibility gaps

21st Century Access: Communications Expand Section 255-type accessibility protections Expand Section 255-type accessibility protections

to Internet-enabled communications services to Internet-enabled communications services

Add improved accountability and enforcement Add improved accountability and enforcement measures for accessibilitymeasures for accessibility

Clearinghouse of accessible products and services Clearinghouse of accessible products and services Reporting obligations by companies Reporting obligations by companies Reports to Congress by FCCReports to Congress by FCC Better outreach and education Better outreach and education Improved complaint proceduresImproved complaint procedures

IP Advantages

Select from among text, video or voice Select from among text, video or voice conversational modesconversational modes

Video communications for ASL usersVideo communications for ASL users Two-way, real time text Two-way, real time text In-service and conferencing callsIn-service and conferencing calls Enhancements to telephony audioEnhancements to telephony audio Alter phone features through software on Alter phone features through software on

server or downloaded to the phoneserver or downloaded to the phone

IP Accessibility and Usability IP accessibility regardless of IP accessibility regardless of

Form: text, video or voice Form: text, video or voice Transmission media – PSTN, IP, wireless, cable, satellite or Transmission media – PSTN, IP, wireless, cable, satellite or

combination combination

Avoid artificial separations that can createAvoid artificial separations that can create Serious accessibility gaps and consumer confusionSerious accessibility gaps and consumer confusion Uneven playing field for companies that follow different Uneven playing field for companies that follow different

rules for similar services rules for similar services

Accessibility solutions – easy at the design and Accessibility solutions – easy at the design and development stages. Expensive and burdensome if development stages. Expensive and burdensome if retrofitted later on.retrofitted later on.

21st Century Act – Communications Relay Services Relay Services

Expand relay obligations to Internet-enabled Expand relay obligations to Internet-enabled communications servicescommunications services

Clarify scope of Section 225 of the Communications Clarify scope of Section 225 of the Communications Act to include calls using multiple forms of relay Act to include calls using multiple forms of relay services between and among people with disabilities services between and among people with disabilities (in addition to calls between people with disabilities (in addition to calls between people with disabilities and individuals without disabilities) and individuals without disabilities)

Hearing Aid Compatibility: Expand federal mandates to Hearing Aid Compatibility: Expand federal mandates to devices used for Internet-enabled communications devices used for Internet-enabled communications

Communications Access Universal Service Reform

Lifeline and Link-up Subsidies for Broadband Lifeline and Link-up Subsidies for Broadband

Current law: Lifeline and Link-up programs offer low income Current law: Lifeline and Link-up programs offer low income discounts for telephone (PSTN) installation and servicediscounts for telephone (PSTN) installation and service

Proposal: Allow low income consumers with disabilities to Proposal: Allow low income consumers with disabilities to apply these USF subsidies to broadband feesapply these USF subsidies to broadband fees

Would encourage broadband use among low income persons Would encourage broadband use among low income persons with hearing and speech disabilities to acquire access to IP-with hearing and speech disabilities to acquire access to IP-based video communication servicesbased video communication services

Communications Access Universal Service Reform

Telecommunications Equipment forTelecommunications Equipment for

People who are Deaf-BlindPeople who are Deaf-Blind

Current: Some state programs distribute free or discounted specialized Current: Some state programs distribute free or discounted specialized customer premises equipmentcustomer premises equipment

Problem: Little or no equipment for people who are deaf-blind in Problem: Little or no equipment for people who are deaf-blind in these programs because of high coststhese programs because of high costs

Proposal: Allocate up to $10 million/year from the Universal Service Proposal: Allocate up to $10 million/year from the Universal Service Fund for communications equipment for people who are deaf-blind Fund for communications equipment for people who are deaf-blind

Provide incentives to develop new equipment capable of enhancing Provide incentives to develop new equipment capable of enhancing independence and productivity of this population independence and productivity of this population

21st Century Access: Video Programming Closed CaptioningClosed Captioning

Expand Television Decoder Circuitry Act to all video Expand Television Decoder Circuitry Act to all video programming devices that are designed to receive or programming devices that are designed to receive or display analog, digital, and Internet programming, display analog, digital, and Internet programming, including video devices of all sizes and recording and including video devices of all sizes and recording and playback devices: PDAs, MP3 players, VCRs, DVRs, playback devices: PDAs, MP3 players, VCRs, DVRs, battery-operated TVs, etc. battery-operated TVs, etc.

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

21st Century Access: Video Programming

Video DescriptionVideo Description

Restore FCC’s video description rules (for Restore FCC’s video description rules (for people who are blind or who have low vision) people who are blind or who have low vision) and extend rules to digital TVand extend rules to digital TV

Require non-visual access to on-screen Require non-visual access to on-screen emergency warnings and informationemergency warnings and information

Ensure that the new DTV standard includes the Ensure that the new DTV standard includes the capacity to deliver video descriptioncapacity to deliver video description

21st Century Act: Usability

Accessible user interfacesAccessible user interfaces Individuals with sensory, motor, and cognitive disabilities, Individuals with sensory, motor, and cognitive disabilities,

as well as older Americans, struggle to operate common as well as older Americans, struggle to operate common electronic deviceselectronic devices

Require access by people who are blind or who have low Require access by people who are blind or who have low vision to television controls (volume, channel selection, vision to television controls (volume, channel selection, etc.)etc.)

Require easy access to closed captioning features (e.g., Require easy access to closed captioning features (e.g., button on remote, first level menu access)button on remote, first level menu access)

Require access (e.g., audio output) by people who are Require access (e.g., audio output) by people who are blind or who have low vision to electronic program blind or who have low vision to electronic program guides and navigational on-screen menusguides and navigational on-screen menus

On the Horizon

Leveling the Playing Field: Achieve independence and Leveling the Playing Field: Achieve independence and autonomy with full accessautonomy with full access

Good business sense: industry benefits when it Good business sense: industry benefits when it incorporates accessincorporates access

Avoid expensive and burdensome retrofits: incorporate Avoid expensive and burdensome retrofits: incorporate access during design and development phasesaccess during design and development phases

Inclusion, not exclusion: upgrades should not remove Inclusion, not exclusion: upgrades should not remove access – e.g. voice recognition technology – avoid a repeat access – e.g. voice recognition technology – avoid a repeat of the “talkies” effect of the “talkies” effect

Access benefits everyone: examples: closed captioning, Access benefits everyone: examples: closed captioning, vibrating pagers and cell phones, slower IVR recordings, vibrating pagers and cell phones, slower IVR recordings, cell phones with audio output, talking caller ID devices, cell phones with audio output, talking caller ID devices, etcetc

Learn More

COAT: COAT: www.COATaccess.orgwww.COATaccess.org

Questions? Questions? info@coataccess.orginfo@coataccess.org

Good bedtime reading: “A New Civil Right: Good bedtime reading: “A New Civil Right: Telecommunications Equality for Deaf and Hard Telecommunications Equality for Deaf and Hard of Hearing Americans” (by Karen Peltz Strauss): of Hearing Americans” (by Karen Peltz Strauss): Gallaudet University Press (2006)Gallaudet University Press (2006)