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Accessibility and Affordability Barriers to Broadband Faced by People with Disabilities

September 22nd, 2009 by Elizabeth Lyle - Special Counsel for Innovation, Wireless Telecommunications Bureau

Elizabeth Lyle BBWe have tentatively planned for a panel at our October 20 workshop to discuss barriers to broadband accessibility and affordability for (i) people with hearing disabilities; (ii) people who are blind and have vision disabilities; (iii) people with speech disabilities; (iv) people who are deaf-blind; (v) people with mobility disabilities; and (vi) people with intellectual disabilities and social communication disabilities, including autism.

Please give us your feedback on workshop planning issues (e.g., how to structure this panel, suggested questions and speakers, and helpful background reading material) and policy issues.  For each disability, we are interested in learning

  • the number of people who use broadband;
  • the biggest accessibility barriers;
  • whether affordability is a major concern;
  • whether subsidizing the cost of specialized equipment would increase broadband use, and, if so, by how much;
  • whether subsidizing the cost of broadband service by low-income consumers in the community would increase broadband use, and, if so, by how much;
  • whether the marketplace is more or less responsive to accessibility concerns than it was in the past;
  • the percentage of mass market consumer broadband equipment and devices that have the needed accessibility features;
  • what broadband applications are potentially the most beneficial;
  • whether more outreach will help spur broadband use, and, if so, whether there are effective mechanisms or networks by which to do so; and
  • any other information that you think would help us better understand the accessibility and affordability barriers faced by people with disabilities, including information responsive to the more specific questions in the PN.

Please file your comments using our Electronic Filing Comment System, using either ECFS Express or our standard submission page if you need to attach a file.

13 Responses to “Accessibility and Affordability Barriers to Broadband Faced by People with Disabilities”

  1. Toni says:

    Your new rule of net nutrality is unconstitutional unless you can tell me where in the constitution it is that say you can do this

  2. Barry M Kunst says:

    I am diasabiled. I used to have broadband high until I could not afford to pay, rent and eat at the same time.Time Warner Commications have a monoploy in zip code 92234 Palm springs. TWC say I own them $ 577 but I do not. What recourse do I have. They turned off my phone and took 3 months to come and get Modem and router which never worked properly. It was a constant unplug and reset the modem and the box. Once my phone turned off and and I have not internet acess at The power co. turned off my power. I cant walk to the mail box.What we have here ismore greedy executives like enron ripping the public off. When over the air broadcasting stop ,that emboldened TWC and they were the the first to turn out TV's off. How can vote intellengently witout TV news and the interned.

    RETURN RESPONSE REQUESTED

  3. Barry M Kunst says:

    DO SOME THING

  4. Guest says:

    This topic relates to broadband and access by people with disabilities.

    There currently is no "rule of net nutrality." The FCC's chairman has simply announced that he intends to begin a proceeding to consider adopting such a rule. If you favor, or have some rational opposition to, such a rule (and if you can figure our how to spell "neutrality"), submit your comments to the FCC when it begins that proceeding. When and how to do so will be well publicized. In the meantime try to keep your posts on topic.

  5. Elizabeth Lyle says:

    I'm sorry about the difficulties you are having with your service provider. Please submit your complaint (with your contact information) to our experts in the Consumer and Governmental Affairs Bureau at this link.

  6. Jim Tobias says:

    There is plenty of evidence that people with disabilities have higher unemployment and lower household income than non-disabled people. They are also relatively older and have lower educational attainment. There's every reason to assume that their underadoption of broadband (which is also well established) is due at least in part to these "mainstream" demographic characteristics. People with disabilities should be included as a targeted category in any overall programs intended to address these factors.

    To these must be added the real or perceived costs of accommodations -- screen readers, specialized keyboards, etc. -- that would drive up the total cost of adoption. Equipment distribution programs that reduce the real costs, coupled with awareness programs that address often incorrect perceptions about accommodations, might help close the broadband adoption gap. These programs should be integrated as closely as possible into public and private sector broadband initiatives.

  7. Jim Tobias says:

    The issue of accessibility of broadband is complicated by the fact that the accessibility features that users need are created and sustained at many points along the value chain of a particular service or application. Briefly, the concept of a value chain originated with Michael Porter, in his book Competitive Advantage: Creating and Sustaining Superior Performance (1985). A value chain is the recognition that the value of a product is created not only by a single entity like a manufacturer, but depends significantly on many other players: component vendors, distributors, retailers, trainers and end users. Value chains can be used to analyze the total social benefit of products and services, and to clarify the relationships between and among links in the chain.

    How does the value chain concept relate to accessibility? In some cases a mainstream product provides an accessibility feature, which the user needs to find and activate to use that feature. In other cases the mainstream product does not have the necessary accessibility feature, so the user connects a piece of assistive technology, and the AT product provides the necessary accessibility feature, working in conjunction with the mainstream product. In both cases, accessibility may still not be achieved if the content or service accessed or enabled by that product is not appropriately formatted or enhanced. From a user experience perspective, broadband technologies are characterized by ever-lengthening and profuse value chains, as companies and other value-adders continue to intensify their specialization, and all elements of the chain experience increased flexibility, customization, and modularization.

    For example, consider how the television value chain has changed. Initially, there were only a handful of broadcast television networks, they produced their own shows and transmitted them over their own facilities. Consumers only needed an antenna and a TV set. Recorded video added the VCR and its successors in scheduling and storing content to the chain. Hardware innovations added computers and portable devices as display platforms. New transmission paradigms added cable, satellite, wireless, and Internet distribution. The transition to DTV required equipment changes along the entire value chain. Significant public and private efforts were made to ensure that this transition and accompanying equipment and process changes did not negatively impact closed captioning. Although progress is being made, many consumers are having significant problems receiving captions at all on their home set-ups or experiencing problems related to intermittent or incomplete caption display.

    For example, a significant barrier stems from design of the HDMI cable that is used to connect new digital TV sets to set-top boxes and other products. It is not capable of carrying caption data (although it does carry the decoded captions embedded in the video signal). This illustrates how any one of the content or technology developers can create a major challenge to accessibility. DTV also makes possible the soon-to-be pervasive direct-to-mobile TV broadcast, which draws mobile users into the value chain. Further, the profusion of production tools has made every viewer a potential studio. The changes in these value chains have transformed television by multiplying stakeholders at every decision point.

    Assistive technology also adds complexity to the chain. For example, users who utilize eye gaze software or a single switch device to navigate online content know that their AT relies on keyboard equivalents to work but they cannot know whether the material they hope to access includes sections that are only operable via a mouse. People in the value chain who train, guide or advise the user, or manage the user's information technology are providers of critical value. This is especially true of institutional settings like schools and workplaces or job placement centers. Organizational decision makers and technology administrators are key links in the accessibility value chain, yet they are rarely well informed about accessibility features and AT compatibility for a variety of factors, including the fact that staying well informed in general about current features and capabilities of any new technology is increasingly difficult.

    These changes have complicated the tasks of consumer information and policy intervention for the public good. The FCC's mandate to develop the National Broadband Plan may not permeate all the business and social relationships and other factors in the rapidly changing and complex broadband value chain that connects content to distributors to products and services to consumers. It should do what it can, however, to clarify these relationships and their implications for policy interventions.

  8. Jim Tobias says:

    You ask "whether the marketplace is more or less responsive to accessibility concerns than it was in the past". I think the "raw" accessibility in products and services does tend to increase, simply because the raw functional capabilities keep growing and the products and platforms are evolving and diverging. However, it's not clear that people with disabilities are benefiting from these capabilities as much as they could. In a profuse and rapidly changing market, merely identifying the feature you want, finding a product that has it, and configuring that feature successfully have become overwhelming tasks for many. In some cases, this is as true of clinical professionals as it is of consumers. Adequate information channels about the accessibility features of mainstream products can be hard to find -- an ironic outcome of the success of universal design. There are certainly some exemplary programs that the FCC should study, such as CTIA's Access Wireless program and PhoneScoop's Finder function.

  9. Jim Tobias says:

    Another exemplary consumer information program is AT&T's project with the OASIS Institute. Senior cell phone users get a chance to ask questions one-on-one with AT&T Wireless staffers; over 40,000 of these sessions have taken place so far. The consumers get their questions answered, and retail staff get commerically valuable insights into the needs and preferences of a growing market segment.

  10. Elizabeth Lyle says:

    Thanks, Jim, for your interesting comments about affordability, the value chain, and marketplace responsiveness. We will have to work through what the implications of the value chain are as we are formulating recommendations for the NBP. Thanks also flagging the Access Wireless, PhoneScoop, and AT&T/Oasis programs -- I looked at them briefly on-line, and they seemed like they could be very helpful.

  11. Jim Tobias says:

    In order to help the Commission understand the degree of underadoption of Internet and broadband by people with disabilities at home, here are some statistics provided by UCSF's Disability Statistics Center, using data from the Current Population Survey:

    INTERNET No disability: 65% Any disability: 38% Hearing: 30% Vision: 24% Cognition: 36% Mobility: 37%

    BROADBAND No disability: 57% Any disability: 29% Hearing: 21% Vision: 23% Cognition: 27% Mobility: 27%

    According to these numbers, people with disabilities use the Internet and broadband about half as much as do people without disabilities.

  12. Jim Tobias says:

    Thanks, Elizabeth. I'll say a bit more about what the market can and can't provide, in the context of the FCC's mission. I think we can assume that there will continue to be a full continuum of accessibility in the "natural market": some features (like volume control and audio jacks) will be more or less ubiquitous without regulatory effort; some will appear here and there and will require diligence on the part of consumers to locate and configure; and some will never appear without clear regulations and enforcement (like audio description). Accessibility features that have a good "universal design market multiplier" -- clear value to non-disabled users -- will permeate the market better than those without a multiplier, costs being equal.

    In this context, perhaps the FCC can explore a hybrid regulatory regime. Where no universal design advantage exists, traditional regulation will be necessary. But where market forces are present, strong or weak, an effective intervention may consist of careful monitoring (of both market offerings and consumer behavior), sponsored industry consortia, negotiated migration paths, and consumer outreach. It's likely that even in these latter cases that strong legal requirements must exist to motivate the parties, but the enforcement program can be correspondingly colleagial and commerce-friendly.

  13. Elizabeth Lyle says:

    Thanks, Jim. Very helpful.

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