Federal Communications Commission

Technological Barriers and Solutions for People with Disabilities

September 23rd, 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 on providing access to people with disabilities to discuss technological barriers, solutions, and costs as they relate to broadband networks, services, equipment, software, content, and tech support.

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.

  • As a general matter, what technical issues do we need to consider as we formulate policy recommendations "to stay ahead of technology?"
  • How would a "functionally inclusive infrastructure" which would build accessibility features directly into the broadband infrastructure be built?  How much would it cost? Should the National Broadband Plan include specific policy recommendations relating to the "functionally inclusive infrastructure?"
  • What are the technical issues that we need to consider as we formulate policies related to "improve access to 9-1-1 (including location capabilities) for those communicating with non-traditional text, video, and instant messaging communications services?
  • On what technical issues relating to equipment, software, content and tech support affecting the accessibility of broadband should we focus?
  • What are the interoperability challenges that manufacturers face and what steps need to be taken to address these challenges?  What policies would promote "openness" and ensure that assistive technology (AT) vendors are not locked out of closed systems?
  • What are the technical challenges related to ensuring that AT equipment is compatible with broadband equipment and software - and that sufficient tech support is available to help consumers navigate the interaction between these devices?
  • How much accessibility should be incorporated in mass market equipment through universal design principles and how much accessibility should be gained through assistive technologies?
  • What are the technical issues related to making broadband media accessible and what are some of the innovations that will be necessary to make user-generated content accessible?
  • What other information that you think would help us better understand the technological barriers and solutions, including information responsive to the more specific questions in our recent Public Notice?.

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.

7 Responses to “Technological Barriers and Solutions for People with Disabilities”

  1. mrvan der says:

    Re: "Other information that ... would help us better understand the technological barriers: Develop a test and evaluation methodology that first examines the software, application or website conducting walk-throughs of the top 5-10 most important (or most frequent) tasks to be performed by the target users. Evaluate both usability as well as accessibility. In the accessibility assessment process perform the tasks without and with assistive technology (e.g., JAWS).

    After the walkthrough assessment, engage with persons with disabilities (PWD) (as many as feasible) experienced with assistive technology. Observe them as they use the software, application, or site to perform the same tasks. When they go astray, explain the intention of the action and describe the observed issue and have the participant explain their experience of the task. Document and quantify and rate the discovered issues

    In writing up the evaluation, use the WCAG guidelines as standards as the basis of the evaluation and recommendations. Be sure to include the usability as well as the accessibility issues. If it is difficult to use by persons without disabilities, it is difficult for PWD.

  2. Elizabeth Lyle says:

    Thanks for your comments. Is this a process that you are recommending for all software, application, and website developers?

  3. Jim Tobias says:

    Universal design and assistive technology. The question of "how much accessibility should be incorporated in mass market equipment" versus how much should be implemented through assistive technology is probably not susceptible to an abstract, universal answer. There are several factors involved:

    - the cost of the accessibility feature, both in a mainstream and AT product (costs will differ) - the cost of getting the feature to the consumer, especially marketing/awareness, evaluation, and support services - the overall technological dynamic: if we think that the feature will eventually enter mainstream products, then that process should be encouraged; if the feature is more marginal, an AT strategy may make more sense

    These decisions should be understood as rational business choices by both mainstream and AT companies; neither type of firm is free to serve only the public and not its owners. If the total social benefit of an instance of universal design or AT is greater than the private benefit that would accrue to the company/companies concerned, then a mechanism should be sought to transfer enough of the social benefit to stimulate the "correct" decision. Such mechanisms, and the econometric tools behind them, are well known in other arenas, such as environmental economics and energy efficiency.

    One place to begin would be to develop an economic model of inaccessibility itself. What are the public and private costs of the many varieties of inaccessibility? These can certainly be measured in terms of educational attainment, employment opportunities, home- and self-management, entertainment, civic participation, etc. Again, applying an economic argument to rationalizing public sector interventions in favor of accessibility does not eliminate the other arguments; in fact, it strengthens them.

    Case studies of the interaction between mainstream and AT products would reveal useful themes and trends. There are probably dozens of examples over the past 30 years or so: speech synthesis in networks and devices, speech recognition in networks and devices, amplification of voice signals, the many specialized and mainstream forms of text messaging and conversation, captioning decoders vs. built-in decoder circuitry -- enough to fill an entire Science/Technology/Society department with graduate students for a generation.

  4. Jim Tobias says:

    "Functionally inclusive infrastructure".

    The idea of building accessibility into the network itself is a powerful one, and goes back at least as far as the 1990s telco work on the "Intelligent Network". By creating a simple method of customization for all users, such an infrastructure would be able to transparently apply "special services" like audio processing, text-to-speech, speech-to-text, location-based navigational assistance to any session involving communication or information. For example, imagine a TRS system that does not require a caller to dial the TRS number in order to communicate with a deaf colleague; simply dialing the colleague's number automatically creates a relay call. Or imagine a screen reader application that works the same way whether the user is on a desktop or a mobile device. Such services would allow users to rely on basic, mainstream hardware in many cases, because the additional functionality is not embedded in that device. For example, the simplest cell phone could speak its own menu and incoming CallerID and SMS messages if the speech synthesis capability was available through the network infrastructure.

    These technologies are already available and mature in some forms; what remains is to create the context in which they can be successfully implemented. Action from the Commission could provide the impetus for success.

    Each assistive functionality in the infrastructure could use one or more of eight categories of technological capability:

    • Speech recognition. A common need for speech recognition is to convert a speaker's voice into text so it can be sent to a deaf person at the other end of a call; another is to convert a video actor's voice into text for captioning purposes. • Speech synthesis. Conversely, speech synthesis can take text created by a person with impaired speech and deliver it to a hearing person at the other end of a call; speech synthesis can be used by a vision impaired person to listen to email or web content. • Routing (automatic delivery or connection). For example, the network can send messages or calls to someone regardless of location, based on a schedule or locator service. • Translation and medium conversion. The network element can translate between languages or convert from one medium to another, such as sign language to English text. Some of these gateway services already exist, such as TRS and TTY-to-SMS. • Interpretation and support. The service can help a user understand where they are, what to do next, etc. An example of this is "augmented reality", in which additional information is superimposed over a live video. A mainstream application would show English words over Japanese store signs; an accessibility application might interpret street signs to locate a person with a cognitive loss, and give them directions to their destination. • Automatic setup. A service can automatically identify the user and establish the proper connections and service preferences. For example, an ID card can alert a network that the user in question prefers large print on the ATM he/she is using. • Notification. A service can inform a user that an accessible form of conversation or content is now available. For example, a user may have encountered an uncaptioned video and requested that it be captioned. Once that has happened, the service can notify the user. • Aggregation and provisioning. A "meta-service" can identify the volume of requests for a specific action (e.g., video description) as a way of assisting service providers with decision-making and resource provisioning.

    None of these service features requires a breakthrough in technology; some are already in use for mainstream and assistive purposes. It remains to be seen how such functionality would best be implemented, whether "in" the infrastructure itself, or "on" it in such a way that elements can communicate transparently and effectively. Either way, significant work will have to be accomplished to establish functional architectures and communication protocols. At the same time, the business model for a sustainable functionally inclusive infrastructure must be rigorously developed. This model should reflect real advantages to all key stakeholders:

    • Users would have access to their personalized services on any device - even borrowed or public devices - without having to worry about different interfaces, or maintenance and upgrades. Automatic, transparent services would reduce the cognitive overhead currently required, which substantially suppresses effective use for some categories. • Accessibility and AT programs would be able to provide low-cost evaluation and exploration opportunities without capital investment. Once the right service features were determined for a user, the program could "subscribe" to the service rather than risk capital often lost by abandonment. Maintenance and upgrade problems would be minimized. Utilization data collection (with suitable privacy safeguards) could help these programs improve their effectiveness and efficiency. • Mainstream ICT companies might be able to offload some of their accessibility burden. For example, a mobile device manufacturer might be able to rely on the infrastructure speech synthesis capability instead of embedding it in every model. • AT companies could reduce their manufacturing and distribution efforts, and focus more on their principal value-adds: customized functionality, training, and support.

    I urge the Commission to work along with other federal agency stakeholders to investigate the opportunity for implementing a functionally inclusive infrastructure as part of the National Broadband Plan.

  5. Jim Tobias says:

    An example of a piece of the "functionally inclusive infrastructure":

    Here is a very interesting article on "HD Voice" ("wideband audio") -- basically, CD-quality audio on a phone call, VoIP or similar network, wireless or wireline:

    HD Voice has clear and immediate benefits for hard of hearing and some speech impaired users -- better intelligibility. It's already there, in one form or another, on both CPE and TE. It's certainly a competitive advantage for P2P VoIP (like Skype) over typical PSTN call quality.

    The writer's point is that network-to-network and infrastructure changes could help spur its adoption, which is stalled right now because both end points and all intervening network elements need to cooperate. (For example, even within a single enterprise running VoIP with a (dormant) wideband capability, users have no way of turning it on -- there's nothing in the user interfaces.)

    Industry has this available today and wants to see it permeate the market; users will benefit from it. Why not make it a part of the National Broadband Plan?

  6. Elizabeth Lyle says:

    So how should we frame our recommendations in the NBP with respect to a functionally inclusive infrastructure? Do we have to look at each application individually? Ask the TAC to come up with some recommendations? Recommend that government fund further research?

    What about HD Voice? What specific recommendation should the NBP contain?

  7. Jim Tobias says:

    I think the functionally inclusive infrastructure will require action at many levels. Part of the power of the idea is that it's a toolkit that will empower developers; at the other end, it's a way for users to have a consistent, personalized interface to all ICT services and applications no matter where they are or what platform they're using. To do both will require high levels of coordination, from standards work all the way to equipment distribution and consumer awareness, with lots of R&D in the middle. There are policy implications. For example, what would it take for an AT funding source like Medicaid, accustomed to buying hardware or software, to change its procedures so that it is able to subscribe to a network-based service? Because it touches so many federal and state programs at so many points, this sounds like a job for the kind of coordination on accessibility that Commissioner Copps raised at the October 20 workshop.

    Regarding HD Voice, I don't know if it needs to be in the NBP. The FCC could sponsor a forum to explore the opportunity and develop a market-based plan. The stakeholders are pretty well defined, the consumer benefit is clear, industry interest is high, and the R&D requirements are low.

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