Federal Communications Commission

A Few More Questions

October 29th, 2009 by Elizabeth Lyle - Special Counsel for Innovation, Wireless Telecommunications Bureau

Elizabeth Lyle BBAs referenced in my last post, we have a few follow up questions from the October 20th workshop.  We would very much appreciate your input on these questions no later than November 16th and sooner if possible.  In some cases, we may have some information in the record about a certain topic, but we would like more information from a broader range of stakeholders.  It is not necessary to repeat things that you've already put in the record (but feel free to cite back to comments you've already filed).

If you think it would be useful to meet with us and discuss, please request an ex parte meeting by clicking here.

Please respond with  your ideas to this blog post, or 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.


1. There was a lot of discussion at the roundtable about the concept of getting companies, independent software developers, consumers, government, and universities together to share best practices, understand consumer needs, and foster innovation. What are the next steps to establishing an innovation center or focus center program?  Are there some specific ideas on this and more information about models we can follow?

2. There were some general concerns expressed that applying regulation to broadband services and equipment might hamper innovation.  Have the processes mandated under Section 255, including as they relate to equipment and devices developed for VoIP services, hampered innovation? Have the FCC's existing captioning rules or wireless Hearing Aid Compatibility rules hampered innovation?

3. What is the effect of Section 255, HAC, and Section 508 regulations on the telecom and electronic and information technology marketplace?

4. The record contains a few examples of companies voluntarily making devices used for Internet access accessible to people with disabilities - in particular, the Apple I-Phone was mentioned several times at the workshop.  What are some other examples of which we should be aware?  What motivates companies to make their products accessible on a voluntary basis?  Will companies consider accessibility issues in the design and development of their broadband products and devices on a widespread basis if there is no mandate to do so?

5. What can the government do to attract additional capital investment to make products accessible?  What can the government do to incentivize independent software designers to create innovative assistive and adaptive technologies?

6. How is the development and distribution of assistive and adaptive technologies currently funded, including assistive and adaptive technologies used to access the Internet?  What specific recommendations should we make to address concerns expressed in the record about the expense of assistive and adaptive technologies?  Are there specific recommendations regarding how state programs could partner with a federal universal service program?

7. Are there specific recommendations about the best way for the FCC to get more involved in International efforts to harmonize standards relating to accessibility?

10 Responses to “A Few More Questions”

  1. Kyt says:

    Some people with Developmental Delay syndrome are even helped by or require Closed Captioning. I use a CapTel 800i phone because I don't successfully process everything I hear. I would love to see the day where by CC of ALL TEXT including that on special features and commentaries are required around the world on all DVDs, Movies, and TV shows - HD, or otherwise. I'd also love to get my hands on a CC German version of Harry Potter and see Regional Zoning Banned.

    I'd love to see all people running for government office be required to take a year long course that teaches them about the trials and tribulations of those who have various abilities, especially those who are Deaf, Blind or in a Wheelchair. Yes, this leaves me out, but I do use Deaf services where I can for Auditory processing issues. (My brain will all of a sudden stop processing what I hear and cause me to think that I can't hear because the volume is too low.)

    I do believe that everyone deserves a better quality of life and should get the adaptive items they need without having to pay so much for them. I'm on Disability. The only way I got my CapTel phone was through a program.
    Thanks! (I found here trying to figure out why my CapTel phone doesn't have CC after we connected a new more secure router. We are going to reset the phone now and see if that works, as we forgot to try that. )

  2. Kyt says:

    I should clarify, that I do use the Internet ALL the time. My CapTel Phone is broadband and connects thru the internet for my closed captioning.

  3. Guest says:

    The government should fund online universities, and create an infrastructure for teachers and students to communicate with each other via video/audio streams, blackboards, and so on. Much of the instruction at these universities should be automated, like programmed instruction courses created for the Navy using BF Skinner's method. The Online University should function as a path for anyone with an internet connection to get an education from an accredited institution, at his/her own pace, concerning the subject matter that is of interest to him/her, for free. In fact, I don't know how much adornment you want to attach to the content, but you could do this university in MMORPG format. It is important that degrees conferred from this online university be respected, so standards

    If anyone with a blackberry can work on his/her six sigma black belt from anywhere...then that will create a choice that will allow people to avoid idle time. "Oh, today I feel like learning about Arrow's impossibility theorem. I could read wikipedia about it, but I don't get any credit for that. Where is an institution that will give me credit for learning something. Well, since I don't get any credit for learning about these theorems, I'll hang around in my social network instead." Is that the way people think? I don't know.

    There will be authentication issues, you will need to know that the person attending the classroom is not somebody besides that person.

  4. Guest says:

    Internet and captioning:
    Need for remote captioning (meetings, videoconferencing and teleconferencing, scripts, video streaming, internet video)
    •\tTechnical barriers exist: different video formats.
    •\tShows captioned when first aired but captions are missing on iTunes, NetFlix, or other on-demand methods (Hulu is good example of captions).
    •\tPotential cable industry argument that when it moves to strictly internet-based model and no longer broadcasts via cable delivery method, they can drop captioning completely
    •\tNeed for websites to provide captioning where there is audio.

    Emergency Information
    •\tTransition from copper lines to VOIP (fiber, cable) makes emergency phone access difficult during extended power outages. People who are deaf cannot obtain information via the radio so the phone line becomes more important for this population.
    •\tDigital radio: key radio news outlets such as NPR and emergency broadcast alerts must be captioned)
    •\t911 can take TTY messages but not text messages from cell phones (in most locales). Text messages and email are the mobile modes of choice for people who are deaf.
    •\tPeople with hearing loss need to be able to call 911 and get response by cell phone. Those who can speak can call 911, tell their location and the problem but cannot hear so they keep repeating the info. One route is a reply via text message or email.
    •\tSupport for 911 calls via internet based relay, including those using instant messenger, CapTel, or Web CapTel.

    Texting (DHOH community use more texting than hearing counterparts)
    •\tPricing is radically out of alignment with actual carrier costs.
    •\tReliability for text messaging delivery is poor.
    •\tModels for text-based interaction with 911 call centers needs to be worked out. This would be via instant messenger or real-time text standards.

    Wireless Data Monitoring Systems
    •\tPricing is too high. Some users use a small amount of data any given day but will occasionally surge to broadband, e.g., video. A smart wheelchair’s built-in computer might use a mobile broadband card to access local data about sidewalks but periodically need to establish a video link with a remote teleoperator assistant for help pressing a cross walk button.

    Wireless Tethering
    •\tPricing is to high. Digital device uses a mobile phone’s broadband data for the connection. Mobile phone cost $30/month beyond the base mobile phone plan to link a wifi enabled watch to a phone data connection to a therapist via the user’s phone to provide virtual coaching for a person with a cognitive impairment. The watch would permit low-level data monitoring so the system would alert the therapist when they need to call and speak to the user. Under normal circumstances, the watch may only use a trickle of data but the user will still be charged as if they were a heavy internet user.

    HDMI (High-Definition Multimedia Interface is a compact audio/video interface for transmitting uncompressed digital data) and Closed Captioning
    •\tHDMI connections do not currently have any way to transmit closed captioning (analog or digital) as the standards called for it. There are apparently two separate standards, the Line 21 standard, and the more modern MPEG standards. The vast majority of televisions available today do not support the second standard over HDMI connection. Also, the vast majority of content is using the older Line 21 standard, which can not be sent over HDMI connections.
    •\tSo, if you are getting a nice new TV, and hook up your DVD player over HDMI to the TV, do not be shocked to see a sheer absence of closed captioning. The fallback is to render the captions upstream, and this is done by some cable boxes and DVRs, but most DVD players do not have the capability to render captions. The HDMI standard should be updated to pass closed captioning data and upstream devices (e.g., cable boxes, DVRs, and DVD players) should be required to render captions due to the market penetration of HDMI equipped televisions.
    •\tThe FCC and Canadian’s CRTC need to establish and/or implement a digital high definition standard to support Closed Captioning. Having an established standard will encourage manufacturers to fall in line. Digital TV standards apparently include a CC component (CEA-708) and which should be implemented.

    •\tUnfair pricing exists. Deaf and hard of hearing people pay basic rates for Cable TV but many programs are not captioned, e.g. Comcast or Verizon carry TCM station or Discovery Channel that are sometimes not captioned—should people with hearing loss have a credit?
    •\tComcast transitioned to digital but has drawn the ire of people with hearing loss because it does not caption its “LOCAL Newsmakers”
    •\tProblem of whom to contact when a program is not captioned; FCC has not been very responsive to complaints about Comcast
    •\tWith HD, HD channels often are not captioned and channels that are captioned produce captions with very poor quality.
    o\t CapTel & TTYs ( Analog,Digital/Mobile/Cell Service): TTYs require analog phone connections. CapTel requires analog, although there is a new model compatible with VOIP that uses the internet for captioning. There is a lack of information for consumers with devices that are incompatible with VOIP-based phone service (e.g., fiber, cable). Phone providers need to help consumers who have TTYs and phone-only CapTel with easy to find options for POTS (plain old telephone service) phone connections. Comcast changed to all digital phone service; the new provider is Verizon. Verizon has packages of digital phone, TV, computer and someone who calls the advertised number via TTY or CapTel should be informed immediately that their phone line has to remain analog.
    •\tPricing models for “mixed-media” connections should be competitive with regular packages. For example, it currently costs more to get POTS for phone and FIOS for everything else when compared to everything on FIOS.
    •\tProviders should not be allowed to remove POTS from households since that leads to a high installation cost when the household needs to add on a device that is not compatible with VOIP. If the provider does remove POTS they should reinstall it for free.
    •\tComplexity and cost of buying a phone and web connection even if consumers do not use a computer, as is the case with many late deafened and older adults.

    •\tRear Window Captioning and DVS Theatrical not widely available (
    o\tDeaf members of a family and non-deaf members can enjoy movie outings together.
    •\tSome people experience problems when using Rear Window Captioning due to difficulty positioning the panel. Theaters should show placeholder content before the show so there is something to reflect (the rear screen is sometimes left blank) and all staff should be trained to assist with the positioning of the panel.

    Submitted by the Disability Community
    to the City of Pittsburgh—Allegheny County Task Force on Disability
    Compiled and edited by Katherine D. Seelman, Ph.D.

  5. Guest says:

    Broadband eAccessibility Policy Recommendations
    Submitted by Katherine D. Seelman, Ph.D.

    1. The FCC should develop and implement a plan to use the Universal Service Fund to subsidize digital, internet protocol-based- equipment, services and training for people with disabilities and older adults.

    2. The FCC should regularly hold public hearings on eAccessibility in the health, education, and built environment and transportation sectors.
    3. The FCC should implement a transition procedure that sends eAccessibility-related complaints to a special unit rather than sending them to the regular complaint bin. Analysis of content can inform decisions.
    4. The FCC should investigate fair pricing for Wireless Data Monitoring Systems and Wireless Tethering and other systems and services in which people with disabilities, older adults and other consumers may use small amounts of data but be charged at the same rates as large data users.

    5. NTIA should:
    •\tDevelop an eAccessibility Plan, with quantifiable national objectives
    •\t Develop and implement a survey of people with disabiities and older adults to identify needs barriers and usage patterns and utilize survey results as baseline data for ongoing monitoring and as evidence to guide policy
    •\tDevelop and always integrate questions about usage, needs and barriers of disabled and older people into its population, industry (consumer electronics….) and public sector (ICT, health, housing, transportation) surveys
    •\tFund the establishment of an eAccessibility unit within NTIA which would target people with disabilities and older adults.

    6. Expand the funding of the National Institute on Disability and Rehabilitation Research to do the following:
    •\tEstablish an Informatics engineering research capability which would:
    o\thire expert personnel
    o\tcompete grants addressing:
    \t accessibility R&D in Informatics and health information technology, robotics and engineering;
    \tsocial science surveys of usage, need and barriers among end user populations; targeted surveys of end users in health, education, employment and independent living
    \ttraining grants for Informatics students and professionals targeting universal design, standards and participatory design/research;
    \tend user information and training
    \ttargeted eAccessibility studies of health, education, employment (employers), built environment and transportation private and public sectors.

    7. Department of Commerce should be funded to do a study of technology assessment and eAccessibility in the ICT industry as a follow-up to its study of the assistive technology industry.

    8. Internal Revenue Service should provide R&D credits and other incentives to ICT industries for the development of universally designed consumer electronics products, processes and ICT.

    9. Federal support for the research and development of communications infrastructure in the 50 states should include mandatory guidelines for eAccessibility.

  6. Ken J. Salaets / ITI says:

    On behalf of the Information Technology Industry Council (ITI), a Washington, DC-based non-profit industry organization, I am appreciate the opportunity to respond to the follow-up questions from the most recent Broadband Initiative Workshop. We welcome the chance to collaborate with the Commission and our fellow stakeholders on this important endeavor. Our response to the questions follow:

    1. One of the clear challenges identified at the workshop was how to share information, e.g., on products and potential solutions already available in the marketplace, on assistive technology (AT) that works with a given device or application, etc. While the concept of establishing an innovation center is certainly worth pursuing, in the interim, the Commission may want to consider establishing a “virtual” center, i.e., a web site or portal to facilitate the sharing of information now. Among other things, the web site could include a section on industry best practices, a calendar of events being hosted around the country or online (such as CSUN, the Accessibility Interoperability Alliance, etc.), an “engineers” section to discuss new developments in technology that may be leveraged to improve accessibility, information on accessibility- or technology-related grant opportunities, and so on.

    Another idea is to continue the workshop model even beyond the drafting and submission of the report to Congress. For example, the Commission could host Broadband Innovation Workshops in conjunction with established events that already draw stakeholders, such as CSUN, GSA’s IDEAS Conference, and so on.

    2. One of the distinct challenges manufacturers face is the question of market acceptance of a new product or technology. While focus groups and test marketing are invaluable, given the rate of technology development, there is considerable risk inherent in all product roll-outs. What many may not know is that technology-related product development is evolutionary, and actual market experience is the best test bed for improving all aspects of a product, including accessibility. Some may be surprised to learn, for example, that many of the consumer electronics products introduced each year do not become successful in the marketplace.

    For all of the praise one particular company justifiably received at the FCC workshop for the built-in accessibility features of its latest generation 3G mobile phone, it is worth noting that neither of the first two releases in that product family had such features. What would have been the impact on innovation had such accessibility features been required (e.g., a built-in screen reader) before the first version of the device could have been introduced? Requiring accessibility in all products before they have achieved market relevance may impact the speed of overall market innovation, as everything has to slow down in order to add such functionality.

    A similar argument can be made about “internationalization” requirements. Some companies require that a product be able to meet all international market-relevant requirements before it can be introduced, while sometimes you get innovation faster when you break such rules for a first release or two. Once said product demonstrates market relevance, then you rush to add things like internationalization, accessibility, etc.

    3. Section 508 has proven to be a catalyst for focusing and accelerating the introduction of accessibility features into all technology. The U.S. Government buys just about everything these days, including products and services that were never intended for the government market. Since most IT and telecom manufacturers do not build distinct products for the government marketplace and commercial markets, the “reach” of the Section 508 standards gets extended well beyond the Federal marketplace. Moreover, the “refreshed” Section 508 standards are being intentionally designed to anticipate and embrace changes in technology and consumer preference, including many of the changes/functionality being contemplated for Section 255, such as real-time text. This built-in flexibility ensures the relevance of the Section 508 standards now and into the future.

    4. Another example of a company taking voluntary steps to deliver accessibility includes software and web-based applications, such as AOL’s real-time instant messaging feature (RTI), available in newer versions of its software application for the Windows operating system. RTI was developed with guidance from Gallaudet University in response to the deaf community's expressed interest in IP-based real-time text functionality. Additionally, the IT industry has played an important role to advance adoption of ARIA, a suite of techniques and technology enhancements developed by the World Wide Web Consortium necessary to enable developers to build accessible, dynamic web applications that make use of advanced user interface controls developed with Ajax, HTML, JavaScript, and related technologies.

    Regarding motivations to incorporate accessibility voluntarily, there are many reasons why manufacturers include such features. One clear factor is the ever-increasing market for accessibility being driven by the increase in end users with age-related limitations. With many workers choosing to remain in the workforce beyond traditional retirement eligibility, businesses are growing increasingly aware of the need to acquire products and services that enable these employees to continue to perform at their highest levels. For example, enterprise-class software, such as an online expense report and approval system, often requires wholesale adoption by all employees of an organization in order to be effective. This motivates software companies to incorporate accessibility into their products, because the inability to address the needs of employees with disabilities could disqualify them from competing for the sale.

    Accessibility advances are also driven by manufacturers receiving feedback from a broad range of actual users, in addition to market research, consumer organizations and so on. Consequently, they are aware of the general interest in, and need for some degree of accessibility to address general needs of individual users, and incorporate it into their platforms. More robust technologies and innovations are then developed by commercial entities to address specific needs of smaller, more targeted audiences. In other cases, industry will fund groups or activities such as the NonVisual Desktop Access project (NVDA) to develop and support innovation and interoperability that can then be incorporated across platforms. As you know, NVDA developed a free and open source screen reader for the Microsoft Windows operating system.

    The FCC could make a significant contribution in this area by leveraging its insight into current and future technology developments and trends. One consideration might be to organize an inter-agency technology panel that agencies such as The U.S. Department of Education's National Institute on Disability and Rehabilitation Research NIDRR, the Commerce Department's NTIA program and other agencies could utilize to better target future grant-making. Given the fast pace at which new technologies are developed and deployed, it is vital that such funds are more effectively targeted to address accessibility-related needs and initiatives that are directly tied to actual commercial environments, i.e., where commercial technology is actually going. Today, many Federal accessibility-specific grants fund development of technology-specific concepts and models without a direct connection to the actual marketplace. Using existing grant dollars to forge stronger collaboration between accessibility experts and industry will ensure people with disabilities have more timely and meaningful access to current and future broadband technologies and products.

    5. In addition to idea on the effective targeting of Federal grant money, the FCC could create and secure funding for an “AT Innovation Fund.” This fund would be designed to assist AT developers in lowering development costs and expanding the “reach” of their products, both in terms of market access and in adapting products to work on and with a broader range of technology platforms via application program interfaces, or APIs. Also, the fund could provide incentives for new developers to jump into the market, facilitating the creation of new ideas and competition and, ultimately, increase options and lower costs for consumers.

    6. ITI does not have any comments to offer in response to these questions.

    7. The Commission should consider joining with the U.S. Access Board, NIST and other federal agencies currently engaged in global discussions that include, or could include, accessibility-related topics or components, such as the Transatlantic Economic Council and NIST’s Standards in Trade Program, etc. The Commission should also consider establishing an Industry Advisory Board to ensure that the Commission has a direct channel from the array of commercial industry sectors and businesses that are actively engaged in global markets and promoting accessibility policies and standards.

    Finally, we would like to bring to the Commission’s attention a survey on the preferences of users of screen readers, conducted by WebAIM, an initiative of the Center for Persons with Disabilities at Utah State University. We believe that you will find it to be very useful. The survey results can be found at

    Thank you for the opportunity to submit comments. Again, ITI would welcome the opportunity to provide further details, or answer any questions that the Commission may have.

    Best regards,

    Ken J. Salaets
    Information Technology Industry Council

  7. RERC-TA says:

    From the RERC-TA:

    1. There was a lot of discussion at the roundtable about the concept of getting companies, independent software developers, consumers, government, and universities together to share best practices, understand consumer needs, and foster innovation. What are the next steps to establishing an innovation center or focus center program? Are there some specific ideas on this and more information about models we can follow?

    One of the first steps would be to figure out the mission or goals of the Center. Its design would have to be able to survive the tides of progress and successive agendas. One way to begin is to look at the needs and objectives of each of the stakeholders to be included and then craft the center or program to meet those needs.

    The FCC can then fund an entity to have the center carry out a series of events – each aimed at contributing to the goal - and each self contained and ending. For example, carrying out a study of all of what is available (and getting everyone to collaborate) once every few years is more valuable than trying to do one study and then trying to keep it accurate over time. The latter will have significant costs because products continue to evolve. It may be easier to stay in budget or track more things if the efforts are focused on tracking technology generally with snapshots over time.

    It is also suggested that the Center not try to do all these activities or studies itself but rather work with others, each time selecting a person or group that is in a good position to handle that activity or study.

    2. There were some general concerns expressed that applying regulation to broadband services and equipment might hamper innovation.

    We have found that applying accessibility regulation can actually cause one to be more creative and innovative. The real issue is that business runs on profit. We do not need regulations for things that a business does naturally because they are profitable. But when something is important and profit will not drive it, then regulations are needed: regulation is society's way of injecting the values of society – such as the need for safety, emergency access, curbing fraud – into the business equation. While disability access can be profitable (e.g., ubiquitous captions on TV is an example of something that is commonly used by everyone but would not have happened without regulation), it is often not perceived as such by industry, and therefore often will not happen without clearly enforced regulations. Also, for some types of disability that are severe or involve multiple disabilities, there is not a significant profit to be made and accessibility regulation is needed to ensure access.

    Have the processes mandated under Section 255, including as they relate to equipment and devices developed for VoIP services, hampered innovation?

    While this question is a bit hard to answer because 255 has not been enforced to any real extent (and as a consequence has been largely ignored), if one looks at products such as the iPhone, one can see a product that was made accessible without hampering its innovation or market lead at all. Great innovation was shown in creating this device and its features.

    Have the FCC’s existing captioning rules or wireless Hearing Aid Compatibility rules hampered innovation?

    We are not aware of any fewer innovations as a result of this type of regulation.

    3. What is the effect of Section 255, HAC, and Section 508 regulations on the telecom and electronic and information technology marketplace?

    This has been positive. However, if these sections were enforced to a greater degree, they would have a much greater impact. Each time that it appears that these laws might be enforced, companies tend to accelerate their accessibility efforts, add to theirr teams - and begin discussing what they can do. However, when it becomes clear that they won't be enforced, these efforts are again trimmed back. People inside the companies report the same thing. Consistency in the FCC’s approach – through the steady implementation and enforcement of its regulations works best in the long run for both sides and greatly assists those inside companies who are trying to address accessibility.

    4. The record contains a few examples of companies voluntarily making devices used for Internet access accessible to people with disabilities – in particular, the Apple I-Phone was mentioned several times at the workshop. What are some other examples of which we should be aware? What motivates companies to make their products accessible on a voluntary basis? Will companies consider accessibility issues in the design and development of their broadband products and devices on a widespread basis if there is no mandate to do so?

    Sometimes if there is a credible threat of regulation or pressure by the community, companies will respond with accessibility. But history shows that even when a company does some things voluntarily for a particular disability, it may not be enough. For example, even the 'accessible' phone that resulted from the FCC complaint was only partially accessible to people who were blind (the subject of the complaint) when it could have been made fully accessible without a single hardware change.

    5. What can the government do to attract additional capital investment to make products accessible? What can the government do to incentivize independent software designers to create innovative assistive and adaptive technologies?

    The government can offer tax incentives for accessibility features. It can also make it unprofitable not to comply (e.g. through fines and other enforcement measures).

    6. How is the development and distribution of assistive and adaptive technologies currently funded, including assistive and adaptive technologies used to access the Internet?

    In the area of information and communications technology, it is largely government funded, but most of the state distribution programs only distribute POTS equipment, not devices for use with broadband technologies.

    What specific recommendations should we make to address concerns expressed in the record about the expense of assistive and adaptive technologies?

    First, the FCC should take action to encourage the universal design of broadband products and services. The goal is to eliminate the need to pay for (unnecessary) assistive technologies (AT) to provide access where access could have been built in. The cost for incorporating universal design is nominal if it is built into the standard design (closed caption decoder capability, which is built into TV sets is a good example of this). AT should be reserved for those aspects that cannot be built in, such as specialized physical interfaces.

    Second, find ways to provide federal support to AT vendors to help lower their costs.

    Third, a public outreach campaign that raises general awareness about accessibility solutions would increase markets and help reduce costs. If people are aware that there are products available that will work for them, they will obtain them (if they can afford them). The proposed NPII would also provide accessibility solutions that would support AT where it is needed and support built-in access (via local and network services) for everyone, regardless of their ability to pay.

    7. Are there specific recommendations about the best way for the FCC to get more involved in International efforts to harmonize standards relating to accessibility?

    The TEITAC rules were carefully harmonized with international standards. The FCC should accept these as they were proposed by the advisory committee because they are the product of extensive discussion on how best to implement Section 255, and include compromises by both consumers and industry. In addition, many countries are already looking to these accessibility proposals for guidance.

  8. Guest says:

    From Elizabeth Spiers:

    After talking with Randy Pope, we believe that perhaps 4,000 deaf-blind
    people can use Braille displays, with or without a phone. The cost of a
    Braille display is around 5,000 dollars-use AFB's reference since AFB is
    very credible and you have talked to Mark Richert on this issue.

    This is only an estimate that Randy and I came up with. We don't have
    anything more exact than the general figures I gave you earlier for 1.2
    million Americans with hearing and vision loss, or the 40,000 to 70,000
    deaf-blind people that COAT had been using before that.

  9. Guest says:

    From Elizabeth Spiers:

    In many cases, [broadband provides the most efficient way for individuals who are deaf blind to access basic phone services]. Internet service has opened up a world for many deaf-blind people of all types and backgrounds. They are able to get information about what’s happening, learn about services, join listservs where they can get information about just anything, and connect with other people.

    However, there is still a sizeable number of people who do not have Internet connection. They may not have computers, or know how to use the Internet, or have the right technology to do so.

    Accessible training is sometimes an issue. Some deaf-blind people can get training on how to use a computer and its programs. However, in some cases, the training may not be specific enough (The trainer will cover some areas but not others); the training may not be long enough (usually constraints from government funding because the majority of deaf-blind people usually get triaining from VR or a local service agency for the blind (and sometimes training is short-term). Also, not all deaf-blind people receive training in a way that is accessible to them. It is hard to learn computer functions with a trainer and interpreter (receiving several different modes of information).

    As a case in point, I experienced this myself at another agency when I had to learn about a computer system the agency used to track its cases (I worked for VR in the past). I have low vision and am hard of hearing so have a lot of functional vision and hearing. I had an interpreter with me as well as the computer trainer. I could learn, but it was difficult because I had to look at the interpreter, look at the computer screen and keep looking back and forth. I learned much better if someone worked with me one on one or if I followed the computer manual. It would be even more difficult for someone who uses tactile ASL and is trying to learn computer functions on a Braille display. A lot of deaf-blind people who have basic computer skills and Braille skills often teach themselves, or consult others.

    There is an excellent listserv for deaf-blind technical users and I’ve come across some of these issues in their discussions.


    For some deaf-blind people, it would be easier to use broadband telephone service with an IP relay service or similar service and a Braille display on their computers. This is by no means a one size fit all approach, however. Some fully deaf-blind people may find it easier to use a VRS with a communication facilitator because their native language is ASL and it is easier for them to communicate and receive information in ASL (usually tactile ASL, TASL).

    So yes, the Commission would need to designate a service where deaf-blind users can use communication facilitators to interpret VRS calls.


    Here is a quick breakdown of some of the types of equipment and situations
    where deaf-blind people could have access to broadband (including all people
    with combined vision and hearing losses). This is a partial listing of
    equipment commonly used by people with both vision and hearing losses.

    Unfortunately, we cannot give exact figures of the people who will need such
    services. We can only give some very rough estimates of the number of
    deaf-blind people who need assistance.

    Statistics-Rough Estimates

    Maybe 40 percent of the deaf-blind population would have difficulty
    affording this type of equipment. If we use COAT's figures of 42,000 to
    700,000 people, this could translate to approximately 16,500 people--40
    percent of 42,000, to 280,000 (40 percent of 700,000). They may be on SSI
    or SSDI, not working, retired, or otherwise do not have assistance with
    purchasing equipment.


    Computers can mean the machines themselves, as well as the Internet, video
    relay services, internet relay services, emails, and websites.

    Computer Programs:

    People could buy programs with some of this pre-installed (for example,
    built-in screen magnification software, or built-in software that permits
    people to adjust font size and background colors on existing software

    Others may need screen enlargement programs like the ones listed below.
    People would have to buy these programs. This is only a partial list of
    some of the more commonly used programs.

    Zoomtext: A screen magnification software program, which costs about $400
    to $500.

    MAGic: Another screen magnification program is MAGic. MAGic can work with
    or without a speech recognition program. A standard program working with
    speech costs about $600. A standard program without speech costs about
    $400. From the website searches I've been doing, a standard program appears
    to be used mostly for home use, while professional programs appear to be
    used for businesses. Most of the people who will need government assistance
    will most likely use these types of programs at home.

    JAWS, available from Freedom Scientific, has standard programs available for
    $895 and professional programs available for $1.095.

    Computers with Braille displays and screen reader software: Braille
    displays usually cost about $5,000. We estimate that perhaps 4,000
    deaf-blind people may need Braille displays with their computers.

    Computers with programs like JAWS and speech recognition software--or those
    who are blind and hard of hearing and have enough hearing to use speech

    Internet Relay Services: Sometimes software for these services can be
    downloaded for free, like Nextalk. With appropriate modifications on their
    computers, deaf-blind people can use these services.

    Related Issues

    Another issue to consider is that deaf-blind people (and other people with
    disabilities) receiving services from vocational rehabilitation agencies may
    still have trouble getting the equipment they need. Many VR agencies have
    to follow a vendor process in which they may only buy equipment from
    VR-approved vendors. These vendors may easily sell computers for $1000
    while you could find the same kinds on your own for $500. Many state
    agencies (including VR) are facing budget cuts and difficulties providing
    services. Also, the waiting time can be very cumbersome and lengthy.
    Priority should be given to people who are not getting any assistance at all
    from anyone, but this is a huge issue--maybe some federal assistance can be
    invaluable here.


    VRS-TVs: are they going to be subsidized? The VRS providers will provide
    TVs, but many aren't big enough for many low vision users. We at AADB had a
    little TV from Sorenson (AADB uses Sorenson as one of our VRS providers),
    but we ended up buying a much larger TV for our needs. Maybe this is
    something that we need to address with the VRS providers, so the providers
    can provide that option. Or we need to subsidize people who need to buy
    accessible equipment.

    VRS Communication Facilitators: These are interpreters who can sit with the
    deaf-blind user (either totally deaf-blind or those who have such bad vision
    that they cannot see the TV interpreter). These are not routinely being
    provided by VRS companies, and they need to be part of the continuum of
    services that VRS provide. This is one way that fully deaf-blind people or
    deaf-blind people with very low vision who otherwise cannot see the VRS
    interpreters on TV screens can access VRS.

    This service doesn't fall within the $10 million subsidy; however, it is a
    much needed service. AADB has been advocating that VRS companies provide
    this service as part of their continuum of services.

    Pagers and cell phones: People do use broadband for cell phone calls and
    text messaging or pagers. Most are deaf or hard of hearing with low vision
    who need larger font and high contrast. Blackberries now have font up to 14
    point and have high contrast screens (e.g, yellow text against a black
    background). Some people need more than that and currently access this with
    a magnifier. People with low incomes would need assistance with broadband
    plans and also with the pagers or cell phones themselves (especially if they
    are used for emergency warning purposes).

    It is possible for people to use a cell phone with a Braille display or use
    the Deaf-Blind Communicator as a pager. Again, some would need help with
    pagers, cell phones, Braille displays, and/or broadband plans.


    FSTTY-a Braille TTY software program, often used in conjunction with a
    PacMate with a 20 cell or 40 cell display. This software permits
    deaf-blind people to make telephone calls, use the Internet, contact others
    via instant messaging, and use the device as a face to face communicator.
    In face to face communication, a Braille user can converse with a person who
    does not know sign language or Braille, and vice versa. Costs for the
    software alone are around $1,200. If it is combined with a PacMate with a
    20 cell display, it is around $5,000. If it is combined with a PacMate with
    a 40 cell display, it is around $7,000.

    Krown TTY: This is another Braille TTY. It has a 20-character Braille
    display on one side and a keyboard on the other. It costs around $6,300.

    DB Communicator: This is another device that can function as a Braille
    TTY, pager (with SMS texting capability), and face-to-face communication for
    deaf-blind people. These components are a Braille Note mPower, and a DB
    Phone which is a special cell phone with a visual display and a keyboard.
    Both are loaded with special deaf-blind software, and both can communicate
    wirelessly with each other via Bluetooth. The DBC Communicator has a
    landline connector and TTY software built in it as well, so it can function
    as a TTY. The DB Communicator costs about $8,000 for all the components

    Other Equipment Issues

    Some deaf-blind people experience declining vision and/or hearing. For
    example, a deaf-blind person who used to be able to see a small TV for VRS
    services may experience a decrease in vision and need a larger TV set. Or
    such a person may need to learn and use Braille. He or she may have been
    able to use a traditional computer, but may now need a Braille display.

    Websites: (FS TTY, JAWS, MAGic) (Krown TTY) (DB Communicator, Braille display) (Zoomtext)

    Elizabeth T. Spiers
    Director of Information Services
    American Association of the Deaf-Blind
    8630 Fenton Street, Suite 121
    Silver Spring, MD 20910
    301-495-4402 TTY/VP;
    301-495-4403 Voice
    301-495-4404 Fax

  10. Guest says:

    Testimony on Broadband Access for People with Disabilities
    Marty Exline, Director
    Missouri Assistive Technology

    As the Federal Communications Commission (FCC) and states explore the assortment of issues surrounding broadband availability, accessibility for persons with disabilities is an issue of paramount importance. Issues facing Internet consumers that the FCC is trying to address through a National Broadband Plan are magnified for persons with disabilities.


    While affordability is an issue for citizens across the board, costs are even more of an issue for Americans who have disabilities. The expenses of a computer purchase and of monthly Internet service provider fees are only part of the equation for many with disabilities. Screen reading software, alternative keyboards, pointing devices, refreshable Braille, voice recognition software, word prediction software, etc. can add hundreds or thousands of dollars to the cost of broadband access for persons with disabilities.

    Funding Options

    One of the areas being explored is the use of the Universal Service Fund toward improving broadband access. The funds have traditionally been used to improve phone access especially in rural areas and for improved access for low-income households. A portion of the funds should be devoted to improving broadband Internet access for persons with disabilities.

    Another potential funding source to provide equipment/software needed to access the Internet by persons with disabilities are telecommunications relay service funds. Forty-five states currently have telecommunication equipment distribution programs funded primarily through surcharges that fund telecommunication relay and equipment distribution programs. Most state programs have income eligibility guidelines. In only one state, Missouri, does the telecommunications equipment program provide adaptive equipment and software not only for telephone access but also for Internet access.

    Telecommunications Access Program for Internet

    Missouri’s program, Telecommunications Access Program (TAP) has two components: TAP for Telephone (TAP-T) and TAP for Internet (TAP-I). It is administered by Missouri’s Assistive Technology Act state program, Missouri Assistive Technology. Individuals with any type of disability may apply for no-cost adaptive equipment or software needed for basic Internet access. Missouri’s TAP-I program began in 2001. Over 3,000 individuals have been served through the TAP-I program to date. Over the program’s last three years, the equipment/software distributed by type are:

    Enlargement Software 35%
    Speech Output 24%
    Alternative Keyboards 22%
    Alternative Pointing Devices 10%
    Assistive Technology Accessories 7%
    Braille Display 1%

    Examples of products by type of equipment/software

    • Enlargement Software: ZoomText, MAGic
    • Speech Output: JAWS, WindowEyes
    • Alternative Keyboards: IntelliKeys, one-handed keyboards, large print keyboards, voice recognition software.
    • Alternative Pointing Devices: trackballs and joysticks, touchscreens, adaptive computer mouse, joysticks, switches, etc.
    • Assistive Technology Accessories: overlay locks, mounting systems for switches, alternative headsets for voice recognition.
    • Braille display: Focus 40

    Of the individuals served in the most recent state fiscal year, 66% had vision impairments, 19% had physical disabilities, and 15% had learning or cognition related disabilities. Annual equipment/software costs for the Internet portion of the program range from $350,000 to $425,000.

    Additional Considerations: Consumer Support

    There are state telecommunications equipment distribution programs that provide little or no consumer support in the selection, installation or training for adaptive telephone equipment. For expansion of telephone equipment distribution programs to also cover Internet-related equipment and software, cross-disability consumer support is an essential component. Offering adaptive computer hardware/software without consumer support will result in less than optimum use or non-use of the equipment/software altogether. It is essential for such programs that there be a statewide entity involved that has the expertise and ability to provide consumer support services. Many individuals applying for Internet-related equipment/software applicants will have little knowledge of issues such as:
    • What equipment/software options are available?
    • What computer system components and requirements do I need for the equipment/software selected?
    • What equipment/software is the best match to address my functional limitations?

    Depending on the devices/software provided, individuals may also need help with installation as well as some training on the use of the adaptations. Missouri’s TAP-I program surveys program recipients about their need for program services:

    Did you need assistance in selecting your equipment?
    Yes 72% No 23% No Answer 5%
    Did you request training on your equipment?
    Yes 51% No 44% No Answer 5%

    Impact of Accessible Internet Use

    The Missouri TAP-I program also surveys users on the use and impact of the program. When asked about the purpose for which they are using the Internet/e-mail, 55% said they were using it to keep in touch with friends and family; 32% were using it to make contacts with businesses; and 32% were using it to do business with the government. Other responses included taking classes on-line; researching prescription medications and prices; grocery shopping and ordering; reading on-line newspapers; and part-time self-employment to list a few.

    Clearly, Internet use is becoming a necessity for Americans in so many realms of day-to-day life. For persons with disabilities, it is a tool which, if accessible, will open a wealth of opportunities not previously available because of functional limitations. We encourage the Federal Communications Commission to incorporate a means of providing Internet access for citizens with disabilities as a central element of the National Broadband Plan.

    For More Information Contact:

    C. Marty Exline
    Missouri Assistive Technology

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Capture The Phone Numbers Using Your Camera Phone

If you have a camera and a 2D matrix code reader on your mobile phone, you can capture the FCC Phone numbers right to your phone by following these three easy steps:
Step 1: Take a photograph of one of the codes below using the camera on your mobile phone.
Step 2: Use your phone's Datamatrix or QR Code reader to decode the information on the photograph. Please note, these code readers are device specific and are available to download on the internet.
Step 3: Store the decoded address information to your phone's address book and use it with your Maps or GPS application.

Datamatrix and QR FCC Phones