[nfbwatlk] FW: [Wcb-l] Fw: [leadership] ACB Reply Comments to FCCon Cell PhoneAccessibility

[Mike Freeman]

I think ACB's comments are basically right on-target. I am a bit uneasy, 
however, at the implication that lack of cellphone accessibility constitutes 
discrmination in the legal sense. The road of "if the sighted have it, the 
blind oughtta also" is a never-ending one in that the only way one can truly 
satisfy its mandate is to regain or obtain one's sight.

That's not to say, however, that FCC shouldn't put a burr in the posterior 
of cellphone manufacturers to make their products more accessible.

Mike Freeman

----- Original Message ----- 
From: "Alco Canfield" <amcanfield at comcast.net>
To: <nfbwatlk at nfbnet.org>
Sent: Thursday, September 23, 2010 3:12 PM
Subject: [nfbwatlk] FW: [Wcb-l] Fw: [leadership] ACB Reply Comments to FCCon 
Cell PhoneAccessibility


>
>
>  _____
>
> From: wcb-l-bounces at wcbinfo.org [mailto:wcb-l-bounces at wcbinfo.org] On 
> Behalf
> Of Denise Colley
> Sent: Sunday, July 27, 2003 11:20 PM
> To: wcb list
> Subject: [Wcb-l] Fw: [leadership] ACB Reply Comments to FCC on Cell
> PhoneAccessibility
>
>
>
> ----- Original Message ----- 
> From: Eric Bridges <mailto:ebridges at acb.org>
> To: leadership at acb.org ; announce at acb.org
> Sent: Wednesday, September 22, 2010 2:13 PM
> Subject: [leadership] ACB Reply Comments to FCC on Cell Phone 
> Accessibility
>
>
> Today ACB filed reply comments concerning cell phone accessibility for
> individuals who are blind, visually impaired, and deaf-blind at the 
> Federal
> Communications Commission (FCC).
>
> Below are the comments. The deadline for reply comments is September 30.
> Please feel free to use these comments in whatever you feel appropriate. 
> The
> Federal Register notice announcing the FCC's inquiry will be sent out in 
> the
> next message. Please feel free to tell your personal stories concerning
> inaccessibility of a  cell phone you currently own, retail store 
> nightmares,
> and any other challenges you have encountered in this area.
>
>
>
> Eric
>
>
>
>
>
> American Council of the Blind
>
>
>
> State of Accessibility for Mobile Phone Devices for People Who Are Blind,
> Deaf Blind or Who Have Low Vision
>
>
>
> CG 10-145; DA 10-1324
>
>
>
> The following comments are submitted on behalf of the American Council of
> the Blind (ACB.) The ACB is a national membership organization whose 
> purpose
> is to work toward independence, security, equality of opportunity, and
> improved quality of life for all blind and visually impaired people. 
> Founded
> in 1961, ACB's members work through more than 70 state and 
> special-interest
> affiliates to improve the well-being of all blind and visually impaired
> people by: serving as a representative national organization; elevating 
> the
> social, economic and cultural levels of blind people; improving 
> educational
> and rehabilitation facilities and opportunities; cooperating with the 
> public
> and private institutions and organizations concerned with blind services;
> encouraging and assisting all people with severely impaired vision to
> develop their abilities and conducting a public education program to 
> promote
> greater understanding of blindness and the capabilities of people who are
> blind.
>
>
>
> Over the past fifteen years, mobile phone devices have revolutionized the
> way consumers interact with their environments. Starting with the most 
> basic
> phones introduced in the 1990s, today's mobile devices are capable of
> providing a remarkable number of features that go beyond their intended
> functions. The world's largest technology software and hardware
> manufacturers have worked to devise sophisticated operating systems and
> hardware systems to encompass enumerable capabilities in today's mobile
> devices. Today smartphones are capable of performing tasks that range from
> entertainment to productivity, from content creation to content 
> consumption,
> and from communications to business logistics. Indeed, many industry
> analysts believe that the miniaturization represented in mobile phones 
> will
> be capable of replacing many functions performed by today's large 
> computing
> devices.
>
>
>
> In the year 2010, therefore-with the exponential innovation in the 
> wireless
> space revolutionizing telecommunications as well as computing, it is truly
> unbelievable that only one model of cell phone provides complete built-in
> accessibility to people who are blind, deaf-blind, or visually impaired. 
> It
> is also a matter of frustration to the blind community that only a select
> few models of smart phones are even compatible with add-on text to speech
> software that is often more costly than the device itself. This little
> accessibility available to the blindness community is further restricted 
> by
> the fact that it is only available on smartphones, fueled by an 
> unfortunate
> underlying assumption that all blind people want access to smartphones. 
> This
> assumption leaves several classes of devices such as basic phones and
> devices otherwise known as feature phones without any accessibility
> features.
>
>
>
> While some progress has been made by a small number of cell phone
> manufacturers, full access to all the features that cell phones offer to 
> the
> sighted population remain largely inaccessible to individuals who are 
> blind,
> visually impaired, or deaf-blind. Access to features is available on a 
> very
> small number of phone models. This means that blind or visually impaired
> users can only receive calls on phones equipped with no speech or braille
> output. As a result, functionality such as calling other phones is
> restricted to people who have memorized telephone numbers and specific key
> sequences. Additional features such as battery status, message indicators,
> caller identification, and sending or receiving text messages (including
> emergency information that is increasingly made available via text 
> messages)
> is not available to blind or visually impaired people.
>
>
>
> Amidst this revolution represented by smartphone devices and an array of
> inexpensive mobile devices available to consumers today, it is not at all
> surprising that the ACB is compelled to view the state of accessibility of
> mobile devices as nothing less than abysmal for blind, deaf-blind, and
> visually impaired consumers. Other than minor exceptions, it is clear to 
> us
> that the nation's blind consumers have been left behind in this 
> revolution.
> We cannot help but believe that there will be further erosion unless 
> radical
> steps are taken to alter the state of mobile phone access for this
> population.
>
>
>
> While it must be acknowledged that Apple Corporation has shown nothing 
> less
> than revolutionary zeal in pursuing accessibility for consumers by making
> all aspects of its iPhone operating system fully accessible to consumers 
> who
> are blind, visually impaired, or deaf-blind at no additional cost, this
> remains is a remarkable exception. In introducing Android, Google's phone
> operating system, the company has certainly shown a willingness to look at
> accessibility for blind and visually impaired consumers; however, androids
> model of accessibility has thus far failed to produce significant progress
> in accessibility-particularly when considering the operation of 
> significant
> phone functions. This is especially true for consumers who are deaf-blind
> wishing to use phones running the Android operating system. While Apple
> remains a business leader for a model of providing accessibility as a part
> of its day-to-day business practices and Google is taking some steps 
> toward
> accessibility, it is less than what can be said for companies such as
> Microsoft, Nokia, and Research in Motion. In fact, it was recently 
> announced
> that Microsoft, in recalling its Windows phone seven operating system, was
> unable to introduce accessibility. As a direct result, mobile phones
> released by Microsoft in October of 2010 will have no accessibility 
> features
> for blind, deaf-blind, and visually impaired consumers. In fact, the
> accessibility available similar to its prior operating systems with add-on
> text to speech software will not even be possible for Windows Phone 7,
> leaving blind consumers without an option of purchasing a Windows phone 
> for
> the foreseeable future. Research in Motion, a company known for its 
> popular
> Blackberry devices, has chosen to pursue a model of providing access that
> would pass the cost of assistive technology to its blind consumers. Like
> Nokia and Microsoft, access to certain Research in Motion devices are
> available to blind and visually impaired consumers by purchasing an add-on
> text to speech software that costs in excess of USD500. The cost for
> Microsoft, Nokia, and Research in Motion's devices can be as much as 2 to 
> 5
> times the cost of the phone itself, directly affecting blind or visually
> impaired consumers or businesses, enterprises, nonprofits, or government
> entities who employ them.
>
>
> I.        Features not accessible to blind, low vision, and deaf-blind
> consumers
>
>
>
>
> As discussed above, the available mobile devices that do provide some 
> level
> of accessibility-whether or not at a significant cost, - generally do
> provide accessibility to basic functions of the phone by using speech and
> braille interfaces. However this functionality is limited to smartphones.
> The work done by the American Foundation for the Blind while testing 
> various
> cell phone features remains seminal in determining the most basic
> functionality that mobile devices must be able to convey to blind, 
> visually
> impaired, and Deaf-blind consumers. But, considering the fact that mobile
> wireless devices are much more than boxes to make phone calls, it is vital
> that they provide full and equal access to all phone functions to all
> consumers whether or not they have sensory disabilities. This 
> functionality
> includes but is not limited to the following:
>
>
>
> *         access all menus
>
> *         edit contacts
>
> *         read messages
>
> *         send and receive text messages
>
> *         read caller-ID
>
> *         determine battery status
>
> *         access the Internet including entertainment options available on
> the phone
>
> *         have access to all built-in applications that accompany the 
> phone
>
>
>
> To have access to this functionality is even more vital for deaf-blind
> consumers. As costs for smartphones and the related assistive technology
> software tend to be often prohibitive, additional viable options must be
> made available. These options do not necessarily need to come through
> technical innovation. Carrier policy and procedures can provide 
> appropriate
> equivalence. In an increasing era of technical sophistication, the
> deaf-blind population is particularly vulnerable to being left behind if
> steps are not taken to address accessibility. Solutions such as texting 
> and
> mobile access to various features by integrating braille can provide a
> significant level of independence to people who are deaf-blind.
>
>
> II.      The cost and feasibility of accessible wireless solutions
>
>
>
>
> While manufacturers of hardware and software for mobile wireless devices 
> can
> provide a better insight on challenges to achieving access, it is notable
> that ensuring access to devices is not entirely impossible to achieve. ACB
> believes that the thought of providing access is highly dependent on the
> business model chosen by the cell phone manufacturer. It is a regrettable
> fact that the cell phone industry has adopted an unsustainable business
> model that passes on the cost of providing access to the consumer. As
> clearly demonstrated by Apple, a different model is not only possible but
> should be the default for the entire industry. This model suggests that 
> the
> cost for providing access is born by the cell phone manufacturer and/or 
> the
> developer of the operating system. With hundreds of millions of cell 
> phones
> sold in the United States each year and since the number of cell phones 
> sold
> is expected to only grow, there is no justification for manufacturers to 
> not
> distribute costs for achieving access as a part of their total business
> costs. Additional justifications often heard which claim that these
> manufacturers have no expertise further fall flat when noting the fact 
> that
> the expertise does exist. In fact, such expertise happens to be outside in
> the form of companies developing screen reading and screen magnification
> solutions.
>
>
>
> In fact, it is all the more reason for ensuring that manufacturer business
> models change in favor of internal business processes of ensuring
> accessibility. External screen reader developers cannot have the 
> development
> resources nor have access to the business culture to make adequate changes
> to operating systems or other software needed in order to keep up with the
> rapid pace of development. For companies such as Microsoft, RIM, and Nokia
> who particularly rely on external screen reader manufacturers, it is 
> evident
> that accessibility to the software made available on their respective
> operating systems is less than adequate. It is further evident that, when
> accessibility is delivered, it is often done so months or years after the
> fact.
>
>
>
> However, no matter how accessibility is delivered, blind, visually 
> impaired,
> or deaf-blind consumers can no longer be expected to bear the cost of
> access. It is simply unthinkable to believe that those who need access to
> hardware and software for mobile devices are expected to pay an additional
> cost. In particular, this business model of providing access is
> unsustainable due to the fact that unemployment among this vulnerable
> population continues to be at a historic high. It is further unthinkable
> that businesses, educational institutions, nonprofits, and governmental
> entities are also expected to bear the cost of access for mobile wireless
> devices when the responsibility for providing access should be the
> manufacturers. ACB finds that the high cost for acquiring access to cell
> phones is often exacerbated by additional costs related to the need to
> change carriers to obtain best access as well as upgrade costs for the
> assistive technology solutions. Contract cancellation costs as well as 
> costs
> for upgrades to assistive technology can add hundreds of dollars to owning 
> a
> cell phone for blind users each year-all this cost to obtain the best
> access. Adequate policy and enforcement of existing laws can certainly
> ensure that blind people are not unduly penalized for their disabilities.
>
>
>
> For many devices, manufacturers can no longer make technical claims to 
> avoid
> making their products accessible. The availability of higher processing
> power for mobile devices along with increasingly smart operating systems 
> has
> changed the way mobile computing occurs. These resources can also be used 
> to
> achieve full access to today's mobile devices. As more and more
> manufacturers begin to standardize operating systems on their wireless
> devices, the technical barriers for achieving full access disappear. And,
> for devices that are unable to use the standard operating system,
> inexpensive technical solutions such as TTS chips can make manufacturing
> significantly more achievable. Furthermore, open source solutions such as
> the Liblouis braille libraries that allow software to seamlessly connect 
> the
> majority of braille devices on the market can make the lives of software
> developers and hardware manufacturers significantly easier.
>
>
>
> Not only is it vital to consider pricing and technical feasibility for
> achieving access to moderate cost cell phones, but it is also necessary to
> consider access to software made available by hardware manufacturers that
> serves as shells on standard operating systems. Software such as Senseview
> made available by HTC or other software made available by Motorola or
> Samsung on their hardware devices fails to provide adequate access.
> Therefore, not only the operating system software must be addressed.
>
>
> III.    Policy and other solutions that FCC can provide
>
>
>
>
> First and foremost, it must be made absolutely clear to all manufacturers
> and carriers that cost for providing accessibility must not be passed on 
> to
> consumers. No matter whether the manufacturer chooses to build 
> accessibility
> into mobile wireless devices or whether it chooses to use an add-on to
> deliver access, all costs for such delivery must be borne by the company.
> Indeed, it must be acknowledged that the delineation for software and
> hardware access must be made among the various parties who take on the
> manufacturing of cell phone devices. ACB certainly recognizes the fact 
> that
> the interplay between hardware and software is complex; it is, however, 
> the
> ultimate responsibility of the manufacturer to provide full access.
>
>
>
> Secondly, the Federal Communications Commission (FCC) should develop, in
> consultation with the blindness community, guidance in the form of a list 
> of
> features that blind or visually impaired persons can expect from a 
> telephone
> out of the box. As discussed above, these features would serve as a 
> minimum
> set of standard mobile wireless features that must be accessible on each
> phone. In particular, these features must be accessible on moderately
> expensive wireless devices. This minimum level of access is significant 
> not
> only for devices that a consumer obtains via contract through cell phone
> carriers, but it is important for prepaid and uncontracted phones. For
> smartphones, however, manufacturers must strive for full access to the
> device. In particular, it is important that a smartphones all built-in
> options are fully accessible; this is true of the basic functionality as
> well as applications made available to perform additional tasks.
>
>
>
> Additional policies that address disincentives for blind consumers to 
> obtain
> full access must be eradicated. Carriers who do not provide sufficient
> choices for blind, visually impaired, and deaf blind consumers to acquire
> accessible wireless devices across the spectrum of pricing options-in 
> favor
> of only smartphone options, must consider policy implications. These
> policies include costs for obtaining mobile devices, contract termination
> charges when the consumer must upgrade to a new phone to obtain the best
> available accessible options, as well as costs for upgrades to assistive
> technology software should there be any. Steps must also be taken by
> wireless carriers to inform consumers of the cell phone choices that are
> available with accessibility options.
>
>
>
> It is clear to the ACB that there is a significant gap between what a
> wireless carrier advertises and what the actual options happen to be. It 
> has
> been a well-known fact that even though some wireless carriers have 
> offered
> accessible phone choices, neither their customer service departments nor
> retail locations for those carriers are aware of the choices available to
> the consumer. Sprint, for instance, in response to this particular FCC
> notice, has indicated a number of choices that it makes available for its
> consumers who are blind or visually impaired. In its response, for 
> instance,
> Sprint note several features that can aid blind or visually impaired
> consumers. These features include dialing the phone by speaking digits.
> While this is indeed a feature that all consumers may find useful, it does
> not solve the fundamental problem inherent for a blind consumer, which is
> the ability to hear audio or tactile feedback when adding, editing, or
> deleting a contact. In addition, no where on Sprint's web site does Sprint
> provide a list of phones, allowing users to compare the features that are
> accessible for particular phones. Additionally, when visiting Sprint's
> retail shops, users have not found useful information regarding choices. 
> It
> must be noted that the problem of awareness is not limited to Sprint 
> retail
> outlets. Verizon, AT&T, and T-Mobile outlets suffer a similar lack of
> awareness. Sprint's response is unfortunately a sad reflection on what the
> carrier considers to be adequate solutions for blind consumers.
>
>
>
> The devices and solutions listed by Sprint that would meet the blindness
> community's needs are completely inadequate. If, indeed, a large carrier
> such as Sprint shows such lack of awareness for the needs of blind and
> visually impaired consumers by inadequately addressing their needs in an
> official filing to the Federal Communications Commission, one can clearly
> imagine the state of accessibility today.
>
>
>
> Deaf-blind consumers, for who access must be made available via braille, 
> the
> challenge for addressing accessibility needs not only lies at the 
> technical
> level but will heavily rely upon policy and procedural methods. For now,
> mobile wireless devices capable of supporting braille output are 
> smartphones
> equipped with screen reading software. Until this changes, the need to
> address accessibility by using financially viable methods is paramount.
> Policies that require deaf blind consumers to purchase data plans or
> hundreds of dollars for smartphones when all they require is basic
> functionality or text messaging is unduly burdensome. ACB recommends,
> therefore, that the FCC consider carrier policy implications that provide
> these disincentives.
>
>
>
> For too long, the FCC has left the problem of accessibility to mobile
> wireless devices in the hands of manufacturers and consumers. The filed
> complaints against manufacturers have not been investigated nor have any
> actions been taken against manufacturers for violating the provisions of
> section 255. Having further discussions with manufacturers is no longer
> adequate to ensure that blind, visually impaired, and deaf-blind consumers
> will have meaningful access to increasingly sophisticated devices in a
> timely manner. Policies and procedures to clarify rules as well as 
> institute
> standards will ensure that mobile devices will be fully accessible to
> consumers who require them.
>
>
>
> The FCC must take clear, unequivocal steps to allow manufacturers, 
> operating
> system developers, and carriers to understand their responsibilities when 
> it
> comes to providing access for consumers who are blind, visually impaired,
> and deaf-blind.
>
>
>
> ACB is committed to continuing our advocacy on this critical issue to 
> insure
> that our membership attains equal access to information and communication 
> in
> the mobile space.
>
>
>
> Respectfully submitted
>
> Eric Bridges
>
> Director of Advocacy and Governmental Affairs
>
> American Council of the Blind
>
> 2200 Wilson Boulevard, Suite 650
>
> Arlington, VA 22201
>
> 202-467-5081
>
> ebridges at acb.org
>
>
>
> September 22, 2010
>
>
>  _____
>
> _______________________________________________
> leadership mailing list
> leadership at acb.org
> http://www.acb.org/mailman/listinfo/leadership
>
>
>  _____
>
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