---------- Forwarded message ----------
From: AFB DirectConnect <[email protected]>
Date: Fri, 1 Oct 2010 13:34:38 -0400
Subject: ALERT!--FCC Extends Chance, Streamlines Process, to Sound Off
on Phone Access Thru Oct 15!
To: AFB Subscriber <[email protected]>
AFB DirectConnect Letterhead
“Please Try Your Call Again!”
FCC Extends Chance to Sound Off on Phone Access:
Streamlined Comment Process Available Through October 15
For further information, contact:
Mark Richert, Esq.
Director, Public Policy, AFB
(202) 469-6833
[email protected] <mailto:[email protected]>
As previously reported, the Federal Communications Commission (FCC) is
accepting comments from all interested individuals and groups about the
current experience of people with disabilities in finding and using
mobile phones. This effort by the FCC is intended to help the Commission
have the clearest possible understanding about the relative level of
accessibility of mobile phone technology currently available in the
marketplace. The record that the FCC is building will be key in
informing future activities, including possible rulemaking.
In response to AFB’s request to extend the deadline for filing comments,
the FCC has agreed to allow comments to be filed on the record through
October 15, 2010. In addition, the FCC will accept comments that are
simply emailed to designated FCC staff rather than requiring commenters
to use the electronic comment filing system which several commenters
have found difficult to use. If you have not done so already, take ten
minutes between now and the end of day Friday, October 15, and tell the
FCC your story.
Comments of any length may be simply included in the body of an email
message and transmitted to
[email protected] <mailto:[email protected]>
or
[email protected] <mailto:[email protected]>
Commenters should include their full name, U.S. Postal Service mailing
address, and the applicable docket number, which in this instance is CG
Docket No. 10-145.
Pass this alert along to anyone you know who may be interested in
letting the FCC hear about the “real world” experience of people with
disabilities.
*Ever gone into a wireless company’s store and asked to see which phones
are accessible to customers with vision loss and been told they have no
idea what you’re talking about?
*Ever had to pay for expensive third party software just to use basic
features on your phone like contacts, caller ID and text messaging?
*Ever tried to research accessible mobile phone availability online only
to find that no information is posted or that the website of the company
you’re checking out isn’t itself accessible?
*Ever get frustrated that the inexpensive phone you have voices some
menus and functions but not others?
*Have you had to pay more for a phone or for a calling and data plan
than you otherwise would have had to pay just to obtain a phone and/or
features you could fully use?
If the answer to these and related questions is, or has ever been, yes,
you can tell the FCC your story and literally set the record straight
and counterbalance the all-too-rosy representations that major industry
groups have made to the FCC.
The following is the text of AFB’s comments submitted to the Commission
on September 13, 2010—
Comments of the
American Foundation for the Blind
Before the
Federal Communications Commission
In the matter of
CG Docket No. 10-145
Assessment of Barriers to Accessible Mobile Technology
13 September 2010
For further information, contact:
Mark Richert, Esq.
Director, Public Policy
(202) 269-6833
[email protected]
The American Foundation for the Blind (AFB) is pleased to offer these
initial comments in response to the Commission’s invitation to describe
the current experiences of individuals with disabilities regarding
telecommunications equipment and service accessibility. Founded in 1921,
AFB is the leading national nonprofit to which Helen Keller devoted more
than four decades of her extraordinary life. AFB’s mission to expand
possibilities for people with vision loss is achieved through the public
policy process, publishing landmark texts in the vision loss field, and
comprehensive information and referral to people with vision loss and
their families and friends.
AFB devotes substantial resources to the evaluation of the accessibility
of mobile technology. Additionally AFB attempts to track the market in
order to provide current information to individuals with vision los as
well as government and industry. We are pleased to provide the following
analysis of accessibility of this vitally important technology in
response to the Federal Communications Commission inquiry.
Overview
Amid the vast array of advanced mobile technology available to the
general public, the landscape of accessible mobile devices which can be
used by the nation’s blind and visually impaired citizens is bleak. To
date, only one mobile phone, Apple’s iPhone, can be used out-of-the-box
by people who are blind or visually impaired. The availability of this
single choice is restricted to only one network. Otherwise, the options
of accessible mobile devices are severely limited for consumers with
vision loss. Blind and visually impaired Americans are forced to choose
among a few mobile devices with access to only a few functions, or
compelled to buy special software that costs at least two to five times
more than the mobile device itself. For example, Mobile Speak (software
that provides speech output for cell phone menus, text messages and web
sites) costs $295. Oratio (the software application that currently
provides access to one Blackberry device) costs $449.
Rather than building in access features from the start, mobile phone
manufacturers generally rely on third-party expensive specialty software
that customers with vision loss must buy on their own on top of the
purchase of the mobile device itself. (To their credit, both AT&T and
Verizon partially subsidize the cost of such software for some of the
phones they provide.)
The following comments are organized in a manner that reflects key areas
of concern regarding accessibility of mobile technology.
Limitations of Third Party Accessibility
In order to obtain accessibility on a mobile phone, many blind and
visually impaired individuals are compelled to purchase their own third
party screen reading and magnification applications. For these
individuals the path from making the decision to use this strategy to
placing the first call can be long, difficult, and expensive.
The first obstacle which must be surmounted when using third party
accessibility applications is cost. The $299USD to $449USD price for
these applications places them beyond the reach of many blind and
visually impaired individuals who, as a group, experience staggeringly
high rates of unemployment. Even with carrier supported pricing $89USD
or $99USD still represents a price which can easily double the total
hardware startup price tag for consumers with vision loss when compared
to their sighted peers.
Even when the customer has the means to purchase a third party
accessibility solution obtaining timely and accurate information from
carriers and manufacturers is difficult or impossible. Because the
number of phones which can be made accessible by these applications is
only a small subset of all available models, and because the knowledge
of sales staff in retail locations is limited, it is very often the case
that suitable phones are overlooked and inappropriate phones are
incorrectly identified as supporting third party software.
Among the collection of phones that support third party accessibility,
important differences create additional access barriers. For example
some models of Nokia phones support only one of the two dominant screen
access packages, and vise versa. Since the software is purchased
independently from the phone a series of Hobson’s choices arise when
either the software changes or it is time to upgrade to a new phone.
AFB has identified the inaccessibility of installation as a significant
and persistent barrier for third party phone access software. Because an
intermediate program needs to be installed on a personal computer, in
order to manage the installation of the accessibility package, that
intermediate program must also be accessible. Often, if not always,
these PC applications are far from being accessible, or require
extraordinarily detailed knowledge of PC screen access technology to
manage. The alternative is to download and install the accessibility
software directly on the phone. Since the phone is inaccessible, this
alternative simply isn’t available.
Defining Accessibility
Important characteristics of mobile phone accessibility have been
identified through the development and maturation of third party
strategies. In at least one instance, Apple’s VoiceOver, for the iPhone,
these same levels of accessibility have been successfully provided by a
manufacturer. In short, in order to say that a phone, or advanced
wireless device is accessible all elements of the operating system,
which are available to the user visually must also be presented
nonvisually, or with enhanced visual access for consumers with low
vision. This includes functions associated with voice calling as well as
network based features such as messaging, e-mail and web-based features
and services. Beyond the features and functionality provided by the
manufacturer and carrier, support for third party applications must be
provided (of particular importance for the installation and use of
screen access software). Again Apple has successfully demonstrated the
practicality and effectiveness of this expectation. To a lesser, but
still important level the Android operating system has proven at least
manageable in terms of accessibility.
Lack of Accessibility Information
AFB has observed an industry-wide pattern of inconsistency and scarcity
of accurate and readily available information specifically addressing
mobile device accessibility. The web sites of the major carriers, prepay
providers and device manufacturers typically contain little if any
obvious information on the home page. Verizon is an exception to this
rule and provides a good example of well constructed and accurate
accessibility information.
More typical is the T-Mobile website, which appears to have no
accessibility information. AFB reviewed www.tmobile.com recently and was
surprised that even a key word search was unable to reveal appropriate
information of use to blind and visually impaired customers or potential
customers with respect to the accessibility of the companies’ products.
Manufactures distribute electronic manuals for both inaccessible and
accessible phones in the PDF format. This format is prone to
inaccessibility by a number of characteristics including the use of
graphic images rather than plane text words such as “Keypad,” “Send
Button”, “Enter Key” and so forth. Some carriers and manufactures
produce manuals for select phone models in alternative formats such as
Braille and Microsoft Word format. This useful service is severely
limited to only a handful of phones and is not always mentioned to
customers.
The overwhelming experience of the many blind and visually impaired
individuals with whom AFB communicates indicates that the in store
experience further exasperates the problem of lack of information. All
too often well meaning sales and technical staff are unable to provide
any meaningful information, or worse provide inaccurate information with
respect to the accessibility of the company’s products and services.
This problem is particularly pernicious when Android phones are being
considered. The confusing variety of devices and features requires very
detailed understanding that only a very few Android devices can
accommodate the limited levels of accessibility to the operating system
and its applications. This level of understanding simply is not present
among rank and file sales associates in phone stores, and as mentioned
above, the web sites which should provide the necessary technical detail
simply do not.
Little Accessibility in Basic Phones
For many individuals experiencing vision los, the specter of mastering
the complex interface of a smart phone with a screen access program or
using Apple’s VoiceOver utility is simply overwhelming, making a basic
phone the only practical choice.
To date, we are aware of only one device in this class of phones that is
fully accessible. Verizon has recently introduced the Haven, which, we
understand, provides comprehensive access to all menu items and
announces navigation and text messaging activities. Beyond this single
example available on only one carrier, AFB is not aware of any fully
accessible basic phone available from any other carrier.
A smattering of phones provide some limited voice announcements of a
limited number of features. LG includes voice output on a few of its
phones, but important information from the directory of stored contacts
can’t be accessed. In addition, we are not aware of other phones in this
category that allows full access to compose, edit and review text
messages.
The practical, real world result is that if you are blind or visually
impaired, and you want a fully accessible basic phone there is only one
phone for you, and there is only one place to get it.
Little Accessibility in Feature Phones
Between the basic phone and complex devices such as the iPhone, which
can support third party screen access software is an important and
almost completely inaccessible class of mobile device. The “feature
phone” provides network-based functions in addition to voice calling
capacity. Text-based messaging and internet browsing are the most
significant of these additional “features.”
To date only a few devices which provide accessible “feature phone”
functionality have been available. Of this small group of products,
several have been discontinued. Of the remaining examples, no device is
fully accessible to a consumer who is blind or visually impaired.
Carrier Performance
Prepay only carriers including TracFone, Virgin Mobile, Straight Talk
Wireless, Boost Mobile, and T-Mobile Prepay comprise an entire segment
of the cellular market which provides no observable or measurable
accessibility to blind or visually impaired customers. This complete
absence of any meaningful accessibility to prepay services, obtained
through this category of carriers precludes blind and visually impaired
citizens from purchasing some of the most economical phone and data
plans available. AFB views this unacceptable situation as a particularly
bitter irony since the Federally supported safelink.com, a program to
provide phones to individuals with low income appears to use TracFone,
which can not provide an accessible phone.
Focusing on the contract carriers we can observe few if any meaningful
indicators of accessible mobile devices in at least two, T-Mobile and
Sprint. With these providers some limited devices and activity to
support customers is observed, from time to time. This is not the same
as a consistent and meaningful set of outcomes which demonstrate the
on-going availability of accessible devices and information.
Verizon Wireless and AT&T have made meaningful progress in fulfilling
the promise of accessible mobile communication for individuals with
vision los. In both instances consistent efforts have produced
successful outcomes. Verizon and AT&T both subsidize the purchase of
third party software enabling individuals to use the most advanced
technology. Verizon has advanced the level of accessibility of basic
phones with the introduction of the Haven and provides a well
constructed and meaningful web site to inform customers and others about
its products and services.
AT&T provides the iPhone, the most accessible mobile device available.
The $99 price of the iPhone 3GS makes the technology more affordable
than ever.
Summary
After nearly 15 years operating under current law, AFB is forced to
report that very little meaningful accessibility has been achieved in
mobile technology. Despite the availability of a wide range of mobile
devices, available from a variety of carriers, only Verizon and AT&T
have taken significant steps to provide meaningful accessibility to
their customers with vision los.
The complete absence of accessible prepay options is a particularly
disturbing and unacceptable development.
AFB encourages the Commission to remedy this seemingly intractable
problem by vigorously enforcing the existing regulatory requirements for
both carriers and manufacturers. Only through aggressive action on the
part of the Commission will meaningful accessibility become the norm,
rather than the exception. In essence, people with vision loss are
simply looking to have access to equipment and services for which they
are currently paying full fare but which they largely cannot use. Thank
you for your leadership to change this unacceptable status quo.
You can unsubscribe at any time. To remove your name from this mailing
list, or to find out what other newsletters are available from AFB,
visit http://www.afb.org/myAFBNewsletter2.asp.
--
Timothy Clark, WTCN Owner and Maniger
http://wtcnradio.listen2myradio.com
Owner of Timothy Clark Productions
Want productions work done at low cheap prices, let us know so as we
can take care of you and your needs
Skypes, djtimothy1 is for personal use
wtcn.radio for radio station
timothyclarkofficial for productions bizness
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