below is a proposed comment I will make to the FCC. I would like you all to
review it and see if I need to make any changes before submitting it to the
agency.
-eric
---
In the matter of Amazon (and others) who seek exemption from both the 1934
communications act and the recently enacted Accessibility in telecommunications
act, I am one of the people who will be most affected by this.
Though Amazon (and others) claim to seek this exemption for every disability,
it is evidently clear that most disabilities don't need accessibility in such
devices. For instance, the deaf can read well without the use of sound, the
mobility impaired can (with only a few exceptions) manipulate the controls just
the same as most others. However, the blind cannot manipulate any of the
controls on such devices without either a tactile or audible feedback. The
claims that Amazon (and others) are making are specious on their face. As
proof, I offer the example of Apple and their various devices and software.
They have made every attempt to be as accessible as possible to every class of
disability as is possible. As a result, their equipment and software are used
by a majority of the blind and done so easily. The cost of their equipment is
comparable to that marketed by other entities that don't offer such features.
Apple is proof that designing in accessibility from the start costs very little
and gains them much in market share (as well as being profitable).
There is only 1 reason why Amazon (and others) would choose this route:
they intend to create niche market items that are so specialized as to
be useful only to one class. Like other vendors of such products, they would
increase the price well beyond the reach of most of the blind to be able to
afford. As an example: The manufacture of the Braille Sense U2 costs less than
$200 per unit to manufacture and yet the retail price exceeds $6,000 per unit
here in the US. This is largely owing to the fact that such vendors use an
income stream model where the devices are funded by the government. Under this
model, Amazon (and others) would be able to charge far higher prices and sell
them to the various Vocational Rehab Agencies. This would put the blind back
into having to justify acquiring such equipment (and most times being denied).
This cannot be allowed.
There is also one other point:
Amazon recently suffered the consequences of litigation as a result of
trying to market their inaccessible devices to students and to make such
equipment a necessary part of that course completion. This violated the
Americans with Disabilities act. Both Amazon and the institution involved were
found in violation and required to make recompense under the law. For this
reason, they should not be allowed the exemption.
On the face of it, Amazon (and others) seek the exemption so as to circumvent
the law of the land. They also claim that including such accessibility features
would be an onerous cost (which it will not given Apple Corp's example). Their
short sightedness in asking for this exemption would, in the long run, be far
more costly.
Thus, I request that you deny the application for exemption. I request this,
not only for myself, but also as a member of 3 major organizations for the
blind here in the US (the National Federation of the Blind, The American
Council of the Blind and Lion's Club International). The current estimated
population in the US that suffers Print Disabilities (such as visual
impairment, dyslexia and some other related issues) exceeds more than 50
million individuals in all population age groups. This, gentlemen, is a
non-trivial percentage of the population of the U.S. We cannot allow Amazon
(and others) to deny us the basic right to read with whatever method we can use
(be it Braille, Audio or other means not listed here).
Thank you for your consideration.
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