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

Alco Canfield amcanfield at comcast.net
Thu Sep 23 22:12:08 UTC 2010



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

----- 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. 





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


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


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


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


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


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


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


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


ebridges at acb.org


September 22, 2010


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