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Supplemental comments in the matter of broadband accessibility for people with disabilities - Workshop II: Barriers, Opportunities, and Policy Recommendations

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Filed on January 6, 2010 by:

Please cite this document as follows:

Vanderheiden, G., Fruchterman, J., Goldberg, L., Hatfield, D., Hill, E., Strauss, K.P., & Tobias, J. (Jan. 6, 2010). Before the Federal Communications Commission, supplemental comments in the matter of broadband accessibility for people with disabilities - Workshop II: Barriers, Opportunities, and Policy Recommendations, GN Docket Nos. 09-47, 09-51, 09-137. Retrieved from: http://fjallfoss.fcc.gov/ecfs/document/view?id=7020355648.

Introduction

In looking at the FCC Update on the National Broadband Plan we were gratified to see that accessibility, including the need for increased web accessibility and building accessibility into products, was reflected in the plan. However there was no specific mention of either software enhancements to the broadband infrastructure that will be needed to handle the new emerging technologies, or an affordable mechanism that will be needed to reach those currently unserved. These enhancements (often referred to as a National Public Inclusive Infrastructure in previous FCC comments) are needed (1) to enable accessibility to emerging technology environments (e.g. cloud, ubiquitous, and multicomponent-multiplatform computing); (2) to create the infrastructure to provide access to those with few resources; and (3) to provide access in a way that is simple enough for elders and others who have trouble with complexity.

This supplemental information was therefore prepared to expand upon the need to include such a provision in the nation’s broadband plan. Included is a short summary followed by more detail on the need, why this is a critical component of any broadband plan, and what it would look like.

These comments were prepared by members of a coalition of academic, industry and non-governmental organizations and individuals who support the inclusion of enhancements to our broadband infrastructure needed to enable access by people with disabilities. For more information see http://NPII.org

We urge the FCC to include specific language on systematic support for such enhancements to the broadband infrastructure when preparing its broadband plan for the nation.

Proposed Component of the Broadband Plan Dealing with Access by People with Disabilities and the Senior Citizens

All Americans should have affordable access to robust and reliable broadband products and services. Regulatory policies must promote technological neutrality, competition, investment, and innovation to ensure that broadband service providers have sufficient incentive to develop and offer such products and services. (FCC Broadband Web site)

Proposed Text for the Broadband Plan     

It is recommended that Congress allocate a sum sufficient (less than 1 percent) of the Universal Service Fund to support the development and operation of software enhancements to the nation’s broadband infrastructure that are needed to ensure that people with disabilities, senior citizens, and others who need non-standard or enhanced interfaces are able to use the broadband information and services that are being extended to other Americans. These infrastructure enhancements are needed to allow current and future accessibility providers (assistive technology (AT) vendors, mainstream information and communication technologies (ICT) companies, free and open-source developers, researchers and service providers) to create a new class of accessibility tools and services that will be needed to address the next generation cloud, ubiquitous computing and multi-platform telecommunication technologies and to extend access to those with limited resources.

These software enhancements to the broadband infrastructure would include

  1. a unified, network-based, delivery system for accessibility technologies
    • that would support built-in accessibility features, commercial AT, and new network-based services
    • that would allow anytime, anywhere accessibility to any computers or other devices users encounter and must use
    • that will work for both current technologies, and emerging cloud computing, ubiquitous computing and ‘internet of things’ environments;
  2. a secure national personal preference system
    • to make it easy for people with cognitive disabilities, seniors, and non-technically oriented users to invoke, set up, and use accessibility features they need - by making it possible for consumers to come up to a computer/mobile device and have it use a personalization system to automatically load and set up the features they need (including features from different vendors)
  3. a set of common development tools and components
    • to increase interoperability of assistive technologies
    • to facilitate and support accessibility advancements built into future operating systems, devices and services
    • to lower the development costs of accessibility features (thus reducing the costs to users, companies and governments); and
  4. a mechanism to ensure that as people acquire functional limitations, they and others working with them become aware of accessibility features and can easily determine which features (built-in and/or from different companies) would be appropriate for their needs
  5. general maintenance, management, and support of the central cloud infrastructure including hardware replacement and expansion

This national infrastructure enhancement would both supplement and facilitate the other broadband access efforts around more accessible content, built-in access features, dissemination etc.

Without this enhancement in the national infrastructure, we will see a perpetuation of today’s patchwork of accessibility programs and products that reach only a minority of Americans with disabilities and address only some of the technologies people are encountering. We will also not have the infrastructure needed to address emerging network-based technologies and, later, ubiquitous computing.

With this enhancement, we will have a way for the ecosystem of accessibility developers and providers to both transition to more powerful and cross-platform solutions and to be able to extend accessibility to people with disabilities who are currently unserved and underserved, allowing the benefits of universal service to extend to Americans with disabilities: those who need access the most, and are the most likely to not have it today.

Why Are Such Infrastructure Enhancements Needed?

The Current Situation

Accessibility lags mainstream developments and deployments

Broadband services and Web technologies are advancing at ever increasing rates, providing new technological capabilities to users at ever-lower costs. While these advances are providing striking benefits to mainstream users of ICT, the rate and complexity of the change is seriously complicating the critical role that AT developers have traditionally played in making the Internet and Web accessible to persons with disabilities. More specifically, the rate and complexity of change, coupled with the limited resources available to these developers, has resulted in AT used by people with disabilities chronically lagging behind their mainstream counterparts and usually only working with a subset of the mainstream technologies and content.

Accessibility not affordable to many

The cost for assistive technologies is often beyond the reach of those who need it, and too high for government to purchase it for all those who need it. Only the best assistive technologies will work with newer web technologies, and few people can afford them. Even those with the best technologies usually don’t have the latest version – which is needed to access the latest mainstream technologies.

Cost of keeping up to mainstream rising

The cost of keeping up with mainstream technologies reduces innovation in assistive technologies. Companies have estimated that as much as 40% of their R&D budget is spent just on keeping up with changes in mainstream technologies.

Challenge of multiplatform, multi-OS, and cloud computing

New directions in broadband technologies, including cloud computing, ubiquitous computing and the evolution toward an ‘Internet of things’ will require an already strapped AT industry to retool and re-architect their products to ensure access to these new environments. They will also require network services and capabilities that do not currently exist (but would be available through the proposed infrastructure enhancements).

Interoperability

Functioning in these new environments will require a level of interoperability between accessibility technologies and mainstream technologies – and between different accessibility technologies – that does not exist today and is not achievable except by concerted national action.

Not all disabilities addressed

The assistive technologies that now exist do not address all disabilities well. Among those populations whose needs have been least adequately served are people who are deaf-blind, and those with cognitive, language, and learning disabilities. In addition, the specific needs of senior citizens, who may have spent their entire lives away from computers and have a difficult time grasping complicated interfaces needed to access broadband services, have not been addressed.

Complexity barrier

Current assistive technologies often add, rather than reduce, complexity. As a result, people who are not technically adept have difficulty in both setting up and using many technologies. Many who need accessibility technologies never try or drop out due to the complexity. Inroads are being made, but some mechanism is needed to allow additional innovators (researchers, consumers, new enterprises) to bring ideas that will address these groups to market and to do so in a way that is more cost effective.

Awareness Lacking

Finally, but importantly, people are not aware of what is possible, see it as complicated, and do not have any easy way to determine that there is something that can help them. Even free features that are built into today’s operating systems are chronically underused because people do not know about them or how to easily access and set up the features to work for them. One of the greatest needs is to include a program that can make those who need accessibility aware that solutions exist, that many are simple to set up and use, and that they range from built-in features that extend accessibility/usability, to advanced aids for those that need them.

Need for a Paradigm Shift

The current accessibility technologies (AT) and infrastructure are not designed or able to handle the ICT environment that is rapidly developing.

Current accessibility technologies work well within the single OS environments we have been experiencing to date when used with major software programs, for those individuals for whom assistive technologies (AT) were available and affordable.

This level of access may be sufficient as long as

However all of these assumptions are being swiftly swept away.

In addition, current assistive technologies are often complex to install, maintain and use. They often add a hard-to-manage, potentially unstable link into already-complex ICT environments. Network-based solutions (combined with personal preference profiles) can provide the means to allow automatic setup of an ICT device to match users’ needs and preferences once they have identified themselves to the device (or provided their preferences without identifying themselves). Such a system could support both built-in access features and commercial AT that would automatically be invoked and configured for the user on whatever operating platform the device uses.

ICT corporations have realized the limitations of delivering ICT on a single operating system platform and have a focused effort on web-based delivery. This can be seen in a number of areas: HTML 5 now includes features only previously available on individual operating systems such as drag and drop, the ability to draw directly onto a canvas in your web page, full interoperability with assistive technology through the integration of WAI-ARIA, standardized browser APIs to access operating system features, and a broad range of standard desktop controls. These features, combined with public reusable web services, are transforming the web, once only a document delivery platform, toward being a convergence platform for applications. This converged delivery platform would also allow assistive technologies to deliver solutions on multiple platforms through a broadband infrastructure, and could leverage the new web technologies and facilitate a scalable Software as a Service (SaaS) delivery model for assistive technology. This would allow AT solutions to be delivered to users regardless of ability or operating system platform. Unfortunately, without such a public infrastructure, only large ICT corporations are able to take advantage of these new network capabilities since these same enterprises are also the ones with the financial resources to invest in the converged web platform.

The accessibility ecosystem (AT vendors, ICT companies, free and open-source developers, researchers, etc.) has been adaptive over the years in addressing new technologies as they emerge. However even at its peak, the ecosystem has been able to serve only a minority of the spectrum of people with disabilities as a whole, and access has chronically lagged behind the introduction of mainstream technologies. The current model for accessibility will not work if we need to deliver access to all, in an affordable manner, across all of the mainstream technologies and computer and mobile operating systems that people will encounter.

We need to change our paradigm, harness network technologies, and provide support to those developing and deploying accessibility technologies if we are to both make the transition to next-generation network-based technologies and to extend accessibility features to all who need them in order to access and use broadband systems and services.

The U.S. is spending billions of dollars to connect everyone to broadband, but for a large group of Americans broadband services will remain unusable (even if they are made available) unless we invest a small fraction of these funds to facilitate and support the needed paradigm shift for accessibility.

Need for a National Public Inclusive Infrastructure

The only way to provide meaningful accessibility to all who need it, across all the mainstream technologies that they will encounter, is to enhance our broadband infrastructure so that it would:

  1. enable and facilitate the development of accessibility solutions that would work in the new cloud and ubiquitous computing environments
  2. make it possible for users to invoke the access features they need on the different devices and operating systems they encounter
  1. make it simple and straightforward for consumers to invoke the features they need
  1. provide a means for new users to easily learn about technological options and features that are available to help them and to make it easy to determine which ones are right for them. (And to make all accessibility stakeholders similarly aware of these options.)
  2. make it easier and less expensive for all parties (AT vendors, mainstream companies, free and open source developers, researchers, consumers) to develop new and innovative built-in and commercial assistive technologies and to deliver them to users in a manner that will work on the wide variety of devices and operating system platforms users will encounter.
  3. make it possible for companies and organizations to offer a whole new category of assistance-on-demand services.

These components are all essential if we are to provide access to all who need it, in an affordable fashion, that is simple and straightforward enough, so that it can actually be used by everyone – including people with disabilities and those who are older who are not technically inclined.

Because of the national nature of the needed infrastructure enhancements, they can only be implemented as part of a nationally coordinated and funded effort.

These components cannot be provided by a single vendor. They need to be shared national systems that will facilitate all users and providers, and therefore should not be expected to be provided by any one provider individually, just as roads are not built by one driver or even a consortium of drivers or car manufacturers. One vendor could not afford to set up all of these components; nor is one vendor likely to trust another or a group of others to structure the components in a manner that will benefit all vendors equally (either technically or in terms of customer contact etc).

These components would reduce the cost to develop, market, and support accessibility solutions. The reduction in development costs would, in turn, reduce the cost to consumers, employers, public computing areas, and governments. As access is extended to everyone who needs it instead of the minority that is served today, the cost savings will be critical. And the cost savings and economic benefits of broad inclusion will amount to many times the cost of creating and maintaining the infrastructure.

Because we need these enhancements (and the networked-based services they would enable) in order to develop and deliver the accessibility solutions for next generation ICT, the enhancements need to be part of any broadband plan that seeks to include all Americans affordably and sustainably.

Note that these enhancements are infrastructure in nature and would not replace efforts by AT vendors, mainstream ICT companies, and free and open-source developers – quite the opposite. A rich development ecosystem based on competition to create the best accessibility features is necessary and will be facilitated, not inhibited, by the proposed infrastructure enhancements. The enhancements would reduce developers' costs, increase interoperability, broaden their reach/penetration, and enable them to offer new types of access features that would be much easier to setup and use. The infrastructure will allow current and new AT providers to focus on user needs and attractive features, rather than developing and supporting network distribution mechanisms and keeping up with all of the different technology value chains and environments coming into the market. Low volume has always reduced the adoption of AT by inflating the cost of selling and supporting each unit, which results in high prices and continued low adoption. The inclusive infrastructure could help us escape this dynamic.

As stated by the lead accessibility architect for a major IT company: "As we move into a mobile, interconnected environment we are rapidly reaching a tipping point where the static models for assistive technology licensing reach diminishing returns. Mobile devices change constantly resulting in low cost devices that change in a very short time span. This makes the cost of expensive AT prohibitive to users and also makes the development of an all-inclusive AT for that device a questionable investment. The static model does not scale. Rather, a high volume low price solution is more appropriate. What is needed is a way to deliver an AT using a Software as a Service (SaaS) model such that assistive technologies can be delivered as a cloud-based service or as a standalone application which makes use of services delivered through the NPII. In this business model AT services can be charged using a varying array of licensing means while leveraging other available assistive technologies, provided and licensed through the NPII. In short, the NPII should be considered a facilitator for more rapid deployment of assistive technologies wanting to enter the mobile arena and a means to prototype new business models for new assistive technologies. Without such an infrastructure it will be much harder for assistive technologies to enter these new markets."

What the Software Enhancements Would Look Like

  Enhancing the broadband infrastructure will allow the growing power of network-based technologies and services to be harnessed and used by accessibility technology developers (1) to provide new types of built-in and commercial assistive technologies and services; (2) to make these new technologies and services available to the people who need them on a timely basis, (i.e., as mainstream broadband technologies and services are made available to the general public); and (3) to lower the cost of both built-in and AT-based accessibility solutions.

The software enhancements to the infrastructure would include:

  1. A unified delivery mechanism to allow users to invoke access features they need on the many ICT platforms they encounter
    1. A unified system is needed to allow a person to invoke both built-in and commercial AT (from different vendors) together in a simple fashion.
    2. A system that allows use of access features across devices is needed to allow access to cloud and ubiquitous computing systems that are rapidly emerging and that may be the best approach for people with limited resources.
  2. A secure personal preference system to allow the different systems a user encounters to auto-configure themselves so the user can operate them.
    1. Without such a system, many users, such as seniors and those with cognitive disabilities, will not be able to configure the different systems they encounter, each time they use them (because it would require that they operate a complex system in order to set it into simple mode).
    2. A national system is needed because it needs to work across technologies and vendors.
    3. The system needs to be secure because it will include personal information on vulnerable populations.
    4. The personal preference system is also critical to enabling both a new level of access and ease of use, and a new generation of built-in accessibility solutions and commercial products (as well as greatly increase the use of existing access features).
    5. Special evaluation tools would allow both professionals and users to identify appropriate solutions and settings that would then be stored in this system.
  3. A mechanism for security screening of access solutions delivered through the national system
    1. To ensure that software delivered through the above systems meets basic security standards to ensure both the security of personal information and the security of the national information system.
  4. A set of tools, common code modules and broadband service support to:
    1. Increase interoperability and compatibility of different accessibility technologies
    2. Lower the cost for the development of accessibility solutions (and thus lower their costs to enterprises, consumers, and governments)
    3. Lower the costs to both AT and ICT vendors for keeping AT current with ICT advances
    4. Lower the cost for ensuring security (see #3 above),
    5. Facilitate mainstream content adaptation to the NPII
    6. Support industry efforts around interoperability and cross platform accessibility
    7. Allow new, and more types, of developers to enter the market serving new disability groups and introducing new or improved accessibility solutions
    8. Allow researchers, consumers, and those working with them to participate more directly and to have a path to make their solutions and ideas available broadly
    9. Allow a new generation of accessibility features and services, such as both network- and human-based ‘assistance on demand.’
  5. An ongoing awareness campaign to ensure that people who need accessibility features and alternate interfaces (and the many other accessibility stakeholders) are aware of and can find features that will help them
    1. For people with disabilities who are not aware of existing solutions that could help them;
    2. For current AT users who need to find new affordable solutions for accessing the new mainstream technologies they are encountering;
    3. For people as they acquire disabilities – e.g., elders, veterans, and those with accident or technology-related injuries – so that they are aware of solutions to allow them to keep accessing broadband services with as seamless a transition as possible;
    4. For enterprise ICT managers who need to be aware of accessibility solutions they could be providing for their employees and customers; and
    5. For families, special educators, clinicians, and others who often determine the technology environments that people with disabilities must deal with.

Examples

Below are some examples of some of the benefits that would result from the creation of the infrastructure enhancements discussed above.

Example 1: Students with Disabilities Attending College In Multiplatform World.

Whereas in the past educational institutions were dominated by a single operating system and standard software packages, it is increasingly common to find different courses of study and different computer labs using different hardware, different operating systems, and often custom software. With the ‘lite’ operating systems like Chrome coming online and Apple tablets coming to campus this problem will only increase yielding more platforms to make accessible and multiplying the versions of AT needed to address them all (if AT even exists for all disabilities for all platforms). The result is that those who maintain the labs have no hope of being able to install and maintain accessibility software for all disabilities for their platforms ­– they do not have the time or software or expertise needed. The result is a rising barrier for students that need specialized access software and need to use the computers labs alongside their fellow students.

The broadband infrastructure enhancements would provide a mechanism for letting the users with disabilities use any of the computers and operating systems on campus. The students could go up to any computer and, when they log in, the personal preference server would pass down the proper settings for both the computer’s built-in access features (for that operating system) and the students’ server-based AT. In this manner the need to support special AT on the individual computers for each type of student on campus is eliminated and students are not bound to particular computers or labs. Students would also have the same setup they were accustomed to from home.

Example 2: Addressing the Complexity Barrier

Imagine June who is retired, lives at home, and wants to use a computer to communicate with her grandkids, share photos, shop, and keep informed about events but the technology was always too complicated for her to use. She hears about all of these things and longs to interact with her children and grandchildren through them. The letters and other forms of communication she is used to no longer work with her family. Yet every time her children or grandchildren try to set her up – it is just too complicated for her. She no longer even tries and just feels older and more isolated.

With the infrastructure enhancements in place she could use a small device about half the size of a USB drive that she could carried on her keychain. Whenever she wanted to use a computer she would just plug it into the computer for a couple seconds and then remove it. The computer would automatically change into a simple form that would be easy for her to use. It would work on the computer her children bought for her (that she could never master) as well as other computers, like the ones at her kids' houses when she is visiting them. Once she is online with a simple interface she can use the computer and its simplified interface to connect to family and friends in a manner she can handle. She could also use it with her doctor and for health information.

Example 3: Providing Access to Those with Little or No Resources

Many people cannot afford a computer or broadband connection much less commercial assistive technologies (that can cost many times more). Some do not even have a permanent place to stay. They could use the computers at the community center and library like their peers but, like the university, these centers do not have the funding or expertise needed to set up, maintain, and keep up to date all of the different types of access software needed by people with the different types of disability.

With the infrastructure enhancements in place the different adaptations that are not part of the operating system already would be maintained in the infrastructure. Both commercial and public accessibility software would be available. People who need accommodation could just use a code, smartcard or USB device to cause almost any computer they encounter (using any operating system) to configure itself (and the network based access software) to the individual. Those who have no resources would then be using both computers and accessibility software free of charge. The access software would either be free public software or software that the library (or other access point) had contracted for for their patrons.

Because users could store their information on any of a series of free websites like Google docs (i.e. they store it in the cloud) they would be able to access all of their information from any computer in any location without their having to own any computer or access software themselves.

Example 4: Providing Access in a Cloud Computing Environment

Many companies are moving to a cloud computing environment. One advantage is the ability to access and use content and applications from any computing platform, including mobile devices and very ‘thin’ or ‘lite’ computers with minimal operating systems. A single employee may find themselves using quite different technologies during a single day as well as over time. Current assistive technologies cannot handle this because they aren’t designed run on the different types of devices and operating systems.

With the infrastructure enhancements in place those members of the staff who have disabilities would have cloud based assistive technologies that could be used across the different systems and devices in harmony with their applications.  In addition, because the solutions are in the cloud they do not need to be installed and maintained by the IT staff.   Any AT the person or company purchased would be purchased as a ‘network service’ and would therefore appear on any computer the person needed to use, without having to involve the IT department each time. Access features and/or commercial AT from different companies can also all be invoked together in a coordinated fashion. The use of a distributed cloud infrastructure may also have benefit to users with devices having limited computational power, such as some mobile devices. AT such as voice to text conversion could be handled by a cloud-based service with load balancing handled by the cloud on behalf of the user. Furthermore ATs, such as a voice command and control systems, could offload the recognition piece to best of breed voice recognition services on the cloud and focus on providing more powerful command and control features.  

Example 5: Using Infrastructure Tools to Create More Types of AT to Cover More Users

Currently there is relatively little variety in AT compared to the variety of types, degrees and combinations of disabilities. For many groups there is no good AT and they either do without or must use AT that is not optimal for their needs. For example a software developer who has dyslexia may have looked at all of the commercial AT but found that it all seems to be aimed at children or people with more severe impairments than he has. The developer may come up with a lightweight software accessibility program that is unobtrusive and meets his needs much better. But often the major vendors are not interested in it because it overlaps with their existing product line and they feel it would reduce rather than increase net sales revenue for them to take on this lighter package.

With inclusive infrastructure tools, the developer would be able to create a disseminable product much more easily – in much the same way the iPhone development environment and tools makes it easy to create disseminable iPhone apps. The infrastructure’s dissemination platform would then make it easy to distribute the new software to others with his particular type and level of disability and who also found existing AT to be too little or too much for them. The infrastructure tools and common components could lead to innovation and diversity in the accessibility field in the same way the iPhone led to diversity and innovation in the smartphone applications field.

Example 6: Using the Common Components of the Infrastructure to Reduce Costs to Stay Compatible with Mainstream Technology.

Assistive technology companies are finding that it is costing up to 40% of their R&D just keeping up and staying compatible with changes in mainstream technology. This cost is expected to rise with the influx of developers and small (mainstream ICT) companies due to the ease of product development with Web 2.0. Where there were about a half dozen major technology vendors before there will soon be hundreds that are creating tools and widgets that are appearing on websites and in cloud applications. And the smaller companies do not pay attention to access like the larger companies do. This problem is can be seen by the extensive and growing number of public service APIs now available on the web today.

The infrastructure enhancements would include common code modules that would be kept up to date with mainstream technology and made available to AT developers. This would help keep AT development costs are down and eliminate much of the extra time spent interacting with mainstream IT companies to work out problems. The infrastructure program would collaborate with IT companies to create solutions and compatible modules that can be used by all AT vendors in their proprietary products. The infrastructure program would also encourage websites and Web 2.0 developers to use components and services that are compatible with the common components – making the task of staying compatible with all these smaller mainstream developers and startups more achievable. Thus by using the common component building blocks in their AT, AT vendors would be able to stay compatible with more mainstream innovations with less investment.

Example 7: A Mainstream IT Company Wants to Release a New Web Technology and Have it Be Accessible.

In the past, if a mainstream ICT company wanted its technology to be accessible on release, it involved working for 6 months or more in advance with multiple AT companies. Even then the company could only really afford to work with a few of the leading AT companies. As a result, when their new technology is released it still would not work with many of the AT that are being used – and would usually require users to purchase the newest version of the AT it did work with.

With the infrastructure enhancement program in place, mainstream ICT companies can work to ensure compatibility with the infrastructure enhancement program’s set of common components and increase the compatibility with all of the AT that use the common components. The ICT company can then work with the few large AT companies who still do their own core work and the company will have covered the field – across disabilities. Since the common components are all open source, the ICT company can even use their own team to make the changes rather than having to pay as many AT companies to make changes in their proprietary code. Finally, since the access software distributed by the inclusive infrastructure program is all server based, AT companies and mainstream developers would immediately have access to the latest versions of AT for compatibility testing ––  and all of the users of AT (that uses the common code modules) can get the new access technology the next time they use their computer.  

Example 8: Access to Other Broadband Connected Devices in the Future

Access to computers is just part of the digital accessibility problem. Ticket machines, kiosks, and even appliances are adopting computer like interfaces that are increasingly inaccessible to people with disabilities.

As these systems become broadband enabled, the same strategies used in computers can be carried over to provide access to these new broadband devices. Public kiosk vendors will likely be among the first to adopt this, allowing people to use their preference profiles and broadband resources to make the kiosks cross-disability accessible and personalizable. Eventually any broadband networked device with a computer like interface, including appliances, thermostats, ATMs etc could allow this type of secure access. And other broadband connected devices may allow themselves to be controlled from any nearby (or personal) computer or smartphone.

Additional information and examples can be found at http://NPII.org.

Conclusion

As we move to ensure that everyone can connect to the broadband infrastructure, we need to also ensure that everyone, including people with disabilities and senior citizens will be able to actually use the information and services being delivered. Otherwise we will just shift from the haves and have-nots to the can use and can use-nots.

Because we are moving to greater and greater dependency on broadband for education, employment, health, commerce, civic participation, and even daily living, we need to be sure that everyone is able to use (not just connect to) broadband services and information. Otherwise people with disabilities, seniors, and others who require special or different interfaces – cumulatively 20% or more of the population – will not be able to access or fully participate in this new world that is evolving.

Current mechanisms and systems are only providing solutions for a fraction of those that need them, and often at very high cost – a cost that is too high for both consumers and governments to afford to bring to all users. In addition, current solutions will not work with the emerging technical directions of broadband technologies.

Broad-based access that would reach all who need it is possible – and affordable - if the accessibility infrastructure is provided. This infrastructure needs to be provided nationally because no individual company can provide a common infrastructure that would support all developers equally.

Therefore, any national plan intended to bring broadband access to all Americans should include a nationally funded component to ensure that critical infrastructure accessibility enhancements are provided. These enhancements, which would support both built-in and commercial alternative interface features, would enable persons with disabilities using different ICT systems at different times and places, to fully participate in education, employment, healthcare, commerce, civic participation and daily living. Such a national investment will be relatively small in comparison to the benefits it will enable and leverage.

Submitted by 

Gregg Vanderheiden
Director, RERC on Universal Interface and Information Technology Access, Trace R&D Center, Univ. of Wisconsin

Jim Fruchterman
President, Benetech

Larry Goldberg
Director, Carl and Ruth Shapiro Family National Center for Accessible Media at WGBH (NCAM)

Dale Hatfield
ICT Consultant, former Chief Engineer FCC

Eve Hill
Burton Blatt Institute

Karen Peltz-Strauss
Principal, KPS Consulting

Jim Tobias
President, Inclusive Technologies

The contents of these comments were developed in part with funding from the National Institute on Disability and Rehabilitation Research, U.S. Department of Education, grant number H133E080022. However, the contents do not necessarily represent the policy of the Department of Education, and you should not assume endorsement by the Federal Government.