Pacific Bell 
Network
Universal Design 
Policy
 Pacific Bell's Advisory Group For People 
With Disabilities (Agpd)


THE ADVISORY GROUPS' RECOMMENDATIONS AND PACIFIC BELL'S RESPONSE

TABLE OF CONTENTS

FORWARD

EXECUTIVE SUMMARY

I. APPLYING UNIVERSAL DESIGN

II. ENHANCING CURRENT ACCESSIBILITY

III. CREATING ACCESSIBLE FUTURE PRODUCTS

INTRODUCTION

Challenging Myths-Meeting Opportunities

The Market in California

Pacific Bell's Commitment

APPLYING UNIVERSAL DESIGN

What Is Universal Design

AGPD RECOMMENDATIONS AND PACIFIC BELL'S RESPONSE

ENHANCING CURRENT ACCESSIBILITY

Pricing

AGPD RECOMMENDATIONS AND PACIFIC BELL'S RESPONSE

CREATING ACCESSIBLE FUTURE PRODUCTS

Personal Communications Services

Broadband

AGPD RECOMMENDATIONS AND PACIFIC BELL'S RESPONSE

APPENDIX

Sample Filter Questions by Disability

QUOTES FROM AGPD MEMBERS

ACKNOWLEDGMENTS

To receive additional copies of this report, please call

415-545-0215 voice

510-644-4054 TDD

PACIFIC BELL




FORWARD

June 1994

The 26 recommendations contained in this report represent a year of work by the members of Pacific Bell's Advisory Group for People with Disabilities (AGPD). On behalf of Pacific Bell I'd like to sincerely thank the members of the AGPD for their hard work, insight and patience with us.

The advisory Group had dialogues with Pacific Bell product managers and officers. The members learned about our product development process and our plans for future products. From the concerns members shared, we learned more about accessibility for people with disabilities.

The Advisory Group caused Pacific Bell managers to stretch their thinking. It also helped us acknowledge that we limit ourselves and the company's revenue potential when we do not recognize the needs of people with disabilities. While this report focuses on Pacific Bell, it is our collective hope it will receive much wider attention, and that it will inspire other companies to make their products and services more accessible.

The Advisory Group's message is one that all companies can learn from and use in their own planning. Simply stated it is,

designing in access is more cost efficient than retrofitting products later and will lead to better designed products which can give companies a competitive advantage.

The AGPD is the latest in a line of consumer advisory groups which have assisted us in recognizing the needs of our customers. I hope you find this report as informative as we have.

Thank you for your interest in the work of Pacific Bell's Advisory Group for People with Disabilities.

R. Lee

Executive Vice President




EXECUTIVE SUMMARY

The twenty-six recommendations adopted by the AGPD fall into one of three categories:

Applying Universal Design--Producing telecommunications products, services, and enhancements that can accommodate the broadest range of users possible, including people with disabilities.

Enhancing Products and Services--Re-examining current offerings in new ways to expand market penetration to people with disabilities.

Creating Accessible Future Products--Designing broadband and PCS so that both these key services are accessible to people with disabilities as soon as they are introduced.

This executive summary provides an overview of these three topics. All recommendations are built on the following assumptions.

Demographic Highlights

People with disabilities addressed in this report include deaf people and those with hearing loss, blind people and those with low vision, and people with disabilities of speech, mobility, and cognition.

Forty nine million Americans indicated during the last Census that they experienced one or more functional limitations due to disability.

A more conservative and relevant estimate indicates there are more than 5.6 million Californians who have functional limitations that somehow compromise their current use of the telephone network.

Market Segment Comparisons

Pacific Bell marketing data for 1993 indicates:

People with disabilities in California represent more total revenue to Pacific Bell than the home office market segment.

People who are blind or have vision impairments spend much more on Pacific Bell products than the general market.

People who are deaf or have mobility disabilities each generate significantly higher usage revenues than the average Pacific Bell customer.

I. APPLYING UNIVERSAL DESIGN

Background

Universal design is a concept used in the process of making architectural environments accessible to people with disabilities. It is based on two simple but important lessons:

-- It is much more cost effective to design access at the blueprint stage than to add access on later, through retrofits and reconstructions.

-- The quality of access is far superior when it is incorporated into the structural design from the beginning.

Our recommendations below encourage Pacific Bell to apply the lessons of accessibility learned within the architectural realm to the design of its own telecommunications technologies and products.

(This especially includes product design at Pacific Bell Information Systems, and also Pacific Bell Directory.)

We believe universal design is the best way for Pacific Bell to capture the smartest thinking about innovative uses for its products, and to meet customers' needs more effectively than is possible to expect from the current design process.

It also is the key for building new market awareness and penetration that translates directly to Pacific's bottom line. [See Sidebar below]

Universal Design for Telecommunications [Sidebar]

Example: Volume Amplification Control in Telephones.

An example of the benefits of designing in access to accommodate the broadest range of users from the very beginning.

When volume amplification is built into the original design or a telephone, the cost is inconsequential.

As a specialized device, incorporated after the fact, it costs about $40--an additional expense for people who are hard of hearing.

Benefits: Useful for hard-of-hearing individuals, and also for anyone using a telephone in noisy environments like airports, hotels, offices, or public phone booths.

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Electronic Curb Cuts

Those of us with disabilities think that universal design in telecommunications will serve the entire society as "electronic curb cuts." Here's what we mean:

Curb cuts at cross walks designed for people unable to negotiate steps actually assist a wide range of people besides people in wheelchairs: parents with strollers, children and messengers on bikes, shoppers with grocery carts.

Universal design in telecommunications can provide opportunities for people who cannot use the telephone network as it is currently constituted or provisioned, as well as for many others with a wide range of abilities and needs.

A prime example of a universal design applications for telecommunications is the use of redundant visual and auditory information. Many of the recommendations in this report draw on that concept.

Useful precedents for universal design are worth studying. A few other industries besides the building trades have proven that designing a product for a group with disabilities usually turns out to be an opportunity for much broader market penetration with the general public as well. [See Sidebar below]

Electronic Curb Cuts [Sidebar]

Books on Tape: First developed for the blind, audio-cassette versions of books and other printed materials have developed into a multi-million dollar industry for a mass market that includes commuters, travelers, and many seniors.

Closed Captioning: Legislation passed in 1990 requires that all television screens 13 inches or larger, sold in the U.S. after July 1993, must have built-in decoder circuitry for current closed captioning. Captioning is an important service for deaf and hearing impaired consumers, but the service is useful and appreciated by others as well--kids learning to read, adults overcoming illiteracy who practice their reading, people who use English as a second language.

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Universal Design Means New Product Filters

The early phase of developing, testing, and implementing new products at Pacific Bell is the critical place to begin incorporating concepts of universal design that consider the telecommunications needs of people with disabilities.

The current checkpoints of product development do not include the accessibility requirements of people with disabilities. Products are designed to meet a variety of other user needs, but the assessment has never been extended to include people with disabilities.

Critical questions regarding use of products or services by people with disabilities must be incorporated into the product development process at Pacific Bell if universal design is to be meaningful. It is particularly urgent to include them before introducing new services like broadband and PCS. [See Sidebar below]

Universal Design: New Uses for Broadband [Sidebar]

There are 1.5 million Californians with vision impairments who are potential customers of a number of broadband services. Designing an iterface for them can enhance the standard by which all users access videotext and other service from Pacific Bell.

To capture those benefits, Pacific must address a potential problem right up front. The user interface for broadband videotext applications must be carefully designed. The gateway designed for the broadest number of potential users will bring the greatest opportunities. That means a way must be found now--before the product is off the shelf--to create an interface that can be used by blind and visually impaired customers whose computer "screen readers" would be rendered useless by Graphic User Interface (GUI) applications, a popular current form of interface.

Designing products and applications for broader market uses today can help businesses like Pacific Bell avoid expensive retrofits--and considerably add to their competitive advantage.

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RECOMMENDATIONS

(The Pacific Bell Responses are included in Chapter I: Applying Universal Design.)

1) Incorporate universal design into the product development process from the beginning, and throughout the process.

2) Require product developers to use the resources and skills of Human Factors Engineering as a critical step in the design and development of all new products.

3) Add both staffing and training capabilities to Human Factors in order to provide the necessary expertise to product managers on functional design requirements for people with disabilities.

4) Develop practical, workable "filters" in Human Factors that can be applied at all critical phases of product development.

5) Require the appropriate leaders of product development to ensure that "filter questions" related to specific functional limitations be analyzed and answered for every new product.

6) Include people with disabilities in the beginning and test phases of all new product designs.

7) Direct vendors (CPE, network switches) to address specific issues of functional access for customers with disabilities as part of their contractual arrangements with Pacific Bell. 30)

II ENHANCING CURRENT ACCESSIBILITY

In reviewing current products and making recommendations, we understand that not every product Pacific Bell offers is applicable for every functional disability; on the other hand, some products are already accessible to certain people with disabilities.

Challenges

Today, when Pacific Bell understands the access needs of people with disabilities, it usually tries to solve them by designing exception processes, or by providing adaptive equipment funded by the Trust (the surcharge on everyone's telephone bills). But the Trust is not designed to address a number of significant barriers to people with disabilities--e.g., Coin Phones, Yellow Pages, White Page Directories, and 411.

Reliance on the Trust or exception processes as the rule of thumb is an ineffective approach--it costs the company in more ways than one. [See Sidebar]

Pacific Bell is in a position to make a profound contribution to its marketplace. Opportunities abound with new telecommunications technologies to bring network access to people with disabilities in new and useful ways. Pacific Bell's challenge is to better understand the issues and make conscious decisions to offer accessibility in its products and services.

The Extra Costs of Exception Processing [Sidebar]

Example: Manual Service.

Costs: A Customer who cannot dial his or her phone requests an operator's assistance to dial, increasing costs that the company is trying to reduce.

Example: Directory Assistance Exception

Costs: A Customer with a vision or mobility disability who repeatedly calls 411 operators free when he needs a phone number is a costly use of company resources.

Example: A visually impaired customer who calls to ask a service rep to read her monthly bill to her over the phone.

Costs: The time it takes the representative to read or repeat items on a phone bill could be spent more productively dealing with new service requests or selling products.

Ultimate costs: Discontented customers and lost market opportunities. People with disabilities resent having to ask for these services. Customers' lack of options means they are dependent on another outside resource. Company resources are not used effectively.

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Affordability

Barriers to people with disabilities are not only technical; they are also economic. The cost of equipment and services that people with disabilities must bear for day-to-day access to other people or information is often much higher than for the general population. We believe these costs (primarily for customized CPE and computers) will become less onerous only as more responsive and accessible network products and services from Pacific Bell and other telcos become more widely available to people with disabilities.

The AGPD's position on affordability is this: Pacific Bell must strive to develop products that meet the accessibility needs of people with disabilities, but must give all customers different pricing plans from which to select. People with disabilities must not themselves bear the costs required to retrofit current products to make them more accessible.

Pricing equity must also be considered when Pacific Bell offers enhancements to existing products. (Pricing recommendations are explained more fully in Chapter II: Enhancing Current Accessibility)

RECOMMENDATIONS

(Pacific Bell's Responses can be found in Chapter II.)

8) Continue the market focus toward people with disabilities so the business and product teams can understand this segment adds revenue, in addition to helping the company improve its product designs.

9) Provide printed materials in a variety of media to better meet customer needs.

Use audiotext services as a means of disseminating information.

Research other formats that would serve the information needs of people with disabilities.

Start with the phone bills.

10) Offer Directory Assistance, White Pages, and Yellow pages in different media, especially Baudot-accessible formats.

11) Promote video teleconferencing applications that create greater access for deaf, hard of hearing, and speech-impaired customers.

12) Test, develop, and promote ISDN's advanced sound quality to hard-of-hearing people.

13) Promote Priority Ringing to households with deaf and hearing customers.

14) Make the Message Center accessible to TDD users.

15) Make products for education accessible to expand the potential market to include special education.

16) Increase efforts to inform customers about the equipment lending program.

Change the name of the program to reflect a functional emphasis. The AGPD prefers the name Pacific Bell Resources for Accessibility (PBRFA).

Develop and use a comprehensive mailing list of organizations serving people with disabilities, seniors, and limited English-speaking communities.

17) Include people with disabilities in advertising and marketing campaigns.

III CREATING ACCESSIBLE FUTURE PRODUCTS

Although there are several technologies on the drawing board, it's clear that Pacific Bell is investing heavily in Personal Communications Services (PCS) and broadband. Both these important services must be accessible to people with disabilities--and designed for accessibility from the beginning.

In order for PCS to be truly accessible to all customers, both the equipment and the network will have to be developed including people with disabilities in the design plan. Pacific Bell must use its leverage with equipment manufacturers to make sure PCS products are as accessible as the network.

Access to the new array of broadband services will also be critical. Our meetings with Pacific Bell's broadband planners confirmed that importance. Employment and educational opportunities for people with disabilities will hinge on having full accessibility to many of these services.

There is also a technical issue related to future broadband developments that the AGPD considers critical; the problem of the interface; more specifically, the Graphical User Interface (GUI). It is included below among our recommendations for making broadband accessible to people with disabilities.

RECOMMENDATIONS

(Pacific Bell's Responses can be found in Chapter III.)

Personal Communications Services

18) Assign top priority to implement Voice Dialing for PCS.

19) Pacific Bell should set vendor standards for PCS equipment and network services in order to address major concerns for specific categories of disability

20) Include people with disabilities in all PCS trials.

21) Develop and market PCS as a "wayfinding" tool to assist users in determining locations, and also as an environment control device.

22) Aggressively market PCS to people with disabilities, demonstrating its advantages both inside and outside the home.

Broadband

23) Include people with disabilities in all phases of broadband trials.

24) Design redundancy in the use of interfaces for broadband products and services.

25) Allow customers to select a mode (text, audio) in which they give and receive information.

26) Establish partnerships or alliances with companies that provide (or plan to offer) information in forms accessible to people with disabilities.




INTRODUCTION

Challenging Myths--Meeting Opportunities

Our country is currently embarked on a path towards an information society of unparalleled opportunity. Of the many questions that remain to be addressed about the direction and timing of this ambitious journey, one of the most central is: Who will participate?

For citizens with disabilities, it is the critical question. Many of the important, hard-fought legislative advances that we have accomplished in the past ten years will be of little consequence if the design of telecommunications systems over the next decade ignores people with disabilities or remains inaccessible to their needs.

This report represents the final recommendations of the Pacific Bell Advisory Group for People with Disabilities (AGPD). We spent the past year questioning, fact-finding, and probing our own assumptions, as well as key managers of Pacific Bell, regarding improved and available access for people with disabilities to the new information infrastructure Pacific Bell is bringing to California.

Although the report calls for several changes in the planning and managing of business activities at Pacific Bell, it does not require sweeping or radical reforms. Our recommendations are built around a business premise we discovered to be at the heart of the company's successful adaptation to the changing realities and needs of customers in the 1990's. We believe that Pacific Bell can best meet its commitments to people with disabilities by improving what it is already doing when it develops, markets and implements services aimed toward its diverse marketplace.

In other words, the company must begin modifying its marketing and product development processes to meet the telecommunications needs of another discreet market segment that it can no longer afford to ignore. People with disabilities are an untapped market, eager for accessible network products and services. Paying attention to their needs can bring new opportunities for both the provider and customer alike. The benefits of this approach have been well documented in the company's initiatives to serve the language dependent and home office markets.

Understanding The Disability Market

The idea of disability is weighted with misconceptions in our society. To many people, disability refers to something that affects only "the unfortunate few." It may not seem unreasonable, therefore, that most marketing decisions today don't reflect the growing numbers of people with disabilities, or associate the unique needs and issues of this segment of the population to a potential source of business revenue. Unknowingly, many companies are missing key opportunities to extend their marketing influence to a significant constituency.

Although disability is not always precisely defined or easily quantified, the updated 1990 Census reveals that:

People with disabilities represent the largest "minority" group in the United States--at its most conservative estimate, 37 million individuals.

There are an additional 9 million people with work-related disabilities, making the total 47 million Americans with disabilities.

This compares with the following numbers for other segments of the American population:

28 million African-Americans

26 million adults over 55

17 million Spanish speakers in the US.

Seniors are a major component of people with disabilities. America is graying, and the older that people get, the more likely they are to develop disabilities.

In addition, the numbers are probably even higher because many people with disabilities are reluctant to identify themselves as such. The negative stigmas associated with being "disabled" are powerful ones.

The Market in California

There are two ways of looking at demographics of disability: the definition of individuals used by the Americans with Disabilities Act of 1990 (such as those with cerebral palsy, epilepsy, HIV infection, learning disabilities, etc.), and functional definitions which quantify numbers of people with specific limitations (e.g., the inability to perform tasks such as reading a newspaper or hearing a conversation over the phone).

Although functional limitation numbers are imprecise, they allow a much larger number of people with disabilities to emerge. Based on rough calculations from data gathered by the National Center for Health Statistics, more than 10 million individuals in California have one or more functional limitation.

The following table shows the approximate number of Californians with functional limitations representing each of six categories of disabilities that are pertinent to this report. The second column shows what portion of those numbers represents functional limitations that affect telephone usage--a more compelling index for telecommunications marketing and product development.

California Population with Functional Limitations Making Telephone Use Difficult

Segment: 

Functional Limitation	Individuals Whose Impairment
                                           Limits Telephone Use

Hard of Hearing: 2.3 M 957 K

Mobility: 5.5 M 2.3 M

Deaf: 216 K 216 K

Vision: 1.6 M 1.5 M

Speech: 300 K 300 K

Cognitive: 456 K 456 K

Total: 10.4 M 5.7 M

Focusing on the percentage of functional disabilities impacted by telephone usage rather than on aggregate functional data, 5.7 million people out of 33 million in California have some sort of disability that affects their use of the telephone or network services.

These figures no doubt underestimate the total number of people with disabilities in California, since the environment here is considered "disability-friendly" for many reasons: good weather (important to people with mobility problems); a network of public and private support services; a liberal political landscape; a culture that tends to be less judgmental of differences; and a newer architectural infrastructure adapted for greater accessibility.

What do these numbers mean?

Functional limitation data can help product developers at Pacific Bell begin making decisions about improving the functionality of products for a wider range of abilities.

Since people can have more than one functional disability, numbers indicating functional limitations identify the size of the need more precisely for product developers and engineers than other data.

These statistics can provide a launching place for the company to begin considering the needs of customers with disabilities.

What Do People With Disabilities Want?
We believe that telecommunications is a powerful key that can now turn in one of two directions: to help ameliorate some of the barriers to people with disabilities, or to create higher walls than ever.

Telecommunications services of the future may develop into a seamless mix of voice, graphics and videotext offerings. As things now stand, this array of new options will be of little use to people who are deaf or have hearing problems, blind or have vision limitations, or those with speech, mobility, and other kinds of disabilities. The much vaunted telecommunications revolution will mean little to people with disabilities if opportunities for jobs, or more inclusive participation in the society, are denied because of barriers designed into the new technologies.

In fact, the revolution may make things worse. What may seem like new and improved high-tech communication to most people may revive old obstacles for people with disabilities. [See Sidebar]

But one needn't project to the future to cite problems of access. For decades, people with hearing, speech, and mobility limitations have had to depend on the help of others, get by with very inadequate communication, or simply do without the ability to use the phone.

Technology: Help or Hindrance? [Sidebar]

New voice synthesis capabilities built into modified personal computers have created a radical improvement in communication for blind and visually impaired people. Much of the value of these gains may be lost, however, as on-line, screen-based information services switch from plain text to systems that include graphics (like the popular "Windows" applications). The voice synthesis systems which can "read" text out loud cannot read graphics. Unless alternatives to GUI's are made available, blind people may once again experience old barriers they thought had been removed.

New and emerging telecommunications services and products like voice processing, videotext, and those associated with automatic number identification (A.N.I) all present potential new barriers as well as the potential to be particularly useful to people with disabilities.

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Today, people with disabilities still lack admission to even the most basic telecommunications services others take for granted:

Relay services allow deaf, hard of hearing, or people with speech disabilities using a TDD to communicate with the hearing/speaking public. This service also works in reverse, allowing a hearing person without a TDD to call a TDD user. Though useful as interim strategies, these relay devices should be replaced by new technologies that can provide the privacy and ease-of-use available to everyone else.

For people with visual limitations, any screen-based telephone display can be so difficult to see it is virtually inaccessible. Information designed to appear on screen must also be designed for access in audible form.

For people with limitations of reach or dexterity, telephone keypads, keyboards, and controls/switches can be impediments preventing full access to voice and data communication.

For people with speech disabilities, there is little equipment available that allows them to have private and understandable conversations over the phone.

For people with disabilities of cognition or memory loss, complicated menus limit the usefulness of audio text, videotext, or computer system software.

In addition, until recently Number Referral for TDD users wasn't an available option--and for deaf people outside of California, it still isn't.

Finally, there is the issue of higher costs many people with disabilities have to assume in order to secure equal access to services most others take for granted. The extra equipment and services that people need for basic communication--or the enhanced services required to access information in an alternative manner--usually cost much more than what non-disabled people pay to be connected or on-line.

Pacific Bell's Commitment

Pacific Bell has lead most other businesses in supporting the rights of people with disabilities. We applaud the company's leadership efforts on Capitol Hill, specifically in regard to the language included in the proposed Brooks-Dingell legislation (HR 3626/#3636) now nearing final approval.

Specific commitments the company championed in this language:

Assurances by all the Bell companies that telecommunications employee and customer premises equipment, as well as advances in network services, will be accessible and usable by individuals with functional limitations.

These functional limitations include disabilities of hearing, vision, movement, manipulation, speech, and interpretation of information.

The only exception to the new guidelines: if the costs of making equipment or services more accessible would result in "undue burden or an adverse competitive impact."

During the last few years, especially since the passage of the Americans with Disabilities Act (1990), the business community has begun to recognize the potential of persons with disabilities as a market segment. The ADA and the Technology-Related Assistance for Individuals Act (1988) both focus on eliminating barriers to full participation by persons with disabilities in American life--not by "curing" the person with a disability, but by curing the problems in the environment (sometimes through legal remedies) which create barriers to participation.

But the ADA does not mandate accessibility in the products people with disabilities must rely upon to improve their environments. That's why the Brooks-Dingell legislation is so critical--and why Pacific Bell's support is such a watershed for people with disabilities. While this agreement from the Bell Companies is a critical first step, improvements must also be secured from the cable industry, information content providers, and other key businesses wanting to participate in the development of the country's new information infrastructure.

People with disabilities are strong supporters of the use of technology because of the dramatic results technology has made in their own lives. We know that without access to modern telecommunications technologies, we cannot participate fully in all aspects of modern life. We also know that supporting new or redesigned technology to accommodate the "fit" between our needs and those of the larger society will create new markets for industries like telecommunications.

The recommendations which follow are specific, workable goals that will improve the fit between telecommunications products and services, and people with disabilities. In adopting them, we believe Pacific Bell will discover new markets to explore, and customers whose lives will offer new insights about the use of its technology.

We intend that these recommendations should also be a wake up call to other companies and industries who must adopt strategies similar to those inaugurated by Pacific Bell if they intend to claim their own lane on the new superhighway.




APPLYING UNIVERSAL DESIGN

Universal design underscores a principal AGPD goal: producing telecommunications products and services that can accommodate the broadest range of users possible, including people with disabilities.

Just as the ADA has shown us that public buildings must be made accessible to people with disabilities, we believe now is the time to make the telecommunications revolution accessible to people with disabilities.

Any redefinition of Universal Service that includes access to the expanded possibilities of the telecommunications network must take into consideration the functional needs of potential users with disabilities. To ensure that people with disabilities will have a fair playing field, the AGPD maintains that universal design must be a critical part of the new definition of Universal Service now emerging, in addition to existing concepts of penetration and affordability.

What Is Universal Design

Architects have begun to show the way. "Instead of responding only to the minimum demands of laws which require a few special features for disabled people, it is possible to design most manufactured items and building elements to be usable by a broader range of human beings, including children, elderly people, people with disabilities, and people of different sizes." (Encyclopedia of Architecture, Design, Engineering and Construction, 1989, p. 754.)

Universal design might be thought of as "accessible" or "inclusive" design. The underlying goal is to design products or services for the fullest range of human function--taking into account the physical, sensory, cognitive, and language needs or abilities of the broadest spectrum of customers during the initial design phase. To do that, design concepts must be adopted with an understanding of how all individuals function when using a product, service, or physical environment.

We believe universal design is a way for Pacific Bell to capture the smartest thinking about innovative uses for its products, and to meet customer's needs more effectively than is possible to expect from the current design process.

What it Does (And Doesn't) Mean for Pacific Bell

In its recently published Blue Ribbon Report Building the Framework, the World Institute on Disability summarizes what amounts to the best reason for Pacific Bell to begin implementing universal design: "Striving to increase ease of use and convenience for the largest possible range of individuals will expand the potential pool of users, multiply marketability, and decrease expenditures for assistive technology. Profitability is enhanced, and cost is contained."

In other words, it offers the company the best way to harness its technology and product development efforts to reach the unmet needs of an important and large group of customers--a new market niche to carve out along the lines of current competitive strategies.

Universal design is not a euphemism for meeting social obligations to the unfortunate few. Universal design does not reduce engineering principles to the notion "one size fits all." Certain specialized devices and tailored adaptations to the "built environment" will probably always be needed.

We also recognize that our recommendations for universal design must be flexible, not monolithic. The principle does not guarantee functional accessibility for everyone. Not all telecommunications products or services can be made accessible for every person with a disability, under all circumstances. For example, there are many variables that need to be considered for the functional category "cognitive disabilities." Designing uniform telecommunications access for people in this complex group is difficult, at best.

Nevertheless, we believe that by expanding the definition of what the fullest range of human functioning amounts to--and designing with that new definition in mind--the need for special accommodations will greatly decrease.

Universal design, as a way of approaching the creation and development of new telecommunications products, may seem too abstract a concept outside the building trades. Our recommendations address specific ways to incorporate concrete universal design principles into product development at Pacific Bell.

Why the Process Needs Changing [Sidebar]

Pacific Bell Message Center--designed, tested, and implemented without considering people who are deaf or hard-of-hearing who use TDD's. As a result, all voice mail instructions to callers today are only voice prompts.

An alternative system that makes Baudot tone prompts available to hearing-impaired users who reach the Message Center was never on the drawing board. Deaf customers using TDD's have no way of knowing whether they've reached voice mail, a disconnected number, or a busy signal. In the same way, the system was never tested to determine if Baudot tones could be recorded accurately on a message Center recording. (Pacific Bell Information Services, to its credit, shared with us the proposal they are considering for a TDD-accessible Message Center.)

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Universal Design Equals New Filters.

The early phases of developing, testing, and implementing new products at Pacific Bell is the critical place to begin incorporating concepts of universal design that consider the telecommunications needs of people with disabilities. Analysis of the current process demonstrates to us a central problem that can best be summarized in four words: the filters need improving.

All ideas generated to address the needs of the telecommunications end user go through filters during the product process. This is a way of "funneling through" hundreds of product ideas and assessing factors such as:

  • market potential
  • costs versus potential revenue
  • strategic fit of the product with existing services
  • research required or available
  • testing and trial projections ...
... and many other considerations that need to be analyzed. The time constraints on this process are often critical: long enough to accommodate all the important issues, but not so long that crucial competitive momentum gets lost.

The current checkpoints of product development do not include accessibility requirements of people with disabilities. Products are designed to meet a variety of other user needs, but the assessment has never been extended to include people with disabilities. [See Sidebar]

What Filters Accomplish [Sidebar]

The kinds of filter questions we're proposing ultimately go beyond the needs of people with disabilities:

They indicate ways of developing products that offer alternative adaptations or interfaces to users who may unexpectedly develop difficulties with telecommunications products--the growing population of seniors, for example--many of whom do not want to be identified as "disabled."

These questions will also help product managers address alternative ways to make network products (like ISDN) less abstract or complex to many potential users.

Universal design will go far beyond what the present Trust subsidies do to provide access to telephone service for deaf and other people with disabilities in California.

If the concept of universal service is to be redefined for all consumers so that all benefit equally, universal design must be a critical component. The Trust has been a valid attempt to remedy the current telecommunications inequities of people with disabilities. At the same time, it is too limited a vehicle to ever address our real need for access onto the information highway.

If Pacific Bell does not include universal design in its strategic thinking now, it will contribute to the burdens placed on a limited instrument like the Trust, as well as on the ratepayers who are taxed to support it.

New Filters for Product Developers

A timely meeting took place last August between the AGPD and product developers responsible for Voice Dialing (VD). Although VD was then nearing its test-marketing phase, the product managers became convinced it was a good idea to include people with speech, vision and mobility disabilities in the product trial.

The Questions we raised were:

How will VD work for people who stutter?

What about people with other speech or cognitive disabilities?

How can the system provide better access for someone who needs to take longer-than-average time to pronounce his or her voice command?

But the larger questions addressed at that meeting point to issues beyond specific user groups. For example:

What are the parameters around which any new Pacific Bell product is designed?

Will individual customers have control over these parameters?

To cite the case of VD:

Can I (the customer) adjust the time it takes the system to accept my voice commands?

Can I program my particular needs into the system as a functional aspect of the telecommunications products I want to use--whether I have a disability or not?

(The Appendix offers more examples of questions for product designers/managers to consider in each category of disability.)

RECOMMENDATIONS AND PACIFIC BELL'S RESPONSE

1) Incorporate universal design into the product development process from the beginning, and throughout the process.

The AGPD does not believe that the incorporation of universal design into Pacific Bell product development will be a simple, one-step process, accomplished overnight. The following are suggested actions designed to introduce universal design as an intrinsic part of the product development process at Pacific Bell:

2) Require product developers to use the resources and skills of Human Factors Engineering in San Ramon as a critical step in the design and development of all new products.

3) Add both staffing and training capabilities to Human Factors in order to provide the necessary expertise to product managers on functional design requirements for people with disabilities.

4) Develop practical, workable "filters" in Human Factors that can be applied at all critical phases of product development.

Company Response to Recommendations 1-4:

We agree incorporating universal design into the entire product development process will result in better designed products for all customers and more accessible products for customers with disabilities. We welcome the challenge of breaking new ground relating universal design to telecommunications. As we reinvent Pacific Bell's culture and processes, we commit to building capability of those involved with product design and management. We believe universal design is a disciplined way of thinking that makes senses for our product process.

We expect changing the processes you identified to take time, although our work will have clear and measurable milestones. Prior to our meeting next year we will:

Develop a training course on Universal Design.

Train one member of every major product team.

Define Human Factor's role in the product process.

Develop guidelines for how to use Human Factors.

Draft principles on universal design that are useful to product design teams.

Select two products to which we can begin applying universal design principles.

Develop an initial working filter by systematically capturing questions from our experience applying universal design to the products selected.

Begin incorporating universal design principles into vendor requirements.

We have already worked with Bellcore to change its product screening process. Bellcore now includes as part of its regular assessment the impact or application of the product concept on people with disabilities and the size of the potential market.

The business made a similar change when it decided to do business in Spanish. The process of integrating Spanish early and in an appropriate manner took several years. Today, however, it's one of our fastest growing segments, responsible for 80% of Pacific Bell's new access lines in 1993. Your work has shifted our thinking. We now understand incorporating universal design will challenge us to develop more creative new product designs that will help Pacific Bell fulfill its vision of being more competitive and accessible to all Californians.

5) Require the appropriate leaders of product development to ensure that "filter questions" related to specific disabilities be analyzed and answered for every new product developed by Pacific Bell.

Company Response:

We agree accountability is important. This report and its response will help communicate that Pacific Bell's leadership expects those in the product development and management organizations to consciously consider the needs of people with disabilities. We will seek to provide the appropriate tools and guidance, such as those described above, to enable managers to fulfill this expectation.

The product development board, which will be introduced with the new product process, will give product teams go or no go decisions at key points in the process. This board will also complete the training course on universal design. Once we have a filter in place for all product teams the board will reinforce the steps which cause managers to consider the functional needs related to people with disabilities. However, it will be critical and more challenging for product teams to address the needs of people with disabilities prior to reaching the board.

6) Include people with disabilities in the beginning and test phases of all new product designs.

An effective way to involve (indirectly) customers with disabilities in the design of products that meet their needs is by developing appropriate questions for product designers that target and focus on those needs.

Consider the issue "hard of hearing." Questions that a product manager needs to think through and investigate with Human Factors might include: How does someone with a hearing loss use this product? Will it function with an amplifier or a hearing aid? Does it use audible signals that can be converted to visual ones? Will some enhancement or alternative feature of the product increase or improve the customer's usage or convenience?

(NOTE: See Appendix for preliminary filter questions relating to all functional disabilities identified in this report.)

Company Response:

We agree. It makes sense to include people with disabilities in the beginning and test phases of new product designs and it will help us incorporate universal design in the new product development process.

The Advisory Group's existence has already helped Pacific Bell understand the value of including people with disabilities in trials and research. The company will ask product development teams to make a conscious decision about including customers with disabilities. Several examples follow which demonstrate the change in the company's behavior the AGPD inspired:

Trials:

"People with Disabilities" were not involved in the initial Voice Dialing product design undertaken by either Bellcore or Pacific Bell. However, they were discussed (at length) as potential users of the service by both design teams. We have included customers with disabilities in our market trial. As of this moment, it appears that the users with disabilities are as active and in some cases more active than the non-disabled users. Post trial market research will provide the final word on customer use and opinion.

New Number Referral Services are now under consideration. The application of these services for people with disabilities has been included in the assessment of market potential since the beginning. The AGPD participated in that assessment as a focus group last year.

The Number Referral product development team will work with Human Factors Engineering in all phases of the product design and testing. If the new Number Referral Services are approved for deployment and funded by the company, technical development for TDD users will take place concurrently within the product process. Then, pending CPUC approval, the new products will be accessible and usable by TDD users at the time of product introduction.

The Electronic Publishing Group (EPG) will certainly involve people with disabilities in the design and development of its products and services. We are developing a wide range of products that will be available across a variety of delivery platforms including telephones, computers, personal digital assistants, and interactive television. Each of these delivery platforms has its own unique capability to meet the needs of people with disabilities. Because so much of our development is in the area of multimedia services, we can consider using audio, video or special keyboards to help increase products' accessibility.

Research

Pacific Bell's Marketing Research Services will educate its clients about the opportunity to include customers with disabilities. Research Services works with (Pacific Bell) clients in two ways, on project specific research, and on company wide demographic and telecommunications use research. For project research the client, considering our advice, ultimately approves the target population.

Last year, we conducted two surveys of customers with disabilities. In addition to learning valuable information we increased our awareness of and sensitivity to people with disabilities. In 1994 we will conduct a major survey for all product teams to use which will include people with disabilities as well as questions pertinent to telecommunications and disabilities.

7) Direct vendors (CPE, network switches) to address specific issues of functional access for customers with disabilities as part of their contractual arrangements with Pacific Bell.

Working with Human Factors, the company's Procurement Department needs to determine specific guidelines for manufacturers of CPE and suppliers of network equipment and software.

CPE

In very preliminary terms, those specs might include the weight of handsets or control devices that are lifted; the amount of pressure required to control wands, joysticks, or push buttons; the size of buttons on keypads; the design of raised buttons versus flat buttons on devices used to access telecommunications; the background colors or patterns on display screens; or capability for input/output ports to attach hardware such as voice synthesizers.

Network equipment

Network switch technology must also (where it makes sense) have the built-in capability to supply audio, text, and Baudot--in other words, redundancy that assures information access to the widest number of users. Until recently, Pacific Bell did not provide its Number Referral Service in Baudot (the method of communicating information to TDD's, or Telecommunications Devices for the Deaf). The network equipment did not have that capacity, so it required going to a third-party to retrofit the original design. This is precisely the sort of problem and expense that can be avoided by applying principles of universal design and establishing these design specifications for all network vendors.

Also Pacific Bell should consider commissioning an advisory body consisting of representative from the major telco companies, equipment suppliers, and network vendors, and charge it with developing universal design standards that cut across the entire industry and address the needs of people with disabilities.

Company Response:

We agree addressing specific issues of functional access through vendors also makes a great deal of sense. Our goal over the next year is to better understand the requirements which can increase access and develop principles we can incorporate into vendor requirements.

For many products, Pacific Bell purchases technology that has products (or features) designed in by the manufacturer. In these cases, it will be critical for Pacific Bell and the disability community to work with vendors early. Presently, only our joint marketing contracts identify requirements; it requires vendors to provide CPE that is hearing aid compatible. Other times Pacific Bell may simply provide the pipe and we have little to no control over how the product (content) is designed.




APPLYING UNIVERSAL DESIGN

Universal design underscores a principal AGPD goal: producing telecommunications products and services that can accommodate the broadest range of users possible, including people with disabilities.

Just as the ADA has shown us that public buildings must be made accessible to people with disabilities, we believe now is the time to make the telecommunications revolution accessible to people with disabilities.

Any redefinition of Universal Service that includes access to the expanded possibilities of the telecommunications network must take into consideration the functional needs of potential users with disabilities. To ensure that people with disabilities will have a fair playing field, the AGPD maintains that universal design must be a critical part of the new definition of Universal Service now emerging, in addition to existing concepts of penetration and affordability.

What Is Universal Design

Architects have begun to show the way. "Instead of responding only to the minimum demands of laws which require a few special features for disabled people, it is possible to design most manufactured items and building elements to be usable by a broader range of human beings, including children, elderly people, people with disabilities, and people of different sizes." (Encyclopedia of Architecture, Design, Engineering and Construction, 1989, p. 754.)

Universal design might be thought of as "accessible" or "inclusive" design. The underlying goal is to design products or services for the fullest range of human function--taking into account the physical, sensory, cognitive, and language needs or abilities of the broadest spectrum of customers during the initial design phase. To do that, design concepts must be adopted with an understanding of how all individuals function when using a product, service, or physical environment.

We believe universal design is a way for Pacific Bell to capture the smartest thinking about innovative uses for its products, and to meet customer's needs more effectively than is possible to expect from the current design process.

What it Does (And Doesn't) Mean for Pacific Bell

In its recently published Blue Ribbon Report Building the Framework, the World Institute on Disability summarizes what amounts to the best reason for Pacific Bell to begin implementing universal design: "Striving to increase ease of use and convenience for the largest possible range of individuals will expand the potential pool of users, multiply marketability, and decrease expenditures for assistive technology. Profitability is enhanced, and cost is contained."

In other words, it offers the company the best way to harness its technology and product development efforts to reach the unmet needs of an important and large group of customers--a new market niche to carve out along the lines of current competitive strategies.

Universal design is not a euphemism for meeting social obligations to the unfortunate few. Universal design does not reduce engineering principles to the notion "one size fits all." Certain specialized devices and tailored adaptations to the "built environment" will probably always be needed.

We also recognize that our recommendations for universal design must be flexible, not monolithic. The principle does not guarantee functional accessibility for everyone. Not all telecommunications products or services can be made accessible for every person with a disability, under all circumstances. For example, there are many variables that need to be considered for the functional category "cognitive disabilities." Designing uniform telecommunications access for people in this complex group is difficult, at best.

Nevertheless, we believe that by expanding the definition of what the fullest range of human functioning amounts to--and designing with that new definition in mind--the need for special accommodations will greatly decrease.

Universal design, as a way of approaching the creation and development of new telecommunications products, may seem too abstract a concept outside the building trades. Our recommendations address specific ways to incorporate concrete universal design principles into product development at Pacific Bell.

Why the Process Needs Changing [Sidebar]

Pacific Bell Message Center--designed, tested, and implemented without considering people who are deaf or hard-of-hearing who use TDD's. As a result, all voice mail instructions to callers today are only voice prompts.

An alternative system that makes Baudot tone prompts available to hearing-impaired users who reach the Message Center was never on the drawing board. Deaf customers using TDD's have no way of knowing whether they've reached voice mail, a disconnected number, or a busy signal. In the same way, the system was never tested to determine if Baudot tones could be recorded accurately on a message Center recording. (Pacific Bell Information Services, to its credit, shared with us the proposal they are considering for a TDD-accessible Message Center.)

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Universal Design Equals New Filters.

The early phases of developing, testing, and implementing new products at Pacific Bell is the critical place to begin incorporating concepts of universal design that consider the telecommunications needs of people with disabilities. Analysis of the current process demonstrates to us a central problem that can best be summarized in four words: the filters need improving.

All ideas generated to address the needs of the telecommunications end user go through filters during the product process. This is a way of "funneling through" hundreds of product ideas and assessing factors such as:

market potential

costs versus potential revenue

strategic fit of the product with existing services

research required or available

testing and trial projections ...

... and many other considerations that need to be analyzed. The time constraints on this process are often critical: long enough to accommodate all the important issues, but not so long that crucial competitive momentum gets lost.

The current checkpoints of product development do not include accessibility requirements of people with disabilities. Products are designed to meet a variety of other user needs, but the assessment has never been extended to include people with disabilities. [See Sidebar]

What Filters Accomplish [Sidebar]

The kinds of filter questions we're proposing ultimately go beyond the needs of people with disabilities:

They indicate ways of developing products that offer alternative adaptations or interfaces to users who may unexpectedly develop difficulties with telecommunications products--the growing population of seniors, for example--many of whom do not want to be identified as "disabled."

These questions will also help product managers address alternative ways to make network products (like ISDN) less abstract or complex to many potential users.

Universal design will go far beyond what the present Trust subsidies do to provide access to telephone service for deaf and other people with disabilities in California.

If the concept of universal service is to be redefined for all consumers so that all benefit equally, universal design must be a critical component. The Trust has been a valid attempt to remedy the current telecommunications inequities of people with disabilities. At the same time, it is too limited a vehicle to ever address our real need for access onto the information highway.

If Pacific Bell does not include universal design in its strategic thinking now, it will contribute to the burdens placed on a limited instrument like the Trust, as well as on the ratepayers who are taxed to support it.

New Filters for Product Developers

A timely meeting took place last August between the AGPD and product developers responsible for Voice Dialing (VD). Although VD was then nearing its test-marketing phase, the product managers became convinced it was a good idea to include people with speech, vision and mobility disabilities in the product trial.

The Questions we raised were:

How will VD work for people who stutter?

What about people with other speech or cognitive disabilities?

How can the system provide better access for someone who needs to take longer-than-average time to pronounce his or her voice command?

But the larger questions addressed at that meeting point to issues beyond specific user groups. For example:

What are the parameters around which any new Pacific Bell product is designed?

Will individual customers have control over these parameters?

To cite the case of VD:

Can I (the customer) adjust the time it takes the system to accept my voice commands?

Can I program my particular needs into the system as a functional aspect of the telecommunications products I want to use--whether I have a disability or not?

(The Appendix offers more examples of questions for product designers/managers to consider in each category of disability.)

RECOMMENDATIONS AND PACIFIC BELL'S RESPONSE

1) Incorporate universal design into the product development process from the beginning, and throughout the process.

The AGPD does not believe that the incorporation of universal design into Pacific Bell product development will be a simple, one-step process, accomplished overnight. The following are suggested actions designed to introduce universal design as an intrinsic part of the product development process at Pacific Bell: 2) Require product developers to use the resources and skills of Human Factors Engineering in San Ramon as a critical step in the design and development of all new products.
3) Add both staffing and training capabilities to Human Factors in order to provide the necessary expertise to product managers on functional design requirements for people with disabilities.
4) Develop practical, workable "filters" in Human Factors that can be applied at all critical phases of product development.

Company Response to Recommendations 1-4:

We agree incorporating universal design into the entire product development process will result in better designed products for all customers and more accessible products for customers with disabilities. We welcome the challenge of breaking new ground relating universal design to telecommunications. As we reinvent Pacific Bell's culture and processes, we commit to building capability of those involved with product design and management. We believe universal design is a disciplined way of thinking that makes senses for our product process.

We expect changing the processes you identified to take time, although our work will have clear and measurable milestones. Prior to our meeting next year we will:

Develop a training course on Universal Design.

Train one member of every major product team.

Define Human Factor's role in the product process.

Develop guidelines for how to use Human Factors.

Draft principles on universal design that are useful to product design teams.

Select two products to which we can begin applying universal design principles.

Develop an initial working filter by systematically capturing questions from our experience applying universal design to the products selected.

Begin incorporating universal design principles into vendor requirements.

We have already worked with Bellcore to change its product screening process. Bellcore now includes as part of its regular assessment the impact or application of the product concept on people with disabilities and the size of the potential market.

The business made a similar change when it decided to do business in Spanish. The process of integrating Spanish early and in an appropriate manner took several years. Today, however, it's one of our fastest growing segments, responsible for 80% of Pacific Bell's new access lines in 1993. Your work has shifted our thinking. We now understand incorporating universal design will challenge us to develop more creative new product designs that will help Pacific Bell fulfill its vision of being more competitive and accessible to all Californians.

5) Require the appropriate leaders of product development to ensure that "filter questions" related to specific disabilities be analyzed and answered for every new product developed by Pacific Bell.

Company Response:

We agree accountability is important. This report and its response will help communicate that Pacific Bell's leadership expects those in the product development and management organizations to consciously consider the needs of people with disabilities. We will seek to provide the appropriate tools and guidance, such as those described above, to enable managers to fulfill this expectation.

The product development board, which will be introduced with the new product process, will give product teams go or no go decisions at key points in the process. This board will also complete the training course on universal design. Once we have a filter in place for all product teams the board will reinforce the steps which cause managers to consider the functional needs related to people with disabilities. However, it will be critical and more challenging for product teams to address the needs of people with disabilities prior to reaching the board.

6) Include people with disabilities in the beginning and test phases of all new product designs.

An effective way to involve (indirectly) customers with disabilities in the design of products that meet their needs is by developing appropriate questions for product designers that target and focus on those needs.

Consider the issue "hard of hearing." Questions that a product manager needs to think through and investigate with Human Factors might include: How does someone with a hearing loss use this product? Will it function with an amplifier or a hearing aid? Does it use audible signals that can be converted to visual ones? Will some enhancement or alternative feature of the product increase or improve the customer's usage or convenience?

(NOTE: See Appendix for preliminary filter questions relating to all functional disabilities identified in this report.)

Company Response:

We agree. It makes sense to include people with disabilities in the beginning and test phases of new product designs and it will help us incorporate universal design in the new product development process.

The Advisory Group's existence has already helped Pacific Bell understand the value of including people with disabilities in trials and research. The company will ask product development teams to make a conscious decision about including customers with disabilities. Several examples follow which demonstrate the change in the company's behavior the AGPD inspired:

Trials:

"People with Disabilities" were not involved in the initial Voice Dialing product design undertaken by either Bellcore or Pacific Bell. However, they were discussed (at length) as potential users of the service by both design teams. We have included customers with disabilities in our market trial. As of this moment, it appears that the users with disabilities are as active and in some cases more active than the non-disabled users. Post trial market research will provide the final word on customer use and opinion.

New Number Referral Services are now under consideration. The application of these services for people with disabilities has been included in the assessment of market potential since the beginning. The AGPD participated in that assessment as a focus group last year.

The Number Referral product development team will work with Human Factors Engineering in all phases of the product design and testing. If the new Number Referral Services are approved for deployment and funded by the company, technical development for TDD users will take place concurrently within the product process. Then, pending CPUC approval, the new products will be accessible and usable by TDD users at the time of product introduction.

The Electronic Publishing Group (EPG) will certainly involve people with disabilities in the design and development of its products and services. We are developing a wide range of products that will be available across a variety of delivery platforms including telephones, computers, personal digital assistants, and interactive television. Each of these delivery platforms has its own unique capability to meet the needs of people with disabilities. Because so much of our development is in the area of multimedia services, we can consider using audio, video or special keyboards to help increase products' accessibility.

Research

Pacific Bell's Marketing Research Services will educate its clients about the opportunity to include customers with disabilities. Research Services works with (Pacific Bell) clients in two ways, on project specific research, and on company wide demographic and telecommunications use research. For project research the client, considering our advice, ultimately approves the target population.

Last year, we conducted two surveys of customers with disabilities. In addition to learning valuable information we increased our awareness of and sensitivity to people with disabilities. In 1994 we will conduct a major survey for all product teams to use which will include people with disabilities as well as questions pertinent to telecommunications and disabilities.

7) Direct vendors (CPE, network switches) to address specific issues of functional access for customers with disabilities as part of their contractual arrangements with Pacific Bell.

Working with Human Factors, the company's Procurement Department needs to determine specific guidelines for manufacturers of CPE and suppliers of network equipment and software.

CPE

In very preliminary terms, those specs might include the weight of handsets or control devices that are lifted; the amount of pressure required to control wands, joysticks, or push buttons; the size of buttons on keypads; the design of raised buttons versus flat buttons on devices used to access telecommunications; the background colors or patterns on display screens; or capability for input/output ports to attach hardware such as voice synthesizers.

Network equipment

Network switch technology must also (where it makes sense) have the built-in capability to supply audio, text, and Baudot--in other words, redundancy that assures information access to the widest number of users. Until recently, Pacific Bell did not provide its Number Referral Service in Baudot (the method of communicating information to TDD's, or Telecommunications Devices for the Deaf). The network equipment did not have that capacity, so it required going to a third-party to retrofit the original design. This is precisely the sort of problem and expense that can be avoided by applying principles of universal design and establishing these design specifications for all network vendors.

Also Pacific Bell should consider commissioning an advisory body consisting of representative from the major telco companies, equipment suppliers, and network vendors, and charge it with developing universal design standards that cut across the entire industry and address the needs of people with disabilities.

Company Response:

We agree addressing specific issues of functional access through vendors also makes a great deal of sense. Our goal over the next year is to better understand the requirements which can increase access and develop principles we can incorporate into vendor requirements.

For many products, Pacific Bell purchases technology that has products (or features) designed in by the manufacturer. In these cases, it will be critical for Pacific Bell and the disability community to work with vendors early. Presently, only our joint marketing contracts identify requirements; it requires vendors to provide CPE that is hearing aid compatible. Other times Pacific Bell may simply provide the pipe and we have little to no control over how the product (content) is designed.




ENHANCING CURRENT ACCESSIBILITY

Telecommunications products on the market today were not developed to meet the functional needs of people with disabilities. The AGPD recognizes several opportunities for Pacific Bell to reverse that omission and begin marketing existing products and services to this underserved market.

The time to do that is now. The 1980's was a decade of significant policy action in the realm of disability and telecommunications access. As an example, California took the lead in removing what has been the most difficult barrier facing deaf people--making the network more accessible through a 24-hour professional relay service. All other states now provide similar services as a result of the Americans with Disabilities Act signed in 1990.

In California the concept of POTS is beginning to lose meaning, and the concept of Universal Service is undergoing revisions driven by new technology. We consider the timing of that shift a new opportunity for people with disabilities. As the melding of computers and telecommunications intensifies, the telecommunications industry has become a testbed for hundreds of innovations that could benefit people with disabilities.

The potential to create new opportunities cuts both ways. At a time of mounting competitive urgency, leveraging its products and technology to meet the needs of consumers with various functional disabilities can bring new market share to Pacific Bell.

In our recommendations (below), we offer ideas to encourage Pacific Bell to review its current offering in new ways that might better serve all its customers, including people with disabilities.

Pricing

Barriers to people with disabilities are not only technical; they are also economic. The cost of equipment and services that people with disabilities must bear for day-to-day access to other people or information (primarily for customized CPE and computers) is often much higher than for the general population.

The AGPD understands that in order to justify offering products and services in an increasingly competitive market, Pacific Bell must have a sound basis for expecting a reasonable return on investment, as well as knowing the target market's willingness and ability to choose a product offering and pay a reasonable fee.

The AGPD's position on affordability is this: Pacific Bell must strive to develop products that meet the accessibility needs of people with disabilities, but must give all customers different pricing plans from which to select.

Two Principles on Pricing

The AGPD recommends adoption of the following pricing principles concerning products/services for people with disabilities.

1) If a company has to retrofit a current product to make it accessible, then the company should not pass on its costs exclusively to customers with disabilities.

2) When a product is available in alternate formats at varying prices, the company must provide customers with disabilities the lowest price for the format that is accessible to people with the particular disability--even if that format has a higher price to other customers. [See Sidebar]

Pricing Options: Practical Examples [Sidebar]

Let's assume Pacific offers 411 information in alternate media with the following prices: printed Directory (free), live operator (nominal charge), audiotext (higher charge), and videotext (highest charge). Here's how different pricing options might apply:

Blind or other customers with vision impairments should not be charged for using the live operator since the printed Directory is inaccessible to them.

The blind customer would be charged for the audiotext option.

A deaf customer should be charged for any of the enhanced options since the printed directory is an accessible form of information.

If the company agrees to offer direct TDD access to 411, then it could not charge for the first three calls (the same pricing arrangement for hearing customers calling 411).

Enhanced Yellow Pages

Pacific Bell Directory could offer a higher pricing scheme to both hearing and deaf customers for access to enhanced delivery of Yellow Pages information.

Pacific Bell Directory could also charge deaf customers for direct TDD-accessible Yellow Pages information if hearing customers were charged for calling a live operator to get Yellow Pages information.

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RECOMMENDATIONS AND PACIFIC BELL'S RESPONSE

8) Continue the market focus toward people with disabilities so the business and product teams can understand this segment adds revenue, in addition to helping the company improve its product designs.

Telecommunications technology can help level the playing field for people with disabilities. We congratulate Pacific Bell for its foresight in viewing people with disabilities as a viable market. The AGPD believes it will happen sooner if the company understands people with disabilities can also add revenue. We have reviewed some of the early data on population and revenue, its clear there's a market. We are confident Pacific Bell will balance its need to make money with its public trust commitment to provide universal access to all Californians.

Company Response:

We agree the business needs to view people with disabilities as a market. The company chartered a Market Team to work with product teams and develop a market plan. The team works with internal groups to increase the business' knowledge of the needs of customers with disabilities. The business will issue the market plan in 1994. The plan will provide data on the market size and identify opportunities and strategies for Pacific Bell to pursue.

9) Provide printed materials in a variety of media to better meet customer needs.

The AGPD wants Pacific to give customers a choice of media for the printed material they receive. This includes bills, information brochures, customer instructions, and marketing materials. While the company has made notable efforts in the past to improve the readability of its bills and printed materials for the general public, it now needs to focus on ways to improve the presentation and delivery of these materials for people with disabilities. Much of the information Pacific Bell supplies simply is not accessible in its current format. Specific action steps follow:

Use audiotext services as a means of disseminating information.

Audiotext is especially helpful for customers with vision impairments and certain learning disabilities (e.g., dyslexia). Pacific Bell can learn from a number of support organizations for the blind, whose expertise includes using a "tone indexing" format in recorded messages, which makes audio information easier to comprehend and use.

Audiotext systems used by Pacific Bell could:

Provide a 24-hour menu of information that would free up operators and service reps.

Make bills more comprehensible to any customer by utilizing "tone indexing" (as done by Recording for the Blind) to help the listener find specific parts of the bill.

Provide a thorough description of new product options and special promotions.

Company Response:

Pacific Bell now uses an audiotext system to communicate important information to its customers. 1-800-2-inform provides

time-sensitive information about topics that are useful for customers. The system was introduced during the past year and can be accessed 24 hours a day, toll free, from any touch-tone phone in California.

It's a menu-driven application, unlike a recorded book which is a sequential application. Customers, visually impaired or not, simply press the buttons on their touch-tone phone to hear specific information. Tone indexing would not work with the menu driven applications.

Recent 1-800-2-inform subjects have been:

Inside Wire service options

Lifeline service

Preventing toll fraud

Safety tips for kids

714/909 area code split

Telecommuting

We offer a 1-800-2-inform for Spanish, Vietnamese, Cantonese, Mandarin and Korean-speaking customers in their native languages, as well as a line for TDD access (1-800-995-8213).

Bill Inserts

Each bill insert is sent to the Telephone Pioneers, our employee volunteer organization, which enters the information on a computer bulletin board. Subscribers throughout the state access the information by calling 415-864-6430.

Research other formats that would serve the information needs of people with disabilities.

Other media which customers may want includes information on disk, in Braille, or in large print (14-18 point). Pacific Bell must research and decide which brochures and materials lend themselves to different formats for people with different disabilities, and make them available to customers.

Company Response:

Pacific Bell will review its residential collateral over the next year to determine when alternate formats, mainly large print, would better meet the needs of the customers and the business.

On any research activity having to do with customer communications, Marketing Research Services will remind project managers of this market segment and suggest that alternative media may be appropriate to consider in order to serve our entire customer base.

Start with the phone bill.

The monthly telephone bill should be the company's first priority. Make it available in alternate formats. For example large print bill would assist low vision customers (about 1M) and help Pacific Bell distinguish itself in the market place. Pacific would save a considerable sum if it could issue customer's bills on disk instead of mailing several pages of paper in an envelope. A disk would provide a more accessible format for customers who have computer "screen readers" that translate text to voice (as do many who are blind or visually impaired). This could also be a good "preview" or trial of the viability of similar videotext services for the general market.

Company Response:

Currently the Pacific Bell phone bill for residential customers is available as a standard print bill. There is a service offered to business customers that provides the bill on a computer disk. This product is not designed for residential customers and carries an additional charge.

Pacific Bell has just completed a feasibility analysis for the large print bill. We have begun development and anticipate a product will be available within a year.

Pacific Bell is also planning to offer the bill in a variety of media to business and residence customers. When approved, customers will have a choice of media in which to receive the first copy of their monthly bill (e.g., standard print, computer disk) at no charge. The current timeline calls for offering the bill in any legal media in the 1995-1996 time frame.

10) Offer Directory Assistance, White Pages, and Yellow Pages in different media, especially Baudot-accessible formats.

This is an expansion of the recommendation above. We know that Pacific Bell and Pacific Bell Directory regard these products as essential services, and will do everything possible to maintain and build marketshare through the application of new technologies. Many would pay extra to use alternate media that offered solutions to our information obstacles. Making these services more accessible to people with disabilities in alternate formats--videotext, audiotext, and fax--would also provide electronic curb cut "tests" for a much wider marketplace.

TDD access to 411 Directory Assistance should be a top priority. Today the deaf community must dial a ten-digit number to access AT&T's Operator Services for the Deaf, who in turn calls the 411 or long distance operator in the appropriate area code location. It's cumbersome for TDD users and costly for all ratepayers.

Company Response:

Directory Assistance (DA) and White Pages

We currently provide a directory assistance exemption to customers who are unable to see or manipulate the White Pages. Customer must provide Pacific Bell with certification of their disability to receive the exemption. Today, Pacific bell cannot technically provide customers direct electronic access (e.g. PC's) to the DA database. When Pacific Bell replaces the existing retrieval system and permits external access, we will work to make the new retrieval system TDD accessible. However, the single line display on TDD terminals may be a barrier to locating common names listings (e.g. Bob Smith) in the DA database.

Yellow Pages

The mission of the Electronic Publishing Group (EPG) is to develop interactive shopping and information products across a variety of delivery platforms ranging from the telephone to the computer to interactive television. Our objective from the start has been to develop a fundamental product and database that meets the needs of our consumers and advertisers and to deliver it across as many platforms as make sense for that product. It is our mission to do this and, therefore, by design we meet the recommendation.

We are actively developing such shopping and information services in two ways. Through our recently announced joint venture with the LA Times, we will be developing a broad based shopping network that assists individuals in finding the businesses, products and services they need through the assistance of a live shopping consultant delivering information over the telephone. In addition, we will be pursuing additional products delivered in an on-line environment. Outside of the venture, we will be developing interactive shopping malls that can be accessed through interactive television. In development, and as these products gain acceptance in the marketplace, we commit to considering their ability to help meet the needs of people with disabilities.

11) Promote video teleconferencing applications that create greater access for deaf, hard of hearing, and speech-impaired customers.

Today, sign language interpreters, who are hired to be a link between deaf and hearing people, often get more money for travel time to and from an assignment than they earn for actually performing their job. (Interpreting agencies pay an average $40 per hour.) The shortage of interpreters in most counties in California also means that it is difficult to schedule the service on short notice.

Video teleconferencing services could fill the gap. Teleconferencing can provide more efficient and available American Sign Language interpreting to a wide range of current users--schools and community colleges, universities, hospitals, public gathering, and many other institutions.

For example, colleges and universities can hire an interpreter in one location and distribute the class--to both hearing and deaf students--to satellite campuses in other locations. Hospitals and medical or professional office buildings can share a centralized video teleconferencing system and utilize interpreters, on shorter notice and at less expense.

Company Response:

Pacific Bell has conducted trials of video teleconferencing with customers who use American Sign Language (ASL). These trials were met with enthusiasm by deaf customers. Pacific Bell will ensure that our sales force understands this application.

Pacific Bell recognizes the potential value of video conferencing for a wide range of applications. Customers in the education and health care market segments have expressed a great deal of interest for various distance learning and telemedicine applications; colleges and hospitals are prominent on the video conferencing customer user list. We are currently working with San Diego State to establish a video teleconference using interpreters in San Diego and deaf people in both San Diego and Alameda. This will be a further demonstration of the value of video teleconferencing and its use in reducing interpreter costs.

Pacific Bell recently announced the Education First Program, which offers network connections for video conferencing available free for one year to elementary and secondary schools, as well as community colleges. This program will stimulate the deployment of video conferencing technology in environments that are accessible to and supportive of people with disabilities. This creates an opportunity to increase the availability of shared sign language interpreting and other visually oriented services.

12) Test, develop, and promote ISDN's advanced sound quality to hard-of-hearing people.

Judging from Pacific Bell's introduction of this new technology, ISDN looks like it may provide a giant leap in information capability to all who have access. Among its many advantages, ISDN could dramatically improve the quality of conversations over the phone lines for people who are hard-of-hearing.

That could be a tremendous improvement for the largest segment of people with disabilities requiring the most improved access to telecommunications. Pacific Bell, working with audiologists and other experts, needs to determine what frequencies of hearing loss are amenable to specific technical remedies that ISDN could provide.

Once implemented, this ISDN "hearing service" could become a major marketing tool for Pacific Bell to groups who might otherwise have difficulty appreciating how they benefit from this "pretty awesome new stuff" (PANS). For example, senior advocacy groups might be more easily persuaded to support ISDN as integral to redefining Universal Service if relevant applications that they need were more fully developed.

Company Response:

Pacific Bell agrees with this recommendation, however, it isn't technically possible at this time. We asked the Strategic Issues Group to put together an assessment of what these customer needs are, what technical capability is required, and an estimate of price sensitivity. We learned that currently CPE produced for ISDN cannot use two B channels simultaneously which is needed to deliver 7Khz audio. We will however share this idea with manufacturers.

13) Promote Priority Ringing to households with deaf and hearing customers.

Priority Ringing allows users to choose up to ten numbers and pre-program them into the phone. When someone from one of those numbers calls, the phone rings with a distinctive ring. When a standard phone rings in a household of both deaf and hearing people, the deaf person sees a visual indicator (usually a flashing light) and hearing people hear a standard ring pattern. A deaf person has no way of knowing whether to answer the call by switching on the TDD to communicate.

Priority Ringing could help solve this problem. It would not only benefit the household (where TDD calls ring with the distinctive ring, and voice calls with the standard ring, for example), but also the caller whose number has been pre-programmed. That's because when a hearing person picks up the phone and answers by voice, the operator of the TDD device that's communicating on the other end may interpret the signal as busy or the wrong number. This time delay and confusion could be avoided if deaf and hearing households understood services like Priority Ringing already available to them.

Company Response:

Pacific Bell's opportunity to promote this product to its entire customer base is limited. Once Priority Ringing has been upgraded to work on calls from outside the local area, there will be more potential to promote this product since it will be more valuable to our customers. Presently, Priority Ringing only works within one calling area (LATA).

However, two options remain viable. First, Pacific Bell will promote Priority Ringing when advertising Custom Calling Services. Second, we will also train the service representatives who speak with TDD users on this application.

14) Make the Message Center accessible to TDD users.

The Message Center is a classic example of a product that Pacific Bell could have designed for greater accessibility with people of disabilities in mind. Unfortunately, the prompts used are voice only and the system is not designed to reproduce Baudot tones. A deaf TDD caller cannot use the system.

Deaf customers using TDD's have no idea if they've reached someone's voice mail, wrong number, or a busy signal. Baudot tones are incompletely recorded on the voice mail system, so that played back messages do not usually include all typed characters, resulting in confusing or incomprehensible communication.

As Pacific Bell Information Systems considers ways to correct this problem, the AGPD suggests that a workable design needs to allow households with both deaf and hearing people to use the Message Center. The potential market for this voice mail product includes friends and family of deaf users, as well as businesses and nonprofit organizations that regularly communicate with deaf individuals.

Company Response:

Pacific Bell Information Services (PBIS) is investigating the technical and economical feasibility of modifying The Message Center to provide the necessary Baudot tones to support TDD's. In its investigation, PBIS is considering product designs which support both deaf only households and combination deaf and hearing households. PBIS is also investigating various ways in which customer support may be provided to deaf customers of the potential TDD Message Center service.

15) Make products for education accessible to expand the potential market to include special education.

Pacific Bell has recently announced it will connect every school and library to the information highway. It is also trialing services for the education market: Knowledge Network Gateway and Classlink. We commend Pacific Bell for its forward thinking and leadership supporting two critical institutions. The Gateway trial also has a home version that is accessible to blind and visually impaired users. The option must remain. As Pacific Bell pursues additional products for schools and libraries, its imperative to design in access for people with disabilities. The AGPD believes Pacific Bell could find special education a substantial market opportunity.

Company Responses:

The Knowledge Network Gateway is an information service developed by Pacific Bell. The dial-in navigation software uses the VT100 emulation protocol for the user interface. This is a basic character mode interface. The interface, though not graphic and glitzy, can run on almost any computer or terminal, thereby allowing equity of access. VT100 character based services can also be interfaced with other software or hardware which gives the user added capabilities, including text to voice capabilities and the ability to make type larger.

It is the intention of the Knowledge Network product development group to enhance the dial-in user interface to a graphical user interface in the future. The group also intends to keep the VT100 interface which can be more usable both by people with disabilities and by users with a variety of computers. The AGPD has educated Pacific Bell about the value of keeping the VT100.

OTHER RECOMMENDATIONS AND PACIFIC BELL'S RESPONSE

There are many other areas of opportunity the AGPD discussed with company leaders that do not fall into specific recommendations for products or applications. The suggestions that follow address strategies to better reach customers with disabilities about programs and products.

16) Increase efforts to inform customers about the equipment lending program. Develop and use a comprehensive mailing list of organizations serving people with disabilities, seniors, and limited English-speaking communities.

Pacific Bell's Deaf and Disabled Services provides assistance to only a fraction of the eligible customers it could ideally serve--about 130,000 out of more than 5 million people. Not everyone who is eligible will take advantage of the service: some prefer to buy their own equipment, others mistakenly think that the program requires low income status, still others who have significant functional disabilities do not consider themselves deaf or disabled.

Pacific Bell needs to reach out aggressively to these organizations and find ways to help them inform their constituencies about the equipment available and how easy it is to obtain. Seniors and the Spanish-speaking community especially need to be targeted for outreach. Pacific Bell should work with service providers who are sensitive to cultural differences in preparing more effective communications with limited English-speaking communities. The company must take steps to increase its outreach to customers who qualify.

Company Response:

Deaf and Disabled Services (DDS) staff continues to expand its outreach program. We have developed a data base of over 600 agencies that work with people with disabilities in California. These agencies receive several mailings from DDS each year.

We are also conducting an internal awareness campaign aimed at the Residence Business Offices and the Public Offices.

We have also developed a video about the equipment lending program that we will send to both the agencies in our data base and to Pacific Bell business offices. We will focus on promoting the equipment lending program to seniors in 1994 by targeting outreach presentations and direct mail.

DDS is also developing a Spanish version of its brochure, and placing ads in publications that serve Spanish and Asian Language populations. Increasing outreach in these communities is a priority. Additionally, we are targeting people with disabilities who live in rural areas through outreach.

Change the name of the program to reflect a functional emphasis.

Toward the end of 1993, after nearly a year getting to know the company and its many helpful resources, the AGPD suggested that the name "Deaf and Disabled Services" deters many potential customers with disabilities who do not identify as "deaf" or "disabled". The two largest disabilities--hard-of-hearing and mobility disabilities--predominate among older adults who aren't born with disabilities but acquire them with age.

We believe this group is unlikely to respond to information or programs when they are labeled "Deaf and Disabled Services." The AGPD prefers the name Pacific Bell Resources for Accessibility (PBRFA). When targeting communications specific disabilities could be added to the name, (e.g. PBRFA for seniors, PBRFA for the deaf, etc.). Pacific Bell should also consider multiple listings in the white pages so different disabilities can easily locate the service.

Company Response:

Feedback gathered from focus groups of people with disabilities has supported the concept of changing the name of the program. Pacific Bell is currently conducting market research with customers who have received equipment from Deaf and Disabled Services, including specific questions on the name change proposal. Preliminary results of that research indicates customers do not have strong ties to the current name, and will be receptive to a new name. A decision on the name change will be made in mid 1994.

17) Include people with disabilities in advertising and marketing campaigns.

One Overriding goal of people with disabilities, regardless of particular issues and strategies, is to have the same opportunities as everyone else. To that end, the AGPD applauds Pacific Bell's previous advertising campaign. In its video portrayal of the full diversity of the people of California, including a person with a disability, it helped illustrate the company's message. "Good Enough Isn't."

The company should continue reinforcing the message in its next advertising campaign that people with disabilities are part of the social landscape. For example, background shots of a downtown district at noon might include a wheelchair user, or shots of people using the phone might include seniors with large button sets, a hard-of-hearing customer using phone amplification, or a blind person operating a phone set equipped with voice dialing. People with disabilities should be included in developing advertising ideas, as well as in focus groups that test those ideas during theme development. Ads should let the viewer see that we are among many people of California who use Pacific Bell's products and services.

Company Response:

Market Communications aggressively seeks opportunities to represent the diversity of California in advertising campaigns. Recent ads which feature people with disabilities include the "Good Enough Isn't" series showed a kayaker who is also a wheelchair rider and a young girl who is autistic; and the "It's real California" series showed a background shot of a wheelchair rider.

During our meeting with the AGPD, we learned more about the presence/absence of people with disabilities in Pacific Bell advertising campaigns. Other discussion points from the AGPD meeting under consideration include:

Use people with disabilities in the background of commercials/photographs.

Background music in commercials is often too loud, decreasing the ability to hear the words for people with impairments.

Request for larger type in collateral and advertising.

How to target seniors better, since they don't perceive themselves as "deaf or disabled".

Opportunity to feature in advertising those service representatives who educate customers on use of special equipment for people with disabilities.

Be careful not to segregate people with disabilities when depicting groups of people in advertising.

In advertising directed toward people with disabilities, focus on ability and the fact that customers can do these things with the special products.

As we develop commercials we'll continue to evaluate opportunities for casting that is inclusive of all California customer groups, including people with disabilities.




CREATING ACCESSIBLE FUTURE PRODUCTS

Over the course of the past year, the AGPD has had the opportunity to witness firsthand many of Pacific Bell's plans for future technology. We've talked with many of the key company leaders spearheading efforts to bring to market technologies that will affect California's future--broadband (both audiotext and videotext applications), Advanced Intelligent Network, ISDN, Voice Dialing, electronic publishing, and enhancements to Operator Services.

Since the influence of PCS and broadband will be pervasive, and both loom large on the policy as well as social horizons, it seems inevitable that at some point there will be requirements to make these services accessible to the disability community, if they aren't already. We believe the company needs to think about the many issues of accessibility now. That urgency is highlighted by the rapid growth of new competition within telecommunications and proposed changes in regulatory policy.

The prospects of broadband and PCS technologies hold great promise for all Californians, but the company needs all the support it can muster to build the information network it envisions. It must not exclude from its design plans the more than 5 million people with disabilities who require equal access to these technologies.

It is not yet clear how PCS and broadband will influence the redefining of Universal Service, but both technologies are certain to be important. If the society that evolves over the next decade comes to take these new personal communications and information tools for granted, then people with disabilities must be provided the means to take them for granted as well.

Personal Communications Services

Mobile communications are not simply luxury services for many people with disabilities. We envision PCS as a major tool for people with disabilities who need more efficient accessibility to communications than they have today.

In order for PCS to be truly accessible to all customers, both equipment and the network will have to be developed so that people with disabilities are included in the design plan. Pacific Bell must use its leverage with equipment manufacturers to make sure PCS products are as accessible as the network. [See Sidebar]

Developing PCS applications for people with disabilities from the beginning can also help Pacific Bell gain crucial marketing intelligence. The uses that customers with disabilities employ for PCS may reveal unexpected insights about how all other people might use PCS.

Who Needs PCS? [Sidebar]

Whatever technology evolves for PCS, it must be able to accommodate people with different needs, including those with special devices to plug into the PCS network. The list includes:

  • Customers who need or want amplified phones
  • Customers who need or want phones with large buttons
  • Customers who need or want speaker phones
  • Customers who require voice dialing
  • Customers who can't reach the pay phone coin slots
  • Customers with vision impairments who cannot locate pay phones
  • Customers who use TDD's.
These are among the customers who will want to use pcs to make their lives easier and their ability to communicate less burdened by physical or geographic constraints.

-----

Broadband

Broadband presents another set of challenges and opportunities. The access concerns of people with vision and speech disabilities become even more acute regarding the much vaunted Information Superhighway.

Certain employment and educational opportunities for people with disabilities will hinge on having full accessibility to many of these services.

Some in the information services industry claim that the disability market is very similar to the home office market. Many people with disabilities are interested in broadband applications that will allow them, like others, to work at home, and so the market potential of telecommuting-related services, according to certain analysts, is large.

While the AGPD supports the use of broadband technology to bring the latest network applications into the homes of people with disabilities, a strong note of caution is in order. We do not support the use of broadband or any other telecommunications technology that might limit employment opportunities for people with disabilities to those jobs that can only be conducted in their homes. In other words, we oppose work-at-home technologies as a substitute for the active inclusion of people with disabilities in the workplace.

Our goal is more choice and accessibility, not further segregation and confinement. The AGPD wants broadband applications to be provided through redundant channels in order that people with disabilities have equal access to information sent and received over the so-called information highway now evolving.

We intend to be major users of that highway, and need the active efforts of major players like Pacific Bell to insure that we have on-ramps.

Finally, there is a technical issue related to future broadband developments that the AGPD considers critical: the problem of the interface; more specifically, the Graphical User Interface (GUI). It is included below among our recommendations for making broadband accessible to people with disabilities.

RECOMMENDATIONS AND PACIFIC BELL'S RESPONSE

Personal Communications Services
18) Assign top priority to implement Voice Dialing for PCS.

The company should investigate several PCS applications that address specific functional disabilities (see next recommendation). To get started the company should investigate voice activation services for people with limited vision and mobility. In doing so, the company should implement technology that employs sophisticated voice recognition capability that can be used by speech impaired customers as well as other users.

Company Response:

Pacific Bell agrees with this recommendation. As the technology permits we will begin our work. Some terminal equipment available today for cellular use incorporates Voice Dialing capabilities, and such equipment will certainly be available for PCS. The development of Voice Dialing capabilities within Pacific Bell's core network can be made available to all wireless providers, including PCS providers. Pacific Bell will continue to actively work with equipment manufacturers to develop Voice Dialing, voice recognition services and equipment for PCS.

19) Pacific Bell should set vendor standards for equipment and network services in order to address major concerns for the following customer categories:

People with limited vision or blindness

Provide raised buttons on PCS-phone sets.

Provide audible displays and feedback of keys pressed.

People who are deaf

Provide phones that use non-auditory signaling (e.g., vibration).

Supply phones that can translate network signals (dial tone, busy signals) onto a visual display.

Provide Baudot tones for TDD in addition to voice prompts for other users.

People with hearing impairments

Provide PCS-phone sets that are hearing aid-and-amplifier-compatible.

People with mobility impairments

Provide PCS-phone sets with adequate spacing between buttons that are easy to depress.

People with cognitive difficulties

Provide more user control over the speed of network information (e.g., instruction prompts that allow users to back up, skip, slow down, repeat information).

Company Response:

Customers with disabilities will be important users of PCS. Pacific Bell believes that equipment and network services should be usable to people with a wide range of functional needs. It is likely that Pacific Bell will not partner with a single manufacturer for PCS. We will incorporate universal design principles into RFP's from equipment manufacturers, educate potential vendors about the importance of considering the needs of this market, as well as the revenue potential of this segment.

20) Include people with disabilities in all PCS trials.

Company Response:

Pacific Bell has and will continue to identify potential customers, including people with disabilities, for all market and technology trials. In the San Diego PCS Market Trial, conducted by Telesis Technologies Laboratory (1993), 5% or 68 people who participated identified themselves as having disability.

21) Develop and market PCS as a "wayfinding" tool to assist users in determining locations, and also as an environmental control device.

PCS could be used to assist in determining location. Like the Pacific Teletrac system that operates on radio frequencies to help identify stolen or lost vehicles, the PCS network could be adapted to help determine where a caller is calling from, or allow the user to "keyback" to a centralized data bank to find important or desired locations in relation to the caller (i.e., the nearest bus stop, the closest pharmacy, etc.). These services would specifically assist travelers, people with Alzheimer's, children, and blind people.

PCS could also be adapted for controlling one's living environment; e.g., turning utilities on and off by use of the handheld device, programming appliances in the home, etc.

Company Response:

Pacific Bell has been actively working with equipment manufacturers to develop the means of providing general location (within 400-500 feet) information through wireless networks for emergency service agencies. Pacific Bell will continue its efforts to develop this capability. The technology, even using satellites, to notify the user that he/she is on the southeast corner isn't commercially available today.

The idea of a single communication device capable of interacting with other devices by way of voice, data, or image formats is one that many in this industry embrace. Pacific Bell intends to continue to be a leader in developing telecommunication services that bring consumers closer to that ideal.

22) Aggressively market PCS to people with disabilities, demonstrating its advantages both inside and outside the home.

Some of the uses for both home and mobile use of PCS have already been described. Another application for product developers/marketers to consider: PCS provides an ideal alternative to coin telephones for many customers with disabilities.

Coin telephones are not accessible to a large number of people with disabilities. For example, blind customers cannot find coin phones; many customers with mobility limitations cannot use coin phones; hard-of-hearing and deaf customers cannot use phones that do not have amplifiers or TDD's. PCS properly designed for these customers will provide dramatically improved access to the network away from home.

Company Response:

Pacific Bell will actively target this market by recognizing the needs of people with disabilities and providing appropriate services. PCS will be a highly competitive market, and the companies that succeed must be able to understand and respond to consumer needs better than the competition.

When Pacific Bell sets the policy and strategic direction for the PCS marketing campaign it will take into consideration the issues in recommendation 17. The advertising strategy could include demonstrating product advantages in the most relevant way for people with disabilities.

Broadband 23) Include people with disabilities in all phases of broadband trials.

Company Response:

We agree that people with disabilities should be included in all phases of broadband trials. By including this segment, PBIS can gather feedback from potential market and increase usability for all customers. Currently, the trial planned for broadband will be in Milpitas in 1994. PBIS will include customers with disabilities in this trial as long as we can identify them in the neighborhood selected.

24) Design redundancy in the use of interfaces for broadband products and services.

Graphics User Interfaces (GUI) are popular with software designers and many computer users today, but difficult for people with vision and cognitive disabilities because they are difficult or impossible to be translated into voice output. Because GUI's are designed to be interpreted through visual images, those with vision disabilities find themselves unable to use GUI's gateways, which do not lend themselves to the sequential presentation of information necessary for voice translation devices.

There are 1.5 million people in California with vision disabilities who would be left behind if GUI's are the exclusive gateway for Pacific Bell broadband products.

In addition, for those requiring a larger print size, the icons used in GUI's are often difficult to distinguish even when enlarged. Icons often require the user to be able to distinguish between figure and background, which low vision users may not be able to accomplish. GUI's are often used in tandem with a mouse, which presents problems for many people whose disabilities impede manipulation.

Designers of Pacific Bell's broadband gateway should take into consideration the needs of people with disabilities. We recommend that early on, Pacific Bell develop an alternative interface in addition to GUI's when designing for multiple users of broadband. (Pacific Bell's Knowledge Network Gateway is an application that already provides both GUI and text interfaces).

More people than just those with vision impairments--for example, people with learning disabilities and other cognitive impairments--would benefit from an alternative.

Human factors and computer experts have told us that interfaces won't improve until enough users complain about them, and until interface designers come to better understand and accept the way the human mind actually works on tasks. GUI's are often not compatible for anybody. Interfaces could and ought to be designed that are simpler and more efficient for mass consumption.

Once again, designing an application for people with disabilities can point toward more innovative applications for the mass market as well.

25) Allow customers to select a mode in which they give and receive information.

No service offered by Pacific Bell over an enhanced, broadband network should be available to users through voice activation alone, nor should it only be available by visual indicators on a computer screen. Allowing customers to select the mode in which they send and receive information will help people with different disabilities while offering more choices for everyone.

Human Factors Engineering can help determine the most appropriate formats that can facilitate gateway access to broadband applications for people with different disabilities.

Company Response to Recommendations 24-25:

PBIS is committed to building in some redundancy in broadband interfaces. We need to obtain more information on designing accessible interfaces so we can make the best business decisions. When Pacific Bell is the content provider we will actively pursue developing "hooks" that can be accessed by existing (and future) technologies. We believe many customers want to choose the format in which they receive information. We will also meet with experts in this field and work with them on developing solutions that meet the needs of a wide spectrum of customers while allowing us to remain competitive in the broadband market.

26) Establish partnerships or alliances with companies that provide (or plan to offer) information in forms accessible to people with disabilities.

Pacific Bell is in a position to influence the way information is provided over its broadband facilities; for example, by encouraging content providers to offer "captioning" and "audio descriptioning" as part of their product offerings.

This will have the effect of serving people who need alternative formats when receiving visual or spoken information, as well as demonstrating added value that can enlarge the market to many more users--those "unintended" beneficiaries of the improvements designed for people with disabilities.

Company Response:

Pacific Bell will actively work with hardware and software suppliers to develop their products so that customers with disabilities can use adaptive technologies, where necessary, to make information accessible. By providing market information and incorporating universal design principles into data provided to broadband content providers, Pacific Bell will send a strong message that information provided in accessible formats mean more customers.




APPENDIX

Sample Filter Questions by Disability

Hard of Hearing

How does someone who has a hearing difficulty use this product?

Will it work with an amplifier?

Will it work with a hearing aid?

Is there audible signaling involved that can be converted to visual or tactile signals?

Are there ways I can design this product to increase hard of hearing customers' use of this product?

Deaf

How does a person who cannot hear use this product?

Is there audible signaling involved that can be converted to visual or tactile signals?

Can this product be used with a Telecommunications Device for the Deaf?

Will the product respond to Baudot tones?

Will prompts be available in Baudot tones?

Can a customer use this service when calling via the California Relay Service?

Can I design this product to increase deaf people's use of the product?

Mobility

How does a person with limited mobility use this product?

Is the product easy to pick up and hold?

Can the product be used with voice activation?

Are buttons spaced far enough apart so people with fine motor control difficulties can press them?

Is there adequate time allowed for these customers to respond to prompts?

Are there ways I can design the product to make it more usable by people with mobility impairments?

Vision

How does a person with limited or no vision use this product?

Are visual displays/prompts provided in an audible format?

Are buttons raised so customers can feel them instead of having to see them?

Is printed material provided in alternate formats (large print, audio text, Braille)?

How can I design this product so that customers with limited vision can easily use it?

Speech

How can a person who stutters or has difficulty speaking use this product?

If voice activation is used, can the system recognize the speech of these customers?

Is there adequate time allowed for these customers to respond to prompts?

Are there ways I can design the product to make it more usable by these

QUOTES FROM AGPD MEMBERS

Sheila Conlon-Mentkowski--Project Director, CATS Initiative, Department of Rehabilitation. "The PacBell AGPD is a shining model for what I would like to see emulated and carried out in other sectors of the business communities. Such partnerships will also ensure staunch allies in the currently unfolding information revolution which will ultimately change and rewrite the 1934 Communications Act and other telecommunications legislation."

John L. Darby--Executive Director Emeritus, Hearing Society for the Bay Area, Inc.. "Communication is the principal basis for establishing and maintaining interpersonal relationships. Telecommunications can enhance or impede interpersonal communication. By increasing access to the telecommunications system, communication for all will be improved."

Gordon Fuller--CEO, S3D Corporation. "Our response to the challenge posed by disability will impact the quality of life for millions of current and future customers. History will judge our actions in the light of a future marked by an aging U.S. population. We must lead the world with products and services emphasizing universal design to reap the rewards of improved performance and enhanced competitiveness."

Stephen Hofmann--Project Coordinator, Transitions Department, West Contra Costa Junior High School District. "Where will the birds rest when all of the telephone wires are buried? People with or without disabilities are in the same predicament. As technology displaces the beauty of nature for the speed and efficiency of human society, we as a people lose. We sacrifice our humanity for progress. Pacific Bell has the rare opportunity and privilege to ensure that by enhancing telecommunications for all people, we as a society can work together efficiently and productively, but also with kindness, compassion and above all, respect for each others differences."

Neil Jacobson--Vice President, Corporate Systems Architect, Wells Fargo Bank. "Telecommunication services must be accessible to all people. By adopting universal design principles, Pacific Bell will expand its market-base to include all people with disabilities. Now is the time to ensure that tomorrow's services are truly enablers for people--not barriers."

June Isaacson Kailes--Disability Policy Consultant. "A product which is universally designed represents increased sales and an increased market share. A positive attitude toward accessibility is a cost effective attitude because:

It is logical and practical.

It `includes` instead of `excludes.`

It increases customer convenience.

It contributes to the economic base.

It helps a business remain responsive and competitive."

Deborah Kaplan--Vice President, World Institute on Disability. "Pacific Bell has distinguished itself in the telecom industry by taking people with disabilities seriously as a market. This is especially noteworthy since current legislation (likely to pass in the 1994 session) will mandate a similar approach. Pacific is now poised to be a model."

Helen Sloss Luey--Project Director and Coordinator of Social Services, Hearing Society for the Bay Area, Inc.. "Many people today feel like foreigners in the culture of technology. As people age, they face increasing barriers in using modern equipment: lack of comfort and familiarity with computers, age-related disabilities, and dwindling economic resources. My concern is that the opportunities created by advances in telecommunications remain within reach of people of all income levels and all levels of technological sophistication."

Chuck McAvoy--Co-Chair, Bell Employees for Adaptability, Pacific Bell. "I'm honored to have been selected to serve on this Advisory Group. I am extremely please to be part of a company that is taking a leading role in including people with disabilities in the telecommunications revolution. I personally feel that Pacific Bell will be an industry leader in accessible product design, proving by example that universal design is the right thing to do as well as being profitable."

Sheri Farinha Mutti--Executive Director, NorCal Center on Deafness. "Access to telecommunications is a critical component in accessibility. The deaf community has demonstrated how improved access (through CRS, TDD Distribution programs, etc.) can level the playing field. The AGPD recommendations, and the company's response will be a model for accessible telecommunications. I look forward to seeing ever increasing access to the network."

Susan Palmer--Special Education Instructor, Visually Impaired, Alum Rock Unified School District. "Access to information is not just an issue of quality of life, it is an issue of equity. By proactively embracing universal design principles, Pacific Bell can enhance opportunities for all. Sidestepping these principles creates barriers and promotes discrimination. Children with disabilities will either flourish in a more accessible environment, or have to fight for access to information."

Rudy Samora--Executive Director, Fiesta Educativa, Inc.. "Being able to communicate one's thoughts, feelings and emotions with other people is paramount to our human existence. Adopting universal design principles will provide telecommunications opportunities to all people with disabilities, people from all walks of life, including those with different cultures, languages and races."

Marc Sutton--Access Product Manager, Berkeley Systems, Inc.. "A revolution in information dissemination is upon us, and with it a challenge: how to provide equal access to that information for all people, including people with disabilities, throughout the world. In a sense, Pacific Bell can become a leader in meeting this challenge."

Joseph Wichmann-Heil--West County Service Team Coordinator, Sonoma County Office of Education. "Children with disabilities are increasingly included in their home, schools and communities. We need to take steps to make sure that, as they grow, they grow into a barrier-free world that allow them to experience themselves as able. Telecommunications and information access, starting with design considerations now, ensures the possibility of full participation for future generations."

ACKNOWLEDGMENTS

The Advisory Group of People with Disabilities wishes to thank all those who made presentation to us. We sincerely appreciate their willingness to learn about the issues we raised and their responsiveness in seeking solutions. (The following people are with Pacific Bell unless otherwise indicated.)

Mary Baker, Project Manager, Custom Billing Disk

Keith Bass, President, Tower Communications

Kitty Bernick, Director, External Affairs, Pacific Telesis

Rick Bradley, Division General Manager, Regional Market Services

Joe Buckley, Director, Market Intelligence

Keith Cambron, Director, Consumer Broadband Systems Engineering

Lee G. Camp, President and CEO, Pacific Bell Information Services

Bonnie Clark, Director, Billing Group

Tim Cleere, Director, Operator Services

Steven Cristol, Assistant Vice President, Marketing Communications

Mike Cutler, Director, Personal Communications Services, Pacific Telesis

Juliana Cyril, Information Specialist, Disability Statistics Program, UCSF

Keith Epstein, Vice President, External Affairs, Pacific Bell Information Services

Elizabeth Fetter, Vice President, Industry Markets

Michael Fitzpatrick, Executive Vice President, Marketing and Sales

Lois Flamm, Director, Human Factors Engineering Group

Austene Hall, Product Manager, Educational Business Unit

Steve Harris, Vice President Broadband Services, Pacific Bell Information Services

Gary Heil, Marketing Manager

Bob Johnson, Manager, Product Opportunity Development

Martin A. Kaplan, Executive Vice President, Quality, Reengineering, & Technology

Larry Kunke, Executive Director, Products and Marketing Planning

Jay La Vergne, Project Manager, Voice Dialing

Robert Lee, Executive Vice President, Regional Markets Group

Hal Logan, Vice President, Business Development, Pacific Bell Information Services

Richard W. Odgers, Executive Vice President & General Counsel, Pacific Telesis

Patricia Parker, Instructor, Pacific Bell Technical Education Institute

Scott Peavler, Director, Marketing Research Services

JoAnne Penrith, Executive Director, Channels and Services

Mark Pitchford, Senior Manager, Consumer Products and Services

Charnee Smit, Manager, Product Opportunity Development

Jim Tobias, Project Director, Bellcore

Diana Whitehead, Area Vice President, Bay Marketing

The Advisory Group members wish to extend a special thank you to Susan Walters and Dmitri Belser. They created a process that allowed us to learn a great deal about telecommunications and to participate in a robust discussion about these issues. Susan's competence and hard work never let us down. Dmitri made sure that every accommodation was made to ensure that each one of us had a chance to contribute. Without contributions, this report would not have been possible.



Copyright © 1996 Pacific Bell. All Rights Reserved.


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