Even in current telecommunications, the
interaction between end-user equipment and network features determines the level
of potential accessibility. For
example, Call Waiting, a switch-based feature, delivers a certain tone to the
subscriber’s line when a second call attempt is made.
Some CPE can detect this tone and display a light, while other CPE can
amplify the tone so that some hard of hearing users can perceive it.
Alternately, a change to the Call Waiting tone coming from the switch
could make it easier for a CPE device to detect the tone electronically or
acoustically. Similar interactions
occur for voice mail, Caller ID, three-way calling, and almost every
telecommunications feature.
As new networks and new CPE emerge, it
is their interactions, not their individual characteristics that will continue
to influence accessibility. Internet
telephony will challenge assumptions about where the accessibility functionality
should reside.
Responsibilities on Section 255 are
split between the Access Board, which provides guidelines on CPE and TE, and the
FCC, which provides guidelines for telecommunications service providers and has
sole jurisdiction over enforcement for all of Section 255, both equipment and
services. The two agencies should
continue to mitigate this separation by coordinating policy wherever possible.
Consumers commented on their inability
to connect their assistive technology directly to a telephone line. This parallels the findings of the UCPA study, in which the
most common design improvement mentioned was combining the telephone with a
communication aid (Simpson/UCPA, 1997).
One likely reason that manufacturers of
assistive technology do not include this telephone functionality is that it
would result in an appreciable additional regulatory burden for them. Their equipment would become subject to FCC Part 68
requirements. Research should be
undertaken to understand whether this is a significant factor in their
decisions, and whether there are any possible federal activities that would
mitigate it, including special regulatory status or technical assistance.
Small manufacturers of SCPE whose products do include telecommunications
functionality, such as TTY manufacturers, should be included in this study.
In approximately half the states,
programs exist to distribute telecommunications equipment to people with
disabilities. They range from
small, means-tested, TTY-only programs to large, entitlement-based programs
carrying dozens of devices. In
almost all cases the equipment distributed is assistive technology, especially
TTYs and amplifiers. These programs
have been responsible for a vast increase in the use of telecommunications by
people with hearing loss, especially those who need to use a TTY.
These programs may be able to play a
major role in continuing the expansion of accessible telecommunications.
First, people with other disabilities not served by distribution programs
also need assistive technology; this would expand the clientele of the equipment
distribution programs. Second,
telecommunications companies have expressed interest in working cooperatively
with any agency that can handle accessibility on a “wholesale” basis,
whether as a purchaser of accessible products or as an information channel to
customers with disabilities. These
programs are well positioned to help industry reach more potential customers.
The Telecommunications Equipment
Distribution Program Association (TEDPA) is a recently-formed organization that
deals with several of the issues before these programs.
TEDPA should be encouraged to work with the telecommunications industry
and federal officials to explore how emerging telecommunications will affect the
mission of its member programs.
At present there is no legal definition
of those peripheral devices that are “commonly used” by people with
disabilities to achieve access to telecommunications.
This Report contains a list of these devices that appeared in the
Consumer Survey responses, and an Appendix (Appendix F) that contains a more
comprehensive list of all the devices that were or are available.
The former may be too exclusive and the latter too inclusive to meet the
definition of “commonly used.” Using
the contents of this Report, the Access Board should develop and update a
listing of peripheral devices and specialized customer premises equipment that
is commonly used by people with disabilities to achieve access to
telecommunications. Industry will
be better able to build in compatibility if it has a clear idea of the devices
with which devices its products must be compatible. Manufacturers of these devices should be encouraged to
contribute to this compatibility effort.
It is highly unlikely that the TTY as we know it today will survive another 20 years. It will either become a very different device, still intended for today’s TTY users, or mainstream equipment will have filled the need originally met by TTYs. In fact, TTYs are already evolving to connect with wireless phones, enable faster transmissions, and include much-desired features like the ability to interrupt. On the other hand, many former TTY users says they hardly use it any more, and now rely more on email and wireless text devices.
However mainstream and specialized technologies evolve, consensus and planning will smooth the way for consumers, manufacturers, telecommunications companies, regulators, program administrators, and other stakeholders. A project should be undertaken to identify key stakeholders and explore how robust markets in mainstream and assistive products and services can meet the needs of tomorrow’s users.