Accessible Telecommunication Systems

1. Accessible Telecommunication Systems Paul R. Michaelis, Ph.D., C.P.E. prmichaelis@avaya.com July 2006

2. The goals of this presentation • Describe three assistive technologies that are commonly used in conjunction with telecom systems. • Review disability access laws and regulations that apply to the telecom industry and to telecom customers. • Demonstrate accessible solutions that have been developed by Avaya. • Describe how these products work, thereby allowing you to see for yourself that accessible solutions don’t have to be expensive, complicated, or hard to administer. • Solicit your feedback about the products we have built, and about the products you want us to build.

3. Avaya’s accessibility philosophy • Many of the people in Avaya who are working on accessible solutions have personal reasons for regarding it as important. • We will not achieve our personal objectives if our solutions are adopted solely by organizations for whom Section 508 is mandatory. (Only about 5% of Avaya’s revenue comes from sales to the Federal government.) • In the private sector, the incremental costs and perceived complexity of accessible solutions are disincentives to the hiring of a qualified person with a disability. • For these reasons, whenever it is possible to do so, we embed our accessibility solutions within our mainstream products, and provide these solutions at no additional charge.

4. A quick review of assistive technologies: (1) What is a TTY?

5. What is a TTY? A TTY (also known as a TDD) is a special text terminal that lets people who are deaf, hard of hearing, or speech-impaired use a telephone to communicate.

6. Some TTY basics • How US TTYs work: • FSK “Baudot” tones. Half duplex. No error correction; no “handshake”; no carrier tone. (TTYs are silent when not transmitting.) There is no ability to interrupt the other person. • 45.45 baud. (Each “bit” is a 22ms tone, either 1400 or 1800Hz.) • Each character consists of seven tones: a start bit at 1800Hz, five tones at 1400 or 1800Hz that specify the character, and 1.5 stop bits at 1400Hz. • Not all TTY users transmit and receive with their TTYs. In fact, roughly half have hearing deficits, but still speak clearly; these users often prefer to receive via TTY but then speak in response. This is commonly referred to as Voice Carry Over or VCO.

7. (2) What is inductive coupling?

8. Inductive coupling • If an object gets within a few inches of most hearing aids, the aids often emit a loud howling sound. This is simple acoustic feedback, similar to the feedback you can get with an auditorium P.A. system. • To prevent this when a phone is being used, the microphone in the aid must be turned off. (Note: The microphone is turned off, but not the hearing aid itself.) • The voice signal from the phone handset is transmitted to the aid via electro-magnetic inductive coupling. • All Avaya handsets have primary inductive coils (commonly referred to as tele-coils or T-coils) that permit the phones to be used with inductively coupled assistive listening devices, such as traditional hearing aids and cochlear implants. • A big problem, not yet solved: The electro-magnetic “noise” produced by many wireless devices makes it impossible to use inductively coupled assistive listening devices.

9. (3) What are JAWS and Window-Eyes?

10. What are JAWS And Window-Eyes? Computer users who are blind often rely on sophisticated text-to-speech screen-reading software adjuncts. Two commonly used packages are JAWS and Window-Eyes. Many of the GUI and web standards are oriented toward allowing JAWS and Window-Eyes to work properly. Windows 2000 and XP include a primitive version of these products. Try using this MS software to do your job: Start > Programs > Accessories > Accessibility > Narrator JAWS (“Java Access With Speech”) is a product of Freedom Scientific http://www.freedomscientific.com/ Window-Eyes is a product of GW Micro http://www.gwmicro.com/

11. Relevant US laws and regulations

12. First generation of disability access laws Architectural Barriers Act of 1968 • First accessibility law; governed physical barriers (doors, stairs, etc.) in transportation facilities and Federal buildings. Hearing Aid Compatibility Act of 1988 • Requires the Federal Communications Commission (FCC) to ensure that all telephones manufactured or imported for use in the United States after August 1989 are hearing aid compatible. Americans with Disabilities Act of 1990 • Permits people with disabilities to file civil lawsuits in order to obtain “reasonable accommodation.” These lawsuits can be expensive for individuals to pursue, which is why many ADA cases are class actions. Within the ADA, there are very few explicit requirements for telecom equipment.

13. Examples of recent telecom-specific laws Section 255,Telecommunications Act of 1996 Empowers the Federal Communications Commission to require disability access provisions in telecom equipment and services. Section 508, Rehabilitation Act of 1973 (As amended in 1998) Adds specific accessibility requirements to Federal procurement regulations.

14. Section 255, Telecommunications Act of 1996 GOAL: Ensure that telecom equipment and services are usable by people with disabilities. REQUIREMENTS:The US Access Board identified specific types of disability (e.g., complete or partial deafness, blindness, paralysis, cognitive impairments) and specific assistive devices (e.g., TTYs, inductively coupled hearing aids, cochlear implants); FCC rules require telecom manufacturers and service providers to take these disabilities and devices into account. ENFORCEMENT: • The FCC is empowered to require compliance in all telecom products designed, built, or modified after February, 1996 if readily achievable. • Possible penalties for noncompliance include fines, loss of FCC product certification, and required retrofitting of the entire product line (not just the product that generated the original complaint). • The FCC determines whether compliance is achievable. There is no right of private action, i.e., theFCC’s decisions cannot be challenged in court.

15. What about Section 255 and VoIP?>>> Read the fine print! <<< CAVEAT EMPTOR • The FCC regulates communication systems. It does not have the authority to regulate “information systems.” • Under current law, the Internet is treated as an information system. • The FCC therefore considers Voice over Internet Protocol to be exempt from their jurisdiction. This exemption makes it possible for VoIP manufacturers and service providers to claim that they are not out of compliance with Section 255, even if they fail to address any of Section 255’s accessibility objectives. • A recommendation: Don’t achieve “compliance” with Section 255 by relying on legal loop-holes. • My presentation to the FCC, asking them to remove VoIP’s S-255 exemption: http://hraunfoss.fcc.gov/edocs_public/attachmatch/DOC-248634A8.pdf

16. Section 508, Rehabilitation Act Amendments GOALS: Ensure that the government’s internal electronic communication and information systems are accessible to government employees with disabilities. Ensure also that the government’s public-access systems are accessible to people with disabilities in the general population. REQUIREMENTS: Specific accessibility features must be present in telecom and information systems developed, procured, leased, or used by the government. (Note the difference in regulatory style: Section 508 imposes specific engineering design requirements, while the FCC’s guidelines under Section 255 say, “We expect manufacturers to find solutions for the disability access problems we’ve identified.”) ENFORCEMENT: Unless they can demonstrate undue hardship, departments and agencies are barred from acquiring systems that do not conform with Section 508’s requirements if a compliant system is available.

17. Code Of Federal Regulations, 36 CFR Part 1194 The “Section 508 standards” were authored by the US Access Board and are in the Code of Federal Regulations, 36 CFR Part 1194: • Subpart A - General Scope (1194.1) • Subpart B - Technical Standards - Software Applications and Operating Systems (1194.21) - Web-based Intranet and Internet Information and Applications (1194.22) - Telecommunications Products (1194.23) - Video and Multimedia Products (1194.24) - Self Contained, Closed Products (1194.25) - Desktop and Portable Computers (1194.26) • Subpart C - Functional Performance Criteria (1194.31) • Subpart D - Information, Documentation, and Support (1194.41)

18. Problems and Solutions

19. A closer look at three Avaya products • TTY-on-VoIP • TTY Messaging • Universal Access Phone Status In all three cases, we did the following: • Identify the users’ needs. • Identify capabilities that already existed within the “plain vanilla” versions of the products, that we could leverage in order to build the accessibility adjuncts. • Because we were able to piggyback onto other solutions that already existed, we have been able to provide these accessibility adjuncts for free.

20. TTY-on-VoIP • Problem: The voice channels on VoIP systems may be unable to transport TTY tones reliably. • Users’ needs: People must be able to use standard TTYs. It must be possible to intermix text and voice on the same call. • Key capability that already existed: VoIP systems use a non-audio mechanism (“RFC-2833”) to transport “touch tone” signals. • The solution: • Detect automatically when a TTY is in use. • Use RFC-2833 protocol to transmit a description of the tones (rather than the tones themselves). Command the receiving system to reconstruct those tones for the TTY at the far end. • Transmit each RFC-2833 packet many times. (Unless packet loss is especially severe, at least one of them will get through.)

21. TTY messaging • Problem: If someone calls you, and you don’t answer your phone, the call gets forwarded to voicemail. What if it’s a TTY user? • Users’ needs: Callers must be able to choose whether they wish to be prompted by voice or in TTY format. Regardless of the prompting style they choose, they must be able to leave a voice or TTY message. • Key capabilities that already existed: (1) The ability to let callers choose the spoken language for prompting; (2) the ability to record and play back TTY tones reliably. • The solution: • Create a TTY “announcement set” in exactly the same way that spoken announcement sets are created, i.e., by generating audio recordings of the prompts and menus that must be presented to users.

22. Universal Access Phone Status • Problem: Business phones use LCDs and LEDs to provide info. • Users’ needs: People with visual impairments cannot get important info, such as caller ID, whether the phone is forwarded, which lines are in use, and whether someone on hold has disconnected. • Key capability that already existed: Specific changes that occur in a telephone’s display can only mean one thing. For example, • Only one thing can cause the LED associated with button #1 to go from steady-on to flashing: “Line 1 on hold.” • Only one thing can cause the LED associated with button #3 to go from flashing to off: “Caller on Line 3 has disconnected.” • The solution: PC-based software that • Monitors changes that occur in the telephone’s displays. • Provides by voice output a description of what those changes mean.

23. Useful web pages • Access Board guidance for manufacturers and service providers: • Section 255: http://www.access-board.gov/telecomm/index.htm • Section 508: http://www.access-board.gov/sec508/guide/index.htm • Avaya information: • Accessible solutions brochure: http://www.avaya.com/master-usa/en-us/resource/assets/brochures/accessibility-brochure.pdf • Section 508 home page: http://www1.avaya.com/enterprise/gov/508/index.html • Other resources: • The FCC Disabilities Rights Office: http://www.fcc.gov/cgb/dro • Section 255 home page: http://www.fcc.gov/cgb/dro/section255.html • Section 508 home page: http://www.section508.gov/