FCC Forum on VoIP
Editor: VoIP (Voice over Internet Protocol) is the transmission of
voice (i.e., telephone calls) over the Internet. It may not sound like
much, but it really is the next BIG thing. It's already happening today,
and many more companies are working on the technology. It WILL impact
your life. Here's a report from NVRC News on the FCC Forum on VoIP.
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On Monday, December 1, 2003, the FCC held a forum on VoIP. Dr. Gregg
Vanderheiden, director of Trace R&D Center at the University of
Wisconsin in Madison was one of the presenters at this forum who helped
to call attention to the need for access to VoIP. As Al Sonnenstrahl of
CSD said, Dr. Vanderheiden is one of the most respected researchers in
the area of technology for people with disabilities. Al points out that
Dr. Vanderheiden's center invented a touch screen which was originally
for people use by people with disabilities -- a touch screen that is now
popular for use in restaurants, video games, ticket counters, etc. Dr.
Vanderheiden's Presentation Expanded Opening Comments of Gregg C
Vanderheiden Ph.D. Professor Industrial Engineering, Director, Trace
R&D Center University of Wisconsin - Madison
I would like to start by thanking the Commission for including access
to VoIP by people with disabilities, including those who are aging, in
the discussions today.
We were asked to comment both on whether PSTN regulatory obligations
should be placed upon VoIP providers, and whether such obligations were
technically or legally feasible. I will leave the legally feasible
discussions to others and instead focus on the other two questions in
turn. First, 'Are there regulatory obligations that should carry over to
VoIP?' and second, "Are they technically (and I would also add
commercially) feasible?'
What is the problem?
New technology often causes people with disabilities to lose access
-- access that was only restored when regulations were created. For
example, hearing aid compatibility disappeared with new phone speaker
technology until legislation was passed to restore it. An exception was
made for cell phones, and such compatibility did not appear in cell
phones until additional legislation was passed. People who are blind
cannot use cell phones today.
Ironically, even when the cell phones have speech which is used for
other features, it still is not possible for a person who is blind to
tell if they are roaming (at high cost) or if they have a good signal,
or if their battery will die soon. Nor can they use any of the menus.
Cell phones that could have been directly usable for many people who are
deaf (but speak) are not usable by them, because it was not specifically
required in guidelines (while tougher-to-do TTY connectivity was
implemented because it was required). Now many deaf people who can speak
and would not otherwise have needed mobile TTYs have to carry one with
them wherever they go just to use their cell phones.
Touch screen phones are appearing which cannot be used by people who
are blind - while simple software strategies would have allowed it.
People with cognitive difficulties, including those who are older,
cannot use newer phones when simple software features could make the
phones easily usable by them. People with low vision have trouble using
phones with hard-to-see keys and harder-to-read legends. Again, simple
software changes can provide large visual display of this information.
The same pattern is appearing in VoIP technologies.
Access to VoIP is very important to people with disabilities. VoIP is
already starting to take the place of traditional telephone calls in
many enterprises. And when VoIP rolls into apartment houses, nursing
homes, and elder care facilities it will be important that people with
disabilities and those who are older can use them.
While there are disability access laws (Section 255) that cover the
PSTN, right now it is unclear whether that extends to VoIP. If people
lose access to telecommunication because it moves to VoIP, they lose the
access that Congress provided with Section 255. The FCC has recognized
that and has had an open (unresolved) proceeding on this since 1999,
when it first issued its Section 255 rules.
As technology progresses, people with disabilities must be able,
along with the mainstream population, to benefit from that progress. And
with a rapidly aging population, the need for access by those with
functional limitations will only be growing.
Should all PSTN regulations carry forward?
The telecommunication regulatory obligations laid out by Congress
were created for a number of purposes, all dealing with important
societal issues that were not (and would not be) addressed by normal
market pressures. As we move from PSTN to VoIP, some of the market
dynamics are changing. Some believe that the problems with PSTN that
were not naturally addressed by market forces would be addressed by the
different market forces accompanying VoIP. The dynamics around
competition, for example are quite different.
Unfortunately, disability access is not one of the areas that will be
addressed by natural market forces. There are many new opportunities for
VoIP technologies to be of benefit to people with disabilities. And
there are people with some particular types or degrees of disability who
will find aspects of VoIP naturally easier to use - without regulation.
But there are no market forces to ensure that general access will be
provided or that the needs of people with most types and degrees of
disabilities will be addressed when their needs differ from mass-market
needs.
VoIP discussions already show that the aspects of VoIP that are
getting serious discussion are those where there are regulations and
those where there is enforcement (or threat of enforcement). In some
cases, better solutions are in fact passed over in favor of 'what will
minimally satisfy' current regulations.
This is not to say that there are not advocates for accessibility
within companies. There are. But they often find that they are unable to
internally sell their access initiatives in this highly competitive
market. It simply is not good business to pay attention or devote
resources to disability access if you are not required to - and more
importantly, if your competitors are not required to do so.
It is not only essential for access obligations to be in place, but
it is important that it be clear that they will be enforced. Otherwise
interested companies cannot afford to follow the regulations and risk
falling behind competitors that don't. Marketplace pressures have not,
are not, and will not cause telecommunication to be accessible to people
with disabilities and those who are aging in any but spotty,
idiosyncratic, and temporary ways. This is the reason there are so many
disability access laws - Section 255 for equipment and service
accessibility, the ADA for relay services, the HAC Act for hearing aid
compatibility. These laws were all needed because the market forces
alone could not respond to and address the needs of people with
disabilities.
Companies are not to blame for this. Profit driven companies are not
bad; they are the type we all want in our investment portfolios.
However, regulations are sometimes needed, and have an important role to
play in putting societal factors into the profit equations - and making
sure that those who address these issues are not put at a disadvantage
to those who do not.
Feasibility
The wonderful thing about VoIP is that this transmission format - and
the type of telecommunication technologies used to implement it - make
it easier to implement accessibility than previous telecommunication
technologies. For example, one VoIP company, AVAYA, has just released a
program that, when loaded onto the phone server, immediately allows
access to much of the phone functionality by people who are blind. And
this is done without any changes to the phones. With small changes to
the phone software itself, full access could be gained without any
hardware changes.
The Trace Center and Gallaudet are currently working with Cisco on a
technique which would allow every phone in an organization to be
instantly capable of text communication (with and without voice
carryover) by simply installing a software program in the call manager.
A deaf person could then walk up to any of the 10,000 phones in an
organization and communicate via text (or text and voice), without
needing any special equipment. In this manner they could use the phone
in their office, a colleague's office, the phone in the conference room,
or the one hanging on the lunch room wall. And this approach does not
require any changes to the phones themselves. It could be implemented
using the VoIP phones that are already installed.
These are just two examples. There are software features that can
address the broad range of disabilities. Some are completely
server-based. Some require only minor changes to the phone software. In
some cases, the techniques have been known for some time, but market
forces have prevented their implementation since they were not in the
'enforced regulation' category.
There is nothing about VoIP that makes accessibility harder overall
than with PSTN. And there are many places where it is much easier - and
where much more can be done. VoIP does present some new issues, but
solutions to these are already known. Yet we are hearing from those in
industry that, in many cases, they cannot move solutions forward until
it is clear that their company will either have advantage or at least
not be at a disadvantage if they devote time and resources to
implementing them.
Conclusion
It is both important and necessary to carry disability access
provisions forward to VoIP. The fact that the current FCC regulations
predicted and accommodated technology evolution allow them to carry
forward to this new technology. With enforced regulations, it will be
technically and commercially feasible and practical to implement them in
VoIP technologies - with great effect for people who are experiencing
disabilities, including those who are older.
Thank you for the opportunity to participate in this forum.
Respectfully,
Gregg Vanderheiden Ph.D. Professor University of Wisconsin- Madison
