Wednesday, May 11, 2005

PANEL DISCUSSION: Partnership Regulation Models

Host: Doug Brolly ( RBC Royal Bank bis Group )

Presenters: Ian Brodie (Canadian Standards Association, Canada ), Gerard Goggin (Disability Studies & Research Institute (DSaRI), University of Queensland, Australia ), Tim Noonan (SoftSpeak Consulting, Australia )

Presenter: Ian Brodie ( Canadian Standards Association , Canada )

Ian Brodie's presentation explored how standards are developed, where ideas for new standards come from and who writes them. The Canadian Standards Association (CSA) uses a consensus model in which it tries to get a broad base of stakeholders with diverse viewpoints on a particular subject area. Within this model, people with disabilities have a voice in developing standards relating to disability issues; they can submit requests for new standards, sit on committees, participate in the public review of drafts standards and have the opportunity to propose modifications to existing standards.

Brodie began by stating that there are four levels of standard development bodies; these bodies are distinguished by how the standards are created, who is involved in the development process and who respects the resulting standards:

1. Standards Development Organizations (SDO) - The Canadian Standards Association is one of four accredited SDO's in Canada. It is a not-for-profit membership-based association serving business, industry, government and consumers in Canada and the global marketplace.
   
   
2. The Standards Council of Canada (SCC) - This body is responsible for the accreditation of standards development organization's (SDO's) in Canada. They formally recognize SDO's competence to develop standards, and comply with specific accreditation criteria.
   
   
3. Bi/Tri-nation standards – These are standards that are created, agreed upon and respected by 2 or 3 countries. An example of Bi-nation standard is found in the electrical area between the US and Canada. NAFTA is an example of a Tri-nation body between Canada, the US and Mexico.
   
   
4. International standards - At this level, countries like Canada , the US, Europe, Asia, and Australia each have one voice in the development of standards. One benefit of international standards is that they make it easier for companies to develop products for the global market.

Brodie described CSA's model for standards development as a balance matrix where each committee consists of a chair, a project manager, associate members and corresponding members. When forming a committee, CSA looks for a balanced representation of people with interests in the ramifications of a specific standard. Brodie described the four categories of members who make up a committee:

• General Interests – These people have a keen interest in the area that the committee is involved with. "They could be researchers or from other areas that have potential overlap."
• Producer Interests – These people are interested in specific standards that will change the way they are currently manufacturing a product. They are also interested in the potential to develop new products that may be possible through the development of a new standard.
• User Interests – These are the people who are interested in the end products that standards lead to. They are seen as important to the process because they often provide valuable insight that may be overlooked by producers.
• Regulators – These people make sure legal restrictions are obeyed when new standards are developed.

Developing standards can be lengthy and expensive. Brodie explained how CSA's development process is funded.

"There are annual dues associated with corporate sustaining memberships. Money also comes from selling copies of the standards themselves but this is very minimal and doesn't offset development costs. They aren't a mass market item but we have some where we might be lucky to sell 50. On the other hand, some regarding electrical codes will sell hundreds of thousands of copies. Finally, it may be the case that industry associations or government departments feel that there's a need or that they would benefit from a standard in an area. In this case they would assist in the development cost in the form of a grant."

CSA standards development process:

1. Preliminary stage

When CSA receives a request for the development of a standard, it conducts an evaluation and the project is submitted for authorization. Requests are evaluated for costs/ benefits/ advantages to stakeholders and society. Requests can come from any interested person, organization, or committee. Brodie gave an example of a request that came from an individual.

The way standards originate certainly can be from an individual to a big industry association. About 35 years ago, there was an ophthalmologist in Toronto whose son was playing hockey and sustained a head injury. He started to look at what types of helmets were on the market and saw a very divergent spectrum in the quality of helmets. He approached CSA with a request and from there we started to develop safe hockey helmets and face protectors."

2. Proposal stage

If the new project is authorized, it is assigned to a steering committee which approves its scope and establishes a technical committee. From here a notice of intent to develop a standard is posted on the CSA website where interested parties can also keep up to date on the project.

3. Preparatory stage

A working draft of the standard is prepared and a project schedule is established. Brodie explained "The committee will go through a process of developing a draft. Depending on the area and depending on the stakeholders at the table, it could be a very harmonious process or it could be very adversarial."

4. Committee stage

The technical committee, facilitated by CSA staff, develops the technical content and reaches all its decisions by consensus.

5. Enquiry stage

The draft standard is offered to the public for review and comment for at least 60 days. Then the technical committee looks at the feed-back from the public, revises the standard and reaches an informal consensus on the technical content of the draft. Finally an internal quality audit ensures that the document complies with Canadian Standards Association policies and guidelines on drafting and presentation.

6. Approval stage

The technical committee approves the technical content of the standard.

7. Publication stage

CSA staff conducts a final edit to verify conformity with CSA's editorial and procedural requirements and then publishes and disseminates the standard. CSA's standards are translated and published in both official languages. Some standards related to disability issues have recently been made available in multiple formats.

8. Maintenance stage

The standard is maintained with the objective of keeping it up to date and technically valid. This may include the publication of amendments, the interpretation of a standard or clause, and a systematic review every five-years.

The committee will meet, or certainly monitor what's happening within the industry. They also consider what's happening around the world, just to keep current on the issue. If a particular standard is not being utilized very well and there's no stakeholder interest, we consider withdrawing it."

Brodie discussed what happens in the case of revisions.

"Within that five year time period we will produce an amendment if revisions are needed. In the case of the banking machine standard, an amendment was published to make some clarifications. If the standard really hasn't changed we'll reaffirm it, but if changes are needed, we'll produce a new edition."

Brodie explained that standards offer a variety of benefits, from facilitating innovation and the transfer of technologies, to improved product quality, consistency, and compatibility. Standards also provide industry with an effective marketing tool (e.g., "CSA certified") when consumers have a choice between similar products. He also noted that complying with standards has the potential to reduce a company's liability and that international standards help to reduce trade barriers between countries.

Discussion:

Deborah Stienstra (University of Manitoba) stated that she had done research regarding the trade of assistive devices between Canada and the US. Her research showed a lack of consistency between devices in the two countries. She told of a Canadian woman with a disability who had to purchase a visual doorbell in the United States because it wasn't available in Canada . "One of the things that came up often was the lack of consistency between devices in Canada and United States . Because of the open trading boundaries, the women thought they could just go over to the United States and buy the appropriate technology. When they brought it back, they discovered it wouldn't work with the electrical standards here." Stienstra questioned Brodie's earlier statement that international standards reduce trade barriers. "That wasn't at all the experience, rather there were no international standards that coordinated accessibility and therefore there were increased trade barriers for women getting access to these devices."

Brodie wasn't aware of that specific example, but said that each province implements its own electrical code and suggested that the product may have met CSA standards for accessibility but not necessarily from an electrical point of view. Another reason for this discrepancy may be found in the history of standards. Before the goal of international harmonization, national standards were sometimes used as technical barriers to trade and to a certain degree that is still happening. Finally, CSA standards are driven by the interest of specific communities, producers and consumers. Brodie said that general interest in assistive devices has waned and it is difficult to get stakeholders to the table in order to create new standards.

Steve Jacobs ( IDEAL Group, Inc .) noted that different companies may not implement a standard in the same way, which results in a worldwide problem related to interoperability and compatibility between AT and mainstream products. He asked "what can be done to help ensure that companies follow the standard when it comes to designing the points of interconnection between AT and regular ICT."  Brodie responded that these types of interoperability problems may not be recognized by the CSA committee members. "Getting that feedback back to the committee members is important and will reduce these types of problems. The people that are using the standard need to feed-back in and tell them the issues so they can do something about it."

Gerard Goggin ( Disability Studies & Research Institute (DSaRI), University of Queensland )

reiterated the importance of the committee structure in producing a successful standard and raised a concern that is being addressed in Australia . "How do groups that don't have many resources, let's say representative organizations of people with disabilities, get the resources to participate in the standards process?" Brodie explained that participation from people on committees is strictly on a volunteer basis. However CSA can provide some funding on an individual case basis "for example, if there was a person representing the disability community that was really keen, willing to participate and make a contribution, we'll certainly look at funding their traveling expenses."

James Watzke ( British Columbia Institute of Technology ) commended CSA for their involvement in the creation of standards that affect persons with disabilities. Watzke said "It's not just persons with disabilities. If I'm a person with a disability and I have a child who plays in playgrounds, they have standards for that, so it ends up being quite a landscape. CSA is working very hard to include concepts like accessibility, inclusivity and usability into the standards development process." That being said, Watzke commented that at some point a standards committee has to draw the line when considering accessibility.

"I've been on committees for CSA where, whether it's banking or something else, where you start to look at interface issues, and the next thing you know we've gone from figuring out a banking machine standard to what would a headset standard look like and the next thing you know you're into Wi-Fi and Blackberry. There has to be a limiting scope or the committee would never get their hands around their charged task. That's just a reality of standards development."

Watzke mentioned that when developing a standard the end users are only one stakeholder and the business reality can not be ignored.

"CSA actually commissioned our group the British Columbia Institute of Technology (BCIT) to look into the question of whether more standards for assistive technology are needed. We surveyed all the regulators, the vendors, and all the big assistive technology providers in Canada and they said 'no, we're not sure we want to be regulated', and CSA had to respect that input. Ultimately there is a business case that has to be built for a standard. Ian doesn't like it when they go to all the trouble of dealing with accessibility, inclusivity and usability issues, then no one adopts or takes up the standard, it's not good for anyone."

Watzke stated that the voice of the end user is important and valued in the standards development process.

"Persons with disabilities can go to CSA's website and learn about new standards coming out that potentially involve accessibility issues. People like Laurie, need to say 'hey, what about interoperability?' because then the committee will get that feedback and at least it will be put on their radar screen. There is a role for advocacy. It's not chaos, its not free floating, there is a process in place to take that feedback and I can promise you, I've been on those committees, we will pay attention to it, because we're mandated by our project manager and CSA to do that."

Referring to Watzke's earlier comment that standards committees need to draw the line when dealing with accessibility issues, Steve Jacobs agreed that an AT design company would not like to be confined by a tight standard that may restrict design process. However in his experience the Assistive Technology Industry Association (ATIA) wants standards relating to interoperability.

"I refer to a simple 'handshake' as the point at which an AT product, designed with the creative genius of a company, interfaces with a computer. I'm not talking ABM's, I'm talking standard computer interfaces and standard AT device interfaces. That is the point at which you find a lot of compatibility issues. My experience has been that, ATIA lists this interoperability problem as one of the top issues to address. It's just the opposite of having no interest in being regulated. They want to have everyone adhere to the way that the 'handshake' is implemented or designed, doing so would solve a lot of problems."

Jacobs asked if it is possible to have an individual who is very knowledgeable about this handshake sit on every committee regarding the development of AT standards. Watzke stated that a committee member may have some knowledge in this interface area but there is not usually a person with that specific role. He also pointed out that the way an AT device communicates with a computer gets very close to being a proprietary issue.

"Standards committees are very careful about removing competitive advantage, and in fact they are often the minimum standard. For example, if a company feels their handset is one of their strong points and better than the rest, they don't want to be restricted by a standard. A standards committee would have to be very careful about trying to put some structure to that. A company's interface is proprietary and can become a barrier for people that are creating AT that interfaces with other technology in very special ways."

Mary Frances Laughton ( Industry Canada ) said it is important to note that CSA is just one of several standard setting bodies involved with information and communications technologies in Canada .

"I think we tend to hear the word 'Canadian Standards Association' and think that they do it all. The Treasury Board Secretariat of the Government of Canada sets a bunch of information technology standards. There's the International Telecommunications Union , there's a whole body of standard setting organizations, and the Standards Council of Canada is the over-arching body. They look at standard setting in Canada and try to collaborate and coordinate these kinds of activities."

She informed everyone that "The joint technical committee of the International Organization for Standardization is in the process of looking at the whole gamut of accessibility standards, from stem to stern, and they're going to be looking at gap analyses at needs studies and requirements documents. I encourage all of you to participate in this, because we need end user involvement. This is where the rubber is going to hit the road, and this is where people will be able to participate."

Presenter: Gerard Goggin ( Disability Studies & Research Institute (DSaRI), University of Queensland , Australia )

Gerard Goggin discussed the government-industry-consumer body that regulates the Australian telecommunications and networked digital technologies industry as well as collaborative partnerships in the development of standards for online banking and e-commerce accessibility. Goggin reviewed the self-regulatory institutions in the Australian telecommunications environment, the chronology and details of which are discussed in the article, "Fostering Universal Access: Lessons from Telecommunications and Disability," by Christopher Newell, Gerard Goggin, Gunela Astbrink, and Holly Raiche. Goggin offered an intellectual framework for understanding the session topic, drawing on his experience as a Policy Advisor during the 1990s for the Consumers' Telecommunications Network and as an Australian Research Fellow at the University of Queensland.

Goggin referred to Digital Disability , a book he co-authored with Christopher Newell, in which they suggest that the Australian context of disability studies and technology differs from the US and UK contexts, as it is "located in a particular national formation with disability with its own characteristics and has historical and political specificity and an intellectual tradition as well." Goggin and Newell's work draw on the social study of science and technology, including the work of Bruno Latour, who explores how technology is socially constructed or shaped. "In Bruno Latour's work, he talks about the sense in which both society and technology are produced together; they're not necessarily pre-existing things. And I think there's a deep insight there."

In Australia during the 1980s and 1990s, there was a shift in Australia from government-owned agencies delivering telecommunications to the privatization of Telstra , its national carrier. With the telecommunications reforms in the late 1980s, Goggin explained, "a whole kind of dispensation was being dismantled around the world." Information and communications technologies became important to consumer organizations and disability organizations, and in 1989, the consumer movement set up the Consumers' Telecommunications Network . It focused on telecommunications issues, and disability organizations "had a very critical role." He pointed out that a difficulty for the disability community was finding available resources to become involved in accessible technology issues.

"One of the issues that emerged for a number of the groups was, when you're a disability organization and you're thinking about health, housing, welfare, transport, a whole range of other issues, how do you actually make the time, with your scarce resources to deal with an issue that needs quite a degree of specialized skills, and requires people to be involved in processes for quite a while."

In 1996-7, at the time that Telstra was being privatized, "a compromise was crafted" in the Australia parliament for legislating funding for research in the consumer aspect of telecommunications and to support advocacy and representation groups. Goggin asserted that this national funding was a pivotal moment that provided "enough resources to keep a core set of people in these processes over a decade" in the areas of accessibility and disability in telecommunications in Australia .

In July 2005, the Australian Broadcasters Authority and the Australian Communications Authority converged to form the Australian Communications and Media Authority (ACMA). The ACMA regulates telecommunications and broadcasting, however, there is still a separate Telecommunications Act and Broadcasting Act , and Goggin pointed out, a whole set of services (e.g., mobile services, mobile SMS and multimedia messaging (MMS)) are on "the interface between telecommunications and broadcasting." He identified "mobile space" as one for which there are no traditions for thinking about or for regulating.

"We've got these traditions of thinking about telecommunications, IT and about computers, these traditions of thinking about broadcasting, about television and radio, and now the internet as well. …What's happening in that scene between telecommunications and the broadcasting, for instance, in mobile space?"

Goggin then shifted to focus on the Australian Communications Industry Forum (ACIF), formed by the telecommunications industry in 1997, and the ACIF Disability Advisory Body (DAB), formed in 1998, as a case study of international interest in the area of disability, accessibility, and inclusive technology. ACIF is an industry-owned, operated, and resourced company that "sits alongside" the ACMA , the Department of Communications, Information Technology and the Arts , and Standards Australia . Goggin defined ACIF as "industry's institutionalization of self regulation" whose role is to implement and manage the communications self-regulation in Australia and "to develop and administer technical and operating arrangements that promote both the long-term interests of end users and the efficiency of international competitiveness in the Australian communications industry."

The DAB meets quarterly and reviews the whole program of ACIF and "provides advice to that body [ACIF] regarding the implications for people with disabilities of its proposed codes, standards and other publications. So it's providing a kind of watchdog or monitoring role across the whole set of codes and guidelines that ACIF does." DAB is chaired by Christopher Newell ( Australian Federation of Disability Organizations ), and is comprised of representatives from the following organizations:

• Communications Aid Users Society
• TEDICORE (Telecommunications Disability and Consumer Representation)
• Women with Disabilities Australia
• Australian Rehabilitation and Assistive Technology Association
• Australian Association of the Deaf
• Physical Disability Council of Australia
• Blind Citizens Australia
• Deafness Forum of Australia
• ACIF project management

Goggin then discussed four achievements of DAB, including

• ACIF G586: 2001 Access to Telecommunications for People with Disabilities Industry Guidelines
• ACIF Any-To-Any Text Connectivity Project
• ACIF Next Generations Network Project
• Fostering Professional Development

DAB authored the ACIF G586: 2001 Access to Telecommunications for People with Disabilities Industry Guidelines in order to "materialize and concretize" what ACIF needs to do to meet its responsibilities under the Telecommunications Act and the Disability Discrimination Act and "to assist the industry forum and its reference groups and working committees to provide equity in access to telecommunications for people with disabilities." These guidelines were informed by international legislation and research and are applied in the development of all ACIF codes and standards.

"In developing this approach with the guidelines, the Disability Advisory Body endorsed a telecommunications charter of the European Union's COST 219 bis, and they'd endorsed this telecommunications charter as a statement of principles for the guidelines and as a means of improving access and equity in Australian telecommunications for people with disabilities."

The Any-To-Any Text Connectivity Project began in 2003 when members of DAB helped to establish the Any-To-Any Text Connectivity Options Working Group. Its purpose is to look at both short-term and long-term real-time text communication issues with a focus on the support of Text Telephony for people who are deaf, people who have hearing impairment, and people who have speech impairment. They also recognize the communications needs of people with intellectual impairment and people with physical impairments.

"Initially the activity is concentrating on the short-term, but the longer-term aim is merely to try and move towards and embody that vision of Any-To-Any Text Connectivity for all those using text or video available at home, at the workplace and on the move."

In 2002 ACIF launched The Next Generations Network Project which was an initiative of DAB. This project involved switched telecommunications networks which are for the most part packet based. DAB's presence in ACIF will ensure that accessibility issues are considered in the upcoming Next Generation Network environment. The ACIF DAB also provided professional development to ACIF staff and key industry participants about telecommunications needs, providing "a mechanism that tried to embed accessibility into all the various aspects of the telecommunications industry."

Goggin concluded that one of the disappointments experienced by the ACIF DAB is that Voice over Internet Protocol (VoIP) "has largely escaped these kinds of processes." He mentioned that ACIF is "still quite an industry-dominated body" and that there is a fragility that results from the tensions in the structure of the organization itself, such as a change in CEO.

"There are certain fragilities in this particular kind of initiative [DAB]—that on the one hand is a cooperative issue between industry and consumers, on the other hand has the dynamics that can change very quickly."

Presenter: Tim Noonan ( SoftSpeak Consulting , Australia)

Tim Noonan discussed collaborative partnerships in the development of standards and how to engage industry to make accessible information technology through the use of standards in the Australian context. He described his involvement on various standards committees and in various accessibility research for organizations such as Standards Australia , Australian Bankers' Association (ABA), the Australian Government's AccessAbility program, and the Smart Internet Technology Cooperative Research Centre (CRC). Noonan has represented various technical and disability organizations on these committees and in his research, including the Australian Telecommunications Users Group (ATUG) and Blind Citizens Australia . He spoke as an expert in technology and disability issues who "is bringing across the wealth of experience and wisdom of the disability community" in order to "bring those types of learning's across to mainstream non-visual user interface design." Noonan began his discussion about the service that allows people to access e-mails via telephone.

"They force the listener to listen to all of the header items in an email that the designer considered worth including, even though everyone often wishes to jump over much of the repetitive, detailed sequentially presented header information. Then its necessary to listen "read" through the entire body of the email with no ability to pause, adjust the speed while you're listening, rewind and rehear something you missed, or check the spelling of something that you might need to know, or to skip forward by paragraphs, in order to skip unimportant content. So in the work that I've been developing at Vision Australia , we're trying to bring a lot of the screen reading functionality, but in a much more user-centered approach."

In the early 1990s, Noonan sat on a Standards Australia committee that was looking at accessible TTY (text telephones), ensuring that the needs of people who are deaf and blind were accommodated.  This was difficult because there was no existing standardization for input/output ports on TTY devices, and there had been strict electrical isolation requirements in Australia which impact import options. Tim also represented ATUG (the Australian Telecommunications Users Group) on the Australian standard for the user interface implementations on automated telephone services (IVRs) which published AS/NZS 4263. Although he was not representing a disability organization, Noonan made sure to get "disabilities and the needs of people with disabilities embodied in the standard." The committee excluded voicemail from the scope of the standard due to the existing "heterogeneous range of voicemail systems," however, they succeeded in creating a standard that reflected the experience of the user, followed conventions, and was centered around human factors and cognitive psychology principles of human information processing. "The Australian context has demonstrated that a reasonably well-centered collaborative standard can result in much more consistent user experiences such as consistency, in our context—zero for telephone operator, nine to initiate a hang-up, one for yes and two for no."

Noonan pointed out that by contrast, in the US , most products have randomly chosen any assignment of keys. The success of embedding accessibility and disability issues in standards development, Noonan stated, ultimately depends on who the chairperson of the committee is "what makes or breaks participation on a national standards board in my experience, is the chairperson of the committee, which is usually from the industry." He added, "if you don't have a good secretary who works for the standards body, is disability aware and interested, then it's a really hard and arduous process."

From 1998-2002 the Australian Government AccessAbility program funded projects to assist people with disabilities to gain improved access to online information and communications services. Through this funding, Blind Citizens Australia engaged Noonan to research aspects of online accessibility which resulted in the report, " Accessible E-Commerce in Australia: A Discussion Paper about the Effects of Electronic Commerce Developments on People with Disabilities ." The purpose of this report was "to research, assimilate, synthesize and draw together research going on in different parts of the world—possible barriers, but also to identify and highlight opportunities of emerging technologies – such as the move away from paper as the sole medium for financial transactions."

During the 1990s the Australian Bankers' Association ( ABA) developed four industry standards that addressed accessibility issues in response to human rights complaints lodged with the Australian Human Rights and Equal Opportunity Commission . The four standards were for telephone banking, electronic funds transfer point of sale (EFTPOS), internet banking, and automatic telemachines. In the research they conducted on banking standards around the world, according to Noonan "the Canadian standard was certainly written in plainer English than anything else." Noonan's role was to consult the disability community and report to the ABA project manager. The most recent challenge, Noonan reported, has to do with advertising in ABMs that have switched to built-in speech; listening to advertisements, he argues, should be optional for people with disabilities.

Noonan moved on to discuss Smart Internet CRC (Cooperative Research Centre), the most recent example of collaborative partnerships in Australia he was involved in, which is "a joint venture with the main objective of commercializing innovative technology. The CRC is made up of universities, manufacturers & industry, and government." In addition to profitable commercialization, this CRC was also very interested in raising awareness of inclusive design—not assistive technology, but for mainstream technology that includes having good design allowing it to be used by a wider range of people including people with disabilities. CRC has strengths in both the area of technical engineering as well as user experience and input, due to various ethnographic and usability studies, and engagement with focus groups. For example, in an ethnographic study on speech recognition software, Noonan related the comments of a focus group participant who said she felt "stupid" talking to a computer in front of her husband. He emphasized that "ultimately the choice has to come down to the consumer. And if you don't do the research of what the consumer or end user is going to want, and you make any assumptions, the probability for a product failing is multiplied over and over again." He added that the speed of technology progress compared to the somewhat protracted bureaucratic process of funding allotment, and the relatively modest budgets available, has been a disadvantage for this project in the CRC in its recent attempt to develop a particular telecommunications prototype device. "it took ages to get the funding request to come through, so by the time it was approved, technology had sort of marched on outside of this entity."

Noonan concluded that companies that develop and manufacture mainstream products often don't understand disability and accessibility issues, and associate these considerations with "higher risks of failure." He called for disability expertise to be integral in the design process, the importance of which Research In Motion (RIM) has recently recognized through their Accessibility Program, as well as larger companies like Microsoft. Otherwise, he cautioned, a range of products, including digital radio receivers and handheld digital voice recorders, are unusable – just as an example – by people who are blind, or people who don't have their vision available at the time.

"There's a whole range of devices that use audio for 99% of their operations and then require a visual interface for that one percent, but that one percent might be just the process of knowing if the machine is on or off, if it is a mini disc recorder, whether it's in pause mode or actually recording, etc."

Discussion:

Steve Jacobs ( IDEAL Group, Inc .) raised the issue of Voice over Internet Protocol (VoIP), calling it an "important problem" in the US and internationally due to the lack of regulatory processes for ensuring accessibility. He explained that the US Federal Communications Commission (FCC) considers VoIP to be an information service as opposed to a telecommunications service.

"What this means to the disability community, at least in the US , if Voice over IP becomes what it is fast becoming, none of the protections afforded by the Telecommunication Act [of 1996] will cover it. The FCC is not in the business of covering information services. If you look at television over the internet, video over the internet, all of the e-services, e-learning, any kind of e-commerce at all, e-health, telemedicine—none of that is going to fall within the jurisdiction of the FCC. There are no teeth to go after a company that designs something that's not accessible. This is something we're up in arms about and we are preparing ourselves to work with Congress this year, during this session, to try and correct or minimize the impact of this."

Goggin acknowledged that in Australia , VoIP "hasn't been clearly recognized and thematized by the disability community or to some extent by the consumer movement." Nor has the Australian government put the issue of VoIP and accessibility to the regulating body, the Australian Communications and Media Authority (ACMA), or to the Australian Communications Industry Forum (ACIF). Goggin described VoIP to be at the "interface between protocols, codes and the networks," which raises questions about the politics of networks. He commented that "certain sets of expectations about accessibility were embedded into [telecommunications] regimes around the world." In the US , the concept of "universal service" was developed with respect to telecommunications, whereas "public service" has been more of a concept in European jurisdictions. He concluded that a key issue has to do with the difficulty of addressing accessibility and rights issues within the current and fast-paced world of technology. "How do we translate some of our concepts about fairness, obligations relating to access and equity, across the different things that now make up our ICT's environment and our digital environment?"

Laurie Beachell ( Council of Canadians with Disabilities ) addressed the difficulty for cross-disability organizations to find a useful way to address the complex issues of access and technology. "We have challenges enough in resourcing the existing structures, but when you get into this complexity, there has to be a body of knowledge and expertise that comes together."

Noonan commented that the complexity of the issue of technology and access has increased in recent years. "As we get to multi-media and all this layering that occurs, the challenges got harder on some levels and easier on others." He listed the Australian Rehabilitation and Assistive Technology Association (ARATA), an organization similar to the Rehabilitation Engineering and Assistive Technology Society of North America (RESNA), as one that addresses access and technology issues, however, its greater focus is on physical disability, rehabilitation, and often comes from the medical model of disability . There is cross-disability representation in telecommunications and banking committees, however, in Noonan's personal opinion, the cross-disability perspective is not always optimally represented in Australia. "I'd say in Australia we could have more good thinkers who are cross-disability focused as well as being technically strong."

Goggin described a number of ways in which the cross-disability perspective has been maintained throughout the telecommunications experience, despite "a weakened coordination structure nationally in Australia in the latter part of the 1990's." Key people (e.g., Christopher Newell) have "embodied" and "been very insistent" about the cross-disability perspective. Goggin also listed the Australian Communications and Industry Forum (ACIF), ACIF Disability Advisory Body , and the Australian Federation of Disability Organizations (AFDO) as organizations that integrate the cross-disability experience to address access and technology issues. The AFDO, similarly to the Council of Canadians with Disabilities (CCD), Goggin explained, "have many other things on their plate and it's very hard to carve out the time for access and technology issues, but there's a strategic opportunity to paint a big picture that's a way to say 'look, this area is so pervasive in everyone's lives—it's just so extraordinarily pervasive. Citizenship is such a key dimension."

Deborah Stienstra ( University of Manitoba ) directed participants to Digital Disability: The Social Construction of Disability in New Media by Gerard Goggin and Christopher Newell for a detailed documentation of key test cases with the Australian Human Rights and Equal Opportunity Commission (HREOC) on access to technology issues and people with disabilities that involved litigation by disability organizations such as Disabled Peoples' International (DPI).

ROUNDTABLE: From Technical Innovation to Innovative Thinking

Presenters: Steve Jacobs (IDEAL Group, Inc.), Umang Dua (Issist), Jeff Pledger (AbleTV.net)

Presenter: Steve Jacobs ( IDEAL Group, Inc .)

In his presentation Steve Jacobs examined the competitive advantages available to businesses that recognize the broader global market implications of technologies designed to accommodate people with disabilities. Using an online conference system, Jacobs was able to broadcast his presentation to several people in Canada and the United States . He stressed that this technology has many benefits as an educational tool; it creates a fully accessible environment and long distance charges don't apply.

Jacobs explained that "The purpose of this session is to talk about emerging technology and its impact on the relationship between people with disabilities and Information and Communications Technology (ITC) manufacturers. We'll talk about policy issues and opportunities." Giving a brief background, Jacobs explained that there is a paradigm shift occurring which is "redefining, and in some instances complicating the relationship between people with disabilities and ICT manufacturers."

Jacobs said that the disability community often asks; "What compels ICT manufacturers to design for access, other than money?" He used the acronym "compels" to list the major factors:

C – Cultural
O – Organizational
M – Moral
P – Political
E – Ethical
L – Legal
S – Social

"All of these influencers are very important, and without them, I don't think we would have accessible design. I can only speak with reference to the US , but I can tell you without laws, standards and guidelines, the state of accessible ICT would not be where it is today. And that has nothing to do with money; it mostly has to do with the law and political pressure."

Using the same acronym, but with different words, Jacobs described the most powerful market force that compels ICT manufacturers to design for access – money.

C – Canadian dollar
O – Ouguiya (Mauritanian Currency)
M – Markkaa (Finland)
P – Pesos
E – Euro
L – Lira
S – Schilling

"Now somewhere between the two different types of forces, there has to be a happy medium. Industry needs to make money, but yet they may need to do things that they can't cost justify, and that's where the laws come into play."

Jacobs turned the discussion to examples of the potential business benefits of accessible design in the mainstream, noting that "in and of itself the business case may not be all that you want to focus on when you work with industry, but there are some quite appealing business cases for accessible design."

Jacobs described five technologies that are now in mainstream use which originated as assistive technologies:

1. word prediction technology
2. text-to-speech technology
3. plain language
4. captioning technologies
5. accessible webpage design

Word prediction software saves keystrokes by predicting words as you type. As characters are typed, word prediction software revises a "pick list." When the desired word or phrase appears, it can be selected and will automatically update what is being typed.

"Word prediction technology was originally designed to help people with mobility and cognitive disabilities to type more easily. This technology is now enabling PDA and cell phone manufacturers to design mainstream products with easier to enter text."

To illustrate, Jacobs showed examples of a cell phone and personal digital assistant (PDA) that use word prediction technology, the later in Chinese.

"Word prediction cuts down the number of button presses. The user first sees the words being predicted displayed across the bottom of the screen. The user then arrows to select the word and presses a key.  With a little practice one can get pretty proficient at doing this…It is an unbelievable time saver. You cannot have a complex enough keyboard on a small PDA to enter Chinese text, but thanks to pioneering work that was done in the disability community, mainstream companies are able to capitalize on this technology."

Text-to-speech technology allows an alternate spoken method for conveying textual information. As the name implies, text-to-speech convert's electronic text into the spoken word, and was originally designed in support of people who are blind. Instead of pre-recording and playing back digitized human speech, synthesized speech is computer-based and is used to speak-out words and phrases. In the past the biggest complaint of consumers was that computer speech sounded too much like a computer. Now, the technology has evolved to a point where you can even choose dialects of a language.  In some cases it's difficult to tell the difference between a synthesized piece of speech and somebody actually speaking it.

"Text-to-speech technologies that accommodate people who are blind, hold potential to assist people who never learned to read. In just the top 20 developing countries there are 740 million consumers who never learned to read. If you're developing e-commerce or e-learning applications or manufacturing PDA's that require the user be able to read, you are limiting your market. If you implement text-to-speech technology in the correct way, it is possible to accommodate people who never learned or can't read."

Originally used as a way to support children who are deaf and people with cognitive reading disabilities, plain language is clear, straightforward written expression, using only as many words as necessary. Recognized for its usefulness, Jacobs explained that plain language has been adopted by governments and businesses.

"Plain language is a practice that is used by the Canadian, US, Australian and UK government, to craft content for laws, standards, guidelines, and medical documents that are more understandable to an average reader. The business benefit of using plain language is that it translates less expensively into other languages. For companies designing content for translation, writing in plain language can save them up to 30 percent of the cost normally associated with translation. The reason it's less expensive is because you use a less words, machine translation is more accurate and therefore less human intervention is needed."

Captioning technology was developed to accommodate people who are deaf by allowing them to read a transcript or dialogue of the audio portion of a video, film, or other presentation in real-time. The resulting transcripts can now be used to do precise word searches of television and videos. Finding specific footage was a time-consuming process, now it is possible to quickly search through video by looking at the captioning for key-words or names. As a demonstration, Jacobs conducted a search for video footage containing Paul Martin, by clicking on that video footage he was able to play that clip. This type of service has proven profitable to the companies offer it.

Originally intended to increase access for people with disabilities, accessible web design is also useful when transcoding pages into wireless formats for PDA's (Blackberries or cell phones). In order to display a webpage on a PDA, the site must be converted into a different format (transcoding). These transcoded pages also allow users to successfully display websites in areas of the world where high-bandwidth in not available..

"The same techniques used to make e-commerce websites accessible to people with disabilities, makes it easier and less expensive to transcode web content into wireless formats used on devices such as PDA's or a cell phones. If you consider that worldwide, there are 3.6 billion consumers living in low-bandwidth environments that have less than one percent of the bandwidth per person than we do in the US, and less than half a percent of the available bandwidth that you have in Canada, it really makes sense to design WebPages to be accessible. For companies wanting to establish an international presence, especially in low bandwidth infrastructures, designing their websites to be accessible will allow them to transcode the pages automatically and then use it cross-platform very effectively."

Jacobs explained that "In order to facilitate change within a company that encourages them to embrace accessible design methodologies, one needs to gain a more in depth understanding of how companies operate.  We have heard presentations over the past day-and-a-half that have stressed that point. You really need to understand how businesses operate, talk their language, know what their hot buttons are, and know what is technically feasible and economically possible in the area of accessible design."

When speaking about integrating accessible design practices into the core of a company's business practices, Jacobs described a continuum of five major steps:

1. latent stage
2. emerging stage
3. consolidation stage
4. institutionalization stage
5. proactive embracement stage

In the latent stage the company has totally ignored or dismissed designing for access. The emerging stage is where most major companies are at, beginning to experiment with approaches dealing with accessibility. At the consolidation stage there is litigation and an expanding view of the need for legislation. Jacobs described legislation as very important because "it's a catalyst for driving people to this stage and beyond it. You can't really do without it." In the institutionalization stage legislation and business norms are established. Jacobs stated that there are fewer companies at this stage. Companies in the proactive embracement stage , the highest level, "realize that accessible ICT design practices are integral to the realities of globalization, having nothing to do with disabilities, are a major source of learning for their employees, are relevant to core business objectives and strategies, drive cost efficiencies through economies of scale and drive mainstream competitive advantage."

In order to assess whether or not attitudes might be a root cause for ignoring the business opportunities surrounding accessible ICT design, one must understand and be able to quantify access-focused attitudes in the corporate environment. Jacobs described five levels related to the evolution of accessible design attitudes:

1. Negative and defensive
2. Negative but compliant
3. Management neutral
4. Positive and strategic
5. Positive, proactive, mainstream integration

Jacobs stated " Negative and defensive is the lowest stage and a company in this state denies accessible ICT design practices and outcomes. They just think it has nothing to do with anything; they're not in that business." Negative but compliant describes a company that adopts a policy based IT access compliance approach as a cost of doing business. Jacobs described their attitude. "You know doggone it, we have to do this, I don't want to get sued, we're just going to do it, but we're not going to do any more than what we have to." At the management neutral stage , Jacobs explains that "Companies have embedded accessible ICT design and information in their core business management practices. They have policies, practices, procedures that profess to include instructions on what to do to design more accessible products." Companies at the positive and strategic stage integrate accessible ICT design practices into their core business strategies. Jacobs stated "The fifth level is described as promoting broad based industry participation in accessible IC design practices. Not only does the company design for access, but they encourage other companies to do the same."

Discussion:

An audience member asked Steve Jacobs if he observed companies at all the different levels of attitude with respect to accessible design practices. Jacobs responded by saying that he doesn't know of any companies at the top level and only knows of a very few at the fourth. He added that it takes people, like the ones attending and presenting at this institute, to facilitate this change.

Gerard Goggin commented that the examples Jacobs gave of companies profiting or saving money from accessible design seemed compelling. He then asked how companies are embracing these market driving forces that stimulate the design of more accessible technology.

Jacobs explained companies have not yet fully embraced these forces.

"I wish I could say that everybody is just jumping over each other to design for access. When we approach companies, we simply describe some of the market forces previously mentioned and then suggest that company management consider them when building their company's strategic long range business plan. There are risks and opportunities, and it should go in that section of their plan. We don't try to tell a company that they could make more money designing for access; they have to come to that conclusion themselves."

Jacobs explained some of the reason why some companies have incorporated accessible design.

"Cell phone manufacturers and broadcasting companies do not follow accessible design principles because people in the disability community threatened to sue them… they do it because they identified it as a mainstream opportunity for an existing technology."

Marie-Lynn Hamilton (Independent Living Resource Centre Winnipeg) noted that Jacobs' presentation dealt with technologies developed for people with disabilities that were subsequently adopted in mainstream products. She asked him if assistive technology companies ever get ideas or use technology from mainstream companies. Jacobs recalled Dr. Andrew Junker, founder of Brain Actuated Technologies , who worked for the US Air force for 20 years as a research scientist. He worked on a band that goes around a jetfighter pilot's head that detects brain and muscle signals. With this band on a fighter pilot is able to control the temperature of his cockpit simply by thinking a certain way. Jacobs explained the application of this technology in the disability community.

"Andrew Junker commercialized this into the disability community [as a product called brain fingers] to enable people with ALS, who have no real control over many muscles in their body, to use a computer. I've demonstrated this product on television; using a computer, I controlled a mouse through a maze without touching a keyboard or a mouse, just through movements of my eyes. It's not an eye gaze system, it's the current generated by the muscles contracting in your eyes and relaxing."

Presenter: Umang Dua ( Issist )

Umang Dua is a principal at Issist, a Canadian based company dedicated to providing affordable accessibility solutions for people with disabilities. Dua's presentation dealt with Issist's business model of giving its iZoom screen magnification software to individuals with disabilities for free, but charging companies/organizations to install the software on their websites. "One of the goals that we had when we started Issist was that we've got to bring down the cost of assistive technology, because it's really ridiculously expensive if you try to buy it yourself. Even with a full-time job I can't afford assistive software."

Dua sited examples of assistive technology (AT) that are very expensive and raised the point that people with disabilities are associated with low employment rate and therefore can't afford such software and devices. "The last statistic I read was 70 percent of those with disabilities, or at least with visual impairments or who are blind are unemployed."

Dua argued that assistive technology is expensive for two main reasons. First, there is a small market for such technology.

"If you have a mainstream application like Microsoft Office, there are so many more consumers, which makes it relatively cheap. It is because of economies of scale that assistive technology vendors have to mark up the prices for their software. They have to maintain their infrastructure, develop new software, do upgrades, etc… that's why it's really expensive."

Secondly Dua explained that another reason assistive technology is so expensive is because much of it is purchased by organizations rather than individual users.

"A lot of the purchases are made by rehabilitation centres, high schools, universities, hospitals, etc… and not by end users. These organizations have to buy it for legal reasons and of course they also have to buy it for their customers, or students etc. [If I'm a developer] and I know that a grant is going to pay for my software, I'll mark it up as high as possible, because it's not coming out of the end user's pocket, or only a small percentage is."

Dua described how the high unemployment rate of people with disabilities is related to and perpetuated by limited access to technology, increasing the divide between people with disabilities and those without disabilities.

"Let's say I'm visually impaired, I want to go to monster.com to look for a job. I don't have a screen magnifier so I can't go to that website, and I don't have a screen magnifier because I can't afford it unless I have a job. You see the vicious circle that goes on from there."

Shifting his focus to mainstream software and website design, Dua stated that most mainstream software and websites are not designed with accessibility in mind.

"The statistic that I read was that 98% of websites are not compliant with accessibility guidelines. If accessibility helps so many people, and in some cases help businesses, why don't companies make their software or their websites accessible?"

To support his claim that accessibility is often ignored, Dua referred to a 2001 survey of 25 companies that develop educational software for children. "Sixty five percent of those companies were not aware of accessibility as an issue. They didn't even know anything about it. None of them are currently addressing accessibility, and 88 percent had no plans to do it in the future." Upon further investigation it was discovered that there were two main reasons these companies had not produced accessible software.

"They assumed that the assistive technology industry was responsible for making their software compatible with the mainstream software vendors. They also stated that their quality assurance department just didn't have time to broaden its testing reach. This was primarily because they didn't factor accessibility in from day one; a lot of people will try to add patches later on, and that tends to be much more expensive"

Dua suggested that one solution to the problem of accessible software being so expensive is for assistive technology vendors to partner with mainstream software vendors. This partnership can make these products free to end users. Dua provided examples to support his claim.

"Let's take the example of Issist. We develop a piece of software (iZoom) which is a screen magnifier. We can go to a website owner and say 'we can improve the accessibility at your website if you partner with us.' We work with businesses in order to generate revenue. We don't charge end users for our software and I think that's a better business model in the long run. The end result of using this business model is that it will drive the prices for AT software down because it will bring in natural competitive market forces.

When there are no grants and companies are able to sustain themselves without any grants being put in from end users for their software because they're working with businesses, it will bring more natural market forces, and more competitive market forces (inaudible) competition. And that will drive prices down for end users." [Umang, can you help clarify this]

Dua explained that this business model is not unique to Issist, and described three other companies that generate revenue this way.

" Texthelp is a company that has a product called Browsealoud that will read out anything that you place your mouse over. So if you visit a webpage that has been speech enabled by Texthelp, it will read it out to you. Readspeaker is another software that does something similar. It reads out an entire webpage in real time, but it's not just whatever you put your mouse over, it will read out the webpage in a linear fashion. UsableNet is a company that has a product called LIFT Text Transcoder , which can convert any webpage into text. They have a modified version of that that they market for websites."

Dua said that each of these companies could have sold their software directly to end users, but have chosen to sell to websites. "That is how," he explained, "the end user gets to use a piece of software for free."

Although Issist launched iZoom only two months before his presentation, Dua said that feedback from end users has been very positive.

"Similar software costs three or four digits easily if you buy it from other vendors. We've really received positive feedback because of this, and it really gives us a positive image. People really like our software, because it's free."

Dua concluded by emphasizing the benefits of partnerships between mainstream and assistive technology vendors. "AT vendors like to partner with other businesses to make their software more accessible instead of charging end users an exorbitant price for the software. This partnership with mainstream companies generates additional revenues for the AT vendors, so they can bring their prices down for end users."

Discussion:

An audience member questioned the proposed business model and wondered how it can actually work.

"The model requires that the developers make a financial investment in accessibility and yet you presented research that shows that 98 percent of websites are not in compliance with accessibility guidelines. If people aren't following accessible design principals in the initial phase of development, how are you going to convince them to pay for something like this?"

Dua responded by giving an example of a company that Issist increased their potential customers and therefore revenue by incorporating a product from.

" Netgrocer is an on-line business that sells and ships food. You can imagine it's more convenient for somebody who's visually impaired to simply go to a website and order something instead of going to a physical store. So if Netgrocer purchases a subscription to iZoom, the user with a visual impairment will now have access to their site and will potentially buy items which will increase their revenues. That makes a business case for the business to purchase our subscription."

Moderator Steve Jacobs ( IDEAL Group, Inc .) suggested that even though the prices of some categories of AT can be lowered using Dua's business model, inevitably there will be some AT products that will continue to be very expensive simply because of the very low number of end users.

"I'm sure that there are categories of AT, maybe screen magnification programs, maybe some programs that use voice recognition and text-to-speech, that can be sold at a lesser cost than they're currently being sold for. But commercially developed AT is still very important.  Many of the higher-end pieces of AT can never be replaced by mainstream manufacturers, especially orphan AT products. Those will continue to be expensive due to the fact that only a few people will ever use them."

Presenter: Jeff Pledger ( AbleTV.net )

Jeff Pledger is the CEO and founder of AbleTV.net, the first global multimedia network for people with disabilities. Through AbleTV he has pioneered new technology that integrates website accessibility with video streaming techniques and offers video with audio descriptions and captioning. AbleTV's mission is to encourage the dissemination of information using advanced emerging technology that is accessible and usable to a broad spectrum of users.

Pledger opened his presentation by stating "The subject of my talk is going to be about emerging technology; simply I'm going to talk about Voice Over IP, could it be a blessing or curse?"

Pledger discussed how TTY's have worked in such environments as landlines, DSL and cell phone environments. TTY was developed as an analog technology and therefore works well in the realm of landlines and DSL. Digital cell phones were initially inaccessible to TTY, but through a few modifications, cell phones are now able to send and receive TTY signals.

Voice over Internet Protocol (VOIP) is the routing of voice conversations over the Internet or through any other IP-based network. When discussing VOIP there are three scenarios related to how it can be used:

• VOIP phone stays resident at one location.
• VOIP used from a calling area is not tied to its physical location.
• A VOIP phone is registered in one location and is taken with the user to another location.

Pledger explained that VOIP is still in its infancy and although the service has seen much improvement within the past few years, it is still not at the level needed to transmit and receive TTY signals. "VOIP uses a public switch network, this causes a major problem by the fact that packets of information are being sent in an uncontrollable fashion." Pledger stated that "if you make a call from Montreal to Toronto using VOIP, your call could easily be routed through Anchorage Alaska to Moscow to Beijing, back to Paris, and then somehow connect all the way over to Toronto."

Currently, many of the major telecommunication service providers are looking at new ways to transmit TTY signals. In order to motivate this process and produce the necessary technology, Pledger said that we need to examine market forces. He suggested that communication between governments, industry and communities of people who use TTY will result in the necessary standards and guidelines needed to produce this technology.

"What we really have to look at is some of the motivating factors that are going to help TTY regarding market forces, not only in industry, but the market forces of the end user community. What would really help out is if governments, industry and communities began cooperating and in engaging in open communication in such a way that standards and guidelines can be made available to produce this new technology."

To show how guidelines and standards change with technology, Pledger used the parallel example of the television. It has had three major technological advance since its conception in the 1940's; black and white, colour and more recently High Definition (HD). With each technological level the development of new standards and guidelines was necessary. In response to HDTV technology, broadcasters have agreed that HDTV will become the standard television format by 2010.

Pledger concluded that VOIP is an example of ever-changing mainstream telecommunication technology. TTY must be modified in order to work on these new networks.

"At some point, industry, governments, and the community are going to have to sit down and acknowledge that older or integrated technologies that won't be able to keep up with new and emerging ones and are going to have to go by the wayside. We need to create new standards and guidelines, draw a line in the sand and set a date to incorporate new technology. We need to look to see what's new and coming up and available."

Discussion:

An audience member asked what will happen with TTY. "How are people who are hard of hearing and also the deaf community going to be able to keep up with the mainstream and be able to communicate and have access?"  Pledger responded by saying "In order for TTY to work in this VOIP scenario, there is need for modifications from industry to be able to allow for those devices to be able to communicate on those networks." Pledger re-iterated his idea that there need to be cooperative efforts between governments, industry and community to find a solution. Adding strength to this argument, Pledger sited his work on Section 255 from the US Telecommunications Act of 1996 as a successful example of this type of cooperation resulting in change. "That was probably one of the first times that I had seen different communities of people with disabilities, advocates, academia and industry work in a cooperative environment to actually accomplish the goal that was set forth by them within the law."

Pledger ended on a hopeful note "What you're going to find is that younger and younger individuals who are going to be growing up with new and emerging technology will move to the forefront and embrace new technology."

Return to 2005 Summer Institute - Inclusive Information Technology and Business Success final report