Transcript of Comments at the FCC's VoIP Forum on December 1, 2003

Gregg C. Vanderheiden Ph.D.
Professor Industrial Engineering,
Director, Trace R&D Center
University of Wisconsin - Madison

Made at FCC's VoIP Forum
Monday, December 1, 2003

Thank you chairman Powell, commissioners, both for including access to VoIP by people with disabilities on the panel and in your comments today.

We were asked to comment both on whether regulatory obligations should be carried over to VoIP providers, and whether such obligations were technically feasible. Let me address these in turn.

Should regulations carry forward?

The regulatory obligations were created by Congress to address issues that would not be addressed by normal market forces. As we move from PSTN to VoIP, some of the market dynamics are changing. and some problems that were not naturally addressed by PSTN market forces may be addressed by the market forces accompanying VoIP. The dynamics around competition, for example are quite different.

Unfortunately, disability access has never been one of the areas that has been addressed by natural market forces.

When new technologies are introduced they often breaks things - and you have to fix them. Telecommunications technology is the same. However there are always lots of things to do - and we only get to the high priority items. It is like that with all of us. We never get to all the important things - just them most important things at the top of the list - because we all have to go home sometime.

This was and is the case with disability access. Disability access issues are always on the list and are "important" - but never high enough to be the ones that get acted on - except when there is regulation or discussion of regulations.

For example, hearing aid compatibility disappeared with new phone speaker technology until the Hearing Aid Compatibility Act was passed to restore it. An exception was made for cell phones, and such compatibility has not appear in cell phones. Fortunately, congress put a clause in the legislation asking the FCC to reconsider the exemption if necessary. - which the FCC has had to do.

When 255 was introduces a lot of activity took place. One company demonstrated a talking phone. But then nothing happened - and the phone never appeared on the market.

Today people who are blind cannot use even basic cell phones. They cannot tell if they are roaming (and incurring steep surcharges) or if they have a good signal, or if their battery will die soon. Nor can they use any of the menus. This true even when the same cell phones have speech output built in for mainstream features but it is not used for disability access.

People who are older, who have low vision... are hard of hearing... have physical limitations... all have problems using cell phones. Problems that can now be addressed by making software only changes to the phones.

And the same pattern is appearing in VoIP technologies.

Access to VoIP is very important to people with disabilities and those who are older.

VoIP is already starting to take the place of traditional telephones 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 VoIP.

And with a rapidly aging population, the need for access by those with functional limitations will only be growing.

Again, some people with particular types or degrees of disability 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.

My job is to work with companies to help them figure out how to make their products accessible.

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). This is not to say that there aren't 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.

Marketplace pressures have not, --- and will not --- cause telecommunication to be accessible to people with disabilities and those who are aging in any but spotty, specific, and temporary ways.

Companies are not to blame for this. Profit driven companies are not bad; they are the type we all want in our investment portfolios and retirement funds. However, regulations are sometimes needed, and have an important role to play in putting societal factors into the profit equations - as well as making sure that those companies that address these issues are not put at a disadvantage to those who do not.

You asked about 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 server. 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 today.

Both of these efforts have been enabled by the FCC's recent interest in VoIP.

These are just two examples.

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.

In Conclusion

It is both important and necessary to carry disability access provisions forward to VoIP.

The fact that the current FCC access standards predicted and accommodated technology advances allows the standards to carry forward to this new technology.

It is technically feasible and, as regulations are enforced so there is a level playing field, it becomes commercially feasible and practical to implement access in VoIP technologies - with great effect for people who are experiencing disabilities, including those who are older.

Thank you.