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1 >> GOOD AFTERNOON.
AND WELCOME TO THIS WEB CAST ON MAKING
2 TELECOMMUNICATIONS PRODUCTS AND SERVICES ACCESSIBLE
TO PEOPLE WITH DISABILITIES.
3 BEING HOSTED BY THE INFORMATION TECHNOLOGY TECHNICAL
ASSISTANCE AND TRAINING CENTER OR ITTATC AS WE CALL
4 IT.
I'M JULIE CAROL.
5 I'M THE DIRECTOR OF GOVERNMENT AND INDUSTRY RELATIONS
FOR ITTATC AND I WILL BE COMODERATING THIS WEB CAST
6 TODAY ALONG WITH MY COLLEAGUE, MICHAEL MORRIS.
BEFORE WE MOVE INTO THE CONTENT OF THE WEB CAST, LET
7 ME GIVE YOU AN OVERVIEW OF THE FORMAT AND YOU'LL WANT
TO HAVE YOUR NOTE TAKERS AVAILABLE, I'LL GIVE YOU
8 SOME PHONE NUMBERS YOU MIGHT NEED DURING THE WEB
CAST.
9 WE WILL SPEND APPROXIMATELY THE FIRST HOUR HEARING
FROM OUR PANELISTS AND THEN THE SECOND HOUR WE WILL
10 MOVE INTO QUESTIONS FROM THE AUDIENCE.
IF YOU EXPERIENCE ANY TECHNICAL DIFFICULTIES DURING
11 THE WEB CAST TODAY, YOU CAN CALL THE STUDIO AND TALK
TO ONE OF OUR ENGINEERS AND THE NUMBER FOR THAT IS
12 703-961-9250, EXTENSION 223.
AND WE WILL BE TAKING THE QUESTIONS THE SECOND HOUR.
13 YOU CAN SUBMIT THOSE QUESTIONS AT ANY TIME DURING THE
WEB CAST AND THE PHONE NUMBER IF YOU'D LIKE TO CALL
14 THEM IN IS 703-961-9250 EXTENSION 226.
YOU CAN FAX YOUR QUESTIONS TO 703-961-9255.
15 YOU'LL SEE AN E-MAIL LINK ON YOUR.
I WILL GIVE THESE NUMBERS OUT ONE MORE TIME BEFORE WE
16 ACTUALLY START ANSWERING QUESTIONS.
BEFORE WE MOVE INTO OUR PANEL, WE HAVE A SHORT VIDEO
17 TODAY PROVIDED TO US BY THE FCC.
K. DANE SNOWDEN WHO IS THE CHIEF OF THE CONSUMER
18 INFORMATION BUREAU AT THE FCC HAS SENT US A VIDEO
WITH THIS MESSAGE:
19 >> I AM DELIGHTED TO BE ABLE TO
PARTICIPATE TODAY IN THIS IMPORTANT EVENT.
20 THESE DAYS IT IS NOT JUST A CONVENIENCE TO BE ABLE TO
ACCESS TELECOMMUNICATIONS EQUIPMENT IN SERVICES; IT
21 IS A NECESSITY FOR LIVING A RICH, PRODUCTIVE LIFE.
AS YOU KNOW, MICHAEL POWELL, THE CHAIRMAN OF THE FCC
22 AS WELL AS THE AGENCY'S OTHER COMMISSION XHIGZS,
SUPPORT SECTION 255 OF THE TELECOMMUNICATIONS ACT.
23 MANY OF YOU MAY ALSO KNOW THAT CHAIRMAN POWELL HAS
PERSONAL EXPERIENCE WITH THE FRUSTRATIONS OF BEING
24 RELEGATED TO THE OUTSKIRTS OF MAINSTREAM SOCIETY
BECAUSE OF A PHYSICAL DISABILITY FOLLOWING A SERIOUS
25 JEEP ACCIDENT DURING HIS SERVICE IN THE ARMY.
THE CHAIRMAN HAS OFTEN SPOKEN OF THE FEELINGS OF



2

1 HELPLESSNESS BROUGHT ON BY HIS LOSS OF INDEPENDENCE
IN DOING HIS DAY-TO-DAY ACTIVITIES.
2 THAT EXPERIENCE FRAMED HIS APPROACH TO THE
COMMISSION'S IMPLEMENTATION OF SECTION 255.
3 HE KNOWS FIRSTHAND HOW IMPORTANT ACCESSIBILITY IS.
HE FEELS STRONGLY THAT THE COMMISSION SHOULD TAKE
4 AGGRESSIVE ACTION WHERE APPROPRIATE TO MITIGATE THE
PROBLEMS THAT PEOPLE WITH DISABILITIES HAVE INACYING
5 TELEPHONE EQUIPMENT AND SERVICES.
IN HIS WORDS AND I QUOTE, "THE PROBLEM HAS BEEN
6 IDENTIFIED, IT IS REAL, AND SHOULD BE REMEDIED AS
QUICKLY AS POSSIBLE." AS CHIEF OF THE CONSUMER
7 INFORMATION BUREAU, THE BUREAU WITHIN THE FCC THAT IS
MOST CLOSELY FOCUSED ON ENSURING ACCESS TO PEOPLE
8 WITH DISABILITIES, I ECHO CHAIRMAN POWELL'S
SENTIMENTS.
9 TODAY THERE ARE 53 MILLION AMERICANS WITH ALL TYPES
OF DISABILITIES AND THIS NUMBER WILL GROW AS OUR
10 POPULATION AGES.
AN INCREASING NUMBER OF US WILL APPRECIATE A
11 TELEPHONE BILL THAT IS FORMATTED IN LARGE TYPE OR
EVEN BRAILLE.
12 A PHONE WITH A NIB ON THE FIVE KEY.
ELECTRONIC MESSAGES THAT DON'T GAR BELL THE TEXT
13 TELEPHONES BY DEAF PEOPLE AND A VOICE MENU SYSTEM
WHICH WORKS WITH TTY'S.
14 DESIGNING TELECOMMUNICATIONS PRODUCTS AND SERVICES
ACCESSIBLE TO PEOPLE WITH DISABILITIES MAKES SENSE.
15 THE MORE PEOPLE WHO CAN USE A PRODUCT MEANS IT'S MORE
BUSINESS AND IT'S THE RIGHT THING TO DO.
16 TODAY'S WEB CAST WILL PROVIDE AN EXCELLENT
OPPORTUNITY TO SHARE INFORMATION AND IDEAS THAT CAN
17 RESULT IN MORE ACCESS, BETTER ACCESS, AND LESS
EXPENSIVE ACCESS FOR ALL AMERICANS.
18 WE AT THE FCC ESPECIALLY IN THE CONSUMER INFORMATION
BUREAU, ARE READY TO HELP IN ANY WAY WE CAN, AND I
19 ENCOURAGE TO YOU GET IN TOUCH WITH US WITH ANY
QUESTIONS OR COMMENTS YOU MIGHT HAVE.
20 OUR VOICE TELEPHONE NUMBER IS 1-888-CALL FCC AND OUR
TTY NUMBER IS 1-888 TELLFCC.
21 IN ADDITION, KAREN PELTZ STRAUSS, A MEMBER OF MY
STAFF AND SOMEONE I'M SURE MOST OF YOU KNOW WELL IS A
22 PANELIST TODAY AND STANDS READY TO PROVIDE
INFORMATION AND ANSWERS TO ANY QUESTIONS YOU MAY HAVE
23 ON THIS IMPORTANT CONSUMER ISSUE.
THANK YOU VERY MUCH.
24 JULIE: ON BEHALF OF ITTATC, I WOULD LIKE
TO THANK CHIEF SNOWDEN FOR TAPEING THAT VIDEO FOR US
25 AND ESPECIALLY THANK THE FCC FOR THEIR SUPPORT IN
THIS WEB CAST TODAY.



3

1 OUR FIRST PANELIST IS SOMEONE WHO'S ALSO FROM THE
FCC, KAREN PELTZ STRAUSS IS THE DEPUTY CHIEF FOR THE
2 CONSUMER INFORMATION BUREAU BUR BUR FCC WHERE SHE
OVERSEES POLICY RATTED TO DISABILITIES AND CONSUMERS
3 ACCESS TO TELECOMMUNICATIONS.
KAREN IS ALSO AN ATTORNEY AND IS AN EXPERT 2349 LAWS
4 RELATING TO DISABILITY ACCESS TO COMMUNICATIONS.
KAREN, THANK YOU FOR COMING.
5 KAREN: THANK YOU, JULIE.
WHAT I'D LIKE TO DO TODAY IS GIVE YOU A BACKGROUND OF
6 SECTION 255 AND JUST PROVIDE A LOT OF BASIC
INFORMATION ABOUT 255 FOR OUR VIEWERS.
7 AS YOU KNOW, SECTION 255 WAS THE SECTION OF THE
TELECOMMUNICATIONS ACT OF 1996 AND IT DIRECTED
8 TELECOMMUNICATIONS MANUFACTURERS AND SERVICE
PROVIDERS TO MAKE THEIR EQUIPMENT AND SERVICES
9 ACCESSIBLE TO PEOPLE WITH DISABILITIES.
TOWARD THIS END, WHAT MANUFACTURERS AND SERVICE
10 PROVIDERS ARE EXPECTED TO DO ARE TO EVALUATE AND
INCORPORATE ACCESS THROUGHOUT THE DESIGN, THE
11 DEVELOPMENT, AND THE FABRICATION STAGES OF PRODUCT
AND SERVICE DEVELOPMENT AS EARLY AND AS CONSISTENTLY
12 AS POSSIBLE.
WHAT THAT MEANS IS THAT MANUFACTURERS AND SERVICE
13 PROVIDERS MUST TAKE INTO ACCOUNT THE NEEDS OF PEOPLE
WITH DISABILITIES AT VARIOUS STAGES OF PRODUCTS AND
14 SERVICE DEVELOPMENT.
BUT MOST IMPORTANTLY RIGHT AT THE START.
15 RETROFITTING LATER ON COSTS A LOT OF MONEY, IT'S
BURDENSOME, AND IT'S UNNECESSARY.
16 WHEN ACCESS IS BUILT IN AT THE INITIAL STAGES, IT'S
INEXPENSIVE AND READILY FITS INTO A PRODUCT OR
17 SERVICES DESIGN.
FOR THIS REASON IT'S ESPECIALLY IMPORTANT THAT PEOPLE
18 WITH DISABILITIES BE INCLUDED WHERE MARKET RESEARCH
IS CONDUCTING OR PRODUCT TESTING AND TRIALS ARE
19 CONDUCTED, PRODUCT DEMONSTRATIONS AND IT'S IMPORTANT
TO WORK COOPERATEIVELY WITH DISABILITY RELATED
20 ORGANIZATIONS.
ONE OF OUR LATER PANELISTS LATER ON MAY TELL YOU
21 ABOUT SOME CONSUMER FORUMS THAT HAVE TAKEN PLACE
WHERE INDUSTRY AND CONSUMERS HAVE WORKED
22 WONDERFULFULLY TO DEVELOP SOLUTIONS TOWARD ACHIEVING
ACCESS.
23 WHAT DOES SECTION 255 REQUIRE?
FIRST IT REQUIRES THAT TELECOMMUNICATIONS PRODUCTS
24 AND SERVICES BE ACCESSIBLE IF READILY ACHIEVABLE.
THIS MEANS THAT IF A MANUFACTURER IS DESIGNS PRODUCT,
25 THEY WANT TO ASK HOW DOES A BLIND OR DEAF OR HARD OF
HEARING PERSON MAKE THIS FEATURE OR FUNCTION WORK.



4

1 IF I'M MAKING A CALL, MAKING A PAGE, OR TRYING TO
CARRY OUT A TRANSMISSION AND I AM DEAF OR HARD OF
2 HEARING, WILL I NEED TO HEAR THE TONE?
IS THERE ANOTHER OPTION INSTEAD OF HEARING THE TONE?
3 IF I'M BLIND, WILL I NEED TO SEE WHAT'S ON THE SCREEN
OR CAN I HAVE AN OPTION?
4 WILL I NEED TO FIGURE OUT WHAT'S ON A KEY PAD?
BASICALLY THE MANUFACTURER AND SERVICE PROVIDER NEED
5 TO LOOK AT AT OUTPUT, THE INPUT, THE CONTROL, THE
MECHANICAL FUNCTIONS, AND THE DISPLAY AND CONTROL
6 FUNCTIONS.
ACCESS IS ONLY REQUIRED IF IT'S READILY ACHIEVABLE
7 AND I'LL GET TO THAT LATER.
IF IT'S NOT READILY ACHIEVABLE, THEN A MANUFACTURER
8 OR SERVICE PROVIDER MUST PROVIDE COMPATIBILITY WITH
WHAT'S CALLED PERIPHERAL DEVICES OR SPECIALIZED
9 CUSTOMER PREMISES EQUIPMENT.
PERIPHERAL DEVICES ARE DEVICES USED IN CONNECTION
10 WITH TELECOMMUNICATIONS EQUIPMENT TO TRANSFORM
TELECOMMUNICATIONS INTO EQUIPMENT THAT'S ACCESSIBLE.
11 SPECIALIZED EQUIPMENT IS EQUIPMENT USED TO ORIGINATE
ROOT OF TELESXHUNGZS WHICH IS COMMONLY USED BY PEOPLE
12 TO ACHIEVE ACCESS.
FOR EXAMPLE, TTY OR AN ARTIFICIALULAR INKS ARE
13 EXAMPLES.
COMPATIBILITY REQUIRES TTYS, AND CONNECTION POINTS
14 FOR EXTERNAL AUDIO PROCESSING DEVICES. WHAT IS
COVERED UNDER SECTION 255?
15 AS I MENTIONED SERVICES, AND THIS EXTENDS TO BASIC
SERVICES AND ADJUNCT TO BASIC SERVICES SUCH AS CALL
16 WAITING, SPEED DIALING, CALL FORWARDING, CALL
MONITORING, CALLER ID, CALL TRACING, AND REPEAT
17 DIALING.
THOSE ARE JUST A FEW EXAMPLES; IT'S NOT AN EXCLUSIVE
18 LIST.
IN ADDITION, THERE ARE CERTAIN INFORMATION SERVICE
19 WHICH IS THE FCC COVERED UNDER SOMETHING CALLED THE
ANCILLARY JURISDICTION DOCTRINE THAT ARE ALSO KOFRPED
20 UNDER SECTION 255.
THESE ARE INTERACTIVE VOICE RESPONSE SYSTEMS.
21 THEY'RE THE MENU CHOICES THAT YOU GET WHEN YOU DIAL A
BANK OR A SCHOOL OR ANY KIND OF A TRANSPORTATION
22 FACILITY.
THESE ARE VERY, VERY DIFFICULT FOR PEOPLE WITH
23 DISABILITIES TO USE.
A HEARING -- A PERSON WITH A HEARING DISABILITY HAS
24 DIFFICULTY BECAUSE MANY OF THESE DEVICES ARE NOT
COMPATIBLE WITH TTY'S AND AN INDIVIDUAL WITH MOTOR
25 DISABILITIES MAY HAVE TROUBLE RESPONDING TO THE
PROMPTS QUICKLY.



5

1 THESE ALSO ARE COVERED UNDER SECTION 255 AS ARE VOICE
MAIL.
2 MANUFACTURERS AS I MENTIONED ARE ALSO COVERED.
ALL TYPES OF EQUIPMENT.
3 EQUIPMENT IS DEFINED AS THE EQUIPMENT USED BY A
CARRIER TO PROVIDE TELECOMMUNICATION SERVICES.
4 WHAT'S IMPORTANT IS THAT IT INCLUDES SOFTWARE THAT'S
INTEGRAL TO SUCH EQUIPMENT AS WELL.
5 AND THAT'S WHETHER OR NOT THE SOFTWARE IS SOLD WITH
THE EQUIPMENT HARDWARE OR IS SOLD SEPARATELY.
6 I MENTIONED BEFORE THAT ACCESS IS REQUIRED ONLY WHEN
LITTLE READILY ACHIEVABLE TO ACHIEVE SUCH ACCESS.
7 IN ADDITION, COMPATIBILITY IS ONLY REQUIRED WHERE THE
READILY ACHIEVABLE TEST IS MET.
8 WHAT THIS MEANS IS THAT ON A CASE BY CASE BASIS THE
FCC WILL BE LOOKING AT WHETHER OR NOT A COMPANY CAN
9 PROVIDE -- WHETHER IT IS OR IS NOT READILY ACHIEVABLE
FOR A COMPANY TO PROVIDE ACCESS.
10 AS I SAID, IT'S DONE ON A CASE BY CASE BASIS, IT IS
ALSO DONE PRODUCT BY PRODUCT SO THAT EACH INDIVIDUAL
11 PRODUCT IS LOOKED AT EACH INDIVIDUAL SERVICE IS
LOOKED AT.
12 THE MOST IMPORTANT THING TO LOOK AT IN A READILY
ACHIEVABLE ANALYSIS IS THE TIMING.
13 YOU HAVE TO LOOK AND CONSIDER WHETHER OR NOT IT WAS
READILY ACHIEVABLE TO INCORPORATE ACCESS DURING THE
14 DESIGN STAGE.
IF YOU LOOK AT IT LATER ON AFTER THE PRODUCT IS
15 FINISHED, THEN MOSTLY IT'S NOT GOING TO BE READILY
ACHIEVABLE.
16 BY THEN IT WILL BE VERY EXPENSIVE TO INCORPORATE.
WHAT ARE WE LOOKING AT?
17 THE COST OF WHAT'S NEEDED, THE NATURE OF THE ACTION.
IF THE COVERED ENTITY, IF IT'S EASILY ACCOMPLISHABLE
18 WITHOUT MUCH DIFFICULTY OR EXPENSE, THEN IT'S
CONSIDERED READILY ACHIEVABLE.
19 IF IT'S TECHNOLOGICALLY INFEASIBLE, THAT WON'T BE
READILY ACHIEVABLE.
20 IF IT WOULD CAUSE A FUNDAMENTAL ALTERATION WHICH
WOULD REDUCE SUBSTANTIALLY THE FUNCTIONALITY OF THE
21 PRODUCT OR RENDER CERTAIN FEATURES INOPERABLE, THEN
THAT LIKELY WOULD NOT BE READILY ACHIEVABLE.
22 AGAIN, IT'S ON A CASE KAIS CASE BASIS.
WE'RE LOOKING AT CHANGES OR ACCESS FEATURES THAT ARE
23 GOING TO BE UNIVERSALLY AVAILABLE WITHOUT MUCH
DIFFICULTY OR EXPENSE.
24 FOR EXAMPLE, NIBS.
A NIB ON THE 5 K TO ALERT PEOPLE WITH VISION
25 DISABILITIES ABOUT WHERE THE OTHER NUMBERS ARE IN A
KEY PAD ARE LOCATED OR AN ABILITY TO CHANGE THE FONT



6

1 ON A PARTICULAR TELECOMMUNICATIONS DEVICE.
A JACK FOR A TTY ACCESS.
2 THE ABILITY TO CHANGE OR INCREASE THE VOLUME.
COLOR CONTRASTS THAT MAY BE A FEATURE THAT ALLOWS
3 PEOPLE TO SEARCH THE LAST NUMBERS DIALOD A TELEPHONE
AND THAT MIGHT BE HELPFUL FOR SOMEBODY WITH ADD, FOR
4 EXAMPLE.
THERE MAY BE NUMBER BLOCKING FEATURES THAT MAY BE
5 HELPFUL FOR PEOPLE WITH DISABILITIES THAT USE CARE
ATTENDANTS.
6 THERE ARE LOTS OF DIFFERENT FEATURES THAT COULD BE
USEFUL FOR PEOPLE WITH DISABILITIES.
7 IN ADDITION, THERE'S A REQUIREMENT UNDER SECTION 255
THAT PRODUCTS AND SERVICES BE USABLE BY PEOPLE WITH
8 DISABILITIES.
THIS MEANS THAT PEOPLE WITH DISABILITIES MUST HAVE
9 ACCESS TO THE DOCUMENTATION FOR THE PRODUCT INCLUDING
INSTRUCTIONS AND PRODUCT INFORMATION.
10 THEY SHOULD HAVE ACCESS TO BILLING INFORMATION AND
TECHNICAL SUPPORT.
11 THAT MEANS THAT IF YOU OWN A COMPANY AND YOU HAVE
CUSTOMER REPRESENTATIVES, YOU SHOULD BE TRAINING
12 THOSE CUSTOMER REPRESENTATIVES TO INSTRUCT THEIR
CUSTOMERS AS TO HOW TO USE PARTICULAR ACCESS
13 FEATURES.
THERE SHOULD BE TECHNICAL SUPPORT HOT LINES THAT
14 PERHAPS HAVE TTY ACCESS OR OTHER TYPES OF ACCESS.
THOSE ARE JUST SOME EXAMPLES.
15 THERE ARE VARIOUS WAYS FOR INDIVIDUALS TO COMPLAIN
AGAINST A COMPANY THAT HAS VIOLATED SECTION 255.
16 AND I DON'T WANT TO GET TOO MUCH INTO THAT BECAUSE I
WANT TO LEAVE SOME TIME FOR MY COLLEAGUES TO SPEAK,
17 BUT JUST LET ME SAY THAT WE DO GET LOTS OF COMPLAINTS
AT THE COMMISSION.
18 GENERALLY THESE COMPLAINTS INFORMAL, NOT FORMAL.
ALL THAT MEANS IS THAT THEY DON'T HAVE TO GO THROUGH
19 A MINI-TRIAL LIKE EXPERIENCE.
FORMAL COMPLAINTS ARE SIMILAR TO LITIGATION WITH
20 DEPOSITIONS AND FILING FEES AND ALL TYPES OF FILINGS.
AND INFORMAL COMPLAINTS ON THE OTHER HAND CAN COME IN
21 ANY FORM.
IT CAN BE A FAX, A PHONE, AN E-MAIL, A LETTER.
22 GENERALLY WE REVIEW THE COMPLAINTS, WE HAVE A STAFF
TO REVIEW THE COMPLAINTS, AND WE SEND SOMETHING UP
23 CALLED NOTICES OF FORMAL COMPLAINTS TO THE COMPANIES
AND THE COMPANIES MUST RESPOND WITHIN 30 DAYS.
24 INDIVIDUALS SHOULD INCLUDE VARIOUS INFORMATION IN
THEIR COMPLAINTS INCLUDING THEIR NAMES, THEIR
25 ADDRESSES, THE ADDRESS OF THE MANUFACTURER OR SERVICE
PROVIDER, DETAILS ABOUT THE EQUIPMENT OR THE SERVICE



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1 ABOUT WHICH THE COMPLAINT IS MADE ARE VERY, VERY
IMPORTANT.
2 WE GET A LOT OF INQUIRIES BUT THEY'RE NOT SPECIFIC
ENOUGH TO RIELZ TO THE LEVEL OF A COMPLAINT, SO WE
3 ENCOURAGE ANYBODY THAT HAS A SPECIFIC COMPLAINT TO
PROVIDE AS MANY DETAILS ABOUT THAT COMPLAINT AS
4 POSSIBLE.
INCLUDING THE DATE THAT THE ITEM WAS ACQUIRED OR WAS
5 ATTEMPTED TO BE ACQUIRED.
AND A STATEMENT OF FACT SUPPORTING THE SAELGZ
6 ALLEGATION THAT THE ITEM IS NOT ACCESSIBLE AND WHAT
RELIEF THE PERSON WANTS.
7 FOR EXAMPLE, IF A TELEPHONE IS NOT HEARING
COMPATIBLE, DOES THAT PERSON WANT THE PHONE TO HAVE
8 THAT COMPATIBLE FEATURE.
THE COMPLAINT SHOULD ALSO SPECIFY HIS OR HER METHOD
9 OF PREFERRED RESPONSE.
DOES THE COMPANY WANT THE -- UNDER THE LAW THE
10 COMPANY HAS TO PROVIDE A RESPONSE IN AN ACCESSIBLE
FORMAT.
11 AS I MENTIONED, WE GET LOTS OF DIFFERENT COMPLAINTS.
SOME ARE ON HEARING ININ INIBILITY, SOME ARE FOR
12 MAKING INFORMATION SERVICES ACCESSIBLE AND ACCESSIBLE
BILLING SERVICES.
13 THERE ARE VARIOUS SANCTIONS AND REMEDIES
UNDER SECTION 255 AS WELL.
14 DAMAGES ARE AVAILABLE FOR VIOLATIONS INCURRED BY
COMMON CARRIERS.
15 WE CAN ALSO IMPOSE FORFEITURES AGAINST VIOLATORS,
LICENSE REVOCATIONS, DECEASE AND DESIST ORDERS, AND
16 IN EXTREME SITUATIONS WHERE THERE ARE PATTERNS OR
PRACTICES OF AGEEJS CASES OF WILLFUL MISCONDUCT, WE
17 CAN ALSO IMPOSE RETROFITTING WHICH WILL REQUIRE A
COMPANY TO REVISE A PRODUCT TO MAKE IT ACCESSIBLE.
18 I THINK I'M GOING TO STOP THERE AND I'LL BE ABLE
AVAILABLE TO ANSWER QUESTIONS, SO THANK YOU.
19 .
>>I HAVE A COUPLE OF QUESTIONS THAT CAME
20 TO MIND.
THE INTERACTIVE VOICE RESPONSE SYSTEMS THAT ARE SO
21 UBIQUITOUS THESE DAYS, WHO IS ACTUALLY RESPONSIBLE
FOR MAKING THOSE ACCESSIBLE?
22 IS IT THE END USER SUCH AS THE BANK OR THE SCHOOL OR
THE AIRLINES, OR IS IT JUST THE MANUFACTURER?
23 KAREN: THAT'S A GOOD QUESTION, JULIE.
UNDER THE SECTION 2 PITCH, THE MANUFACTURERS ARE
24 RESPONSIBLE FOR MAKING THESE ACCESSIBLE.
HOWEVER, UNDER TITLE 2 AND TITLE 3 OF THE AMERICANS
25 WITH DISABILITIES ACT, THE END ENDERS AS WELL ARE
RESPONSIBLE FOR PROVIDING ACCESS TO THEIR CUSTOMERS



8

1 AND THEIR BENEFICIARIES AND THE PARTICIPANTS OF THEIR
PROGRAMS AND ACTIVITIES.
2 TITLE 2 COVERS STATE AND LOCAL GOVERNMENTS.
TITLE THREE COVERS PLACES OF PUBLIC ACCOMMODATIONS
3 SUCH AS BANKS, SCHOOLS, ET CETERA.
EACH OF THESE ENTITIES THAT ARE COVERED UNDER THE
4 AMERICANS MERN MERN MERN ACT MUST PROVIDE ACCESS OR
EFFECTIVE COMMUNICATION FOR INDIVIDUALS FRY TRYING TO
5 REACH THEIR SERVICES.
THEY DON'T NECESSARILY HAVE TO PROVIDE ACCESSIBLE IBR
6 SYSTEMS IF THEY'RE PROVIDING SOME OTHER FORM OF
ACCESS.
7 SO FOR EXAMPLE, IF THEY PROVIDE A VOICE OPERATOR AS
AN OPTION, THEN THEY WOULD SATISFY THEIR REQUIREMENTS
8 OR IF THEY PROVIDED THROUGH A TTY ACCESS, THEY MIGHT
SATISFY THEIR REQUIREMENT.
9 SO IT'S A DUAL OBLIGATION BUT THE ACTUAL OBLIGATION
TO MAKE THE SYSTEMS ACCESSIBLE COMES -- IS ENFORCED
10 AGAINST MANUFACTURERS OR MANUFACTURERS ARE REQUIRED
UNDER SECTION 255.
11 >> SO IF SOMEONE WANTS TO FILE A COMPLAINT
ABOUT THIS TYPE OF THING WITH THE FCC, YOU ACTUALLY
12 NEEDS TO KNOW WHO THE MANUFACTURER WAS IN ADDITION TO
THE END END END?
13 >> EXACTLY.
THAT'S CORRECT.
14 >> AND DOES SECTION 255 COVER INTERNET
TELEPHONY?
15 PEOPLE CAN ACTUALLY TALK ON THE PHONE VIA INTERNET
THESE DAYS.
16 IS THAT COVERED?
>> THAT'S ALSO AN EXCELLENT QUESTION AND
17 SOMETHING THE FCC HAS BEEN TRYING TO GRAPPLE WITH
OVER THE LAST TWO TWOS.
18 YOU MAY KNOW AT THE TIME THE FCC RELEASED A NOTICE
NOI INQUIRY ON WHETHER OR NOT INTERNET TELEPHONY
19 SHOULD BE COVERED UNDER SECTION 255.
AND WE'RE STILL CONSIDERING THAT QUESTION AT THE
20 COMMISSION.
>> THANK YOU.
21 OUR NEXT PANELIST WILL BE DOUG WAKEFIELD.
DOUG IS AN ACCESSIBILITY SPECIALIST WITH THE U.S.
22 ACCESS BOARD.
HE'S WORKED IN THE AREA OF DISABILITY TECHNOLOGY FOR
23 ABOUT 11 YEARS I BELIEVE.
AND HE IS THE LEAD STAFF PERSON AT THE ACCESS BOARD
24 ON THE NEW SECTION 508 STANDARDS AS THEY APPLY TO
ELECTRONIC AND INFORMATION TECHNOLOGY AND DOUG IS
25 ALSO THE ACCESS BOARD'S TELECOMMUNICATIONS
SPECIALIST.



9

1 SO THANK YOU, DOUG.
>> THANK YOU, JULIE.
2 IT'S INTERESTING THAT WE'RE MOVING FROM KAREN WITH
THE FCC TO ME, WE'RE ALMOST FOLLOWING HISTORY HERE
3 BECAUSE THE TELECOMMUNICATIONS ACT WAS IN 1996 AND
508 WAS PASSED IN 1998.
4 AND IN 1996 WHEN THE TELECOMMUNICATIONS ACT WAS
PASSED, CONGRESS GAVE MARCHING ORDERS TO THE ACCESS
5 BOARD WHERE I WORK TO DEVELOP THE GUIDELINES FOR 255.
THAT WERE CALLED 255 THAT WERE USED TO IMPLEMENT THE
6 ACCESSIBILITY REQUIREMENTS UNDER THE
TELECOMMUNICATIONS ACT.
7 WHAT HAPPENS GENERALLY IS CONGRESS WILL PASS A RULE
OR A PIECE OF LEGISLATION AND THEN DESIGNATE SOME
8 AGENCY, GENERALLY WITHIN THE EXECUTIVE BRANCH TO
ACTUALLY WRITE THE IMPLEMENTING RULE.
9 THE ACCESS BOARD HAS DONE THE ADA GUIDELINES, YEARS
AGO THEY DID THE ABA WHICH PEOPLE HAVEN'T ALWAYS
10 HEARD OF, IT'S ARCHITECTURAL BARRIERS ACT AND THEN
THEY DID THE TELECOMMUNICATIONS AND THEN IN '98 THEY
11 WERE GIVEN A -- OR WE WERE GIVEN THE MARCHING ORDERS
TO DO 508.
12 AND IT REALLY TIES TOGETHER HERE, BECAUSE 508 IS
TALKING ABOUT ACCESS TO ELECTRONIC AND INFORMATION
13 TECHNOLOGY.
AND PART OF ELECTRONIC AND INFORMATION TECHNOLOGY IS
14 COMMUNICATIONS.
SO IN MANY WAYS PART OF OUR JOB WAS ALREADY DONE
15 EXCEPT THAT SOME TWEAKING HAD TO BE DONE.
THERE ARE SOME BASIC DIFFERENCES BETWEEN THE TWO
16 RULES THAT HAVE TO BE TAKEN INTO CONSIDERATION WHEN
DEVELOPING 508.
17 FIRST OF ALL, THE LEVEL OF ENFORCEMENT IS STRICTER
WITH 508.
18 KAREN MENTIONED READILY ACHIEVABLE.
READILY ACHIEVABLE IS A FAIRLY LOW THRESHOLD OF PAIN.
19 ON THE OTHER HAND, 508 SAYS THAT YOU MUST DO IT
UNLESS IT BRINGS ON AN UNDUE BURDEN.
20 NOW, AN UNDUE BURDEN MEANS SOME BURDEN IS DUE.
DEPARTMENT OF JUSTICE SAYS IF YOU'RE GOING TO USE THE
21 UNDUE BURDEN CLAIM, YOU BETTER DOCUMENT IT VERY
CAMELY.
22 IT'S LOOKED AT RATHER STERNLY BY JUDGES AND SO ON.
THE OTHER BIG DIFFERENCE IS THAT -- AND IT RELATES TO
23 TELECOMMUNICATIONS AS WELL AS ALL OTHER PARTS OF 508,
AND THE TELECOMMUNICATIONS OF '96.
24 255 OF TELECOMMUNICATIONS IS SAYING THAT
MANUFACTURERS SHALL.
25 508 IS SAYING FEDERAL AGENCIES SHALL.
AND THIS REALLY IS A MARKED DIFFERENCE.



10

1 IN OTHER WORDS, THEORETICALLY, 508 IS NOT TELLING
MANUFACTURERS TO DO ANYTHING.
2 UNLESS THEY WANT TO SELL TO THE FEDERAL GOVERNMENT.
SINCE THE FEDERAL GOVERNMENT PURCHASED ROUGHLY, WHAT,
3 I GUESS I HAVE TWO YEAR-OLD NUMBERS NOW SO IT'S
PROBABLY GONE UP, BUT AS OF 1999 THE GOVERNMENT
4 PURCHASED $39 BILLION WORTH OF TECHNOLOGY.
THAT'S A SIZABLE CUSTOMER.
5 AND WE THINK IT'S GOING TO HAVE A PROFOUND EFFECT IN
GENERAL BECAUSE MANUFACTURERS ARE NOT GOING TO
6 DEVELOP NEW EQUIPMENT SPECIFICALLY FOR THE GOVERNMENT
WITH ACCESS FEATURES OR THAT'S 508 COMPATIBLE AND
7 THEN TURN AROUND AND SELL A WHOLE SEPARATE LINE OF
INACCESSIBLE PRODUCTS TO THE GENERAL CONSUMER.
8 SO WE BELIEVE RATHER FIRMLY THAT JUST THE ECONOMICS
ARE THERE THAT 508 WILL HAVE AN IMPACT ON ALL PRODUCT
9 LINES, NOT JUST THOSE THAT ARE SOLD TO THE
GOVERNMENT.
10 NOW, ONE OF THE MAJOR DIFFERENCES I KNOW THAT PEOPLE
LOTS OF TIMES LAKE TO TAKE DIFFERENT SECTIONS OF 508
11 AND COMPARE IT TO OTHER EXISTING EITHER SETS OF
GUIDELINES AND SO ON.
12 FOR EXAMPLE, WE HAVE IN 508 A SECTION ON SOFTWARE.
WE HAVE FOR WEB APPLICATION, WE HAVE A
13 TELECOMMUNICATIONS SECTION.
WE HAVE MULTIMEDIA PRODUCTIONS.
14 WE HAVE SELF-CONTAINED CLOSED SYSTEMS AND WE HAVE
DESKTOP AND LAPTOP COMPUTERS.
15 THOSE ARE THE DIFFERENT SECTIONS OR THE DIFFERENT
COMPONENTS THAT WE HAVE ADDRESSED.
16 AND THEN WE ALSO HAVE A COMPLETELY SEPARATE SECTION
THAT ADDRESSES DOCUMENTATION AND SUPPORT.
17 SO ANYBODY LOOKING AT A DEVICE HAS TO DETERMINE TO
WHAT EXTENT DOES EACH OF THESE COMPONENT APPLY.
18 FOR EXAMPLE, A HIGH-END CELL PHONE -- FIRST OF ALL,
OBVIOUSLY IT'S TELECOMMUNICATIONS.
19 SO OUR TELECOMMUNICATIONS STANDARDS WHICH IN A VERY
CLOSE WAY, I'D SAY 90 PERCENT MIRROR THE RELEVANT 255
20 GUIDELINES.
THOSE ALL APPLY.
21 BUT IT'S ALSO A CLOSED SYSTEM. IT'S A SELF-CONTAINED
CLOSED SYSTEM. AND A SELF CONTAINED CLOSED SYSTEM
22 ISN'T QUITE AS OBSCURE AS IT SOUNDS.
WE SHOULD HAVE HAD A NAMING CONTEST BECAUSE EVERY
23 TIME THAT I HAVE MENTIONED THIS CATEGORY SOMEBODY
SAYS, WHAT IN BLAZES ARE YOU TALKING ABOUT?
24 AND I SAY YOU TELL ME.
WHAT IS A SELF CONTAINED STAND-ALONE ITEM?
25 THEY WOULD SAY IT'S A CELL PHONE OR KIOSK OR
WHATEVER.



11

1 IT'S A DEVICE WHAT YOU DON'T ORDINARY ATTACH
PERIPHERALS TO.
2 AND IN THOSE CASES OUR STANDARDS SAY THAT YOU CANNOT
EXPECT AN END END END TO INSTALL OR CONNECT
3 ASSISTIVEECKINOLOGY, THAT SYSTEM MUST BE INTERNALLY
INHERENTLY ACCESSIBLE TO PEOPLE WITHOUT REQUIRING
4 THEM TO ATTACH DEVICES.
AND THIS MEANS THAT TELECOMMUNICATIONS ALSO FALL
5 UNDER THE REQUIREMENTS OF SELF CONTAINED CLOSED
SYSTEMS.
6 FOR EXAMPLE, IN THE TELECOMMUNICATIONS SECTION WE DO
NOT ADDRESS TOUCH SCREENS.
7 BUT WE DO ADDRESS TOUCH SCREENS IN OUR SELF CONTAINED
STAND ALONE.
8 AND SO IF A TELEPHONE SYSTEM, A TELEPHONE -- BECAUSE
A TELEPHONE WOULD ALSO BE YOUR DESK PHONE, YOU
9 GENERALLY DON'T ATTACH THINGS TO IT.
YOU CAN'T INSTALL SOFTWARE GENERALLY.
10 I'M SURE IN THE FUTURE YOU'LL BE ABLE TO AND EVEN
SOME HIGH END PHONES NOW YOU CAN, BUT IN GENERAL THAT
11 TELEPHONE HAS TO BE TREATED AS A STAND ALONE DEVICE.
AND THERE ARE SOME PHONES OUT THERE THAT HAVE TOUCH
12 SENSITIVE TOUCH SCREEN TYPE EVEN DIALING.
AND WE HAVE RATHER STRICT -- A STRICT STANDARD FOR
13 THE TOUCH SCREENS AND BASICALLY IT SAYS IF YOU'RE
GOING TO PROVIDE A TOUCH SCREEN, THAT'S FINE.
14 CAN YOU PROVIDE A TOUCH SCREEN BUT YOU MUST ALSO
PROVIDE A REDUNDANT SET OF CONTROLS THAT MEET THE
15 STANDARDS THAT WE HAVE WRITTEN FOR MECHANICALLY
OPERATED CONTROLS.
16 MECHANICALLY OPERATED CONTROL IS ONE THAT YOU PUSH,
TWIST, PULL, YOU DO SOMETHING TO.
17 PHYSICALLY REACT WITH IT.
SO IN LOOKING AT THE TELECOMMUNICATION PRODUCT, YOU
18 REALLY HAVE TO LOOK AT ALL THE DIFFERENT SECTIONS OF
508 THAT MAY APPLY.
19 AGAIN, GO BACK TO OUR CELL PHONE, OUR HIGH END CELL
PHONE.
20 IT'S A TELECOMMUNICATIONS PRODUCT, IT'S A SELF
CONTAINED UNIT.
21 BUT IT ALSO UNDOUBTEDLY WILL HAVE SOFTWARE.
AND IF IT HAS SOFTWARE AND IT HAS MENUS THEN YOU NEED
22 TO THINK FROM THE STANDPOINT OF WHETHER IT'S A 508
COMPLIANT PRODUCT.
23 CAN A PERSON HAVE ACCESS TO THOSE MENUS?
IF THEY HAVE A MOBILITY RELATED DISABILITY, CAN THEY
24 RUN THE LITTLE BUTTONS ON THE SIDE THAT MOVE YOU UP
AND DOWN THROUGH THE MENUS?
25 IF THEY HAVE SAY VISUAL IMPAIRMENT, CAN THEY SEE THE
DISPLAY OR IS THERE ANY OTHER WAY TO GET THE



12

1 INFORMATION OUT OF THE PRODUCT IF YOU CAN'T SEE IT?
YOU CAN USE THE PHONE, YOU CAN MAKE A CALL, YOU JUST
2 CAN'T SEE WHO'S CALLING AND YOU CAN'T SEE WHO CALLED
LAST AND YOU CAN'T SEE HOW MUCH BATTERY LIFE YOU HAVE
3 LIFE UNTIL IT GOES DEAD AND THEN YOU KNOW FOR SURE.
SO IN GENERAL -- OH, ONE OTHER THING I WANT TO
4 MENTION TOO THAT IS VERY DIFFERENT BETWEEN THE
TELECOM AND THE 508, TELECOM, BECAUSE IT IS A SINGLE
5 COMPONENT RULE, THAT BEING FOCUSING ON TELECOM HAS
ALL OF THE NEED FOR HELP DESK AND DOCUMENTATION
6 MENTIONED IN THE 255 RULE ITSELF.
508 HAS TAKEN THAT SECTION BECAUSE IT APPLIES TO
7 ANYTHING.
IT APPLIES TO SOFTWARE PRODUCTS, COMPUTERS, STAND
8 ALONES, AND SO THERE IS A SEPARATE SECTION THAT
REQUIRES THE AVAILABILITY OF ACCESSIBLE DOCUMENTATION
9 UPON REQUEST AND IT REQUIRESAT A LIST OF THE ACCESS
FEATURES AND THAT HELP DESKS BE ACCESSIBLE TO MEET
10 THE COMMUNICATION NEEDS FOR ALL END USERS.
AND THIS MAY MEAN THAT THEY HAVE TO HAVE TTY
11 CAPABILITY.
SO THAT'S THERE AS FAR AS TELECOMMUNICATIONS.
12 IT'S THERE AS FAR AS SELF CONTAINED STAND ALONE.
IT'S JUST IN A DIFFERENT SECTION BECAUSE IT APPLIES
13 TO ALL PRODUCTS.
SO IN GENERAL WE FEEL AT AT BOARD THAT THE 508 IS
14 GOING TO EVEN INCREASE THE PACE OF CHANGE THAT'S
TAKING PLACE IN THE TELECOMMUNICATION INDUSTRY RIGHT
15 NOW.
BECAUSE OF THE MARKET DRIVEN NATURE OF 508.
16 AND I WILL END BY JUST SAYING THAT EVEN WITH THE
READILY ACHIEVABLE STANDARD, IT'S BEEN RATHER AMAZING
17 WHAT SOME OF THE PRODUCERS OF TELECOMMUNICATION
EQUIPMENT ARE REALLY DOING.
18 I MEAN, THEY TOOK IT SERIOUSLY ACHIEVABLE; THEY'RE
TAKING IT OFFLY SERIOUS AT UNDUE BURDEN.
19 THANK YOU, JULIE.
>> COUPLE OF FOLLOW-UP QUESTIONS IF I MAY.
20 YOU TALKED A LOT ABOUT EQUIPMENT AND
TELECOMMUNICATIONS PRODUCTS.
21 DOES SECTION 508 ALSO COVER TELECOMMUNICATION
SERVICES?
22 AND IF SO DOES IT COVER THE SAME SERVICES THAT
SECTION 255 COVERS?
23 >> IT COVERS THE SAME, AND ACTUALLY IT
COVERS -- I'LL GO OUT ON A LIMB AND SAY IT ACTUALLY
24 COVERS SOME MORE.
YEAH, WE HAVE PROVISIONS THAT ARE TALKING ABOUT
25 SERVICES SUCH AS CALLER ID AND OTHER SERVICES.
WE SAY THAT THE SERVICE MUST NOT COMPRESS OR DESTROY



13

1 SIGNALS FOR TTY'S, IT MUST BE COMPATIBLE WITH
CARRYING THE STANDARD TTY SIGNALS, BUT A
2 TELECOMMUNICATIONS PRODUCT, AND THIS IS WHERE I
BELIEVE WE ARE SLIGHTLY DIFFERENT THAN THE F. C. C.
3 AND IT'S NOT AN INCOMPATIBILITY PROBLEM AT ALL, F C C
IS DEALING PRIMARILY WITH THE SPECTRUM, THE SERVICES,
4 AND SO ON.
508 IS DEALING WITH ELECTRONIC AND INFORMATION
5 TECHNOLOGY.
SO IF A TELECOMMUNICATION PRODUCT COMMUNICATES WITH
6 ANOTHER TELECOMMUNICATION PRODUCT DIRECTLY AND IT
ISN'T USING A SERVICE, IT IS STILL COVERED.
7 >> WOULD THAT BE A TWO TWO WAY PAGER?
>> YEAH.
8 A TWO-WAY PAGER THAT DOESN'T USE -- I'M THINKING OF
SOME OF THESE HAND HELD WALKIE-TALKIE TYPE THINGS.
9 THAT'S STILL COVERED.
I DON'T KNOW WHAT THE EXACT TERM IS WITHOUT
10 MENTIONING A SPECIFIC PRODUCT NAME.
BUT YEAH.
11 THEY'RE COVERED EVEN THOUGH THEY'RE NOT USING A
SERVICE.
12 >> AND SINCE THE TELECOMMUNICATIONS
INDUSTRY HAS TWO STANDARDS, THEY HAVE TO BE CONCERNED
13 ABOUT NOW, 255 AND 508, CAN YOU PROVIDE ANY HELP ON
COMPARING THE TWO.
14 IS ONE A HIGHER STANDARD?
IF I COMPLY WITH ONE, AM I SAFE ON THE OTHER ONE OR
15 DO I REALLY HAVE TO LEARN BOTH IF I'M A
TELECOMMUNICATIONS INDUSTRY.
16 >> I'LL THROW THIS OUT AND MAYBE KAREN
WOULD LIKE TO SAY SOMETHING ABOUT IT.
17 IF YOU COMPLY WITH 508, YOU CERTAINLY ARE IN
COMPLIANCE WITH 255.
18 IF YOU COMPLY WITH ALL PARTS OF 508, NOT JUST THE
TELECOMMUNICATIONS, IN OTHER WORDS, IF YOU COMPLY
19 WITH THE TELECOMMUNICATIONS AND YOU COMPLY WITH THE
DOCUMENTATION REQUIREMENTS, THE SOFTWARE
20 REQUIREMENTS, AND THE STAND ALONE PRODUCTS.
KAREN: I WOULD AGREE WITH DOUG.
21 IN FACT, THE ACCESS BOARD HAS GUIDELINES UNDER
SECTION 255 WHICH SET FORTH SUBSTANTIAL GUIDANCE TO
22 THE INDUSTRY ON HOW TO ACHIEVE ACCESSIBILITY.
AND THE 508 GUIDELINES GENERALLY MIRROR THE SAME TYPE
23 OF GOALS.
I WANT TO RESPOND TO ONE THING THAT YOU MENTIONED
24 JUST RECENTLY AND THAT IS WHEN THE NETWORK IS NOT
INVOLVED ARE THE PIECES OF EQUIPMENT USED TO ACHIEVE
25 TELECOMMUNICATIONS COVERED.
THAT IS A SECOND PART OF THE NOOH I, THE NOTICE NOI



14

1 REQUEST INQUIRY THAT I MENTIONED BEFORE.
AS YOU MENTIONED, JULIE, INTERNET TELEPHONY AND ASKED
2 WHETHER THAT'S COVERED, WELL A SECOND QUESTION WE
ASKED IS THE EXTENT TO WHICH A COMPUTER-BASED
3 EQUIPMENT IS COVERED WHEN THE FUNCTIONS ACHIEVE BY
THOSE END PRODUCTS ARE NOT GOING THROUGH THE NETWORK
4 ITSELF.
AND SO THAT'S STILL AS WELL A QUESTION THAT'S OPEN TO
5 INTERPRETATION AT AT COMMISSION.
>> SO YOU'RE SAYING THOSE ARE COVERED
6 UNDER 508 BUT NOT NECESSARILY YET UNDER 255.
>> EXACTLY.
7 >> THANK YOU.
I'D LIKE TO MOVE ON NOW TO OUR NEXT PANELIST.
8 IS KEITH THUR SON.
HE'S BACK BY POPULAR DEMAND.
9 KEITH WAS AT OUR FIRST WEB CAST IN JUNE WHICH IS
ACTUALLY ARCHIVED, BY THE WAY ON THIS WEB SITE IF YOU
10 WOULD LIKE TO GO UP AND TAKE A LOOK AT IT.
KEITH IS THE ASSISTANT TO THE DEPUTY ASSOCIATE
11 ADMINISTRATOR FOR THE OFFICE OF INFORMATION
TECHNOLOGY AT GSAN AND KEITH IS THE ONE WHO WAS
12 INSTRUMENTAL IN DRAFTING THE NEW FEDERAL ACQUISITION
REGULATIONS THAT BRING SECTION 508 UNDER GOVERNMENT
13 PROCUREMENT.
KEITH, THANK YOU.
14 >> THANK YOU.
GSA HAS BEEN INVOLVED IN ACCESS IN TECHNOLOGY ITEMS
15 FOR A LONG TIME.
UNDER THE ORIGINAL SECTION 508 THERE WAS SOME
16 REQUIREMENTS THAT GUIDELINES BE PUT OUT AND THEY WERE
IN THE LATE 80S AND EARLY 1990S AND I THINK WE CAN
17 SAFELY SAY ONE OF THE REASONS WHY WE HAD A REDRAFTING
OF THE SECTION 508 LAW WAS BECAUSE FEDERAL AGENCIES
18 IS DID NOT PROVIDE A STRONG ADHERENCE TO THOSE
GUIDELINES AND THEREFORE BECAUSE THE FEDERAL AGENCIES
19 WEREN'T ASKING FOR THESE CAPABILITIES IN REQUESTS FOR
PROPOSALS, THE INDUSTRY DID NOT PROVIDE THEM.
20 AND WITH A DECADE ALMOST PASSING WITHOUT SIGNIFICANT
PROGRESS IN THIS AREA, I THINK THE CONGRESS FOUND IT
21 WAS IMPORTANT TO PUT SOME MORE TEETH INTO SECTION
508, RIGHTFULLY SO.
22 WHAT'S OCCURRED IS BASED ON THE ACCESS BOARD
PUBLISHING THE STANDARDS THEMSELVES AND THE
23 REQUIREMENT IN THE LAW THAT THE FEDERAL ACQUISITION
REGULATIONS BE REVISED.
24 GSAN AND THE OTHER TWO PARTNERS THAT ARE THE VOTING
MEMBERS OF THE FEDERAL ACQUISITION REGULATIONS,
25 THAT'S NASA AND DOD, LED A PROCESS TO REVISE THE
FEDERAL FRL FRL REGULATIONS TO MAKE SURE THAT



15

1 AGENCIES TOOK INTO CONSIDERATION THE 508 REQUIREMENTS
FOR THE INITIAL PLANNING AS KAREN SAID EARLIER, THE
2 TIME AND PLACE TO CONSIDER ACCESSIBILITY IS IN THE
VERY FRONT END OF THE PLANNING PROCESS.
3 AND THAT'S NOT ONLY TRUE WITH THE TECHNOLOGY PRODUCTS
BUT IT'S TRUE WITH THE ACQUISITION AS WELL.
4 SO WE ARE REQUESTING THAT THE AGENCIES AND PUT IT IN
THE FAR THAT WHEN THEY DO THE MARKET RESEARCH ONE OF
5 THE VERY FIRST THINGS THEY'RE GOING TO ASK ABOUT IS
THE 508 STANDARDS BEING COMPLIED WITH AND THE
6 PRODUCTS THAT ARE BEING OFFERED.
NOW, AS DOUG MENTIONED, IT'S NOT THE MARKETPLACE'S
7 REQUIREMENT TO PROVIDE ONLY 508 PRODUCTS BUT IT'S THE
FEDERAL AGENCY'S REQUIREMENT TO BUY AND IMPLEMENT
8 SECTION 508 COMPLIANT PRODUCTS.
AND THE PARTICULAR PART OF THE LAW IS WHEN ITEMS ARE
9 PROCURED.
SO ANY ITEM PROCURED AFTER JUNE 21, 2001 ARE REQUIRED
10 TO COMPLY WITH SECTION 508 UNLESS THEY HAVE AN
EXCEPTION OR IT'S AN UNDUE BURDEN.
11 THERE ARE SOME ENUMERATED IN THE LAW, IN THE
STANDARDS AND IN THE FAR.
12 THERE'S A SECTION 508.GOV WEB PAGE AND THERE YOU
REQUEST R CAN GET THE REGULATIONS, YOU HAVE ACCESS TO
13 THE ACCESS BOARD'S STANDARDS, IT LINKS OVER TO THE
DEPARTMENT OF JUSTICE FOR THEIR INFORMATION, BUT IT
14 ALSO HAS SOME INFORMATION ON FREQUENTLY ASKED
QUESTIONS, AND IN THERE THEY ARE PARTICULARLY TUNED
15 TO THE PROCUREMENT COMMUNITY AND VENDORS TRYING TO DO
BUSINESS WITH THE GOVERNMENT ASKING SOME QUESTIONS
16 THAT CAME IN.
OVER A PERIOD OF THE LAST SIX MONTHS AND PROVIDING
17 THE ANSWERS.
THOSE ANSWERS HAVE BEEN REVIEWED BY A NUMBER OF
18 AGENCIES THAT ARE IN THE LEADERSHIP ROLE SO THERE'S
CONCURRENCE ON THEM AND WHILE THEY ARE NOT POLICY
19 SETTING THOSE ANSWERS GIVE YOU A PRETTY GOOD CLEAR
VIEW OF WHAT THE PROCUREMENT REMGZS MEAN AND THE
20 STANDARDS.
THE EXCEPTIONS THAT ARE AVAILABLE [] ARE PRETTY
21 NARROW AND HAVE PRETTY PRECISE MEANING.
ONE OF THE EXCEPTIONS IS IF THE ITEMS ARE BEING
22 BOUGHT ON A MICROPURCHASE PRIOR TO JANUARY 2003,
THAT'S THE CREDIT CARD PURCHASES THAT THE GOVERNMENT
23 HAS THE CAPABILITY TO DO, AND THOSE ARE LIMITED TO
$2500 OR LESS.
24 SO FOR THE MOST PART, TELECOM ARE USUALLY LARGER
SYSTEMS, SO YOU USUALLY WOULDN'T USE THE
25 MICROPURCHASE EXCEPTION.
AND IF YOU DO, YOU SHOULD KNOW THAT YOU CANNOT USE



16

1 THAT AGAIN AFTER 2003, THAT YOU NEED TO LEARN HOW TO
GET THOSE PRODUCTS COMPLIANT.
2 THERE'S ALSO AN EXCEPTION FOR NATIONAL SECURITY.
THOSE PEOPLE THAT ARE WORKING ON NATIONAL SECURITY
3 USUALLY AT DOD OR OTHER SECURITY AGENCIES USUALLY ARE
PRETTY MUCH AWARE IF THEIR SYSTEM IS A NATIONAL
4 SECURITY SYSTEM.
AND FOR THOSE THAT DON'T, THEY CAN GO TO THEIR
5 LEADERSHIP AND THERE ARE LISTS OF NATIONAL SECURITY
SYSTEMS.
6 THOSE CAN GET EXCEPTIONS.
IS THERE IS AN EXCEPTION IF THE ITEM IS BEING USED
7 INCIDENT TO THE CONTRACT.
SO SECTION 508 DOES NOT APPLY TO THE CONTRACTORS'
8 PREMISES.
IT ONLY APPLIES TO THE DELIVERABLES THAT ARE BEING
9 FURNISHED TO THE GOVERNMENT FOR SERVICES.
SO IT'S THOSE TELECOM SERVICES THAT ARE BEING
10 DELIVERED AND MADE AVAILABLE FOR THE GOVERNMENT USE
AND THE WHERE THE GOVERNMENT IS PROVIDING THAT USE TO
11 THE PUBLIC.
ALSO THERE'S AN EXCEPTION FOR REMOTE CAPABILITIES
12 FACILITIES AND THOSE ARE LOCATED IN REMOTE LOCATIONS
THAT ARE USUALLY ONLY FREQUENTED BY SERVICE
13 PERSONNEL.
NOW IN THE CASE OF TELECOMMUNICATIONS, THAT MIGHT BE
14 A ROUTER OR SOMETHING OF THAT NATURE MAY HAVE AN
EXCEPTION BECAUSE IT'S NOT GENERALLY ACCESSIBLE BY
15 THE WORKPLACE AND THE PUBLIC AND IS USUALLY BEING
APPROACHED BY A SERVICE TECHNICIAN AND ONLY ON AN
16 OCCASION BASIS.
AND I THINK YOU'LL FIND THAT THE ACCESS BOARD HAS
17 ADDITIONAL CLARIFICATION IN THAT AREA ON WHAT THEY
CONSIDER THAT EXCEPTION TO BE AS WELL.
18 AND THEN THERE'S ALSO THE ONE FOR WHERE THERE'S AN
UNDUE BURDEN.
19 AND THAT'S WHERE AS DOUG SAID THAT IT'S NOT POSSIBLE
BECAUSE EITHER OF THE TECHNOLOGY OR BECAUSE OF A
20 FINANCIAL CONSTRAINT FOR THE GOVERNMENT TO PROVIDE
THAT ITEM IN AN ACCESSIBLE WAY AND THAT'S A PRETTY
21 HIGH THRESHOLD ACROSS.
IT HAS TO BE DOCUMENTED, AND SUPPORTED UP THE CHAIN
22 OF COMMAND.
SO WITH EXCEPT WITH THOSE NARROW SCOPES OF THOSE
23 EXCEPTIONS, THEN ALL PRODUCTS WE EXPECT WILL BE
BOUGHT ACCESSIBLE.
24 NOW, WE KNOW WE'LL BE GOING THROUGH A TRANSITION
PROCESS WHERE THE INDUSTRY HAS JUST BECOME AWARE OF
25 THE STANDARDS LESS THAN A YEAR AGO.
WE KNOW THAT PRODUCT CYCLES HAVE TO GO THROUGH A



17

1 REVISION PROCESS EVERY 18 TO 24 MONTHS AND THAT
DURING THIS TRANSITION PROCESS THERE WILL BE TIMES
2 WHERE AGENCIES NEED TO BUY SOME PRODUCTS THAT ARE
PARTIALLY ACCESSIBLE.
3 AND IN THE FAR QUESTIONS AND ANSWERS YOU'LL SEE THAT
THERE'S EXPLANATION FOR WHAT TO DO ABOUT PARTIALLY
4 COMPLIANT PRODUCTS.
WE ENCOURAGE YOU TO LOOK AT THE REGULATIONS, THEY'RE
5 ON THE WEB SITE THEY ARE PRETTY CLEAR, BUT ALSO LOOK
AT THE FREQUENTLY ASKED QUESTIONS AND YOU'LL GET
6 ADDITIONAL INFORMATION.
I'LL END THERE AND I'LL WAIT FOR QUESTIONS.
7 >> THANK YOU.
SUPPOSE PROCUREMENTS THAT COVER LEASES WELL AS
8 PURCHASE, IS THAT CORRECT.
>> THAT'S GREAT.
9 THAT'S EXACTLY RIGHT.
THE PURCHASE, THE FEDERAL FRL DECISION REGULATIONS
10 APPLY TO PURCHASES FOR PRODUCTS, SERVICES AND A LEASE
WOULD ALSO BE A PURCHASE OF SERVICES.
11 >> SO IF A FEDERAL AGENCY IS LEASING, FOR
EXAMPLE, A TELECOMMUNICATIONS SERVICE OF SOME SORT
12 AND THEY ENTERED INTO THAT AGREEMENT BEFORE JUNE 21,
WHEN DOES SECTION 508 GET TRIGGERED FOR MAKING THAT
13 SERVICE ACCESSIBLE?
>> THE TRIGGER FOR 508 IS WHENEVER A NEW
14 PROCUREMENT IS MADE, EITHER A MODIFICATION OR A TASK
ORDER, ANYTHING OF THOSE NEW PRODUCTS OR SERVICES
15 THAT ARE ACQUIRED AFTER JUNE 21 MUST BE MADE
ACCESSIBLE.
16 FOR THOSE THAT ARE UNDER CONTRACT PREVIOUS TO THAT,
THERE IS NO LEGAL REQUIREMENT FOR THOSE TO BE
17 RETROACTIVELY MADE ACCESSIBLE.
HOWEVER, AGENCIES MUST REMEMBER UNDER SECTION 504
18 THEY HAD A PRE-EXISTING STANDARD TO MAKE PRODUCTS AND
SERVICES ACCESSIBLE FOR THEIR EMPLOYEES.
19 SO THEY SHOULD HAVE A GAME PLAN ON HOW THEY'RE GOING
TO MIGRATE AWAY FROM THOSE NONCOMPLIANT PRODUCTS OVER
20 TO COMPLIANT PRODUCTS AND TAKE THOSE OPPORTUNITIES
WHEN SYSTEMS ARE UPGRADED TO BUY COMPATIBLE PRODUCTS,
21 508 COMPLIANT PRODUCTS WHEN CAPABLE AND POSSIBLE.
>> WHAT ABOUT MODIFICATIONS TO EXISTING
22 CONTRACTS?
STPHAO: /*.
23 >> MODIFICATIONS TO EXISTING CONTRACTS ARE
NEW ACQUISITIONS AND THOSE MODIFICATIONS FROM THEN
24 ON, THE PRODUCTS AND SERVICES NEWLY ACQUIRED NEED TO
BE ACCESSIBLE BUT THAT MODIFICATION DOESN'T REQUIRE
25 THAT THAT ENTIRE CONTRACT THAT PRE-EXISTED JUNE 21 BE
RETROACTIVELY REMEDIATED.



18

1 >> THANK YOU VERY MUCH, KEITH.
AND I'M SURE WE'LL REVISIT SOME OF THESE ISSUES IN A
2 LITTLE WHILE.
I WANT TO MOVE ON TO OUR NEXT PANELIST WHO IS JIM
3 TOBIAS.
JIM IS THE PRESIDENT OF INCLUSIVE TECHNOLOGIES AND
4 HAS BEEN WORKING IN THE FIELD OF TECHNOLOGY AND
COMMUNICATIONS ACCESS FOR ABOUT 25 YEARS AND
5 CURRENTLY IS A CONSULTANT PRIMARILY TO THE PRIVATE
SECTOR ON A NUMBER OF THESE ISSUES THAT WE'RE TALKING
6 ABOUT TODAY.
JIM, THANK YOU FOR JOINING US.
7 JIM: THANKS, JULIE.
WE APPRECIATE THE OPPORTUNITY TO KIND OF ACT HERE AS
8 TECHNICAL RELIEF.
I GUESS IF ANY EVERY DRAMA THERE SHOULD BE SOME
9 ECONOMIC RELIEF, WE SHOULD BE THE TECHNICAL RELIEF
FOR THE DAY.
10 FOR THOSE ENGINEERS WHO'VE BEEN FORCEED TO LISTEN TO
THIS WEB CAST SO FAR AND MAYBE DIDN'T RELATE TO ALL
11 OF THE REG REGY INFORMATION, WE'LL GIVE YOU A FEW
MINUTES OF TECH TALK HERE.
12 WHAT WE DO AT INCLUSIVE TECHNOLOGIES, AND I DON'T
KNOW IF THAT'S -- IS THAT BEING BROAD NOW?
13 BECAUSE THE OTHER -- I'M GOING TO NEED THE CLOSE-UP
CAMERA.
14 INSTEAD OF THE WEB SITE TO BEGIN WITH.
OKAY, JUST GO THEY SAY.
15 WHAT WE TRY TO DO IS TRANSLATE THE GUIDELINES AND
STANDARDS INTO FEATURES THAT MANUFACTURERS AND
16 SERVICE PROVIDERS CAN IMPLEMENT ON THEIR PRODUCTS AND
SERVICES.
17 AND THIS IS NOT AS EASY AS IT MIGHT SEEM.
FOR PEOPLE WHO ARE UNFAMILIAR WITH DISABILITY, FOR
18 EXAMPLE, OR ACCESSIBILITY, IT'S HARD TO READ THE
REGULATIONS AND UNDERSTAND INSTANTLY HOW THEY SHOULD
19 CHANGE THEIR PRODUCTS.
SO ONE OF OUR JOBS AND AS JEWLY MENTIONED, WE WORK
20 MOSTLY WITH PRIVATE SECTOR COMPANIES BUT NOT
ENTIRELY, ONE OF OUR JOBS IS TO COME IN AND TAKE A
21 LOOK AT THE PRODUCTS THAT THEY'RE MANUFACTURES SO FAR
AND EXPLAIN TO THEM WHERE THERE ARE ACCESS BARRIERS
22 AND WHERE THERE ARE ACCESS ADVANTAGES IN THOSE
PRODUCTS AND WE FIND THAT THAT'S A VERY EFFECTIVE WAY
23 OF GETTING THEM UP TO SPEED.
AND I'M GOING TO SHOW OFF SOME EXAMPLES AND YOU
24 SHOULDN'T TAKE THE FACT THAT I'M DEMONSTRATING ONE OR
ANOTHER OF THESE PRODUCTS AS AN ENDORSEMENT OR A
25 CRITICISM OR WHAT HAVE YOU.
THIS IS A RELATIVELY NEW CELL PHONE THAT'S JUST ON



19

1 THE MARKET AND YOU MIGHT NOTICE IT'S OF COURSE SMALL
AND ONE OF THE CONCERNS THAT PEOPLE HAVE ABOUT CELL
2 PHONES IS THAT THEY'RE CONSTANTLY SHRINKING SO THAT
SOMEONE WITH A PHYSICAL DISABILITY, SAY A DEXTERITY
3 DISABILITY, MIGHT HAVE INCREASINGLY MORE AND MORE
TROUBLE OPERATING THEM.
4 AND MANY OF THESE PHONES HAVE THESE NAVIGATIONAL
KEYS.
5 IN THIS CASE IT'S A ROUND KEY WITH ARROWS, UP, DOWN,
LEFT, AND RIGHT, AND THAT'S HOW YOU NAVIGATE THROUGH
6 THE FEATURES OF THE PHONE.
ONE OF THE EXCELLENT THINGS ABOUT THIS PARTICULAR
7 PHONE IN CONTRAST TO OTHERS THAT ARE ON THE MARKET IS
THAT THE NAVIGATION KEY IS IN BLACK AND THE ARROWS
8 ARE IN WHITE.
SO ACTUALLY I THINK IF THERE HAD BEEN, AND I WOULD
9 ECHO KAREN'S POINT THAT OF HOW IMPORTANT IT IS TO
WORK WITH CONSUMERS WITH DISABILITIES IN DESIGNING
10 PRODUCTS, IF THERE HAD BEEN SUCH A GROUP INVOLVED IN
THE DESIGN OF THIS, I THINK THAT SOME OF THE LOW
11 VISION USERS WOULD HAVE SAID CAN YOU MAKE THAT
NAVIGATION KEY BLACK AND MAKE THE ARROW KEYS WHITE.
12 SO THIS BY COINCIDENCE HAPPENS TO BE A VERY WELL
DESIGNED VERSION OF THAT. I DON'T KNOW IF YOU CAN
13 SEE THE NUMERALS THAT ARE ACTUALLY ON THE DISPLAY,
BUT FOR DIALING THOSE NUMERALS ARE DOUBLE SIZE AND
14 THEY'RE QUITE READABLE.
SO ALTHOUGH THE PHONE IS SMALL, THE DISPLAY IS KIND
15 OF LARGE AND THE NUMERALS ON THE DISPLAY ARE EASY TO
READ.
16 I'LL GO THROUGH A NUMBER OF THESE PDA'S, THESE
WIRELESS PDA'S THAT ARE BECOMING A VERY IMPORTANT
17 PART OF THE WORKPLACE AND THEY'RE EVEN GOING INTO
EDUCATIONAL SETTINGS NOW.
18 THIS IS THE PALM 7 X WHICH OBVIOUSLY USES THE PALM
OPERATING SYSTEM AND AN INTERESTING ACCESS FEATURE
19 ABOUT THIS DEVICE IS THAT YOU CAN TURN IT ON JUST BY
LIFTING THE AN ANA.
20 AND THAT NOT ONLY TURNS THE DEVICE ON BUT YOU CAN
HAVE IT LAUNCH WHATEVER APPLICATION YOU WANT.
21 SO AGAIN, FOR SOMEONE WITH A DEXTERITY IMPAIRMENT,
THIS MIGHT BE THE EASIEST WAY TO OPERATE THE PALM.
22 ONE OF THE INTERESTING THINGS ABOUT ALL OF THESE
PDA'S IS THE STYLIST WHICH IS A KEY ACCESSIBILITY
23 ISSUE.
ON THIS PALM, IT'S KIND OF TUCKED INTO THE BACK OF
24 THE CASE ITSELF AND YOU HAVE TO PRESS UP ON IT IN
ORDER TO FREE IT FROM ITS LITTLE STORAGE LOCATION.
25 AND THEN WHEN YOU WANT TO STORE IT BACK YOU HAVE TO
INSERT IT THERE AGAIN.



20

1 AND I CAN IMAGINE THAT THERE ARE MANY PEOPLE WHO
WOULD HAVE SOME DIFFICULTY OPERATING THIS PARTICULAR
2 DEVICE.
THIS, BY THE WAY, THIS PALM UNIT AND MOST OF THESE
3 UNITS COME WITH THEIR OWN CARRYING CASES.
BUT YOU CAN GET AFTER MARKET THIRD CARRYING CASES
4 THAT CHANGE HOW YOU RETRIEVE THE OBJECT AND HOW YOU
PUT IT BACK IN.
5 THIS HEWLETT PACKARD JOR NADA DOESN'T HAVE A CASE OR
DOESN'T NEED A CASE BECAUSE THE CASE IS BUILT INTO
6 THE UNIT ITSELF.
SO IT HAS KIND OF A CLAM SHELL OPENING AND THE CASE
7 COVERS THE UNIT ENTIRELY.
THIS HAS AN INTERESTING STYLIST STORAGE IN THAT THE
8 STYLIST IS RATHER FLAT.
IT'S KIND OF -- THE CROSS SECTION OF THIS IS KIND OF
9 AN AIRPLANE WING.
IT'S A FLATTENED THING AND IT SITS RIGHT IN THE
10 INSIDE OF THE CASE, SO THAT'S HOW YOU WOULD HAVE TO
TAKE IT OUT AND PUT IT BACK IN.
11 SOME OTHER IMPLICATIONS ON THIS PARTICULAR ONE ARE
ANOTHER KIND OF CONTROL THAT'S BECOMING VERY POPULAR
12 IN CELL PHONES AS WELL AS THESE WIRELESS PDA'S AND
THAT IS THE JOG DIAL.
13 IN THIS CASE IT'S BUILT ALMOST FLUSH, SOMEWHAT
RECESSED ON THE SIDE OF THE CASE, AND IT'S A LITTLE
14 WHEEL THAT YOU CAN PRESS IT DOWN AND IT SPRINGS BACK
TO MIDPOINT OR YOU CAN PRESS IT UP AND IT STRINGS
15 BACK TO MIDPOINT AND YOU CAN ALSO PRESS IT IN AND IT
ACTIVATES THE BUTTON.
16 SO THIS IS KIND OF LIKE THE MOUSE, IF WE WERE IN AN
APPLICATION HERE, IF YOU WANTED TO SELECT AN ITEM,
17 YOU WOULD PRESS IN ON THE BUTTON AND IT WOULD
HIGHLIGHT AND ACTIVATE WHATEVER ITEM YOU HAD
18 SELECTED.
HERE'S ANOTHER ONE WHICH IS THE COMPAQ
19 IPAC AND THIS HAS A LOT OF INTERESTING ISSUES OR
ACCESSIBILITY FEATURES AS WELL.
20 ONE OF THE THINGS THAT'S INTERESTING TO ME IS THAT
THE NAVIGATION KEY ON THIS ONE IS THE SPEAKER AS
21 WELL, SO IT'S KIND OF AN INTERESTING LITTLE DESIGN
THERE AT THE BOTTOM.
22 IT HAS PRETTY GOOD AUDIO FIDELITY AND IT IS THE SAME
DEVICE THAT YOU PRESS FOR DOWN UP AND LEFT AND RIGHT.
23 AND THE STYLIST IN THIS ONE IS STORED AT THE TOP AND
THERE'S A LITTLE PUSH BUTTON THERE AND YOU PRESS THE
24 PUSH BUTT ON AND OUT POPS THE STYLIST.
SO THAT'S ANOTHER ACCESSIBILITY FOR SOMEBODY WHO
25 MIGHT HAVE A PROBLEM SLIDING THE STYLIST OUT OF THE
CASE.



21

1 ABOUT THE STYLISTS OR STILI, I GUESS THEY ARE,
ANOTHER THING THAT THE MARKET OFFERS IN ADDITION TO
2 THIS WIDE VARIETY OF PDA'S THAT PEOPLE CAN SELECT
FROM IS A LARGE AND ACTIVE AFTERMARKET.
3 THIS IS A TRUE TIP STYLIST.
THERE ARE THREE OF THEM HERE AND THEY'RE CUTE LITTLE
4 GADGETS THAT FIT RIGHT OVER YOUR IF ANYTHINGER TIP
AND YOU CAN PRESS THEM IN SO THEY STAY ON YOUR FINGER
5 NICELY AND THEY HAVE A GOOD DENSITY OF PLASTIC SO
IT'S NOT GOING TO DAMAGE THE TEST SENSITIVE PORTION
6 OF THE PDA.
I HAVE THEM TODAY IN RED, WHITE, AND BLUE, AND I
7 SHOULD ALSO SAY THAT THE WHITE ONE GLOWS IN THE DARK.
SO THOSE OF YOU WITH LOW VISION MIGHT FIND THAT THE
8 BEST WAY TO USE A PDA WOULD BE WITH SOME BACK
LIGHTING WHICH CAN INCREASE THE CONTRAST AND THEN A
9 GLOW IN THE DARK STYLIS SO THAT YOU CAN FIGURE OUT
WHERE YOU'RE HOVERING OVER IT IN ORDER TO STRIKE THE
10 SERVICE WHERE YOU NEED TO.
THIS IS A DEVICE THAT'S A PROTOTYPE OF A TECHNOLOGY
11 CALLED FAST TAP BY A COMPANY CALLED DIGITAL WIRELESS.
VERY INTERESTING CONCEPT.
12 IF YOU LOOK AT THE KEYBOARD AND THIS IS AS I SAY A
PROTOTYPE AND THEY INTEND TO LICENSE THIS TO PHONE
13 MANUFACTURERS, THE KEYBOARD HAS THE REGULAR NUMERIC
KEYBOARD LAYOUT BUT IN ADDITION IN THE LITTLE DIAMOND
14 SHAPED AREAS BETWEEN THE BUTTONS IF YOU UNDERSTAND
WHAT I MEAN, ARE OTHER BUTTONS THAT ARE RAISED.
15 SO YOU CAN IN FACT ENTER TEXT BY PRESSING THOSE SMALL
BUTTONS, THOSE SMALL DIAMOND-SHAPED BUTTONS IN
16 BETWEEN THE LARGER NUMERIC BUTTONS. THE IDEA OF A
PRODUCT LIKE THIS IS THAT INSTEAD OF USING THE
17 SOMEWHAT DIFFICULT SYSTEM FOR ENTERING TEXT ON A 12
DIGIT KEY PAD BY PRESSING A, THE 1 KEY ONCE FOR A AND
18 TWICE FOR B AND 3 TLEES FOR C.
THIS CAN GIVE YOU DIRECT ACCESS TO A, B, OR C.
19 AND AGAIN, THIS IS SNOT SOMETHING YOU MIGHT WANT TO
THINK OF AS A ONE-SIZE FITS ALL, THIS IS THE
20 AUTOMATIC COMBINATION FOR ALL USERS.
WE DON'T TAKE -- WE DON'T USE THAT MODEL VERY MUCH IN
21 OUR CONSULTING WORK; WE HAVE KIND OF A PRODUCT
ECOLOGY MODEL WHICH SAYS THAT -- AND THIS IS I THINK
22 WHERE WE MIGHT DIFFER WITH THOSE WHO HAVE SMOKEN FROM
A MORE REGULATORY PERSPECTIVE.
23 ALTHOUGH ALL OF THESE PRODUCTS ARE SUBJECT TO 255 AND
508, WE THINK THAT CONSUMERS ARE MUCH BETTER SERVED
24 IF THERE ARE A BROAD RANGE OF PRODUCTS, ANY ONE OF
WHICH WILL BE EXTREMELY ACCESSIBLE FOR ONE GROUP WITH
25 DISABILITIES EVEN THOUGH IT MIGHT BE LESS ACCESSIBLE
FOR ANOTHER GROUP OF PEOPLE WITH DISABILITIES.



22

1 AND I THINK THE GOAL SHOULD BE IF WE COULD LOOK AT
THIS SORT OF INDUSTRY WIDE TO MAKE SURE THAT THE
2 PRODUCT ECOLOGY IS DIVERSE AND ROBUST SO THAT THERE
ARE MANY CHOICES FOR ANY GIVEN PERSON WITH A
3 DISABILITY.
NOW, THE PROBLEM WITH THAT IS INFORMATION.
4 AND I THINK WE'LL ALL AGREE THAT MOVING OVER TO THE
WEB PAGE THAT I HAVE BROUGHT UP, INFORMATION ABOUT
5 ACCESSIBLE INFORMATION TECHNOLOGY AND
TELECOMMUNICATIONS IS THE SCARCITY.
6 A STUDY THAT WE PERFORM WOULD BUYER DOUG'S AGENCY,
THE ACCESS BOARD, INDICATES THAT AS MANY AS 20
7 PERCENT OF CONSUMERS WITH DISABILITIES UNDERESTIMATE
THE ACCESSIBILITY OF PRODUCTS THAT ARE AVAILABLE TO
8 THEM.
AND I THINK IT'S OBVIOUS WHY.
9 PEOPLE ARE PESSIMISTIC ABOUT THE ACCESSIBILITY OF
MAINSTREAM PRODUCTS BECAUSE THEY'VE HAD SO MANY
10 FAILED EXPERIENCES WITH THEM.
IT'S JUST ASSUMED THAT WHATEVER COMES OUT ON THE
11 MARKET WON'T BE ANY BETTER.
COMPANIES SHOULD BE AWARE OF THIS AND SHOULD TO SOME
12 EXTENT TILT THEIR MARKETING TO THE EXTENT THEY TAKE
THIS MARKETING SERIOUSLY SO THAT THE ACCESSIBILITY
13 AND USABILITY FEATURES ARE CORRESPONDINGLY HEIGHTENED
AND THERE'S MORE ATTENTION PAID TO THEM IN MARKET
14 GUILTY.
SO ONE OF THE PROJECTS THAT THAT DOUG'S AGENCY
15 SUPPORTED WAS A MARKET MONITORING REPORT.
AND THE IDEA OF THE MARKET MONITORING REPORT WAS TO
16 REVIEW SOME, A HANDFUL OF THE 20,000 TELECOM PRODUCTS
THAT ARE OUT AT ANY GIVEN TIME, TRY TO UNDERSTAND,
17 TAKE A SNAPSHOT OF HOW ACCESSIBLE THEY WERE AND WHAT
FEATURES THEY HAD AND WHAT FEATURES THEY DIDN'T HAVE
18 TO SEE WHERE COMPANIES NEEDED TO MAKE THE MOST
PROGRESS AND WHERE THE SITUATION WAS ALREADY
19 ACCEPTABLE.
SO WE CREATED A DATA BASE THAT HAD A LIST OF ALL OF
20 THE ACCESS FEATURES THAT WE COULD IDENTIFY, A LIST OF
CONDITIONS OR DISABILITIES THAT HAVE IMPLICATIONS FOR
21 TELECOMMUNICATIONS, ALL OF THE SECTION 255
GUIDELINES, AND ALL OF THE PRODUCTS THAT WERE COVERED
22 BY 255.
SO THESE ARE PRODUCT CATEGORIES LIKE FAX MACHINE OR
23 MODEM OR WHAT HAVE YOU.
AND I'M NOT GOING TO GO THROUGH THE ENTIRE DATA BASE,
24 BUT IT'S STILL UP ON THE ACCESS BOARD WEB SITE AND
THAT'S WWW.ACCESS-BOARD.GOV/TELECOM,/MARKET REP
25 MARKETREP.
AND I THINK WE HAVE SOME GOOD INFORMATION THERE.



23

1 NO MATTER WHICH WAY YOU'RE COMING INTO THIS TOPIC.
IF YOU HAVE A DISABILITY AND NEED INFORMATION ABOUT
2 PRODUCTS, IF YOU ARE A COMPANY YOU NEED TO UNDERSTAND
MORE ABOUT DISABILITIES, THE INFORMATION IS THERE.
3 I JUST WANT TO SHOW YOU ONE EXAMPLE OF HOW WE SEE
INFORMATION SERVING BOTH COMPANIES AND CONSUMERS.
4 THIS IS A DATA BASE SEARCH PAGE AND AT THIS POINT WE
CAN SELECT A PRODUCT TYPE AND LET'S SAY CORDLESS
5 TELEPHONES AND WE CAN SELECT AN ACCESS FEATURE AND
LET'S SAY ILLUMINATED DISPLAY AND WE CAN SEARCH FOR
6 PRODUCTS THAT HAVE BOTH OF THOSE CHARACTERISTICS,
THAT IS THEY ARE CORDLESS TELEPHONES WITH ILLUMINATED
7 DISPLAYS AND WE HAVE A PRODUCT HERE AND THERE'S
INFORMATION ABOUT THE PRODUCT AND YOU CAN ALSO CLICK
8 ON ONE OF THE LINKS AND YOU CAN SEE A PICTURE OF THE
PRODUCT.
9 SO THERE'S A WAY OF CONVERTING OR TRANSLATING THE
REGULATIONS INTO CONSUMER PRODUCT FEATURES.
10 AND AGAIN, THE VALUE THEY SEE FOR THIS IS THAT
CONSUMERS WILL BE INTERESTED IN UNDERSTANDING WHAT
11 PHONES OR OTHER PRODUCTS ARE OUT THERE THAT THEY CAN
USE AND I THINK COMPANY DESIGNERS ARE ALSO CURIOUS
12 ABOUT WHERE THEIR COMPANY PRODUCTS SIT WITH RESPECT
TO OTHER MANUFACTURERS AND WE'RE HOPING I THINK TO
13 BUILD SOME KIND OF COMPETITION AMONG MANUFACTURERS
AND SERVICE PROVIDERS SO THAT THEY ARE CONSTANTLY
14 IMPROVING THEIR PRODUCTS AND I THINK I'LL END IT
THERE IF YOU HAVE ANY MORE QUESTIONS FOR ME.
15 >> JIM, IS THIS SOMETHING THAT PEOPLE CAN
INPUT INFORMATION INTO?
16 >> YES.
WE'RE ACTIVELY LOOKING FOR INFORMATION FROM COMPANIES
17 AND AS WAS MENTIONED BEFORE, THE PRODUCT CYCLE IN THE
TELECOM AND INFORMATION TECHNOLOGY INDUSTRY IS VERY
18 FAST, SO PRODUCT INFORMATION NEEDS TO BE CONSTANTLY
UPDATED.
19 SO WE'RE VERY HAPPY TO RECEIVE INFORMATION AND YOU
CAN SEND IT IF YOU'RE A COMPANY OUT THERE ABOUT
20 INFORMATION WITH YOUR PRODUCTLESS, E-MAIL INFORMATION
TO US AT.
21 MMR AT INCLUSIVE.COM.
MOVING ON, OUR NEXT PANELIST IS CLAUDIA
22 GORDON.
CLAUDIA IS A STAFF ATTORNEY WITH THE NATIONAL NASHL
23 NASHL NASHL DEAF'S LAW CENTER.
COMPLAUDIA WAS BORN IN JAMAICA AND MOVED TO THE
24 UNITED STATES WHEN SHE WAS 11.
SHE LOST HER HEARING WHEN SHE WAS EIGHT YEARS OLD.
25 AND SHE IS A GRADUATE OF HOWARD UNIVERSITY AS WELL AS
THE AMERICAN UNIVERSITY'S COLLEGE OF LAW.



24

1 AND SO FAR AS WE KNOW IS THE FIRST BLACK DEAF
ATTORNEY.
2 FEMALE ATTORNEY.
CLAUDIA.
3 THANK YOU.
>> THANK YOU.
4 IT'S MY PLEASURE TO BE HERE WITH THIS MARVELOUS GROUP
OF PANELISTS.
5 OUR ORGANIZATION REPRESENTS 180 DEAF AND
HARD-OF-HEARING PEOPLE IN THE UNITED STATES AND THIS
6 IS A MAJOR PART OF OUR CONCERN IN THE AREA OF
TELECOMMUNICATIONS AND THE USE OF THESE PRODUCTS.
7 NAD SEE SECTION 255 AND 508 AS MARVELOUS
OPPORTUNITIES TO LEVEL THE PLAYING FIELD FOR DEAF AND
8 HARD-OF-HEARING PEOPLE.
THERE ARE SOME AREAS THAT STILL REMAIN PROBLEMATIC
9 FOR US.
ONE OF THE GREATEST CONCERNS IS INTERACTIVE VOICE
10 MENUS.
A DEAF PERSON THAT CALLS WITHOUT A COMPARABLE SERVICE
11 WOULD NEED SOMETHING THAT WOULD HAVE A DIRECT
CONNECTION TO TTY, FOR TTY USERS.
12 WHAT THAT MEANS THAT WEELD HAVE TO USE THE RELAY
SERVICE WHICH IS A THIRD PARTY BEING INVOLVED WHICH
13 MEANS A DELAYED TIME OR A LAG TIME WOULD BE INVOLVED
WITH THE INTERACTIVE VOICE RESPONSE MENUS.
14 IT TAKES TIME FOR THE RELAY OPERATOR TO CATCH THE
DIFFERENT OPTIONS THAT ARE PROVIDED AND THE RELAY
15 OPERATOR DOES NOT HAVE ENOUGH TIME TO INTERPRET THIS
INFORMATION TO THE DEAF CALLER, HAVE THE DEAF CALLER
16 MAKE THE APPROPRIATE CHOICE, AND GET THE RESULT.
SO WHAT HAPPENS IS THAT THERE'S A TIME OUT.
17 AND WE FEEL THAT THERE IS A SOLUTION THAT CAN BE
SIMPLY PLACED AND CAN SOLVE IT.
18 WE CAN HAVE A TTY MENU THAT WOULD BE A DIRECT CONNECT
FOR TTY USERS AND OTHER MACHINES THAT COULD GIVE
19 SIMILAR OPTIONS OR PERHAPS IF THIS IS NOT A
POSSIBILITY THEN THE MENU ITSELF SHOULD OFFER A
20 CHOICE WHERE A DEAF CALLER COULD OPT FOR MORE TIME
WITHOUT THE DISCONNECT HAPPENING, THE TIME OUT
21 PROCEDURE HAPPENING.
WE STRONGLY ADVOCATE FOR COMPARABLE TTY HOTLINES
22 WHERE DEAF CALLERS CAN HAVE EQUAL ACCESS TO SERVICES
AS HEARING CONSUMER COUNTERPARTS HAVE.
23 ONE OF THE POINT RELATE TO TTY AND RELAY SERVICES.
AVAILABILITY OF SERVICE IS A PROBLEM.
24 AND ALSO WE REQUIRE TRAINING.
TRAINING OF STAFF MEMBERS.
25 WHETHER IT'S A GOVERNMENT AGENCY OR A PRIVATE
COMPANY, A PRIVATE AGENCY.



25

1 STAFF MEMBERS SHOULD KNOW HOW TO RECOGNIZE A TTY CALL
OR TO KNOW WHAT A RELAY CALL IS.
2 OFTEN A DEAF CALLER INCLUDING MYSELF HAVE HAD
EXPERIENCES WHERE A PERSON WILL HANG UP ON US BECAUSE
3 THEY DON'T UNDERSTAND WHAT A RELAY CALL IS OR THEY DO
NOT RECOGNIZE A TTY SIGNAL SO AGAIN, PEOPLE DO NEED
4 TRAINING.
IT IS AN INTEGRAL PART OF RESOLVING THE PROBLEM WITH
5 TELECOMMUNICATION ISSUES THAT WE FACE IN THIS AREA.
ANOTHER MAJOR PROBLEM THAT WE'RE STILL EXPERIENCING
6 THAT I FEEL IS UNDER 255 AND SECTION 508, I THINK THE
PROBLEM SHOULD BE RESOLVED SHORT SHORT IS THAT OF
7 CAPTIONING OF VIDEO TAPES.
FOR EXAMPLE, SOME GOVERNMENT AGENCIES WILL USE A
8 VIDEO TAPE FOR TRAINING STAFF AND STILL WE'RE FINDING
THAT THE TAPE IS NOT OFTEN, NOT ALWAYS CAPTIONED.
9 SO WITH 508, GOVERNMENT AGENCIES SHOULD NOT BE ABLE
TO PURCHASE OR WILL NOT PURCHASE VIDEO TAPES THAT ARE
10 NOT CAPTIONED.
AND THE SECTION 508 SHOULD ENSURE THAT PRODUCTS DO IN
11 FACT HAVE CAPTIONING.
AS MY COLLEAGUE KAREN STRAUSS MENTIONED, IT IS IN
12 FACT CHEAPER TO GIVE A RESOLUTION THAT IS IMPLEMENTED
IN THE BEGINNING OF THE CYCLE AS OPPOSED TO AN ADD-ON
13 THAT'S DONE LATER.
THAT IS IN FACT A MORE COSTLY ALTERNATIVE.
14 WE ALSO FEEL THAT THERE IS A MAJOR PROBLEM WITH USE
OF DIGITAL TELEPHONES.
15 IT'S SIMPLE BECAUSE DIGITAL PHONES ARE NOT COMPATIBLE
AT ALL WITH TTY'S OR FOR MOST HEARING AID USERS TO BE
16 ABLE TO CONNECT WITH A DIGITAL PHONE.
AGAIN, IT'S NOT COMPAT I BELIEVE /*IBLE.
17 WE REALLY HOPE THERE IS A QUICK SOLUTION TO THIS
PROBLEM.
18 FOR USERS OF DIGITAL PHONES TO BE ABLE TO CONTACT TTY
USERS.
19 IN THE MEANTIME, NATIONAL NASHL OF THE DEAF FEELS
THAT ANALOGS SHOULD NOT BE GOTTEN RID OF BECAUSE THE
20 RESULT IS THAT WE NEED TO BE ABLE TO MAINTAIN
ACCESSIBILITY.
21 ONE OTHER AREA OF CONCERN WHEN GOVERNMENT AGENCIES,
OFFICES OR PRIVATE COMPANIES USE AUTOMATIC INTERCOMS,
22 PUBLIC ADDRESS ANNOUNCEMENT SYSTEMS, FOR DEAF OR
HARD-OF-HEARING PEOPLE, PERHAPS THEY'RE GOING TO THE
23 IRS OFFICE OR THE SOCIAL SECURITY OFFICE, THEY'RE
SITTING THERE WAITING TO GET ASSISTANCE.
24 THERE IS A NUMBER OR CALL SYSTEM THROUGH AN INTERCOM.
A DEAF USER WOULD NOT BE ABLE TO KNOW WHEN IT WAS
25 THEIR TURN.
A STAFF MEMBER MIGHT NEED TO COME UP AND LET A DEAF



26

1 OR HARD OF HEARING PERSON KNOW IN FACT IT IS THEIR
TURN.
2 OR VISUAL TEXT WHICH WOULD ALLOW THE PERSON TO ACCESS
A VISUAL MANY WHERE DEAF AND HARD HARD HARD PEOPLE
3 WOULD BE ABLE TO KNOW THROUGH THE VISUAL MESSAGEING
THAT IT WAS THEIR TURN.
4 THERE'S ALSO TECHNOLOGY THAT MANY RESTAURANTS USE
TODAY WHERE THERE IS A I HAVE BRAITING MECHANISM AND
5 THIS KIND OF MECHANISM COULD BE PUT IN PLACE FOR DEAF
AND HARD HARD HEARING PEOPLE IN OTHER AREAS.
6 AND FINALLY ONE OTHER MAJOR AREA THAT REMAINS A
PROBLEM.
7 THERE ARE MANY WEB INTERNET SITES THAT ARE AUDIO
ENABLED.
8 THAT THERE IS A VOICE INTERACTIVEITY AND THIS IS NOT
SOMETHING THAT A DEAF OR HARD OF HEARING PERSON COULD
9 SUCCESSFULLY USED AND SO THERE NEEDS TO BE A TEXT
EQUIVALENT FOR ANY AUDIO SIGNAL.
10 AND THAT'S BASICALLY SOME, NOT ALL, BUT SOME OF OUR
CONCERNS AT THE NATIONAL NASHL NASHL NASHL DEAF.
11 AND WE'RE STILL IN THE PROCESS OF TRYING TO FIND
RESOLUTIONS FOR THESE VARIOUS PROBLEMS.
12 IN THE MEANTIME, WE SUPPORT FLEXIBILITY.
WE KNOW THAT TECHNOLOGY IS CONSTANTLY CHANGING, THAT
13 IT'S CHANGING RAPIDLY.
WE DON'T WANT TO LOCK OURSELVES INTO ONE APPROACH,
14 ONE RESOLUTION WHERE THERE COULD BE A BETTER
RESOLUTION THAT WILL APPEAR AT A LATER TIME.
15 SO WE DO SUPPORT FLEXIBILITY AND WE LOOK AT OTHER
STLUGZS THAT CAN SOLUTIONS THAT CAN APPEAR DOWN THE
16 ROAD AND WE'RE LOOKING BROAD MINDEDLY AND WE'RE
LOOKING AT REASONABLE WAYS TO WORK TOGETHER WITH
17 GOVERNMENT AGENCIES, PRIVATE INDUSTRY ALSO.
AND MANUFACTURERS.
18 TO BE ABLE TO FIND THE BEST APPROACH.
TO MAKE TELECOMMUNICATION TECHNOLOGY ACCESSIBLE FOR
19 DEAF AND HARD-OF-HEARING PEOPLE ALL OVER THE
UNITED STATES.
20 >> THANK YOU, CLAUDIA.
CLAUDIA, YOU MENTIONED THAT OFTEN VIDEOS ARE NOT
21 CAPTIONED.
IF AN AGENCY OR AN ORGANIZATION IS CREATING A VIDEO
22 OR SUPPOSE THEY HAVE ONE ALREADY, AND THEY WOULD LIKE
TO GET IT CAPTIONED, CAN YOU RECOMMEND SOURCES FOR
23 WHERE THOSE PEOPLE SHOULD TURN.
>> YES.
24 I CAN.
THERE ARE SEVERAL ORGANIZATIONS.
25 I CAN'T THINK OF THEM OFF THE TOP OF MY HEAD.
KAREN, PERHAPS YOU COULD HELP.



27

1 KAREN: GALLAUDET UNIVERSITY IN
WASHINGTON, D.C. MAINTAINS A LIST OF VARIOUS
2 CAPTIONING AGENCIES AVAILABLE THROUGHOUT THE NATION.
SO ANYONE INTERESTED IN FINDING OUT THE BEST
3 CAPTIONING AGENCY FOR THEM, I WOULD RECOMMEND
CONTACTING GALLAUDET.
4 >> GREAT.
THANK YOU.
5 SOUNDS LIKE SOMETHING WE SHOULD HAVE ON OUR WEB SITE.
>> IN ADDITION, IF I COULD ADD, NAD HAS AN
6 AFFILIATION WITH AN AGENCY, CAPTION MEDIA PROGRAM,
CMP, AND THEY ALSO CAN BE CONTACTED.
7 I DO ALSO ENDORSE KAREN'S SUGGESTION TO CONTACT
GALLAUDET UNIVERSITY FOR GOOD REFERRALS.
8 >> DOES NAD HAVE A WEB SITE, CLAUDIA WHERE
PEOPLE COULD FIND THESE TYPES OF RESOURCES?
9 >> OH, YES.
YOU CAN CONTACT NAD'S WEB SITE AT WWW W.NAD.ORG.
10 THERE'S A WHOLE RANGE OF INFORMATION ON THE WEB SITE
AND I WOULD ENCOURAGE ALL OF OUR VIEWERS AND
11 LISTENERS TO VIEW THE WEB SITE.
>> THANK YOU.
12 JIM, I'M GOING TO PUNT TO YOU.
IF THERE ARE SOME SOLUTIONS FOR THINGS LIKE THESE IV
13 R PROBLEMS, WHY ARE DEAF AND HARD HARD HARD PEOPLE
STILL HAVING SO MUCH TROUBLE GETTING ACCESS [].
14 .
>> THAT'S AN INTERESTING POINT AND JUST TO
15 STEP BACK FOR A SECOND,I GUESS I DON'T THINK THAT
IT'S THE TECHNOLOGY THAT IS REALLY THE MAJOR BARRIER.
16 THERE HAVE BEEN TECHNICAL SOLUTIONS FOR LET'S JUST
SAY IVR'S AND TTY'S FOR 15 YEARS OR MORE.
17 THE ISSUE IS FINDING THE RIGHT PEOPLE WITHIN THE
ORGANIZATIONS AND KAREN ALREADY SPOKE TO THE FACT
18 THAT THERE IS SOMETHING OF A DIVIDED JURISDICTION AND
ON THE ONE HAND YOU HAVE SECTION 255, THE OTHER YOU
19 HAVE THE AMERICANS WITH DISABILITIES ABLTHD.
I THINK IT WOULD BE RELATIVELY HARD FOR A CONSUMER
20 WANTING TO COMPLAIN TO LET'S SAY ABOUT THEIR BANK'S
IVR.
21 IT'S NOT GOING TO BE OBVIOUS WHO THE MANUFACTURER OF
THAT IVR PLATFORM IS.
22 SIMILARLY, WITHIN THE COMPANY THAT MANUFACTURED THE
IVR IN THE FIRST PLACE, IT'S HARD TO FIND THOSE
23 PEOPLE IN THE KEY DESIGN AND DECISION MAKING
POSITIONS TO IMPLEMENT THE ACCESSIBILITY FEATURES
24 THAT WE WANT.
AND THEN LET'S SAY THAT THEY DO IMPLEMENT THEM, THEN
25 IT'S THE BANK'S RESPONSIBILITY, THEIR INFORMATION
MANAGEMENT PEOPLE AND THEIR INFORMATION TECHNOLOGY



28

1 PEOPLE TO UNDERSTAND WHAT THOSE ACCESS FEATURES ARE
AND WHY THEY'RE THERE AND HOW TO IMPLEMENT THEM, HOW
2 TO CREATE A PARALLEL SET OF TTY PROMPTS, LET'S SAY.
THAT ACCESSES THE SAME DATA BASE INFORMATION BUT
3 INSTEAD OF USING VOICE IT USES BAUD TONES FOR TTY
USERS.
4 IT'S NOT A TECHNICAL ISSUE AS MUCH AS IT IS A
SOCIOLOGY OF TECHNOLOGY.
5 HOW DECISIONS GET MADE, HOW COMPANIES INFORM
THEMSELVES, AND HOW WE CAN ADVOCATE WITHIN THOSE
6 LARGE ORGANIZATIONS IN A WAY THAT GETS CHANGE TO
HAPPEN RATHER THAN FORCES THOSE COMPANIES INTO KIND
7 OF A RETRACTED AND DEFENSIVE POSTURE.
IS THERE A LIST OF MANUFACTURERS OF ACCESSIBLE IVR
8 SYSTEMS?
LET'S SEE.
9 THERE IS NO LIST PER SE, BUT THAT'S A VERY GOOD IDEA.
AND KAREN MENTIONED THE IVR ACCESSIBILITY FORUM WHICH
10 I CHAIR AND WE'RE JUST GETTING STARTED SO WE'VE GOT A
NUMBER OF PROJECTS UNDERWAY RIGHT NOW, BUT TO HAVE
11 SOME INFORMATION LIKE THAT AND IT MIGHT EVEN BE IN A
FORMAT LIKE THE MARKET MONITORING REPORT SO THAT
12 BANKS THAT WERE LOOKING FOR A SUCCESSFUL IVR WOULD
KNOW WHICH VENDORS TO DETECT.
13 BUT ONE THING I WANT TO EMPHASIZE IS THAT IT'S NOT
SPIRAL OBVIOUS WHAT THOSE ACCESSIBILITY FEATURES ARE
14 AND WHAT THE BARRIERS ARE IN AND GIVEN PLATFORM AND
WHAT THE IMPLEMENTATION GUIDANCE NEEDED FOR ANY GIVEN
15 PLATFORM EITHER.
SO I GUESS AS A CONSULTANT I'M DOING THE USUAL
16 CONSULTANT THING AND TRYING TO PUMP UP THE BUSINESS,
BUT THERE ARE SOME SUBTLES IN IT EVEN JUST FOR TTY
17 COMPATIBILITY.
>> KEITH, IT IS A 508 ISSUE.
18 IS GSA GOING TO BE ABLE TO HELP WITH COMPILING ANY OF
THIS INFORMATION AND WILL THAT BE AVAILABLE TO
19 CONSUMERS IN THE BELIEVE AND TO THE INDUSTRY?
>> YES.
20 WE'VE PARTICIPATED AND WORK WITH THE INDUSTRY IN
ORDER TO ESTABLISH A TEMPLATE FOR EACH MANUFACTURER
21 TO COMPLETE CONCERNING THEIR PRODUCTS.
AND WHAT THAT TEMPLATE DOES IS IT GOES THROUGH THE
22 508 ACCESSIBILITY STANDARDS MENTIONED IN EACH FEATURE
AND THEN THE VENDOR OR THE MANUFACTURER DECLARES HOW
23 WELL THEY COMPLY AND HOW THEY COMPLY WITH EACH OF
THOSE STANDARDS.
24 AND SO ON THE SECTION 508.GOV WEB SITE, THERE IS
INFORMATION ABOUT THE TEMPLATE AND WE WOULD ASK THE
25 MANUFACTURERS AND DISTRIBUTORS TO GO AND LOOK AT
THAT, TO DOWNLOAD IT, AND TO PUT THAT INFORMATION ON



29

1 THEIR WEB SITE AND LET US KNOW WHERE IT IS.
WHAT WE DO THEN IS WHEN FEDERAL AGENCIES AND OTHERS
2 ARE LOOKING FOR INFORMATION AND THEY GO IN, PUT
CERTAIN INFORMATION INTO THE SEARCH ENGINE, IT WILL
3 THEN FIND THOSE TEMPLATES OUT ON THE MANUFACTURER'S
WEB PAGES SO THAT THEY CAN SEE HOW WELL THEY COMPLY.
4 IT'S A GOOD AWARENESS VEHICLE TOO SO EACH OF THE
MANUFACTURERS ARE AWARE OF AT LEAST THE 508 SIDE OF
5 IT AND I'M SURE THEY'RE WORKING ON THE 255 SIDE OF
IT.
6 >> LAFRT BUT NOT LEAST, WE HAVE SUSAN
PALMER.
7 SHE'S THE SOCIAL DIRECTOR FOR REGULATORY AFFAIRS FOR
CINGULAR WIRELESS AND IS ANOTHER ONE OF OUR PANELISTS
8 WHO HAS BEEN WORKING FOR YEARS IN THE DISABILITY
TECHNOLOGY ACCESS FIELD.
9 SUSAN IS ALSO A FOUNDING MEMBER OF THE ASSOCIATION
FOR ACCESS ENGINEERS AND CURRENTLY SERVES IN AN
10 ADVISORY CAPACITY ON NATIONAL INITIATIVES.
THANK YOU FOR COMING.
11 >> THANK YOU FOR HAVING ME HERE TODAY.
IT'S GREAT THAT I'M FOLLOWING CLAUDIA BECAUSE A LOT
12 OF THE MESSAGE THAT I'LL GIVE TODAY IS REALLY THE
IMPORTANCE OF WORKING WITH CONSUMERS AND WORKING WITH
13 OTHER PEOPLE IN THE INDUSTRY.
AT CINGULAR WE HAVE A COMMITMENT TOWARD ACCESSIBILITY
14 AND WE BELIEVE THAT ACCESS SHOULD BE PART OF BUSINESS
AS USUAL.
15 THAT MEANS THAT WHEN WE'RE WORKING WITH OUR VENDORS,
WE EXPECT THEM TO COMPLY WITH ALL EXISTING
16 REGULATIONS SUCH AS DESIGN, DEVELOP, AND FABRICATE
PRODUCTS THAT ARE ACCESSIBLE TO AND USABLE BY PEOPLE
17 WITH DISABILITIES.
IT MEANS THAT WE LOOK IN OUR OWN HOUSE AND SAY HOW
18 CAN WE MAKE OUR SERVICES MORE USABLE?
HOW CAN WE MAKE ACCESS TO OUR COMPANY EASIER?
19 FOR EXAMPLE, IN SOME CASES THAT MIGHT BE BILLING IN
ALTERNATIVE FORMATS.
20 IN OTHER CASES IT MIGHT BE A TTY SXHER.
WE'RE LOOKING OUT FROM THE COMPANY AND ON CHANGES
21 WE'RE MAKING, WE'RE HOPING TO BUILD A STRONG
FOUNDATION.
22 AND THAT HELPS US TO COMPLY NOT ONLY WITH THE
REQUIREMENTS OF SECTION 255 BUT ALSO HELPS US BETTER
23 ADDRESS THE NEEDS OF OUR FEDERAL CUSTOMERS.
SO WE BELIEVE THAT BUILDING IN ACCESSIBILITY IS NOT
24 ONLY A REQUIREMENT BUT IT'S A GOOD BUSINESS DECISION.
ONE OF THE WAYS THAT WE DO THAT IS TO WORK VERY
25 CLOSELY WITH CONSUMERS.
CONSUMERS ARE THE EXPERTS AROUND DISABILITY ACCESS,



30

1 AND WE DO THIS IN SEVERAL DIFFERENT WAYS.
ONE IS THAT WE HAVE A FORMAL BODY CALLED OUR WIRELESS
2 ACCESS TASK FORCE.
AND THE WIRELESS ACCESS TASK FORCE IS COMPOSED OF
3 REPRESENTATIVES FROM VARIOUS DIFFERENT DISABILITY
ORGANIZATIONS AND THEY PROVIDE US WITH HIGH-LEVEL
4 INPUT ON POLICY DECISIONS, PROCESS CHANGES, AND
OCCASIONALLY VERY HIGH LEVEL INFORMATION ABOUT
5 PRODUCT OR PROUKT CONCEPTS.
THEY ARE NOT OUR TEST BODY BECAUSE THEY'RE NOT A
6 REPRESENTATIVE BODY; THEY DON'T MAKE UP THE
DIFFERENCE FOR DOING GOOD MARKET RESEARCH AND THEY
7 DON'T TAKE THE PLACE OF GOOD HUMAN FACTORS WORK, BUT
THEY DO HELP US IN THE VERY BEGINNING TO MAKE SURE
8 WE'RE THINKING ALONG THE RIGHT LINES AND TO MAKE SURE
WE'RE FOLLOWING ALL THE STEPS THAT WE NEED TO IN
9 TERMS OF BASIC REASONING.
FOR THOSE OF US WHO WORKED IN ACCESSIBILITY FOR A
10 NUMBER OF YEARS, WE'VE SEEN COMPANIES THAT HAVE
INTENDED TO DO THE RIGHT THING GO DOWN THE RIGHT PATH
11 BECAUSE THEY REALLY DIDN'T GET ENOUGH INFORMATION
EARLY ON FROM THE ACTUAL USERS.
12 WE ALSO FIND THAT WORKING WITH USERS VERY EARLY HELPS
US TO AVOID COSTLY MISTAKES AND TO USE SOME OF THE
13 TECHNIQUES THAT ARE WELL KNOWN WITHIN THOSE
COMMUNITIES BUT MAY NOT BE KNOWN BY PEOPLE WHO DON'T
14 HAVE DISABILITIES.
SO IT'S A REALLY COST SAVING MECHANISM.
15 WE ALSO BELIEVE THAT IN PRODUCT DEVELOPMENT YOU NEED
TO LOOK AT ACCESSIBILITY THROUGHOUT THE PRODUCT LIFE
16 CYCLE AND YOU HAVE TO START AT DAY 1.
YOU CANNOT ADDRESS ACCESSIBILITY LATE IN THE PROCESS
17 BECAUSE THEN IT'S TOO LATE TO MAKE CHANGES.
ALSO IF YOU ADDRESS IT LATE IN THE PROCESS YOU CAN'T
18 TAKE ADVANTAGE OF THE CHANGES THAT COULD BE PERHAPS
MORE MARKETABLE NOT ONLY TO THE FEDERAL GOVERNMENT
19 BUT MORE USABLE BY GENERAL CUSTOMERS AS WELL ARE
APPEALING.
20 SO WE BELIEVE THAT THROUGHOUT THE PROCESS YOU REALLY
HAVE TO LOOK AT ACCESSIBILITY.
21 AND TO DO THAT, AGAIN YOU HAVE TO GET RESEARCH,
INCLUDING PEOPLE WITH DISABILITIES, HAVE YOU TO DO
22 PRODUCT TRIALS, FIELD TEST, AND MAKE SURE THAT
INDIVIDUALS WITH DISABILITIES ARE INCLUDED IN YOUR
23 PROCESSES.
WE ALSO RELY PRETTY HEAVILY ON HUMAN FACTORS AND
24 HUMAN FACTORS IN OUR COMPANY WE WORK WITH HAVE HAD A
LONG HISTORY IN TERMS OF ACCESSIBILITY IN
25 COMMUNICATIONS SO THAT REALLY HELPS A LOT.
NOW, WHAT HAPPENS THEN IF YOU ARE A COMPANY THAT HAS



31

1 JUST COME ONTO THE SCENE, YOU'RE A NEW TELECOM
PROVIDER OR HAVE JUST SUDDENLY BECOME AWARE OF THE
2 LAW WHICH I'M SURE MOST OF US HAVE ALREADY KNOWN FOR
A WHILE, BUT THERE ARE SOME RESOURCES THAT ARE OUT
3 THERE.
YOUR FIRST THING IS TO MAKE SURE THAT YOU'RE HAVING
4 FEEDBACK AND THAT YOU'RE UNDERSTANDING WHAT THE RULES
ARE, AND THERE ARE SEVERAL URL'S OR WEB SITES, TELL
5 BE ON THE WEB SITE FOR ITTATC AS WELL THAT ARE
EXTERNAL.
6 THERE ARE SOME RESOURCES WHO ARE CONSULTANTS,
FOOTWORK, COMMON GROUND SOLUTIONS, PAM RANSOM IS A
7 PERSON WHO'S WORKED FOR A NUMBER OF YEARS WITH
CONSUMER ORGANIZATIONS AND WITH INDUSTRIES, HAS DONE
8 THE BASIC TRAINING ALONG WITH CTIA, THE CELLULAR
COMMUNICATIONS AND INTERNET ASSOCIATION, AROUND 255.
9 THERE ARE CONSULTANTS OUT THERE WHO HAVE HAD
EXPERIENCE OUT THERE WORKING WITH BRINGING INDUSTRY
10 AND CONSUMERS TOGETHER.
SO IF YOU'RE AFRAID TO GO OUT BECAUSE YOU'RE AFRAID
11 YOU'RE GOING TO SAY THE WRONG WORDS OR NOT BE ABLE TO
REALLY IDENTIFY THAT THIS RESOURCE HAS BEEN AROUND
12 FOR 15 YEARS AND HAS A LONG TRACK RECORD OF SUCCESSES
OR THIS PERSON JUST OPENED SHOP AND HAS A DISABILITY
13 BUT SAYS THEY'RE AN EXPERT, IF YOU'RE A LITTLE
CONCERNED ABOUT THAT, YOU MAY WANT TO CONSIDER GOING
14 TO ONE OF THOSE ORGANIZATIONS LIKE COMMON GROUND
SOLUTIONS TO START BRIDGING THE GAP AND START MAKING
15 CONTACT WITH DIFFERENT CONSUMER GROUPS.
ALSO CONSUMER GROUPS USUALLY HAVE WEB SITES AND
16 INFORMATION ABOUT THEM.
YOU CAN FIND OUT MORE ABOUT THEM THROUGH THAT.
17 IF YOU'RE LOOKING FOR MORE TECHNICAL AND TRAINING
INFORMATION, THERE'S ORGANIZATIONS LIKE INCLUSIVE
18 TECHNOLOGIES AND I KNOW YOU GAVE THE URL EARLIER.
WE'VE HAD VERY GOOD LUCK WORKING WITH INCLUSIVE AND
19 OTHER FOLKS HAVE WORKED WITH THOSE RESOURCES.
GO OUT THERE AND LOOK FOR THEM.
20 THEY WILL SAVE YOU A TREMENDOUS AMOUNT OF MONEY AND
TIME.
21 THEY WILL HELP YOU TO ASK THE RIGHT QUESTIONS AND
THEN ALSO TO APPLY THE PROCESSES YOU NEED THAT ARE
22 SPECIFIC TO YOUR COMPANY AND HOW YOUR COMPANY IS SET
UP SO THAT YOU ARE LOOKING AT ACCESSIBILITY IN A WAY
23 THAT MAKES SENSE FOR EACH OF YOUR COMPANY'S
PROCESSES.
24 YOU CAN'T SAY EVERY COMPANY SHOULD DO THINGS THIS
CERTAIN WAY, BECAUSE EVERY COMPANY'S DEVELOPMENT
25 PROCESS IS GOING TO BE DIFFERENT.
EVERY COMPANY'S WAY THAT INTERACT WITH CUSTOMERS IS



32

1 GOING TO BE DIFFERENT.
SO SOMETIMES IT HELPS TO HAVE SOME OF THOSE RESOURCES
2 EITHER DIRECTLY THROUGH CONSUMER AND CONSUMER
ORGANIZATIONS OR THROUGH THIRD-PARTY CONSULTANTS.
3 THERE'S ALSO A MYRIAD OF TECHNICAL RESOURCES THAT ARE
AVAILABLE RANGEING FROM WEB SITE DEVELOPMENT TO
4 TELECOM ACCESS.
ONE THAT WE'VE HAD A LOT OF LUCK WITH IS AT TRACE AND
5 THAT'S TRACE.WISC.EDU AND I PARTICULARLY THAT'S A
GOOD BASIC INTRODUCTION FOR A COMPANY THAT'S NOT
6 FAMILIAR WITH THESE PROCESSES.
THERE ARE A LOT OF CHALLENGES AND I WOULD ARGUE WITH
7 DOUG THAT READILY ACHIEVABLE IS NOT PAINFUL AT ALL;
IT IS.
8 ANY CHANGE IS PAINFUL, AND WHEN YOU'RE TALKING ABOUT
A LARGE COMPANY, MAKING CHANGES THAT MAKE SENSE MAY
9 INVOLVE 10 DIFFERENT ORGANIZATIONS, THEY MAY INVOLVE
PUTTING YOUR TESTING FOR YOUR WHOLE NETWORK OUT THERE
10 TO MAKE SURE THAT THE CHANGES NORTH CAUSING PROBLEMS
OR DEGRADING THE SERVICE ELSEWHERE.
11 SO THERE'S A LOT OF THINGS THAT NEED TO BE DONE.
THAT'S A MAJOR CHALLENGE.
12 YOU HAVE TO MAKE SURE YOUR COMPANY'S DIFFERENT
ORGANIZATIONS ARE WORKING TOGETHER.
13 ANOTHER CHALLENGE WHICH CLAUDIA MENTIONED WAS THAT
CHANGES CONSTANT IN THIS ENVIRONMENT.
14 SO IT'S IMPORTANT TO MAKE SURE THAT THE CHANGES THAT
YOU'RE MAKEING IN YOUR PROCESSES CAN BE ADAPT
15 ADAPTABLE AND THAT TRAINING IS ONGOING.
IT'S NOT A SINGLE HITTER.
16 IT'S NOT LIKE YOU CAN GO FORTH AND SAY THIS IS A
WORD, THE, AND EVERYBODY'S GOING TO KNOW IT AND WE'RE
17 SET.
THE TECHNOLOGY CHANGES QUICKLY.
18 WE NEED TO MAKE SURE THAT WE'RE TAKING ADVANTAGE OF
THAT NOT ONLY TO ENSURE THAT WE'RE NOT BLOCK PEOPLE
19 FROM PARTICIPATING THROUGH INACCESSIBLE PRODUCTS BUT
TO TAKE ADVANTAGE OF USING ALL THESE CHANGES TO MAKE
20 THINGS MORE AND MORE ACCESSIBLE.
ONE TOOL THAT WE'VE HAD A LOT OF LUCK WITH WHICH BOTH
21 KAREN AND JIM MENTIONED IS PARTICIPATION IN INDUSTRY
AND CONSUMER FORMS.
22 ONE SUCH FORM IS A TTY FORM.
THAT AND THE IVR FORM ARE BOTH HOUSED AT THE ALLIANCE
23 FOR TELECOMMUNICATION INDUSTRIES SOLUTIONS.
AND WHILE THE PROGRESS IS SLOW, I WOULDN'T SAY FOR
24 ANYBODY WHO PARTICIPATES IT'S FUN, BUT I WOULD SAY
THAT THE RESULTS ARE FAN FANIC, AND AS A RESULT OF
25 THE EFFORT, NOT JUST IN THE TELECOM INDUSTRY SIDE,
THE SERVICE PROVIDERS LIKE CINGULAR WIRELESS AND



33

1 MANUFACTURERS LIKE ERICSON OR MOTOROLA OR LUCENT, BUT
BECAUSE THERE'S BEEN CONSUMER REPRESENTATIVES TO
2 TELECOMMUNICATIONS FROM DEAF IP CORPORATED, SELF HELP
FOR HARD-OF-HEARING PEOPLE, ORGANIZATIONS LIKE THAT
3 THAT CAN HELP US STAY ON TRACK, WE'RE LOOKING AT
MIDDLE OF NEXT YEAR HAVING ACCESS TO DIGITAL WIRELESS
4 WITH TTY'S WHICH IS EXCITING FOR US.
IT'S DIFFICULT, IT'S NOT CHEAP, BUT IT'S THE RIGHT
5 THING TO DO.
AND BECAUSE WE'VE BEEN WORKING TOGETHER, WE'RE ABLE
6 TO UNDERSTAND CONSUMER NEEDS BETTER.
ANOTHER EXAMPLE OF THIS, A REAL CHALLENGE IS IVR AND
7 MESSAGING.
WE DON'T HAVE ALL THE ANSWERS FOR THAT.
8 AND FOR INDUSTRY TO ADDRESS THE NEEDS OF CONSUMERS
BETTER, THERE HAVE TO BE ONGOING DIALOGUE.
9 AND ATTIC APPLIANCE FOR TECHNOLOGY TELECOMMUNICATIONS
SOLUTIONS HAS A FORM FOR ADDRESSING THOSE NEEDS AND
10 WE'RE VERY INTERESTED IN PARTICIPATION ACROSS.
WE DO HAVE GOOD REPRESENTATION FROM DEAF AND HARD OF
11 HEARING ORGANIZATIONS.
WE'VE RECENTLY HAD ADDITIONS FROM ORGANIZATIONS FROM
12 PEOPLE WHO ARE MRIENLD. IF YOU'RE INTERESTED IN
THAT, MY CONTACT INFORMATION IS THERE OR YOU CAN
13 CONTACT ATTIS.ORG AND THEY CAN HELP YOU ALSO GET
INVOLVED IN THIS PROCESS AND LEARN MORE ABOUT WHAT'S
14 HAPPENING ALONG THE LINES OF ACCESS TO VOICE MAIL AND
MESSAGEING.
15 THESE EFFORTS ARE REALLY VERY IMPORTANT.
IT'S VERY IMPORTANT FOR CONSUMERS WHO ARE OUT THERE
16 TO GET INVOLVED AND TO EXPRESS NEEDS NOT JUST IN A
WAY OF I'M REALLY FRUSTRATED WHICH IS A VALID FEELING
17 BUT TO SAY WHEN YOU'RE TALKING TO A COMPANY, THIS IS
THE PRODUCT, THIS IS THE ISSUE, THIS IS HOW, WAYS
18 THAT I'VE SEEN IT RESOLVED MAYBE IN OTHER PRODUCTS.
VERY SPECIFIC INFORMATION.
19 AND I WOULD REALLY STRONGLY ENCOURAGE CONSUMERS TO
CONTACT THE COMPANIES DIRECTLY.
20 THERE IS A LIST OF COMPANY CONTACTS UNDER 255 ON THE
FCC WEB SITE AND TALK TO THOSE ORGANIZATIONS.
21 HELP THEM UNDERSTAND HOW BETTER TO ADDRESS YOUR
NEEDS.
22 FINALLY, I WOULD NOT EVER HESITATE TO LOOK AT SOME OF
THE RESOURCES THAT ARE PROVIDED BY THE GOVERNMENT.
23 SECTION 508.GOV HAS WONDERFUL SITES INCLUDING RULES
AND SOME BASIC INFORMATION, IF YOU'RE NEW INTO THE
24 FIELD, YOU CAN GET SOME BACKGROUND.
THE DISABILITY RIGHTS OFFICE AT THE FCC HAS A
25 WONDERFUL WEB SITE THAT PROVIDES A LOT OF BACKGROUND
ON ACCESS ISSUES.



34

1 IT'S NOT JUST 255, IT CAN BE 711, OR
TELECOMMUNICATIONS RESOURCE SERVICE.
2 THE ACCESS BOARD HAS SPECIFIC INFORMATION ON 255 AND
508 AND ALL THESE THINGS CAN GIVE YOU SOME GROUNDING.
3 AND THEN AGAIN THERE ARE EXTERNAL CONSULTANTS THAT
YOU CAN WORK WITH AND TRAINING YOU CAN HAVE THROUGH
4 DIFFERENT ORGANIZATIONS.
TRACE HAS HAD A TRAINING ON 255; I DON'T KNOW IF
5 THEY'LL BE DOING THAT AGAIN, I HOPE.
MAKE CONTACTS, FIND OUT MORE INFORMATION AND MAKE
6 SURE YOU'RE NOT WORKING IN A VACUUM, THAT THE CHANGES
YOU'RE MAKING REALLY ARE GOING TO BE WORKING WITH THE
7 NEEDS WITH DISABILITIES AND MAKE SURE YOU HAVE
CONTACTS WITH DIFFERENT ORGANIZATIONS AND
8 REPRESENTATIVES FROM THOSE COMMUNITIES AS WELL.
>> THANK YOU, SUSAN.
9 I JUST HAVE ONE QUICK FOLLOW-UP QUESTION.
I KNOW THAT THE PROPRIETARY NATURE OF THE INDUSTRY
10 CAN MAKE IT DIFFICULT TO EXCHANGE INFORMATION
ESPECIALLY AT AT PRODUCT DESIGN STAGE.
11 ARE YOU AWARE OF ANY MECHANISMS WHEREBY PRODUCT
DESIGNERS AND THE TECHNICAL FOLKS CAN SHARE AN
12 EXCHANGE AND BENEFIT FROM ONE OTHER'S INFORMATION?
>> TO SOME EXTENT THERE'S SOME LIMITATIONS
13 IN TERMS OF COMPANIES WORKING WITH EACH OTHER.
FORUMS ARE AN EXCELLENT EXAMPLE OF HOW TO TALK ABOUT
14 BASIC ISSUES IF NOT ABOUT SPECIFIC PRODUCTS.
COMPANIES CAN ALSO WORK WITH CONSUMER ORGANIZATIONS
15 OR INDIVIDUALS WITH SPECIFIC EXPERTISE LIKE
AUDIOLOGISTS OR A WEB DESIGNER AND HAVE THEM SIGN A
16 NONDISCLOSURE AGREEMENT AND THAT PROVIDES ADDITIONAL
PROTECTION.
17 THERE ARE SOME MECHANISMS IF YOU ARE INVOLVED IN A
PROCESS ALONG THE LINES OF EVALUATING SOMETHING YOU
18 NEED TO BE AWARE THAT IT'S IMPORTANT FOR TO YOU KEEP
THAT INFORMATION CONFIDENTIAL AND FOR COMPANIES TO
19 MAKE THEMSELVES VULNERABLE IN THAT WAY REQUIRES SOME
RESPONSIBILITY ON THE PART OF THOSE IN THE CONSUMER
20 ORGANIZATIONS WHO WANT TO PROMOTE ACCESS.
SO THERE ARE SOME PROTECTIONS, BUT I THINK THE BEST
21 PROTECTION IS JUST AN OPEN AND HONEST DIALOGUE WITH
CONSUMERS AND AN UNDERSTANDING OF HOW CONSUMERS CAN
22 ASSIST INDUSTRY OVER ALL WITH EFFORTS.
>> THANK YOU.
23 OKAY.
WE WANT TO MOVE TO TAKING QUESTIONS FROM THE AUDIENCE
24 AS WE DID PROMISE.
LET ME GIVE YOU THE PHONE NUMBERS ONCE AGAIN.
25 SOME QUESTIONS ARE ALREADY COMING IN AND WE WILL TAKE
A BRIEF MOMENT FOR MICHAEL MORRIS TO GIVE US AN



35

1 OVERVIEW OF ITTATC SO YOU KNOW WHO WE ARE THAT'S
HOSTING THIS WEB CAST TODAY AND WHAT RESOURCES WE CAN
2 PROVIDE.
IF YOU'D LIKE TO PHONE IN YOUR QUESTION, THE NUMBER
3 AGAIN IS.
703-961-9250, EXTENSION 226.
4 YOU CAN FAX QUESTIONS TO 703-961-9255.
YOU CAN ALSO USE THE E-MAIL OR CHAT LINK ON YOUR
5 SCREEN.
NOW I'M GOING TO TURN IT OVER TO MICHAEL.
6 >> THANK YOU,.
I WANT TO THANK ALL THE PANELISTS FOR BEING HERE WITH
7 US, PROVIDED A GREAT DEAL OF INFORMATION AND
QUESTIONS HAVE BEEN COMING IN.
8 BUT BEFORE I START WITH QUESTIONS, I WANTED TO JUST
BRIEFLY PROVIDE AN OVERVIEW OF ITTATC.
9 ITTATC STANDS FOR THE INFORMATION TECHNOLOGY TRAINING
AND TECHNICAL ASSISTANCE CENTER.
10 IT WAS FUNDED BY NIDRR AT AT U.S. DEPARTMENT OF
EDUCATION LAST NOVEMBER.
11 NIDRR IS THE NATIONAL INSTITUTE ON DISABILITY AND
REHABILITATION RESEARCH.
12 ITTATC IS A CONSORTIUM.
THE PRIMARY GRANTEE IS AT AT GEORGIA INSTITUTE OF
13 TECHNOLOGY AND IT IS AT THEIR CENTER ON ASSISTIVE
TECHNOLOGY AND ENVIRONMENT ACCESS.
14 ALSO KNOWN BY THE LETTERS KATEA.
FOR THOSE OF YOU WHO HAVE NEVER TAKEN A LOOK AT THE
15 ITTATC WEB SITE, IT IS ALSO A GREAT RESOURCE FOR
INFORMATION, POTENTIAL CONTACTS, AND INDIVIDUAL
16 EXPERTS THAT MIGHT HELP YOU WHETHER YOU'RE AN AGENCY
OR WITHIN GOVERNMENT OR A PART OF INDUSTRY.
17 THE ITTATC WEB SITE IS ITTATC.ORG.
ITTATC WAS FUNDED BY THE DEPARTMENT OF EDUCATION
18 REALLY TO DO SEVERAL THINGS.
FIRST ITS PRIMARY PURPOSE IS TO INCREASE
19 UNDERSTANDING AND KNOWLEDGE OF THE REQUIREMENTS OF
SECTION 255 OF THE TELECOMMUNICATIONS ACT AND ALSO
20 SECTION 508 OF THE REHABILITATION ACT.
ITS PURPOSE REALLY IS TO PROVIDE OPPORTUNITIES LIKE
21 THIS WEB CAST TO PROMOTE INTERACTIONS BETWEEN
GOVERNMENT, INDUSTRY, AND THE DISABILITY COMMUNITY,
22 HOPEFULLY TO INCREASE UNDERSTANDING AND KNOWLEDGE
UTILIZATION ABOUT ACCESSIBLE IT THAT IMPACTS INDUSTRY
23 POLICIES AND PRACTICES.
OUR GOALS ARE TO PROMOTE WIDESPREAD USE OF ACCESSIBLE
24 AND USABLE ELECTRONIC AND INFORMATION TECHNOLOGY IN
THE HOME, THE SCHOOL, AND THE WORK PLACE.
25 AND TO SUPPORT THE REPLICATION OF PROMISING POLICIES
AND PRACTICES AT BOTH THE FEDERAL AND STATE LEVELS



36

1 REGARDING WEB SITE ACCESSIBLEITY, ACCESSIBLE IT IN
THE PUBLIC WORKPLACE, AND PROCUREMENT OF ACCESSIBLE
2 IT PRODUCTS AND SERVICES.
SOME OF THE ACTIVITIES THAT ITTATC HAS ENGAGED IN IN
3 ITS FIRST YEAR AND WILL BE ENGAGING IN OVER THE
COURSE OF THE NEXT FOUR YEARS OF THE FUNDED PROJECT
4 ARE TO CREATE AND MAINTAIN THE WEB SITE THAT I
MENTIONED AS A PORTAL OF INFORMATION ON ACCESSIBLE
5 DESIGN METHODS, RESOURCES AND TRAINING FOR INDUSTRY
PRODUCT DESIGNERS, WEB DEVELOPERS, PROCUREMENT
6 OFFICERS AND CUSTOMERS WITH DISABILITIES.
OUR GOAL IS ALSO TO DEVELOP TRAINING MATERIALS AND
7 OFFER ON-SITE AND ON-LINE TRAINING BOTH FOR TELECOM
MANUFACTURERS AND DEVELOPERS, ALSO FOR PROCUREMENT OF
8 IT AND COMPANIES THAT OFFER IERXSZ T PRODUCTS AND
SERVICES ON METHODS FOR DEVELOPMENT OF ACCESSIBLE
9 PRODUCTS AND SERVICES.
THERE ARE A NUMBER OF PARTNERS THAT ARE PART OF THE
10 IT CONSORTIUM.
IN ADDITION TO THE GEORGIA INSTITUTE OF TECHNOLOGY
11 CENTER FOR ASSISTIVE TECHNOLOGY AND ENVIRONMENTAL
ACCESS, OTHER PARTNERS INCLUDE THE WORLD INSTITUTE ON
12 DISABILITY, REGIONAL DISABILITY AND BUSINESS
TECHNICAL ASSISTANCE CENTER, THE TRACE CENTER THAT
13 SUSAN MENTIONED, THE INFORMATION TECHNOLOGY
ASSOCIATION OF AMERICA, COMMUNITY OPTIONS, INCLUSIVE
14 TECHNOLOGIES REPRESENTED ON THE PANEL BY JIM TOBIAS,
THE ASSOCIATION FOR ASSISTIVE TECHNOLOGY PRODUCTS,
15 AND ALSO THERE IS A NATIONAL ADVISORY COUNCIL WHICH
IS COMPOSED OF LEADING REPRESENTATIVES FROM INDUSTRY,
16 REPRESENTATIVES FROM GOVERNMENT AND REPRESENTATIVES
OF THE DISABILITY COMMUNITY.
17 FOR THOSE OF YOU WHO WOULD LIKE TO MAKE CONTACT OTHER
THAN VIA THE WEB SITE OF ITTATC, THERE IS A TOLL FREE
18 NUMBER OF THE NUMBER IS.
1-866-9-ITTATC.
19 OR 1-866-948-8282.
THERE IS ALSO A FAX NUMBER.
20 404-8949320.
ITTATC IS AT THE CENTER FOR ENVIRONMENTAL ACCESS AT
21 THE GEORGIA INSTITUTE SNUT TECHNOLOGY.
THERE ARE A VARIETY OF QUESTIONS THAT HAVE COME IN
22 AND LET ME START WITH ONE THAT REALLY IS OPEN TO THE
ENTIRE PANEL.
23 AND I'LL DOES FOR VOLUNTEERS OR PERHAPS WE CAN GET
SOME ANSWERS FROM EACH OF YOU TO THIS FIRST QUESTION.
24 AND THAT QUESTION IS THAT FIVE YEARS AGO SECTION 255
WAS PASSED INTO LAW.
25 IT WOULD HAVE BEEN VERY DIFFICULT TO HAVE A CRYSTAL
BALL TO PREDICT WHERE WE'D BE TODAY, BUT WE DID



37

1 RECEIVE A QUESTION FROM AN INDIVIDUAL IN WASHINGTON
D.C. WHO ASKED HAS WHAT HAS OCCURRED IN NS OF
2 ACCESSIBLE PRODUCT AND SERVICES?
HAS IT MET YOUR EXPECTATIONS?
3 AND IF NOT, WHY NOT?
ANYONE WANT TO TRY THAT TO START OUT?
4 MAYBE KAREN SINCE YOU REPRESENT THE F. C. C., I'LL
THROW THAT TO YOU FIRST, BUT HOPEFULLY SOMEONE WILL
5 QUICKLY FOLLOW.
>> I THINK WE'VE MADE A LOT OF PROGRESS IN
6 FIVE YEARS.
WITH ANY NEW LAW THERE'S GOING TO BE AN INITIAL
7 PERIOD OF NEEDING TO EDUCATE THE POPULACE, NEEDING TO
EDUCATE THE ENTITIES, I THINK WE'VE GONE A LONG WAYS
8 TOWARD THAT GOAL.
I THINK THAT CONSUMERS ARE NOW BECOMING EDUCATED ON
9 WHAT THEIR RIGHTS ARE, THE NUMBERS OF INQUIRIES AND
COMPLAINTS THAT WE'RE GETTING ARE GOING UP.
10 AS SUSAN AND JIM MENTIONED, THE OPPORTUNITIES FOR
COOPERATION BETWEEN CONSUMERS AND INDUSTRY ARE
11 EXPANDING.
I HIGHLY ENCOURAGE, I WANT TO JUST REITERATE IT ONE
12 MORE TIME, MORE INVOLVEMENT BY INDUSTRY IN THE IVR
FORUM, THE INTERACTIVE VOICE FORUM THAT JIM TOBIAS IS
13 HEADING UP.
IT'S CRITICAL FOR INDUSTRY TO UTILIZE THESE FORMS TO
14 THE FULLEST.
WHAT WE SAW OCCUR WITH THE TTY FORUM WHICH WAS A
15 FORUM TO DESIGNED TO ENABLE TTY'S TO BE ACCESSIBLE TO
DIGITAL SERVICES.
16 IT WAS PRETTY ASTONISHING.
WHEN IT WAS STARTED, THE IT WAS A GIVEN THAT THERE
17 WAS NO WAY FOR TTY'S TO BE ACCESSIBLE FOR DIGITAL
SERVICES.
18 AND NOW WE FEEL THAT BY NEXT YEAR THESE WILL BE
ACCESSIBLE.
19 WE'RE REVERSING A LOT OF INITIAL TRENDS OF IGNORING
ACCESSIBILITY.
20 THE 1996 ACT FOR TELECOMMUNICATIONS WAS WHAT THE
AMERICANS MERN MERNS ACT WAS FOR EVERYTHING ELSE AND
21 IT TAKES TIME TO IMPLEMENT SOMETHING OF THAT
MONUMENTAL IMPACT.
22 BUT I DO THINK THAT WE'RE MAKING STEADY GAINS.
>> I WOULD CONCUR THAT WE ARE MAKING
23 GAINS.
I SEE A LARGE DIFFERENCE IN HOW THE COMMUNICATIONS
24 ARE HAPPENING WITHIN INDUSTRY BEHIND THE SCENES.
IT'S NO LONGER WHY IT'S HOW.
25 IT'S HOW WILL WE DO THIS, WHAT ARE THE METHODS,
WHAT'S THE BEST TECH NEEK. AND THERE'S NOT AN



38

1 INITIAL DO WE HAVE TO WHICH WAS BEFORE THE LAW,
CERTAINLY THE QUESTION.
2 THE OTHER THING I SEE IS WITH 508 YOU HAVE THE LAW
WHICH IS THAT 255 WHICH IS A STICK AND YOU HAVE A
3 CARROT.
SO THAT AS WE SEE PRODUCTS THAT ARE BEING PURCHASED
4 BECAUSE THEY'RE ACCESSIBLE, THAT WILL JUST REINFORCE
THE COMPANIES THAT ARE DOING THE RIGHT THING.
5 THAT SAID I THINK THAT THERE'S A LONG WAY TO GO AND
THE BEST WAY WE CAN GET THERE IS BY WORKING TOGETHER,
6 CONSUMERS, INDUSTRY, AND GOVERNMENT.
>> OKAY.
7 SECOND QUESTION IS FROM AN INDIVIDUAL ALSO IN WASH
WASHINGTON, D.C. WHY DOES THE F C C NOT CONSIDER
8 TELECOMMUNICATIONS EDT'S EQUIPMENT DISTRIBUTION
PROGRAMS TO BE PART OF UNIVERSAL SERVICES? MOST
9 PEOPLE BUY A PHONE FOR $30 OR SO, BUT IF YOU NEED A
TTY THAT'S GOING TO ADD TO THE PRICE BY SEVERAL
10 HUNDRED DOLLARS.
IT SEEMS TO ME THAT THIS AND OTHER PIECES OF
11 ASSISTIVE TECHNOLOGY SHOULD BE A PART OF THE EDP
SYSTEM.
12 >> I GUESS THAT'S ME AGAIN.
I'M GOING TO FIND THIS INDIVIDUAL.
13 NO, I'M KIDDING.
THE UNIVERSAL SERVICE PROGRAM WHICH IS IMPLEMENTED
14 BY THE F C C IS A PROGRAM THAT WAS CREATED UNDER THE
1996 ACT AND DIRECTED TO VERY DISTINCT AREAS OF OUR
15 TELECOMMUNICATIONS SYSTEM.
AND SPECIFICALLY IT WAS GEARED TOWARDS SCHOOLS AND
16 LIBRARYS AND RURAL COMMUNITIES AND INSULARMINORITIES,
LOW INCOME, RURAL COMMUNITIES.
17 IT DID NOT -- IT DOES NOT AT PRESENT UTILIZE
UNIVERSAL SERVICE FUNDS FOR EQUIPMENT DISTRIBUTION
18 PROGRAMS.
AGAIN, I DON'T EVER CLOSE THE DOOR TO ANYTHING, AND
19 IT IS POSSIBLE THAT ONE DAY UNIVERSAL SERVICE FUNDS
COULD BE USED FOR EQUIPMENT DISTRIBUTION PROGRAMS.
20 THAT IS NOT WHAT WAS ENVISIONED IN THE 1996 ACT
INITIALLY.
21 HOWEVER, IT'S POSSIBLE THAT ONE DAY THAT COULD BE
EXPANDED TO COVER EQUIPMENT DISTRIBUTION PROGRAMS.
22 >> IF I COULD JUMP IN WITH A COMMENT ON
THAT. I'M REMINDED OF THE PEOPLE IN THE COUNTRY, IN
23 THE TELECOM INDUSTRY WHO SUFFER WORST FROM THIS
PROBLEM ARE MY BELL SOUTH FRIENDS IN THE STATE STAIT
24 FLORIDA AND THE REASON IS THAT THEY GET SO MANY SNOW
BIRDS COMING DOWN FROM LITERALLY ALL OF THE OTHER
25 STATES AND SAYING, WELL, WAIT A MINUTE, MY EQUIPMENT
DISTRIBUTION PROGRAM IN MINNESOTA OR WYOMING GIVES



39

1 OUT FREE AMPLIFIERS, WHY DON'T YOU PEOPLE?
AND THEY GET A DIFFERENT MESSAGE FROM EVERYBODY.
2 SO THERE'S ROOM FOR SOME STANDARDIZATION OF EQUIPMENT
THAT'S DISTRIBUTED AND THERE'S ROOM FOR EXPANDING IT.
3 AND I'LL JUST TALK FOR A SECOND ABOUT A PROJECT THAT
THE TELECOM REHAB ENGINEERING RESEARCH CENTER IS
4 COORDINATING AND THAT IS THE TTY TEXT EVOLUTION
PROJECT, AND THE IDEA IS THAT WE'VE ALL KNOWN FOR A
5 LONG THYME THAT TTY'S AS A TECHNOLOGY, THE OLD
PROTOCOL TECHNOLOGY IS OBSOLESCENT AND YET THERE ARE
6 MANY USERS WHO HAVE A STRONG AFFINITY FOR IT BECAUSE
IT IS A PRODUCT THAT THEY IDENTIFY WITH THEIR
7 CULTURE.
WHAT WE ALSO SEE IS LEADING ELEMENTS OF THE TTY USING
8 COMMUNITY EARLY ADOPTERS, YOU MIGHT CALL THEM, ARE
MIGRATING TO OTHER TECHNOLOGIES TO SUPPLEMENT THEIR
9 TTY.
TWO-WAY PAGERS, INTERNET CHAT, AND INSTANT MESSENGER
10 AND WHAT HAVE YOU.
AND WHAT WE WANT TO DO IS UNDERSTAND WHERE THAT'S
11 GOING, WHERE ARE THOSE USERS NOW, WHAT MAINSTREAM
TECHNOLOGIES ARE THEY GOING TO WANT TO USE TODAY AND
12 TOMORROW, AND HOW WE CAN BRING THOSE LATE ADOPTERS
INTO THAT MAINSTREAM TEXT COMMUNICATION CHANNEL WHICH
13 IS SO MUCH MORE POWERFUL AND SO MUCH MORE INTEGRATED
IN THE USE OF PEOPLE IN THE SOCIETY AT LARGE.
14 AND WHERE THE EQUIPMENT DISTRIBUTION PROGRAMS FIT IN,
IS WE'D LIKE TO BRING THOSE PROGRAMS IN AS YET
15 ANOTHER WAY OF MOTIVATING MAINSTREAM COMPANIES TO
ADDRESS THE NEEDS OF CONSUMERS WITH DISABILITIES.
16 THESE PROGRAMS GIVE OUT HUNDREDS OF THOUSANDS OF DHZ
A MONTH IN FREE TECHNOLOGY TO PEOPLE WHO NEED THEM.
17 WE'D LIKE TO SEE MAINSTREAM DEVICES FIT INSIDE THEIR
PROGRAMS IN A WAY THAT PREVENTS ABUSE AND BRINGS
18 ELEMENTS OF THOSE COMMUNITIES INTO THE MAINSTREAM
COMMUNICATIONS MODE.
19 SO IT'S ANOTHER OPPORTUNITY FOR THE CARROT VIEW, LIKE
THE 508 VIEW, RATHER THAN PURELY A REGULATORY STICK.
20 >> THIS IS A QUESTION I BELIEVE WE HEARD
IT THE LAST WEB CAST, AND THAT IS, IS THE FEDERAL
21 GOVERNMENT GOING TO SET UP A LAB FOR TESTING PRODUCTS
SO THAT WE CAN KNOW FOR SURE WHETHER A PRODUCT MEETS
22 THE EITHER 508 OR 255 STANDARDS.
I GUESS PROBABLY BACK TO KEITH FOR THAT.
23 >> THANK YOU.
THIS QUESTION HAS BEEN ON THE TABLE SINCE THE
24 BEGINNING OF THE 508 STANDARDS.
AND OBVIOUSLY EVERYONE WOULD LIKE AN EASY ANSWER,
25 YES IT COMPLIES, NO IT DOES NOT.
UNFORTUNATELY, THE ANSWER IS MORE DIFFICULT THAN THE



40

1 YES OR NO RESPONSE.
AS I SAID EARLIER, THERE'S A LOT OF CONDITIONS THAT
2 MIGHT PLAY INTO EACH OF THOSE ANSWERS.
GSA DID BEGIN SOMETHING CALLED THE ACCESSIBILITY
3 FORUM TO BRING TOGETHER THE INDUSTRY AND THE SEVERAL
COMMUNITIES INVOLVED WITH ACCESSIBILITY TO TRY TO
4 WORK TOWARDS FACILITATING THE ACCESSIBLE INFORMATION
BECOMING AVAILABLE TO THE FEDERAL GOVERNMENT IN THE
5 MARKETPLACE, AND THE OUTCOME OF THAT, THOSE
DISCUSSIONS SO FAR HAVE NOT LEAD TOWARDS THE
6 DEVELOPMENT OF A TESTING LAB THAT WILL PROVIDE THAT
KIND OF TESTING SERVICE FOR US.
7 SO I THINK IT'S MORE COMPLEX THAN PEOPLE ORIGINALLY
THOUGHT IT MIGHT BE, AND SO FAR THERE'S NO PLAN TO
8 PUT THAT IN PLACE.
>> JUMP IN ON THIS ONE AS WELL, BECAUSE
9 I'M GLAD YOU MENTIONED THE ACCESSIBILITY FORUM.
AND IT IS THE PERFECT PLACE FOR THESE DISCUSSIONS
10 BECAUSE THERE ARE PEOPLE THERE FROM INDUSTRY WHO
UNDERSTAND THE STANDARDS ENVIRONMENT.
11 AND THAT'S A LITTLE BIT OF THE SOURCE OF THE PROBLEM.
IF YOU THINK ABOUT THE WORLD FROM THE PERSPECTIVE OF
12 A COMPLIANCE ENGINEER WHICH IS SOMEONE IN A COMPANY
WHO MAKES SURE THAT THEIR PRODUCTS MEET THE
13 REGULATIONS THAT COVER THAT PRODUCT, THEY'RE
ACCUSTOMED TO LAB TEST KIND OF VIESHLT WHERE YOU TAKE
14 A METER AND YOU POINT IT AT THE PRODUCT THREE FEET
AWAY AND YOU SEE WHAT THE READING IS.
15 AND IT'S EITHER TOO HIGH OR NOT TOO HIGH AND IT'S
EASY TO CHECK OFF WHETHER IT PASSES THAT TEST.
16 ACCESSIBILITY AND EVEN THE 508 AND 255 INVOLVE SO
MANY COMPLICATED INTERFACE ISSUES THAT ARE SO MANY
17 UNRESOLVED.
I'M ON ONE OF THOSE WORKING GROUPS THAT ARE LOOKING
18 AT THE MEASURES AND METRICS ISSUE.
AND WHAT WE'VE COME TO SO FAR IS A CLEAR
19 UNDERSTANDING THAT THERE ARE SOME ISSUES THAT ARE
VERY SUSCEPTIBLE OF STANDARDS PROCESS AND SOME THAT
20 NEVER WILL BE.
AND OUR FIRST JOB IS TO SEPARATE THOSE OUT INTO CLEAN
21 CATEGORIES.
AN EXAMPLE OF THE FORMER IS THE READABILITY OF LCD'S.
22 ONE OF THE BIG PROBLEMS IN THESE PRODUCTS AND SO MANY
LCD'S ARE OUT THERE IS THAT WE HAVE NO WAY OF LINKING
23 SOMEONE'S VISION, IF I'M A 27/70, ON MY BEST
CORRECTED VISION IS 20/70, I KNOW WHAT THAT MEANS
24 WITH BLACK LETTERS ON A WHITE CHART AT THE DOCTOR'S
OFFICE.
25 I DON'T KNOW WHAT IT MEANS ON A PRODUCT LIKE THIS.
CAN I READ THIS PRODUCT OR CAN'T I READ THIS PRODUCT?



41

1 AND WHAT WE NEED TO DO IS BETWEEN TESTS THAT
COORDINATE LCD READABILITY TO STANDARD VISION TEST.
2 WE THINK WE CAN DO THAT FOR VISION A NUMBER OF SUBTLE
WAYS.
3 WE CAN DO IT WITH AUDITORY STIMULI AS WELL, WE CAN DO
IT TO SOME EXTENT WITH TACTILE AND DEXTERITY BUT THE
4 LARGER COGNITIVE ISSUES OF INTERFACE DESIGN AND CORE
FUNCTIONALITY OF A PRODUCT IS NOT GOING TO BE
5 SOMETHING THAT'S AS EASILY ACCESSIBLE OF
STANDARDIZATION.
6 >> I THINK YOU HAD A LEVEL OF COMPLEXITY
WHEN YOU TALKED ABOUT USERS, SOMEBODY'S WHO IS LATE
7 DEAFENED, SOMEONE WHO IS A NATIVE SIGNER MIGHT
APPROACH THE SAME THING DIFFERENTLY.
8 YOU CAN HAVE TWO PEOPLE WHO HAVE VISION LOSS THE SAME
WAY MEDICALLY BUT HAVE DIFFERENT APPROACHES
9 MEDICALLY.
I THINK WE NEED TO BE CAREFUL NOT TO RUSH INTO THIRD
10 PARTY TESTING BEFORE WE KNOW EXACTLY WHAT WE'RE
TESTING.
11 WE RUN THE RISK THERE OF DEVELOPING SURRENDERS THAT
ARE REALLY LOW OR STANDARDS THAT DON'T REALLY MOVE
12 WITH THE FAST FACE OF THE TECHNOLOGY.
SO I THINK WE NEED TO TAKE A CAUTIOUS APPROACH AND DO
13 WHAT JIM IS TALKING BFIND OUT WHAT WE CAN
STANDARDIZE, FIND OUT WHAT WE NEED TO STANDARDIZE SO
14 THERE'S THE NEED OF THE PRODUCTS TO INTERACT WITH
EACH OTHER AND THEN MOVE FROM THERE.
15 AND THAT'S NOT SOMETHING YOU'RE GOING TO SEE IN JUST
A YEAR OR TWO.
16 >> HERE'S A VERY SPECIFIC QUESTION.
I'M IN THE MARKET FOR A VOICE ACTIVATED CELL PHONE.
17 I'VE NOT BEEN ABLE TO FIND ONE.
ARE THERE ANY ON THE MARKET THAT ARE RELIABLE AND
18 WHAT IF I'M IN A NOISY ENVIRONMENT WHEN TRYING TO
MAKE A CALL?
19 WILL IT STILL WORK?
JIM, YOU MAY BE THE BEST --
20 >> YEAH.
THE ANSWER IS YES.
21 I DON'T KNOW HOW YOU'VE BEEN ABLE TO TEST VARIOUS
PRODUCTS, BUT ONE THING TO KEEP IN MIND AND THIS
22 SPEAKS TO THE POINT I RAISED EARLIER ABOUT PRODUCT
ECOLOGY, YOUICAL HAVE SPEECH RECOGNITION OR SPEECH
23 SINTH SILS FOR EXAMPLE THAT LIVES INSIDE YOUR CELL
PHONE OR IT CAN LIVE INSIDE THE PHONE NETWORK AND YOU
24 CAN EVEN HAVE SYSTEMS LIKE COMPAQ HAS A REALLY
INTERESTING EXPERIMENT WITH A COMPANY CALLED
25 TELECONNECT OR TELETECH OR SOMETHING LIKE THAT WHERE
SOME OF THE PROCESSING IS DONE IN THE IPAC AND SOME



42

1 OF IT IS DONE IN THE INFORMATION NETWORK.
SO THIS AGAIN I GUESS SPEAKS TO THE INFORMATION
2 ISSUE.
WE NEED TO HAVE AN UNDERSTANDING OF WHAT THE HAND SET
3 OPTIONS ARE AND WHAT THE NETWORK BASED SERVICE
OPTIONS ARE AND WHAT THE AVAILABILITY IS OF BOTH THE
4 HANDSET AND THE SERVICE PLAN.
YOU KNOW ONE OF THE CONFUSING THINGS FOR ALL CELL
5 PHONE CUSTOMERS AND I'M SURE AT F. C. C. GETS
COMPLAINTS ABOUT THIS, IS TRYING TO COMPARE THESE
6 VERY COMPLICATED MULTIDIMENSIONAL DECISIONS THAT WE
HAVE TO MAKE AS CONSUMERS AS TO WHICH HAND SET OR HOW
7 MANY THREE MINUTES A MONTH ON WHICH CARRIER ADDING
ACCESSIBILITY TO THAT DECISION RAISES THE INFORMATION
8 REQUIREMENT ANOTHER LEVEL.
SO CUSTOMERS WITH DISABILITIES HAVE NOT ONLY ANOTHER
9 FACTOR OF INFORMATION THAT THEY HAVE TO INFORM
THEMSELVES ABOUT, BUT ANOTHER DETERMINANT IN MAKING
10 THEIR DECISION.
SO AGAIN, IT'S AN MADAM FOREMAN /* INFORMATION PUZZLE
11 BUT I HAVE TO SORT OF GET TO THE BOTTOM LINE, I'VE
SUCCESS FLOWFULLY USED MANY SPEECH RECOGNITION CELL
12 PHONES.
ESPECIALLY IF YOU ONLY HAVE FIVE OR 10 NUMBERS YOU
13 CALL FREQUENTLY.
THE SMALLER THE LIST THAT YOU WANT TO DIAL BY VOICE,
14 THE BETTER THE PERFORMANCE IS.
AND USING A HEADSET WILL IMPROVE YOUR PERFORMANCE
15 DRAMATICALLY IN A NOISY ENVIRONMENT.
>> I'D LIKE TO ADD TO THAT TOO THAT JIM
16 MENTIONED IF IT'S NETWORK BASED OR IF IT'S IN THE
PHONE, THAT MAKES A BIG DIFFERENCE WHEN YOU RUN, WHEN
17 YOU TRAVEL, HAVING ONE OF THOSE PHONES MINE IS
NETWORK-BASED SO WHEN I'M OUT OF MY LOCAL CALLING
18 AREA, THEN MY VOICE COMMANDS NO LONGER WORK.
SO THAT'S ONE THING YOU WANT TO CHECK ON.
19 >> THE NEXT QUESTION IS REALLY AN UPDATE
ON 508 AND THE QUESTIONER ASKS, CAN ANYONE COMMENT ON
20 HOW SECTION 508 HAS BEEN IMPLEMENTED SINCE THE JUNE
18TH WEB CAST AND HAS ANY AGENCY USED YET IN THE
21 FEDERAL GOVERNMENT THE UNDUE BURDEN CLAUSE AND HAS
THERE BEEN ANY INJUNCTIVE RELIEF CLAIMS FILED BY ANY
22 PERSONS OR GROUPS SINCE THE JUNE DATE.
>> I GUESS THAT'S ME AND THE ANSWERS ARE
23 YES, NO, NO.
>> I'M NOT QUITE SURE WHAT THEY MEANT BY
24 COMMENTS SINCE THE JUNE 18TH.
THAT'S WHEN YOU HAD YOUR WEB CAST.
25 WE GET COMMENTS ALL THE TIME TELLING US WHAT WE DID
RIGHT AND WHAT WE DID WRONG.



43

1 AND WE ACTUALLY WELCOME THEM.
BELIEVE IT OR NOT.
2 IF SOMEBODY HAS A LEGITIMATE COMPLAINT OR SAYS, YOU
KNOW, THIS JUST ISN'T WORKING, WE'D LIKE TO KNOW IT
3 BECAUSE WE WILL BE UPDATING 508 IN THE NOT TOO
DISTANT FUTURE.
4 TECHNOLOGY IS CHANGING TOO FAST AND SO I AM ALREADY
WRITING DOWN THOSE AREAS WHERE WE KNOW AND WE KNOW
5 SOME OF THE THINGS ARE GOING TO BE CHANGED ALREADY.
IT'S REALLY TOO EARLY FOR AN UNDUE BURDEN TO BE
6 FILED.
REMEMBER THAT AN UNDUE BURDEN -- WELL, THE UNDUE
7 BURDEN IS FILED BITE AGENCY AND I WOULDN'T KNOW
WHETHER ONE HAS BEEN -- BECAUSE IT'S NOT FILED.
8 IT'S JUST A DECISION MADE AT THE PROCUREMENT LEVEL
AND THE DOCUMENTATION HAS TO BE KEPT IN THE
9 PROCUREMENT FILE.
I KNOW AGENCIES HAVE PROCEDURES IN PLACE TO REVIEW
10 ANY UNDUE BURDEN CLAIMS BEFORE IT'LL BEA LOUED.
AND I'M SORRY, WHAT WAS THE LAST QUESTION?
11 HAVE THERE BEEN ANY RELIEF?
NO BECAUSE THERE HAVEN'T BEEN AND LAWSUITS.
12 THERE HAVEN'T BEEN ANY COMPLAINTS THAT I KNOW OF.
AND THE REASON IS THAT IT'S ONLY PRODUCTS THAT ARE
13 PROCURED AFTER JUNE 21.
AND SO THE PRODUCT WOULD HAVE HAD TO BE PROCURED AND
14 THEN A COMPLAINT FILED AND THESE THINGS DON'T HAPPEN
OVERNIGHT.
15 >> I'D LIKE TO ADD ON THAT, BASED ON THE
AMOUNT OF QUESTIONS THAT ARE COMING IN, IT APPEARS
16 THAT AGENCIES ARE FULLY ENGROSSED IN IMPLEMENTING
SECTION 508 AND ARE TAKING IT SERIOUSLY AND THE
17 VOLUME OF QUESTIONS COMING FROM COMPANIES INDICATE
THAT THEY ARE FULLY ENGAGED IN ATTEMPTING TO COMPLY.
18 SO THE ROBUST ATMOSPHERE OF ATTEMPTED COMPLIANCE IS
VERY REAL, SO I THINK THAT IN ITSELF IS A REPORT THAT
19 PEOPLE ARE TAKING IT SERIOUSLY.
>> I HAVE A SIMILAR QUESTION ABOUT THE 255
20 COMPLAINT PROCESS THAT KAREN YOU MENTIONED AND THE
QUESTIONER ASKS, HAVE THERE BEEN MANY COMPLAINTS
21 EITHER INFORMAL OR FORMAL AND CAN YOU CITE TO AN
EXAMPLE OR TWO OF WHERE THERE HAS BEEN RESOLUTION BY
22 THE AGENCY THAT RESULTED IN IMPROVED ACCESS?
>> YES.
23 WELL, WE DO AS I MENTIONED BEFORE GET A STEADY STREAM
OF COMPLAINTS AND WE AT THIS POINT ARE GETTING 10 OR
24 12 A MONTH.
ONE SITUATION WHICH WE DID RESOLVE INVOLVED THE
25 PROVISION OF INFORMATION SERVICES OR DIRECTORY
ASSISTANCE SERVICES IN ACCESSIBLE FORMAT.



44

1 SO WE'VE HAD THAT SUCCESS, WE'VE HAD A COUPLE OF
OTHER SAID.
2 THE MAJORITY OF OUR COMPLAINTS RANGED AS I MENTIONED
FROM ACCESSIBLE BILLING TO DIRECTORY ASSISTANCE TO
3 INTERFERENCE AND COMPATIBILITY WITH HEARING AIDS,
WIRELESS PHONES AND HEARING AIDS.
4 IT'S A VERY, VERY SIGNIFICANT SET OF COMPLAINTS THAT
WE RECEIVE AT THE AGENCY AND THOSE RELATE TO WHAT JIM
5 AND SUSAN WERE TALKING ABOUT BEFORE AND THAT'S THE
DIFFICULTY OF STANDARDIZATION.
6 BECAUSE HEARING AIDS DIFFER SO SIGNIFICANTLY
FREQUENTLY PERSON TO PERSON AS DOES HEARING LOSS AND
7 WHEN YOU COMBINE THAT WITH TRYING TO MAKE THOSE AIDS
COMPATIBLE WITH DIGITAL TELEPHONES, IT'S VERY, VERY
8 DIFFICULT TO STANDARDIZE.
WE'VE GOTTEN INNUMERABLE COMPLAINTS ABOUT HEARING
9 AIDS BUT ARE WORKING ON THE ISSUE -- ON A MORE GLOBAL
LEVEL RATHER THAN ON AN INDIVIDUAL COMPLAINT LEVEL.
10 >> TWO SOMEWHAT RELATED QUESTIONS, ONE
COMING FROM SAN FRANCISCO, THE OTHER ONE FROM HERE IN
11 WASHINGTON, D.C. ONE IS CAN ANYONE DISCUSS THE KIND
OF PROS AND CONS OF THE NEW PRODUCTS THAT ARE ON THE
12 MARKET THAT ARE SELF-EVALUATION SOFTWARE TO ASSESS
THE ACCESSIBILITY OF A WEB SITE BUT THEN WE HAVE A
13 RELATED QUESTION WHICH IS ARE THERE ASSESSMENT TOOLS
FOR ASSESSING ACCESSIBILITY OUTSIDE OF WEB SITE
14 ACCESSIBILITY IN NS OF OTHER TYPES OF ELECTRONIC AND
INFORMATION TECHNOLOGY PRODUCTS.
15 >> I PROBABLY CAN TAKE THAT ONE.
THERE ARE SEVERAL PRODUCTS NOW OUT THERE THAT PEOPLE
16 ARE SELLING OR MAKING AVAILABLE FREE.
THAT SAY THEY'LL GO IN AND TEST WEB SITES OR WEB
17 PAGES.
TO DATE, WE CERTAINLY AT AT BOARD DON'T ENDORSE ANY
18 SPECIFIC PRODUCT.
WE HAVE NOT SEEN ONE THAT WE WOULD SAY, WOW, THAT'S
19 THE ONLY ONE YOU SHOULD EVER BUY.
THEY'RE ALL QUITE DIFFERENT FROM EACH OTHER.
20 AND THE ONLY THING I CAN SAY AS FAR AS 508 IS YOU
MIGHT WANT TO RUN ANY OF THOSE TOOLS TO JUST SORT OF
21 GET A GENERAL OVERVIEW.
DON'T TAKE THEM TOO SERIOUSLY BECAUSE I'VE SEEN
22 PEOPLE TRY VERY HARD TO DO A GOOD JOB AND GET BADLY
BEATEN UP BY SOME OF THESE TESTS THAT -- FOR THINGS
23 THAT REALLY WEREN'T, JUST WEREN'T A PROBLEM.
THE OTHER SIDE OF THE COIN IS I'VE SEEN THESE TESTS
24 GO OUT AND COME BACK AND GIVE A PAGE THAT WAS TOTALLY
INACCESSIBLE, A CLASS A RATING.
25 SO SO CODE IT CORRECTLY.
FOLLOW THE 508 PROVISIONS.



45

1 >> I THINK THAT DEMONSTRATES THAT
COMPLIANCE WITH SECTION 508 IS NOT TOTALLY
2 AUTOMATICALLY MACHINE TESTABLE.
THAT IT REQUIRES A HUMAN FACTOR.
3 MOST OF THESE TOOLS CAN TEST 60 TO 80 PERCENT OF THE
COMPLIANCE ON A WEB PAGE.
4 THE GOOD NEWS IS THAT WE LIKE THE WAY THAT THE
MARKETPLACE IS RESPONDING.
5 THERE ARE FIVE OR SIX COMPANIES NOW THAT HAVE TOOLS
OUT THERE THAT TEST.
6 SOME OF THOSE TOOLS, MAKE SURE YOU CHECK THE
DIFFERENCES. AND THEY'LL AUTOMATICALLY ASK WHETHER
7 YOU'D LIKE TO REQUEST THE FOLLOWING PAGES.
I WOULD LIKE TO COMPLIMENT SOME OF THE TOOLS WHERE
8 THEY'VE PUT IN STRUCTURES AS MANAGEMENT TOOLS SO CAN
YOU SEE GLOBALLY ACROSS MANY WEB SITES IN YOUR
9 COMPANY.
WHAT TYPES OF ERRORS ARE OCCURRING SYSTEMICALLY OR
10 WHERE THE HOT SPOTS ARE IN CERTAIN PARTS OF YOUR
PROGRAM THAT ARE NOT ACCESSIBLE AT ALL BUT OTHER
11 PARTS ARE VERY ACCESSIBLE.
SO IN THEIR PLACE THEY HAVE SOME VERY GOOD FEATURES
12 IN THEM AND ARE NICE AS DOUG INDICATED A NICE
COMPLEMENT TO THE HUMAN DEVELOPMENT AND TESTING
13 THAT'S GOING ON.
SO FAR WE HAVE NOT SEEN THE EQUIPMENT TOOLS IN OTHER
14 BITS OF SOFTWARE.
IT'S ONLY FOCUSED ON THE WEB RIGHT NOW BUT I'M
15 CONVINCED THAT DOWN STREAM THAT THE MARKETPLACE WILL
START TO RESPOND AND WE'LL GET IN OTHER TESTING TOOLS
16 AS WELL AS AND OTHER SOFTWARE BESIDES THE WEB.
>> I WILL JUST ADD THAT THERE ARE SOME
17 WINDOW WOIND TESTING SOFTWARE TESTING TOOLS THAT TEST
FOR A FEW FEATURES THAT ARE VERY GOOD AND YOU CAN
18 FIND THEM AT THE MICROSOFT SITE.
>> THIS QUESTION COMES FROM ATLANTA AND
19 WANTS TON WHETHER ANY OF THE PANELISTS AS WELL AS THE
ITTATC CENTER WILL BE AVAILABLE AT THE IDEAS SHOW
20 WHICH IS IN WASHD WASHINGTON D.C. THIS TUESDAY AND
WEDNESDAY, AND MAYBE THE PANELISTS CAN EXPLAIN WHAT
21 IS THE IDEAS SHOW.
>> EVERYBODY IS GOING TO BE THERE.
22 RAISE YOUR HAND IF YOU'RE GOING TO BE THERE.
RAISE YOUR HAND IF YOU'RE NOT.
23 >> IDEAS SHOW WAS INITIALLY STARTED BY THE
DEPARTMENT OF AGRICULTURE.
24 IT'S COSPONSORED NOW BY MANY AGENCIES.
THERE IS A WEB SITE FOR IDEAS THAT YOU CAN FIND
25 INFORMATION ABOUT IT.
IT BEGINS ON TUESDAY AND RUNS THROUGH MUCH OF THE



46

1 REST OF THE WEEK.
>> DO YOU KNOW THE WEB SITE?
2 >> I BELIEVE THAT'S IDEAS.ORG BOO BUT IF
YOU GO TO SECTION 508.GOV, THERE'S A LINK ON TOP OF
3 THAT TO GO TO THE IDEAS CONFERENCE.
SO GO TO SECTION 508.GOV.
4 >> AND I WANT TO SAY THAT A CERTAIN SELECT
NUMBERS OF ATTENDEES AT THE IDEAS CONFERENCE WILL WIN
5 A FREE MAGIC SECTION 508 BALL.
SO IT'S AN IMPORTANT TOOL IN EVALUATING YOUR
6 COMPLAINTS.
>> AND ITTATC WILL BE THERE.
7 WE'LL HAVE A BOOTH AT IDEAS.
>> WE'RE NOT GOING TO GET TO ALL THE
8 QUESTIONS THAT ARE HERE.
I PROBABLY HAVE ANOTHER HALF DOZEN.
9 I THOUGHT AS WE'RE BEGINNING TO RUN OUT OF TIME THAT
I MIGHT ASK THE PANELISTS IF YOU'D HAVE ANY FURTHER
10 REMARKS KIND OF CONCLUDING REMARKS THAT YOU MIGHT
WANT TO MAKE TO THE MANY PEOPLE THAT MIGHT BE
11 LISTENING OR WATCHING THIS ACROSS THE COUNTRY.
KAREN?
12 >> YES.
I HAVE ONE.
13 I THINK A FEW OF THE PANELISTS MENTIONED THE F. C.
C.'S WEB SITE AND I DON'T THINK WE ACTUALLY GAVE THE
14 URL.
IT'S WWW.FCC.GOV/CIV/DRO.
15 IF YOU WOULD LIKE INFORMATION ABOUT DISABILITIES
ISSUES.
16 I THINK IF YOU GO TO SLASH CIV THERE SHOULD BE A LINK
THERE FOR DISABILITIES ISSUES AND WE ENCOURAGE PEOPLE
17 TO GO THERE.
THERE'S INFORMATION ABOUT SECTION 255, ABOUT RELAY
18 SERVICES, ABOUT SECTION 508, VIRTUALLY ANY ISSUE
RELATING TO ACCESS.
19 WE ALSO HAVE A MAILBOX FOR SPECIFIC DISABILITY
RELATED QUESTIONS CALLED ACCESS AT F. C. C..GOV.
20 AND WE ENCOURAGE ANYBODY TO SEND IN THEIR CONCERNS,
INQUIRIES, OR COMPLAINTS VIA THAT MAILBOX.
21 IRXSZ OTHER COMMENTS?
JIM?
22 >> I'D LIKE TO CONTRIBUTE THE ACCESS BOARD
ON THEIR EXCELLENT GUIDANCE DOCUMENTS WHICH THEY NOW
23 HAVE UP.
THERE'S SOME I THINK DOUG MENTIONED THEM BUT THEY
24 REALLY DESERVE A LOT INSPECTION, THEY PROVIDE GREAT
TECHNICAL GUIDANCE, THEY PROVIDE VERY FOUND P SOUND
25 REAL WORLD GUIDANCE, SO QUALIFY YOU CO.S OUT THERE
WHO ARE CYNICAL ABOUT OFFICIAL INITIATIVES, YOU



47

1 SHOULD REALLY BALANCE YOUR VIEWS.
A VERY IMPRESSIVE SET OF INFORMATION.
2 >> OKAY. I'LL TURN IT BACK TO YOU.
>> I'LL CERTAINLY LIKE TO THANK ALL OF OUR
3 PANELISTS FOR DOING SUCH A GREAT JOB AND BRINGING SO
MUCH EXPERTISE TOGETHER AT ONE TIME.
4 WE HOPE WE HAVE PROVIDE THE THE AUDIENCE WITH
RESOURCES AS WELL AS RAISE SOME ISSUES FOR FURTHER
5 EXPLORATION.
AND WE THANK YOU ALL FOR VIEWING AND TUNING IN.
6 WE WOULD LOVE TO HAVE YOUR FEEDBACK SO WHEN WE DO
THESE IN THE FUTURE WE CAN BENEFIT FROM WHAT WE MIGHT
7 HAVE DONE WELL OR NOT SO WELL, SO PLEASE FILL OUT THE
FEEDBACK FORM OR THE EVALUATION FORM, AND LET US KNOW
8 HOW YOU FELT ABOUT THIS WEB CAST.
AND THANK YOU VERY MUCH.
9 >> THANK YOU.

 
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