COMMENTS TO THE UNITED STATES ACCESS BOARD
on Supplementary Guidelines on Communications Access
July 25, 2006 at the Crowne Plaza Hotel, Washington, D.C.

Thank you Access Board for this opportunity to present some recommendations from the American Association of People with Disabilities (AAPD).

AAPD is the largest national nonprofit cross-disability member organization in the United States, dedicated to ensuring economic self-sufficiency and political empowerment for the more than 51 million Americans with disabilities; AAPD operates programs in political participation, leadership development, mentoring and career exploration, and public policy advocacy. AAPD works in coalition with other disability organizations for the full implementation and enforcement of disability nondiscrimination laws, particularly the Americans with Disabilities Act (ADA) of 1990 and the Rehabilitation Act of 1973, in addition to other statutes.

I am Jenifer Simpson, Senior Director for Telecommunications and Technology Policy at AAPD, and I am happy to present today some of recommendations for Supplementary Guidelines on Communications Access in the development of technical and scoping requirements for the unmet needs of individuals with disabilities in regard to effective communication in the built environment.

There are three priority areas which we believe the Access Board should undertake to ensure universal communications accessibility for persons with disabilities in addition to several other steps that need to be addressed in the area of effective communications:

  1. Emergency Notifications
    Requirements so that fire alarms and other emergency notification devices can be heard/seen/understood by persons with vision disabilities, by persons with hearing disabilities, and by persons with disabilities that involve some combinations of lowered hearing and vision ability (e.g., elderly persons).
    1. As a priority, these should be devices that are customarily used in hotels, restaurants, shopping malls, airports and other public places.
    2. Our deaf members have indicated that different color lights and flashing capacity should be targeted as part of required standards. Other members have indicated that plain language criteria should be addressed for any text based notices about emergencies.

  2. Web Site Accessibility
    Web sites for entities that have a public geographic nexus should be accessible and usable for persons with disabilities.
    1. For example, a web site for a food or book chain, or for a department store, should have its associated web site designed to be accessible and usable to persons with vision and hearing disability as part of the enjoyment of the goods, services and privileges of the retail entity.
    2. Sec. 508 requirements or other web accessibility design standards should be required options for these web sites.
      1. Video streaming with any audio stream on such web sites should have a text output or “captioning” available.
      2. The web site should be easily navigable and usable by persons with vision disabilities, and users of JAWS and other equipment.

  3. Home Appliances in Public Locations
    Devices that are home appliances made available in public spaces, such as microwave ovens and other cooking, cooling, heating and services devices often made available in waiting areas, such as at bus stations, hospital waiting rooms and other locations, should be purchased by ADA covered entities to be accessible to the widest number of persons.
    1. Should be usable by persons with vision and hearing disabilities
    2. Should be usable by persons with cognitive and physical disabilities
    3. Should have easily understood plain language instructions available in large font printed format
    4. If wireless or internet access is part of the device operation, such as via remote control (of the device), that should be compliant with Sec. 255 accessibility and usability requirements.

    AAPD also supports activities that address acoustic standards in educational and other environments that promote effective communication. There should be standards to ensure appropriate acoustical environments for learning settings, particularly in educational facilities, that would support children with hearing loss, learning disabilities and developmental delays in speech and language acquisition, or other disabilities typically affected by ambient sound or environmental stressors.

    1. Such requirements should involve review of sources of radio frequency interference to hearing aids or implants used by children or patrons, and the staff, of the establishment and requirements on how to address such interference.
    2. An accessibility review for radio frequency may establish sources of possible radio frequency interference on the site or nearby, such as from machinery, broadcasting or other radio frequency transmission.
    3. Other factors, such as light, ambient noise and “echo” effects, materials and textures.

Some additional areas the Access Board should consider include the following:

For Persons With Speech Disabilities and Persons With Hearing Disabilities

  1. Development of alternatives to audible emergency instructions delivered over public address systems in prioritized locations (e.g., schools, airports, shopping malls, amusement parks). Consider scoping into two different information areas, one for “fixed” and another category for “changing information.”
    1. For “fixed information” accessibility could involve a requirement for availability of written instructions that is posted in multiple locations throughout the facility with an easily recognizable standardized symbol or emblem so that persons with hearing disabilities are aware of the general procedures used, such as for evacuation or site lock-down, with a description of the types of situations that could trigger emergency announcements over the public address system (e.g., flooding, fires, criminal or terrorist activity, “heavy” weather, other social disruption scenarios)
    2. For “changing information,” such as departure or arrival delays, cancellations and gate changes, such as at airports, bus and train stations, a summary screen on the bank of arrival/departure screens that captures this information as fast as possible in text format such as when the announcement is first made by the airport staff, or, alternatively, a screen with video streaming capability, such as a crawl or scroll, on the general information screens, that provides these updates in a fast and timely fashion. Such a system could also be used for emergency information.
    3. Consider requirements for output that is text-based in nature that would be displayed on personal wireless devices such as PDAs, Blackberries, cell phones, etc., or that is disseminated over the free Public Internet and that would available to consumers or passengers subject to the changed information.

  2. Entities that provide voice notification services, such as a voice phone call-back when “taxi ready” or “plane flight confirmed” or “alarm system reset” or other verbal notification, should also ask for Email or Instant Messaging screen name to provide this information in an alternate format for persons with hearing and other disabilities who rely on text.

  3. Fast food restaurants that have drive-thru machines, alternatives for persons with speech and hearing and hearing disabilities, or for persons with disabilities who confused or unable to understand complex visual menu boards.
    1. Accessibility could be a button to push that light up at the sales staff station that a consumer with a hearing or speech disability or other disability will be driving up to the window and ordering. Even if this is abused by pranksters, there is little harm involved as the prankster will be unveiled as non-disabled when ordering.

  4. If a public telephone, particularly one with a TTY attachment, has been removed a sign should posted that indicates where the nearest public telephone with a TTY is now located.

  5. Whenever a public entity has been wired for broadband (T1, any DSL, or other broadband connection, including wireless) there could be a requirement for a videophone booth connecting to TRS Video Relay Services. This could be part of any location where there is installed a Voice Over Internet Protocol (VoIP) phone.

  6. Wherever there is free television service made available in public places, such as shopping malls, hotel lobbies, other locations, the default setting should be “closed captioning always on”:
    1. So that persons with hearing and other disabilities can watch television and individuals are not put in the position of begging for this or have to run around looking for the remote or other control device or to search for the appropriate authority figure
    2. It is unlikely anyone would object to this default setting as such public places are generally noisy and the closed captioning benefits everyone.

  7. Requirements should be established, based on studies, for persons with hearing disabilities who are sign language users, lip readers, and/or have cochlear implants or other hearing aids so that they may
    1. Take advantage of different lighting, including reflective capacities of painted or other surfaces and that address the minimal level and ambient light needs to distinguish finger signing, lip movements, and multiple sounds in the environment.

For Persons With Vision Disabilities

  1. Public information and transaction devices for blind and low vision persons:
    1. Accessibility should address topics such as nibs, ridges, variable surfaces, and logical or intuitive step processes.
    2. Information transaction machines, such as public information kiosks with screens and menus that include directions and maps, or information devices that are standing signs that provide maps and directions, such as in shopping malls, airports and other public locations,
      1. Accessibility could involve a single push button as an alternative option that would provide an audio output for priority locations on the map, such as toilets, public safety stations, and elevator locations.
      2. Such a button would have to be standardized on public information devices in regard to location (for instance, bottom right hand corner, convex, diameter about 1/3 inch, etc.)

  2. Point-of-sales machines, such as automatic teller machines, fare vending machines, other automated sales machines (food, flowers, newspapers) should be accessible:
    1. Accessibility could involve a standardized button on the device that provides audio output directions to a nearby human vendor, or audio instructions on how to operate the machine, or additionally, spit out of a disposable Brailled paper strip that a Braille-reader could use, or generation of audio output via various wireless radio frequency systems.

  3. Simple kiosk with audio outputs available in fast food establishment for blind and low vision persons to preview the menu.

  4. Informational signs or cues that provide information for persons who are blind or with low vision so that they may
    1. navigate through public areas (e.g., different and recognizable surface textures for pathways through public spaces, in buildings, on walls and on objects of public use – handrails, doorways)
    2. Requirements, based on studies, on how lighting, including reflective capacities of painted or other surfaces, impacts wayfinding and the legibility of informational signs for people who have low vision.

  5. Street signs should be large font and high contrast, or otherwise accessible, especially where there is new congregate homes development or particularly for residential areas or assisted living developments established for the elderly.
    1. Replacement street signs should also follow this requirement, particularly for older or long established neighborhoods where there may be high concentrations of elderly persons with vision disabilities.
    2. New wireless technologies should also be considered for street sign/direction wayfaring, with priority given to areas where safety may be involved (e.g., intersections, crossing of multiple lanes, large public enclosed areas such as terminals and stations) and for Exit and Emergency information signage.

For Persons With Cognitive Disabilities
Informational signs in plain language and large font that are instructions on how to operate devices in places of public accommodation so that persons with cognitive, learning, vision and other disabilities can figure out how to operate equipment (and also likely to benefit persons who are elderly, or for whom English is a second language).

  1. For hotels and motels this could include devices such as temperature thermostats, televisions including remote controls or remote keyboards, and phones in hotel rooms, hairdryers, and coffee machines.
  2. for businesses and other commercial establishments this could include devices such as fire extinguishers, non-pay phones made available for users at the site, emergency aid kits, or other

For Persons With Physical Disabilities

  1. For persons with vision, gait, and other disabilities
    1. A requirement that stair riser edges in public places be marked or edged in an alternate easily-discerned high contrast color
      1. To prevent falls and slips on escalators and fixed stairways
      2. To aid in wayfaring
    2. A requirement that handrails, including those on escalators be of a high contrast color or striped and of an easily graspable substance and texture
      1. To prevent falls and slips on escalators and fixed stairways
      2. To aid in wayfaring.

  2. For persons with physical disabilities, who are users of non-standard size wheelchairs, or who use alternative wheeled mobility devices, openings and space allowances that are not standard size and that do not violate current ADA requirements should indicate the dimension.
    1. Example: door height is 7 ft, or opening width is 45 inches.
    2. Such markings should be standardized, e.g., of a typical lettering and close to ground level, for instance.

JS/AAPD: 7/28/06

American Association of People with Disabilities
1629 K Street NW, Suite 503 • Washington, DC 20006
phone 202-457-0046 (V/TTY) • 800-840-8844 (V/TTY) • fax 202-457-0473 • www.aapd.com