The FCC and Accessibility

Overview

One of the great things about the Obama Administration is that they've generally lowered the bar for citizen participation in federal policy. I'm much rather post something in a blog than go through a formal sending of a snail mail letter!

The FCC just did a series of four blog posts asking for feedback on their new accessibility plans. Here are my comments on the big picture and a couple of their proposals. I'm also going to copy portions into the comments section of their specific posts.

Comments on the FCC's Accessibility Plans (June 2010)

My main recommendation to the FCC is to be more ambitious about accessibility. Although the Clearinghouse and Awards programs could be helpful to the cause of greater access for people with disabilities, I don’t think they truly take on the biggest opportunity for change.

We have a model for this kind of change: TTYs (text telephones) and relay services though the telephone. When the technology in question was the telephone, those people with disabilities with the greatest barrier to use, the deaf, had access to technologies that provided a decent level of service.

We need to think much bigger with the Internet and the full range of disabilities. It’s certainly within our technical capabilities to provide a basic level of access to the information and communication capabilities of the Internet and web through broadband. For each American who has a disability that affects access to information and communication capabilities, there are tech solutions that could be delivered through broadband to make that resource accessible.

If the FCC lacks the funding and/or legislative authority to make this happen, then my recommendation is to seek that funding and authority, and then make it happen.

Examples of the kinds of solutions that I believe are possible:
• Wizards that helps people determine the accessibility features they need, without a focus on disability diagnosis (needs and preferences over disability labels)
• Infrastructure that makes it easier for resources to implement accessibility (see the proposed National Public Inclusive Infrastructure-NPII from Prof. Gregg Vanderheiden of the TRACE Center)
• Cloud-based tools that read text aloud to broadband users who are visually impaired, learning disabled or developmentally disabled
• Basic AT tools built into the web and broadband

We definitely need to do more than simply talk about these needs - we must provide the resources/funding to develop and prove these solutions out in the short run and to deploy and maintain them over the long run.

Specific comments on the proposed Clearinghouse.

Disability information clearinghouses have been set up in the past, and have failed to fully meet the need or realize the potential of such a solution. If the FCC is to succeed with a new clearinghouse, it needs to avoid the mistakes of the past.
• Old Clearinghouses rapidly became out of date, especially after the initial grant expired. The FCC should embrace a more Web 2.0 approach where users, experts and vendors can update the data every day, keeping it relevant and timely. Oversight needs to be with a light hand.
• Material should be posted under an unencumbered open content license, so that the content can be shared widely, especially in case of the Clearinghouse losing funding as some future date (so that the content can be freely moved to a new home)
• Promotion: the Clearinghouse won’t matter if no one visits. Consider Google and other search engine advertising (or see if Google will partner on a Google Grant). Actively optimize for search engines so that the people who need to find the information will.
• The Clearinghouse could also host wizard functionality to help people decide what they need, and provide trial access to key accessibility technologies so that users can actually experience what the AT would do for them.
• The biggest enemy of a Clearinghouse is irrelevancy. Make it an indispensable tool for people with disabilities, their families, educators, rehab professionals and the assistive and mainstream technology industries.

Specific comments on the proposed Chairman’s Awards.

I think identification of problems could be a very exciting opportunity, to build up a detailed list of requirements that could inspire developers and problem solvers. It’s not clear that money awards would be an important driver of this Phase: the gift of attention to the issue would be the main payoff.

The bigger question is about how to structure the second phase. Awards programs are around providing incentives to encourage certain kinds of behaviors. The FCC has to think about what its biggest objectives are. Are they intended to inspire students? Change the behaviors of mainstream tech companies? Launch new solutions for people with disabilities? Recognize past accomplishments?

Of these different options, I’d be most excited about awards that would lead to innovation and new solutions for people with disabilities. The assistive tech field struggles with funding, and innovation is slower than in mainstream technology.

Some awards programs are around encouraging students and individual inventors: with the incentive being prestige or a minor amount of money ($5-10,000). These encourage students and professors to think about accessibility. They don’t tend to lead to widespread adoption that benefits people with disabilities directly, though. Larger awards can encourage groups that have more capacity for sustained services. For example, the Tech Museum Awards of five $50,000 prizes each year attracts many organizations with real capacity who are seeking both prestige and funding that could be significant in getting the new projects off the ground. Lastly, you have larger X-Prize style awards, where the prizes are large and are intended to spur investments larger than the prize money involved. It’s not clear how effective this approach would be in accessibility, where most of the people (individuals, small AT vendors, nonprofits) who would be competing don’t have the funds necessary to win the prize. Of these three types, I think the medium-sized prizes would have the biggest impact.