1.0 OVERVIEW

1.1. CHARGE AND RESPONSIBILITIES OF THE TELECOMMUNICATIONS ACCESS ADVISORY COMMITTEE

This report contains recommendations of the Telecommunications Access Advisory Committee (TAAC or Committee) to the Architectural and Transportation Barriers Compliance Board (Access Board). The TAAC was convened by the Access Board in June 1996 to assist the Board in fulfilling its mandate under the Communications Act of 1934 as amended by the Telecommunications Act of 1996, Section 255 (hereinafter referred to simply as section 255). Section 255 requires that the Access Board, in conjunction with the Federal Communications Commission (FCC or Commission), develop guidelines, by August 8, 1997, for access to telecommunications equipment and customer premises equipment (CPE) by individuals with disabilities. Portions of section 255 which are relevant to the charge of the TAAC read as follows:

(b) MANUFACTURING -- A manufacturer of telecommunications equipment or customer premises equipment shall ensure that the equipment is designed, developed, and fabricated to be accessible to and usable by individuals with disabilities, if readily achievable.

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(d) COMPATIBILITY -- Whenever the requirements of subsections (b) ... are not readily achievable, such a manufacturer ... shall ensure that the equipment ... is compatible with existing peripheral devices or specialized customer premises equipment commonly used by individuals with disabilities to achieve access, if readily achievable.

(e) GUIDELINES -- Within 18 months after the date of enactment of the Telecommunications Act of 1996, the Architectural and Transportation Barriers Compliance Board shall develop guidelines for accessibility of telecommunications equipment and customer premises equipment in conjunction with the Commission. The Board shall review and update the guidelines periodically.

In selecting members of the TAAC, the Access Board sought to ensure representation of the various interests affected by the promulgation of accessibility guidelines. Committee members represented organizations advocating for the access needs of individuals with disabilities, manufacturers of telecommunications equipment and customer premises equipment, manufacturers of specialized customer premises equipment, manufacturers of software, and telecommunications service providers. Between June 1996 and January 1997, the Committee held six meetings, each of three working days in length, during which members worked to develop recommendations for implementing section 255's requirements. This report contains those recommendations, and is intended to guide the Access Board in the final preparation of the section 255 guidelines. The Committee hopes that the diligent efforts to achieve consensus among the various interests represented on the TAAC have laid the groundwork for future cooperative efforts in the implementation of section 255.

In preparing the recommendations contained in this report, the Committee recognized that evolving telecommunications technologies often make it difficult to distinguish whether a product's functions and interfaces are the result of the design of the product itself, or are the result of a service provider's software or even an information service format. It was the intent of this Committee to recommend steps to ensure that telecommunications equipment and CPE are accessible to and usable by individuals. The recommended guidelines do not differentiate between hardware and software implementations of a product's functions or features, nor is any distinction made between functions or features built into the product and those that may be provided from a remote server over the network.

This report is divided into six sections:

  • Section 1: "Overview," describes the mandates and charges of the Access Board, the FCC, and the TAAC, as well as eight guiding principles created by the Committee to assist in the development of accessibility guidelines.
  • Section 2: "History of Telecommunications Access for Individuals with Disabilities," provides historical information on legislation and manufacturing practices impacting telecommunications access for individuals with disabilities.
  • Section 3: "Definitions," sets forth definitions and terminology which are utilized throughout the TAAC Report.
  • Section 4: "Process Guidelines," sets forth proposed processes for manufacturers to follow in designing and developing accessible equipment.
  • Section 5: "Performance Guidelines," provides examples of how to make telecommunications equipment accessible. This section, along with Appendix C, will be updated on a regular basis, and is intended to provide engineers and product developers with a sense of what persons with disabilities need in order to effectively access and use telecommunications equipment and CPE.
  • Section 6: "Compliance and Coordination Guidelines," outlines a process for ensuring compliance with the accessibility guidelines and establishes mechanisms for coordination between industry and people with disabilities.

1.2. PURPOSE

The provisions of section 255 reflect Congress' recognition that individuals with disabilities need improved access to telecommunications technology. Congress placed an obligation on manufacturers to consider accessibility when designing, developing, and fabricating telecommunications equipment and CPE. Among other things, these recommendations set forth factors to be considered throughout these processes to achieve accessibility. Because the pace of technological change is so rapid, it is expected that many aspects of accessibility which are not readily achievable today may become readily achievable in the future. Manufacturers need to remain current in their assessment of whether it is readily achievable to make their products accessible by seeking out information on how to incorporate access into those products.

An important approach in designing accessible products is called universal design. This is the practice of designing products so that they are usable by the broadest possible audience. Products designed in this way are usable by more people without reducing the usability or attractiveness for mass or core audiences of the product. With universal design, the goal is to ensure maximum flexibility, benefits, and ease of use for as many individuals as possible. In the past, some products or designs developed with universal design principles have attracted a wider audience than may have otherwise been attracted by the product. For example, curbcuts, originally designed to ensure wheelchair access, are routinely used by parents with strollers, bicyclists, and delivery personnel. Similarly, closed captioning on television programming, created for the benefit of individuals who are deaf or hard or hearing, is frequently used in airports, restaurants, and other noisy locations where it is difficult to hear the audio portion of the programming. Finally, an audio adjunct to caller ID not only enables individuals who are blind to learn the identity of a caller, but enables family members eating dinner to identify callers without leaving the dinner table. The TAAC encourages the use of universal design in the manufacture of telecommunications equipment and CPE.

1.3. GUIDING PRINCIPLES

In developing the final accessibility guidelines required by section 255, the TAAC recommends that the Access Board adhere to the following eight principles:

  1. The guidelines must be specific enough that one can determine when they have been followed.
  2. The guidelines must be sufficiently flexible to give manufacturers the freedom to innovate.
  3. Products should be made accessible to and usable by people with as wide a range of abilities or disabilities as is readily achievable.
  4. Whenever it is not readily achievable to make a product accessible to and useable by individuals with disabilities, the manufacturer or provider of that product shall ensure that the product is compatible with existing peripheral devices or specialized customer premises equipment commonly used by individuals with disabilities to achieve access, if readily achievable.
  5. The Committee understands that it may not be readily achievable to make every type of product accessible for every type of disability using present technology. Future technologies may result in accessibility where it is not currently readily achievable.
  6. Because telecommunications technology is changing so rapidly it is expected that the guidelines will need to be updated on a regular basis.
  7. The guidelines must reflect the fact that computer, telephone, information, and tele-transaction systems may converge such that single devices may simultaneously provide all of these functions.
  8. The guidelines should address process, performance, and compliance and coordination issues.