Assessing the Compliance of Wireless Service Providers with the CRTC Accessibility Policy

April 10, 2014

While the enclosed study was commissioned by the Commission, the observations and conclusions are those of the author alone.  The Commission makes this study available for reference by the wireless industry and other potentially interested persons.

Executive Summary

CONNECTUS Consulting Inc. (CONNECTUS) is pleased to present to the Canadian Radio-television and Telecommunications Commission (CRTC) with its Final Report, Assessing the Compliance of Wireless Service Providers with the CRTC Accessibility Policy (the Study).

The Study was undertaken to accomplish three interrelated objectives:

The first objective is to provide the CRTC with a better of understanding of the level of compliance by Canadian Wireless Service Providers (WSPs) with the requirements set out at paragraphs 44 and 46 of Broadcasting and Regulatory Policy CRTC 2009-430 (the Accessibility Policy):

• Offering and maintaining at least one type of wireless mobile handset that will provide access to wireless service by persons who are blind and/or have moderate-to-severe mobility or cognitive disabilities; and

• Consulting with parties representing persons with disabilities on an ongoing basis to determine which handsets they will make available to address the needs of persons with disabilities, as well as reasonable technical and lifecycle support of these handsets in order to address unique needs, such as those imposed by assistive technologies.

The second objective is to identify on-going gaps in the provision of wireless handsets compliant with the policy by Canadian WSPs and gaps in accessibility features of handsets for persons who are blind and/or have moderate to severe mobility or cognitive disabilities.

The third objective is to identify prospective solutions to these gaps.

Individual testing of mobile handset devices and Assistive Technologies did not take place, and the information provided herein is based on third-party reporting and qualitative research findings.

We conclude that the handset accessibility gaps identified in previous research studies are, to a degree, closing - but have not yet been fully resolved.

We further conclude that Canadian WSPs are partly complying with the Commission’s Accessibility Policy, in that each provides at least one handset device (typically a smartphone) that provides for access to wireless services for persons with certain disabilities as outlined at Paragraph 44.

However, it is important to note that handsets themselves may only provide for more complete access to the wireless system in combination with available apps and third-party Assistive Technologies.

In other words, Canadian WSPs provide a handset (typically an Apple product on the iOS platform or a Samsung product on the Android platform) that, when combined with specific applications and/or third-party Assistive Technologies, meets a range of accessibility needs for those with vision, mobility and/or cognitive disabilities.

Over a relatively brief period of time, advancements have been made to wireless accessibility, including new versions of screenreaders, applications for those with vision disabilities, larger screen sizes, slow motion replay, more and better auditory cues and better interfaces with external Assistive Technologies (AT).

Where handset accessibility has advanced and certain gaps have been addressed, it has been in the smartphone category of mobile devices, and not in the feature phone or more basic type of wireless device. This is a trend that is likely to continue as smartphones assume a much greater proportion of the wireless handset market.

However, it is evident that other gaps persist or have emerged, as the fundamental sustainability of solutions remains an unanswered question. These gaps include:

• A continuing need for “enhanced” wireless accessibility, through apps and third-party Assistive Technologies that effectively complete the “accessibility cycle”. That is, handsets themselves must support apps and AT solutions, or access to certain functionalities remains incomplete.

• A continuing absence of definitions, standards and best practices, especially a definition of “accessibility”. Updated checklists of accessibility needs would better guide WSPs in their procurement practices.

• Increasing reliance on accessibility through smartphones, which are rapidly outdistancing feature phones in Canadian market share. Driven by applications development, smartphones offer excellent potential for meeting accessibility needs, but higher price points and absence of very basic smartphones in WSP inventories are clear disadvantages. A further disadvantage is the rapid turnover of smartphones, which can remove handsets with high quality accessibility features from the market.

• The continuing lack of a universal design strategy means that the integration of accessibility into the initial design phase is still absent from the cycle of development and production. This is especially important with respect to the role of the AT community, as assistive devices are critical third party-developed elements of handset accessibility for those with (especially) mobility disabilities or cross-cutting disabilities.

• Effective lifecycle support for handheld devices is required in order to ensure the on-going implementation of universal design in the wireless handset industry. This is especially important in a system of product development and comparatively rapid turnover, in order to ensure awareness, understanding and market pull for innovation.

• Effective consultations with user groups is key, as users are best equipped to inform WSPs of continuing innovation in accessible design, applications, assistive technologies and the interaction among these.

• Due to spectrum issues, there are potential limitations on handset availability from new market entrants, as they operate HPSA networks on the AWS band. However, specific carriers have indicated that they maintain the latest Android models in their inventories, and can assist iPhone 5S customers with reconfiguring their phones to operate on their mobile networks.

• An on-going challenge to develop an accessibility solution for severe mobility disabilities - a finding from previous research studies as well. The role of third-party AT is especially important in this instance, especially given the need to not only touch, but swipe, the screens of smartphones in order to access various functions.

While gaps identified in previous research have been at least partly remedied through increased adaptation of accessibility features in next generation smartphones, mobile handset accessibility can be maintained: through continuing market solutions; through the development of best practices for lifecycle support for solutions; and through the development of best practices for on-going consultations among stakeholders in the value chain of product development, production and distribution.

Examples of continuing market solutions include the increased screen size of smartphones and various scanning technologies developed form the Apple iOS7 platform.

With respect to Paragraph 46 of the Accessibility Policy, WSPs note a number of initiatives with respect to lifecycle support: requesting accessibility features from manufacturers; communicating with manufacturers to ensure that accessibility features are retained in subsequent generations of models; and using a checklist of accessibility features (which likely needs to be updated). WSPs anticipate further enhancements to accessibility as applications and software reach new levels of sophistication.

A number of cost-effective Best Practices have been outlined in previous research, with respect to lifecycle support for innovative products. At the core of these best practices is cooperation and active collaboration among various stakeholders in the chain of supply and demand is essential for supporting accessibility solutions for wireless devices. Defining core accessibility features; identifying those features that support AT required by users; and integrating accessibility criteria into WSP procurement specifications are some of the best practices that could be further developed. Establishing a North American Accessibility Procurement Forum would serve as a vehicle for discussion and potentially leverage the accessibility reporting mandated by the U.S. 21^st Century Video and Communications Accessibility Act (CVAA),

On-going consultations with the user community are an essential part of standardizing accessibility features and ensuring the retention of core features in future handset models. There a number of cost-effective Best Practices that can contribute to the development of a consultation model; adopting the following measures would facilitate WSP compliance with Paragraph 46 of the Accessibility Policy. These include:

• Identifying an Accessibility Officer within WSPs, who possesses expertise and decision-making influence in product development, engineering or other technical field. This approach works to formalize stakeholder outreach within each WSP.

• Establishing a forum (with a Chair) for WSP Accessibility Officer discussion and interaction, which enables continuing discussion and sharing of information between WSPs.

• Establishing responsibility for outreach to national user organizations. One potential model is to have the Chair of the WSP Accessibility Officers assume responsibility for this.

• Creating a WSP/User Group Forum, comprised of Accessibility Officers and representatives from key user groups, as a central conduit for discussion and the exchange of information between WSPs and users. Ideally, a modest stipend would be provided to disability organizations in exchange for the experience and expertise of representatives from disability organizations.

• Establishing a protocol for outreach to the handheld device industry and the AT sector - an important consultative element for developing device/AT lifecycle support strategy.

• Using the Forum as a conduit for providing information to consumers, leveraging user group presence and communication platforms and WSP customer service practices.

• Building effective stakeholder relationships using a number of best practices to support these, such as nominating an executive champion from the WSPs, ensuring that representatives from both sectors have decision-making influence or authority, and implementing a 360 process that specifically assigns tasks to companies/user groups/sub-committees which then report by to the Forum.

• In a more basic sense, the Forum would both set objectives and determine the success milestones associated with these - whether high-level or more granular goals.

The above noted measures would ideally combine to ensure the continued presence and evolution of sustainable solutions to wireless mobile accessibility, requiring the active and continued participation of all players in the chain of supply and demand.

Introduction

CONNECTUS Consulting Inc. (CONNECTUS) is pleased to present to the Canadian Radio-television and Telecommunications Commission (CRTC) with its Final Report, Assessing the Compliance of Wireless Service Providers with the CRTC Accessibility Policy (the Study).

The Study was undertaken in order to accomplish three interrelated objectives:

The first objective is to provide the CRTC with a better of understanding of the level of compliance by Canadian Wireless Service Providers (WSPs) with the requirements set out at paragraphs 44 and 46 of Broadcasting and Regulatory Policy CRTC 2009-430 (the Accessibility Policy):

44. Accordingly, the Commission requests that, by 21 October 2009, all WSPs offer and maintain in their inventories at least one type of wireless mobile handset that will provide access to wireless service by persons who are blind and/or have moderate-to-severe mobility or cognitive disabilities.^{Footnote 1}

46. The Commission requests that WSPs consult with parties representing persons with disabilities on an ongoing basis to determine which handsets they will make available to address the needs of persons with disabilities. Also in consultation with these groups, the Commission requests that the service providers provide reasonable technical and lifecycle support of these handsets in order to address unique needs, such as those imposed by assistive technologies. ^{Footnote 2}

The second objective is to identify on-going, critical gaps in the provision of wireless handsets compliant with the policy by Canadian WSPs and gaps in accessibility features of handsets for persons who are blind and/or have moderate to severe mobility or cognitive disabilities.

The third objective is to identify prospective solutions to these gaps. In addition, the Study examines gaps that are proving difficult to overcome, the reasons for these difficulties, and what solutions would be required to address these.

The Study adopted a largely user-centric focus in order to identify key gaps in wireless accessibility.

Our Report is organized in two main Parts.

Part I presents an assessment of current Canadian WSP compliance with Paragraph 44 of the Commission’s Accessibility Policy - the availability of at least one handset that meets the accessibility needs of those with vision, mobility and/or cognitive disabilities. Continuing gaps in wireless accessibility for people with disabilities are also noted.

Part II of our Report identifies potential solutions for on-going gaps in wireless handset accessibility, divided into three sections.

The first section identifies market solutions, e.g. handsets which currently address accessibility barriers and prospective entries to the handset device market that will include or promote solutions to accessibility barriers or gaps.

The second section identifies best practices for lifecycle support for solutions, e.g. cooperation among various stakeholders in the chain of supply and demand, changes to manufacturing/procurement processes and development of fluid guidelines/standards based on a regular cycle of consultation with stakeholders.

The third section will identify best practices for effective, on-going consultation between WSPs and disability groups, e.g. industry/stakeholder forums, designation of assigned responsibility for accessibility within wireless companies, and regular mechanisms for on-going communication, such as newsletters, blogs or other social media content.

Reference is also made to previous research studies that included solutions to gaps and/or best practices in their findings.

The Conclusion to the Report summarizes our findings. Appendix A provides a list of resources used for the Report and Appendix B provides a brief biography of the Report author.

Methodological Approach to the Study

The study was developed using four qualitative methodologies.

First, key studies in the subject area of handset accessibility were reviewed and summarized. The major findings of two studies, Lew et al, Creating an Accessible Mobile Handset Eco-System: The Associated Life Cycle Issues Neil Squire Society and Treviranus et al, Mobile Wireless Handset Accessibility Assessment Inclusive Design Research Centre, OCAD University (March 2011), were brought forward to the current assessment of WSP compliance with the Commission’s Accessibility Policy, to determine if previously discovered gaps in accessibility persist.

Second, the study focused on identifying key factors in handset accessibility, through a review and analysis of handset manufacturer/operating system (platform) websites and related information; Canadian WSP websites; Assistive Technology websites and documents; websites and related documents on applications designed to enhance accessibility to wireless services; and websites and related documents on the development of future technologies, applications, Assistive Technologies and handset.

Third, recent filings made by Canadian WSPs to the CRTC in response to interrogatories on compliance with the Accessibility were reviewed and summarized.

Fourth, consultations were conducted with representatives from the Canadian disability community and U.S.-based accessibility experts to identify current and future challenges - and solutions - to accessibility to the wireless system for persons with disabilities. The organizations contacted were the Neil Squire Society; the Alliance for Equality of Blind Canadians; the National Educational Association of Disabled Students; Inclusive Technologies Inc. (U.S.); and the National Centre for Accessible Media (U.S.).

Findings from each of the above noted qualitative methodologies were summarized for purposes of reporting. Studies, websites and other documents used as the basis of research are identified in the Bibliography that concludes this Report.

Part I - On-going Gaps in Wireless Handset Accessibility

Two caveats are noted for purposes of this section of our Report.

First, individual testing of mobile handset devices and Assistive Technologies has not taken place, and the information provided herein is based on third-party reporting and research findings.

And second, handset accessibility and the above noted gaps have largely been addressed in the smartphone category of mobile devices, and not in the feature phone or more basic type of wireless device. This is a trend that is likely to continue as smartphones assume a much greater proportion of the wireless handset market.

This part of our Report is based on:

• A review of two key studies previously completed for the Commission provided detailed analyses of wireless handset accessibility: Treviranus et al, Mobile Wireless Handset Accessibility Assessment Inclusive Design Research Centre, OCAD University (March 2011) (the OCAD Study); and Lew et al, Creating an Accessible Mobile Handset Eco-System: The Associated Life Cycle Issues Neil Squire Society (the Neil Squire Study);

• A review of accessibility reports recently filed with the Commission by Canadian WSPs, together with information provided on WSP websites/ accessibility pages;

• Additional research in the field of communications accessibility; and

• Consultations with representatives from the North American disability community.

We conclude that the handset accessibility gaps identified in the above noted research studies by OCAD and Neil Squire Society are, to a degree, closing - but have not yet been fully resolved.

We further conclude that Canadian WSPs are partly complying with the Commission’s Accessibility Policy, in that each provides at least one handset device (typically a smartphone) that provides for access to wireless services for persons with certain disabilities as outlined at Paragraph 44.

However, it is important to note that, as detailed in the Neil Squire Study, it is not the handsets themselves that necessarily provide for access to the wireless system, but may only do so in combination with available apps and third-party Assistive Technologies. The following table summarizes how certain accessibility features can potentially meet the needs of individuals who are blind, and/or have moderate to severe mobility disabilities and/or moderate to severe cognitive disabilities.

In each case, Canadian WSPs provide a handset (typically an Apple product on the iOS platform or a Samsung product on the Android platform) that, when combined with specific applications and/or third-party Assistive Technologies, meets that accessibility needs outlined below - with one exception. As noted in both the OCAD Study and the Neil Squire Study, full accessibility remains elusive for individuals with severe mobility disabilities.

On-going Gaps

Certain accessibility gaps have been, and continue to be, addressed through the development of platforms, apps and devices. New versions of screenreaders, applications for those with vision disabilities, larger screen sizes, slow motion replay, more and better auditory cues, better interfaces with external Assistive Technologies - these are just a few of the advancements made to wireless accessibility over a relatively short period of time.

However, it is evident that other gaps persist or have emerged, as the fundamental sustainability of solutions remains an unanswered question.

1. There is a need for “enhanced” wireless accessibility, through apps and third-party Assistive Technologies supported by handheld devices.

The Neil Squire Study noted that handsets are not accessible on their own, as they require some form of assistive technology to provide solutions that meet the full range of accessibility needs. ^{Footnote 4}

In other words, devices are a necessary part of fulfilling accessibility needs, but are in and of themselves insufficient: specific applications, additional software, and/or additional hardware in the form of Assistive Technology (such as the above noted Tekla Shield/App and the Griffin Mouthstick Stylus) are also essential elements that must be introduced at various points of the accessibility continuum.

Compliance to Paragraph 44 of the Accessibility Policy would therefore be achieved were WSPs to provide a handset device packaged with applications designed to facilitate accessibility to wireless services.

An example of this in terms of U.S. WSP service is the Sprint ID Pack (for the Android platform) available in the U.S., which enables customers to select and device packaged with specific applications, wallpapers and widgets tailored to the interests of an individual consumer. Partnering with AppsforAndroid and the U.S. Department of Education, Sprint has develop five “accessibility-themed ID Packs”, which enable customers with disabilities to purchase a device with a range of pre-loaded applications designed to enable access to a range of smartphone accessibility. There is no additional cost for the service. ^{Footnote 5}

In addition, Sprint and other carriers provide the “Mobile Accessibility” suite of screenreading applications for customers with vision disabilities, at no additional charge. Mobile Accessibility was developed by Code Factory, a U.S.-based accessibility software firm, for the Android platform. ^{Footnote 6}

2. Continuing absence of definitions, especially for accessibility.

The information presented in Table 1 above indicates that many or most accessibility needs with respect to the wireless system are met by existing applications and AT solutions, and by compatible handsets available in Canada.

However, the disability community points out that the current situation has evolved outside of any established definitions, standards and/or best practices. While WSPs note that there is no reason for accessibility features to disappear - and a likelihood that their availability will grow in number and functionality - the disability community notes that without established accessibility benchmarks or regulation, there is no guarantee for the continuing presence of accessible handset devices in the Canadian marketplace.

The disability community further points out that solutions have emerged in a more spurious, inconsistent and unpredictable fashion, and definitions based on an updated checklist of accessibility needs would better guide WSPs in their procurement practices.

This was also a key finding of the Neil Squire Study, which concluded:

• A lack of standards and definitions inhibits “any coordinated efforts on the part of wireless service providers, handset manufacturers and assistive technology manufacturers to design compatible products that have a reasonable product lifecycle”. ^{Footnote 7}

• “Market pull” by WSPs is an essential part of the accessibility eco-system, as handset manufacturers will be reluctant to implement certain features in the absence of “concrete orders from WSPs”. But given the lack of definitions, WSPs may differ in what defines “accessibility”. ^{Footnote 8}

• Procurement guidelines by the Canadian WSPs are required to ensure that these features and “more specifically the hardware and software interfaces in these devices will be supported by the manufacturers for the coming generations of new models”. ^{Footnote 9}

• For example, the USB-On-The-Go specification is currently only available on a small number of handsets and given the nature of product lifecycle in the industry, “without demand for this specification it will not remain in handsets for long”. ^{Footnote 10}

3. Increasing reliance on accessibility through smartphones.

Smartphones are clearly assuming a dominant position over feature phones in the marketplace. Some 62 percent of Canadian mobile subscribers reported owning a smartphone in 2013, an increase of 17 percent from the previous year.

This major growth has been largely driven by advancements in applications development - which has seen apps for persons with disabilities become something of a growth industry itself. These have included to date, iComm (picture and words app), Parking Mobility/GSP to locate parking for those with disabilities, Sign Smith ASL Essential/Lite (sign language application), and the Proloquo2Go speech communication assistant. Bio-Aid is a recent application that turns an iPhone into a hearing aid. Rather than amplify sound, the application replicates the biology of the human hearing system, allowing for a more targeted hearing experience. ^{Footnote 12}

New and more sophisticated applications for sign-to-speech/text conversion and speech/voice recognition to text are also in development, and rapidly progressing to the market stage.^{Footnote 13}

However, increasing reliance on smartphones for accessibility to the wireless system has at least two disadvantages.

First, while smartphones are greater accessibility enablers than feature phones, they are also more expensive. For individuals with disabilities and accompanying income restrictions, this can be an economic barrier to ownership.

In addition, there is an absence of a very basic smartphone in WSP inventories, which can be cost effective to own and at the same time, provide the necessary accessibility features and facilitate the required add-ons for persons with disabilities.

This in turn raises the second drawback to reliance on smartphones for access to the wireless system: as noted by the Neil Squire Study, rapid turnover in products can potentially remove accessible devices from the marketplace. In other words, a device with high quality accessibility features may be replaced with a device that is superior for the able-bodied but with inferior (or non-existent) accessibility features.

4. Continuing lack of a universal design strategy.

As pointed out by the Neil Squire Study, until universal design - i.e. a cycle of development and production that integrates accessibility into the initial design phase rather than relying on a time-consuming and costly retrofitting process - becomes more prominent, market pull factors will necessarily include both product lifecycle support strategies and structured consultations among all players in the value chain, including the disability community itself.

This is especially important with respect to the role of the AT community, as assistive devices are critical third party-developed elements of handset accessibility for those with (especially) mobility disabilities or cross-cutting disabilities. The disability community notes that AT can represent a significant investment by people with disabilities, and should not be made obsolete because of changes to accessibility in handsets (for example, as a result of changes to Application Program Interfaces (APIs).

As an example of the manner in which universal design has been incorporated into telecommunications processes including wireless, a case study on accessibility and innovation at AT&T sets out the key elements in establishing a culture of inclusion. This includes the development of a Voluntary Product Accessibility Template for use by suppliers in determining the relative accessibility of their products. ^{Footnote 14}

5. Effective lifecycle support for handheld devices.

As noted above, in order to ensure the on-going implementation of universal design in the wireless handset industry, the development of best practices in lifecycle support is essential. This is especially important in a system of product development and comparatively rapid turnover, in order to ensure awareness, understanding and market pull for innovation. This is explained in further detail below.

6. Effective consultations with user groups.

Users are best equipped to inform WSPs of continuing innovation in accessible design, applications, assistive technologies and the interaction among these. Given the importance of assistive technology in daily life, there is considerable awareness of technology development in the disability community. It is relatively easy to both establish and maintain a cycle of consultation with users, as explained in more detail below.

7. Potential limitations on handset availability from new market entrants.

A final, potential handset accessibility gap has less to do with devices and is more a function of spectrum allocation.

Newer mobile phone companies such as WIND and Mobilicity operate HPSA networks on the AWS band, which limits handset availability. Therefore, users with disabilities who require specific handsets for specific accessibility features may be more limited in their choice with these and other carriers as a result of spectrum issues.

However, WIND and Mobilicity have indicated the availability of various Blackberry and Samsung handset models in their inventories. WIND has further noted that it can assist iPhone 5S customers with reconfiguring their phones to operate on WIND’s mobile network.

8. An on-going challenge to develop an accessibility solution for severe mobility disabilities.

As a general observation, both the OCAD Study and the Neil Squire Study concluded that the most significant accessibility gaps with respect to mobile devices are experienced by individuals with severe to moderate mobility disabilities. The OCAD Study also found that more minor accessibility issues persist with respect to both visual and cognitive disabilities.

In addition, the need for a functional interface with a mouthstick stylus was noted by both the OCAD Study and the Neil Squire Study.^{Footnote 15} To this end, it is worth noting a few details about the Griffin Mouthstick Stylus AT solution.

First, user reviews of the Griffin Mouthstick Stylus are generally positive, with respect to its usefulness and functionality for moderate mobility disabilities.

In terms of limitations, user reviews note that the stylus has little in the way of colour contrast along its length, which means it can be challenging to determine at which point the stylus is about to touch the screen. For those individuals with a combined vision disability or low vision, this might prove to be problematic in using the device. ^{Footnote 16} A previous limitation - that the stylus was produced at a fixed length of 12 inches - has been eliminated, as it is now produced in a retractable format.

However, the mouthstick stylus solution is further limited with respect to accessing the various functions of smartphones for those with more severe mobility disabilities. That is, a certain amount of head/neck/shoulder mobility is necessary in order to swipe the screen. Those with severely limited mobility will be unable to do so with the stylus.

In terms of accessibility features and functionalities, scanning technologies (e.g. from Pretorian Technologies in the U.K.) have been developed for the Apple iOS7 Switch Control that simplifies access to device functionalities. More advanced solutions have also been developed for the Android platform and related devices, especially the latest generation of Samsung Galaxy handsets, although it is not yet known when these will be introduced to the Canadian marketplace. ^{Footnote 17}

As concluded by the Neil Squire Study,

For a good portion of people with moderate to severe mobility impairment, being able to connect to an external pointing device that accommodates their physical ability to a mobile phone would be an important step forward. There are only a few pointer cursor solutions available for mobile devices and unfortunately the trend toward touch-screen devices may endanger continuing support for this option. ^{Footnote 18}

(A pointing device is a cursor-specific Human Interface Device (HID) that allows a user to input select data to a device without touching that device. The most common pointing device is a computer mouse; rolling balls and joysticks are sometimes used as pointing devices by people with mobility disabilities. So are head-operated pointing devices. But the point made by the Neil Squire Study is that certain mobile device touchscreens cannot be accessed with a pointing device because they have no concept of a cursor - for example, devices on the iOS platform such as iPhones. While Apple devices provide a wide range of accessibility solutions, this presents a particular barrier to persons with mobility disabilities that might be addressed through procurement processes as set out in Part II of our Report below.)

The Neil Squire Study focused almost exclusively on accessibility needs for people with mobility disabilities, and the availability of design, software and hardware solutions to meet those needs. The gap analysis undertaken by the Neil Squire Study concluded,

Compared to what was available only a few short years ago the possibilities for making mobile technologies accessible have improved greatly. .. Both the assistive device developers and mobile phone manufacturers are very close to having the necessary connectivity elements built into their products that could enable the connection of external assistive input devices. ^{Footnote 19}

Part II - Facilitating Handset Accessibility - Best Practices

While gaps identified in previous research have been at least partly remedied through increased adaptation of accessibility features in next generation smartphones, it is important to note the methods through which mobile handset accessibility can be maintained: through continuing market solutions; through the development of best practices for lifecycle support for solutions; and through the development of best practices for on-going consultations among stakeholders in the value chain of product development, production and distribution.

Each of these measures would serve to facilitate WSP compliance with the Commission’s Accessibility Policy.

Continuing Market Solutions

As noted above, the wireless handset industry is characterized by innovation. In this sense, handsets are continuously modified and updated with new versions released in 12-month cycles. While older versions are not immediately rendered obsolete (owners often keep their devices for two to four years and/or trade them in when contracts expire), applications eventually enter the marketplace for the newest models of smartphones only. In addition, new models tend to have greater memory capacity and faster download speeds, among other features.

Nonetheless, for accessibility to the wireless system, continuing market solutions may reside more in applications and the actual handset. Similarly, Assistive Technology devices like the Griffin Mouthstick Stylus continue to enter the marketplace.

As an example of continuing markets solutions for accessibility, there had been concerns expressed in the past that cell phones were becoming smaller, posing additional challenges for persons with disabilities. However, recent product cycles have seen handset screens become larger; for example, the Samsung Galaxy handset to be released in 2014 has a 5.25” display screen. The 2013 Samsung Galaxy s4 had a 5” screen, the s3 a 4.8” screen and the s2 a 4.3” screen.^{Footnote 20} It is neither universal design nor accessible functions that are driving increases to screen sizes; rather, consumer demand has created an “electronic curb cut”, where consumer interest in larger screen sizes has an unintended curb cut consequence for users with disabilities. ^{Footnote 21}

A further example of continuing market solutions can be found in the above noted platform development for both Apple and Android, and potential accessibility solutions for those with more severe mobility disabilities. Various scanning technologies have been developed for the Apple iOS7 Switch Control platform, for the more extreme end of the mobility disability market.

Best Practices - Lifecycle Support for Solutions

With respect to lifecycle support for solutions, practices on this front vary between the WSPs, given a lack of formalized industry standards, and - as noted by a number of WSPs in their recent filings to the Commission - because the relative size of the Canadian wireless handset market is a considerable challenge to the ability of WSPs to exercise significant market pull with global manufacturers and influence their OEM decisions.

Nonetheless, in their February 2014 filings on accessibility measures, WSPs noted a number of initiatives with respect to lifecycle support within their companies.

First, WSPs request accessibility features from manufacturers, and consider it mandatory that manufacturers maintain those features of the course of a product lifecycle.

Second, WSPs are of the general view that, once an accessibility feature has been integrated into a handset’s design, it generally stays there in subsequent models. If it is removed - something that WSPs indicate they monitor closely - then the WSPs contact the manufacturer to ensure it is re-introduced or substituted with at least an equivalent feature.

Third, with respect to the accessibility features requested from manufacturers, WSPs have established (in consultation with user groups) a matrix of these features that serves as a checklist for their procurement processes.^{Footnote 22} This matrix is in turn based on the Global Accessibility Reporting Initiative (GARI), a project administered by the Mobile Manufacturers Forum (MMF) that has developed a checklist of accessibility features of mobile devices by accessibility need. (It is worth noting that the Canadian disability community considers the GARI checklist to be in need of updating. The primary concern is with the need to update MMF definitions of disability, and a lack of updated information on GARI with respect to the latest accessibility features to reach the market.)

Fourth, there is a general sense and considerable confidence among WSPs (which deal regularly with handset manufacturers) that accessibility features will not only be maintained, but improved over time (as has been the case over the past 18 to 24 months). This is because, in the highly competitive nature of the mobility industry on a global level, the major equipment manufacturers regularly update their platforms/operating systems - and the operating systems of most phones already contain built-in accessibility features.

Fifth and finally, as noted by one WSP, “Phones are now more about the software than the hardware.” More and more independent software and app developers are building new features for existing operating systems and systems currently in development. It is therefore anticipated - again, through procurement relationships, on-going communication and monitoring - that users will see further enhancements to the accessibility features of handset devices.

We note that, per the input of the WSPs to the CRTC in February 2014, the WSPs appear to differ from company to company in their approach to accessibility, in terms of staying updated on new features and applications, lifecycle support, and/or community outreach practices.

A number of cost-effective Best Practices have been outlined in previous research, with respect to lifecycle support for innovative products. At the core of these best practices is cooperation and active collaboration among various stakeholders in the chain of supply and demand is essential for supporting accessibility solutions for wireless devices (and in the case of that particular Study, more accessibility choice for people with mobility disabilities). ^{Footnote 23}

To this end, adopting the following Best Practices in lifecycle support would facilitate WSP compliance with Paragraph 46 of the Accessibility Policy.

1. Define core accessibility features and requirements on an industry-wide basis, in consultation with user groups, based on the Accessibility Policy.

This is essentially a benchmarking exercise, intended to establish a baseline of functionality already in the marketplace. The absence of consistently applied definitions is viewed by the disability community as a major barrier to on-going procurement of relevant devices.

2. Identification of accessibility features that will continue to support the range of AT required by users; identify technical specifications.

A second benchmarking exercise that would expand on the above noted definitions by engaging AT requirements, through discussion with AT manufacturers.

3. Integration of accessibility criteria into procurement specifications by WSPs.

Brings accessibility into the procurement checklist used by WSPs.

4. Regular, documented interaction with handset manufacturers that includes discussion/manufacturer response to procurement specifications

Outcomes of discussions with handset manufacturers would be brought into consultations with the Canadian disability community.

5. Identify and document which core accessibility features must be retained in future product cycles.

For example, USB On-the-Go creates a basic and easy migration path for existing AT solutions, but needs to be maintained in future product cycles. This in turn prevents effective solutions from becoming obsolete.

6. In the absence of a formal process for the development of industry-wide standards, WSPs work individually on definitions and procurement guidelines, but to the greatest extent possible and without divulging proprietary/competitive information, share these guidelines on an industry-wide basis, potentially coordinated by the Canadian Wireless Telecommunications Association.

The CWTA has a joint industry-user Accessibility Committee and has developed an information website www.wirelessaccessibility.ca. As such, the CWTA performs something of a role in coordinating the flow of information and organizing stakeholder discussions concerning accessibility. The above noted Best Practice would potentially fit well in extending the current role of the CWTA.  This Best Practice would involve an extension of this coordinating function.

7. Provide regularly updated information about products that meet the needs of specific disabilities.

Players in the supply chain can keep users informed of which devices are available with which accessibility features, and from which WSPS. For their part, WSPs would integrate this information into their websites.

The need for updated consumer information was noted in the Neil Squire Study, specifically about what types of AT are available to users, and which phones are compatible with which solutions. The Study noted that it is not practical for AT manufacturers to test their technologies with every mobile device on the market (some of which have a very short market life), so solutions are needed to provide consumers with up to date information about AT/phone compatibility and availability - and providing this information is the part of the WSP role. ^{Footnote 24}

There is also a need for providing updated information to developers, such as providing details on technical specifications of device accessibility features. One existing model is the Developer Program at AT&T, which provides extensive technical information to the developer industry.^{Footnote 25}

8. Establish a North American Accessibility Procurement Forum.

A roundtable consisting of representatives of key players in the wireless accessibility cycle: the user community, platform/product/app developers, handset manufacturers, WSPs, AT manufacturers and others. Such a forum would serve as a vehicle for discussion and provide up to date information on technology development while maintaining a focus on accessibility needs - and communicate on-going/prospective market solutions to all players.

The timing for this type of initiative is excellent, as the 21^st Century Video and Communications Accessibility Act (CVAA) requires equipment manufacturers to report on their accessibility initiatives, consultations with the disability community and accessibility features of their products on an annual basis. These annual reports could serve as a basis of discussion at the Forum and, in addition, could potentially be utilized by Canadian WSPs for their own procurement roadmaps.^{Footnote 26}

9. Take the steps necessary to update the Global Accessibility Reporting Initiative (GARI).

The disability community notes that GARI is outdated, and is therefore a questionable resource for WSP accessibility checklists.

Potential Outcomes of Best Practices in Lifecycle Support

The above Best Practices focus on the development of consistency and standardization of basic accessibility features in handsets. In the absence of this, the disability community has noted that WSPs will not realize the value of such AT solutions as USB On-The-Go without a broad “accessible procurement strategy” that is developed and implemented on an industry-wide basis.^{Footnote 27}

The Neil Squire Study also makes a case for lifecycle support through an “accessible procurement process”, arguing that WSPs will not know whether they have achieved the objectives of the Accessibility Policy without such a collaboratively developing such a process. For example, handsets with USB On-The-Go were only recently released into the Canadian marketplace; they provide access to a wide range of AT solutions. But the Study argues that WSPs will not realize the value of USB On-The-Go in the absence of an “accessible procurement strategy”.^{Footnote 28}

The Study describes the basic elements of an accessible procurement strategy in nine phases: ^{Footnote 29}

• Phase 1 - Opportunity identification (with respect to accessibility needs, as opposed to a business opportunity)

• Phase 2 - Define the customer characteristic and user cases for the new product or service

• Phase 3 - Define the product feature elements to meet customer expectations

• Phase 4 - Validate the market opportunity

• Phase 5 - Develop formal procurement guidelines and validation procedures

• Phase 6 - Create a third-party developer community

• Phase 7 - Marketing strategy

• Phase 8 - Customer support strategy

• Phase 9 - Product launch

Once again, the Neil Squire Study emphasizes the need for customer outreach once an accessible procurement process has been established by a WSP, including updated information on the WSP website, availability of information in an accessible format, training sales staff and Customer Service Representatives, and potentially developing relationships with AT players to assist with user enquiries.^{Footnote 30}

Key Gap in Current Lifecycle Support

If there is a perceived gap in the current practices of Canadian WSPs to build lifecycle support for devices, it is likely in the area of (i) creating standards definitions for accessibility and, further defining how these translate into handset accessibility, and (ii) relationships with the Assistive Technology sector. While such relationships may be, in the view of WSPs, best left to the manufacturing sector, it is likely worthwhile to build a knowledge base and maintain communication with the AT sector, which is a critical player in the provision of third party devices that must be functional with current and next generation handsets. This is especially important in addressing any lingering gaps in handset accessibility for those with mobility disabilities.

Best Practices - On-going Industry/Community Consultations

On-going consultations with the user community are an essential part of standardizing accessibility features and ensuring the retention of core features in future handset models. There a number of cost-effective Best Practices that can contribute to the development of a consultation model; adopting the following measures would facilitate WSP compliance with Paragraph 46 of the Accessibility Policy.

1. WSPs identify an Accessibility Officer, with expertise and decision-making influence in product development, engineering or other technical field.

This formalizes responsibility for stakeholder outreach within each WSP, while raising the profile of accessibility within individual companies.

Ideally, WSPs would further identify a member of their executive or senior management to serve as an accessibility champion who would bring discussions and decision-making to a senior level (in much the same fashion as broadcasters have assigned responsibility for diversity initiatives and best practices to members of senior management).

2. Establish a forum for WSP Accessibility Officer discussion and interaction.

This enables continuing discussion and sharing of information between WSPs, e.g. on a quarterly basis. Identify a Chair for the group.

3. Establish responsibility for outreach to national user organizations.

Key users groups are typically national organizations representing people with disabilities. One potential model is to have the Chair of the WSP Accessibility Officers assume responsibility for outreach to national organizations.

At the same time, WSPs with regional presence would communicate with provincially-based user groups.

4. Establish a WSP/User Group Forum, comprised of Accessibility Officers and representatives from key user groups.

The Forum would serve as the central conduit for discussion and the exchange of information between WSPs and users.

It has been a longstanding concern of the disability community that delegates to this type of forum or working group are rarely if ever compensated for their participation and their expertise. The model for the WSP/User Group Forum would ideally provide a modest stipend in exchange for the experience and expertise of representatives from disability organizations.

5. Establish a protocol for outreach to the handheld device industry and the AT sector.

This formalizes a consultative element to a strategy for device/AT lifecycle support.

6. Use the Forum as a conduit for providing information to consumers, leveraging user group presence and communication platforms (e.g. user group websites, publications, Accessible Media Inc. (AMI) etc.) and WSP customer service practices (e.g. Customer Service Representatives, website pages, etc.).

This delivers a consultative element to consumer outreach; specific consumer information initiatives can circle back to the Forum for discussion and refinement.

7. Building Effective Stakeholder Relationships.

In general, a number of the above noted best practices work to build and positively sustain industry/stakeholder relationships. Specific to WSPs and the disability community, best practices can focus on demonstrations of commitment and follow-up from both sectors:

• One or more executive champions for accessibility from the WSPs that would remain actively engaged in Forum activities

• WSP representatives with decision-making influence or authority, and representatives from the disability community with the mandate to act for their constituents; in other words, solid leadership from each sector

• Determining the consensus nature of the Forum from Day One

• Providing some form of compensation for disability groups lending their experience and expertise to the process

• Implementing a 360 process that would specifically assign tasks and responsibilities to companies/groups/sub-committees, which would then report back to the Forum at large

• Longevity - the Forum would become a structurally integrated part of the Canadian wireless industry, requiring stated long-term commitments from each sector

• Creating a variety of process-related elements that would drive the Forum forward in a cohesive manner, e.g. establishing a mandate, vision and/or goals; setting priorities; writing a strategic plan; establishing clear expectations for each sector.

8. Measuring Success

Success can be (and needs to be) measured using a number of methods that would be established by the Forum membership. One basic measurement would be to identify whether specific goals - for example, short-, medium-, and long-term objectives - have been fully or partially achieved. These objectives can in turn be high-level (maintaining/growing membership) and much more granular (e.g. implementing an accessibility checklist in the procurement practices of all WSPs, with an associated timeline for completion).

Potential Outcomes of Best Practices in Industry/User Group Consultation

A national-level forum comprised of representatives from industry and the disability community creates a conduit for on-going communication between the two sectors, while allowing dialogue and consensus-building on what is possible (and what is not) in terms of procurement practices, the retention of accessibility features and other elements of device lifecycle. It also formalizes a more consultative approach to strategies on lifecycle support while providing an additional support mechanism for communicating to consumers.

Key Gap in Current Consultations

The CWTA Accessibility Committee currently serves as the forum for industry/ user group consultation. While a number of WSPs indicate their participation on the Committee, its mandate, activities and membership are uncertain at present. If the Committee were to serve the function of the above-noted forum, it would require the full participation of Canadian WSPs and national-level disability organizations, together with assigned leadership (e.g. a Chair), CWTA secretariat support and the development of a consensus-based strategic plan.

Conclusion

We conclude that Canadian WSPs are at least partly compliant with Paragraphs 44 and 46 of the Commission’s Accessibility Policy.

With respect to Paragraph 44 - offer and maintain at least one type of wireless mobile handset that will provide access to wireless service by persons who are blind and/or have moderate-to-severe mobility or cognitive disabilities - WSPs generally provide a handset that meets specific accessibility needs. However, handsets themselves may not on their own enable end to end accessibility, but play a key role in supporting required apps and/or third-party Assistive Technologies.

With respect to Paragraph 46 - consult with parties representing persons with disabilities and provide lifecycle support for handsets - WSPs have some measures in place that would be facilitated by establishing Best Practices in stakeholder consultation and lifecycle support, together with continuing market solutions for accessibility needs.

It is evident that a number of accessibility gaps persist, that the above noted Best Practices would address in a number of cases.

• There is a need for “enhanced” wireless accessibility, through apps and third-party Assistive Technologies supported by handheld devices

• Continuing absence of definitions, especially for accessibility

• Increasing reliance on accessibility through smartphones

• Continuing lack of a universal design strategy

• Effective lifecycle support for handheld devices

• Effective consultations with user groups

• Potential limitations on handset availability from new market entrants

• An on-going challenge to develop an accessibility solution for severe mobility disabilities

Best Practices in Lifecycle Support for Solutions include:

• Define core accessibility features and requirements on an industry-wide basis, in consultation with user groups, based on the Accessibility Policy

• Identification of accessibility features that will continue to support the range of AT required by users; identify technical specifications

• Integration of accessibility criteria into procurement specifications by WSPs

• Regular, documented interaction with handset manufacturers that includes discussion/manufacturer response to procurement specifications

• Identify and document which core accessibility features must be retained in future product cycles

• In the absence of a formal process for the development of industry-wide standards, WSPs work individually on definitions and procurement guidelines, but to the greatest extent possible and without divulging proprietary/competitive information, share these guidelines on an industry-wide basis, potentially coordinated by the Canadian Wireless Telecommunications Association.

• Provide regularly updated information about products that meet the needs of specific disabilities.

• Establish a North American Accessibility Procurement Forum.

• Take the steps necessary to update the Global Accessibility Reporting Initiative (GARI)

Best Practices in Industry/Community Consultation include:

• WSPs identify an Accessibility Officer, with expertise in product development, engineering or other technical field

• Establish a Forum for WSP Accessibility Officer discussions and interaction

• Establish responsibility for outreach to national user organizations

• Establish a WSP/User Group Forum, comprised of Accessibility Officers (with decision-making influence) and representatives from key user groups (with the mandate to represents their constituents)

• Establish a protocol for outreach to the handheld device industry and the AT sector

• Use the Forum as a conduit for providing information to consumers, leveraging user group presence and communication platforms (e.g. user group websites, publications, etc.) and WSP customer service practices (e.g. Customer Service Representatives, website pages, etc.)

• Employ a number of initiatives to establish and maintain effective working relationships between the sectors, highlighting mutual commitment to a process that becomes structurally integrated within the Canadian wireless industry

• Establish effective methods of measuring success, from high-level to more detailed, based on consensus goals and strategies for achieving these objectives

The above noted measures would ideally combine to ensure the continued presence and evolution of sustainable solutions to wireless mobile accessibility, requiring the active and continued participation of all players in the chain of supply and demand.

Appendix A - Resources

• Able Data

• AFB Access World Magazine - Accessible Apps for Android device

• Appadvice.com - Applications for the Blind on Apple Devices

• Apple - Accessibility - Third Party

• AT&T Developer Program

• Canadian Radio-television and Telecommunications Commission (CRTC), Broadcasting and Regulatory Policy CRTC 2009-430, Accessibility of broadcasting and telecommunications services, July 21, 2009

• Carter, Paul (2013) “Product Review: Griffin Mouthstick Stylus” Disability Now July 8, 2013.

• Cisler, Amy and Kristine Osmond, “Choosing a Smartphone” Assistive Technologies Seminar, 2013

• Code Factory (2013) Mobile Accessibility Android

• Comscore (2013) Canada’s Digital Future in Focus

• CONNECTUS Consulting Inc. (2012) The Evolution of Alternative Communications Technologies for the Deaf, Hard of Hearing and Speech Impaired

• Disability Horizons (2013), The Best Apps for People with Disabilities

• G3ict (2011) “Case Study: Accessibility, Innovation and Inclusion at AT&T”

• Global Accessibility News, Smartphone App turns iPhone into a Hearing Aid, April 3, 2013

• Griffin Technologies

• International Business Times, February 11, 2014 “Samsung Galaxy s5 Release Date”

• Lew et al, Creating an Accessible Mobile Handset Eco-System: The Associated Life Cycle Issues Neil Squire Society (the Neil Squire Study);

• Sprint (2013) “Commitment to People with Disabilities”

• Sprint, January 12, 2012 “AppsforAndroid Expands Mobile Offerings”

• SSB Bart Group (March 2014), Android Accessibility Properties and TalkBack

• SSB Bart Group (June 2012), The Mobile Accessibility Landscape

• Treviranus et al, Mobile Wireless Handset Accessibility Assessment Inclusive Design Research Centre, OCAD University (March 2011) (the OCAD Study)

• YouTube, Pretorian Technologies device for the Apple iOS7 Switch Control

• The study also reviewed the February 2014 filings to the CRTC from Wireless Service Providers, which outlined their respective compliance with the CRTC Accessibility Policy.

Appendix B - Report Author

This Report was researched and authored by Richard Cavanagh, Partner, CONNECTUS Consulting Inc. Dr. Cavanagh has over 20 years of experience in researching and analyzing Canada’s communications industries, with a specialized focus on social policy and accessibility issues. He has recently completed research on the evolution of technology in the broadcasting and telecommunications industries.

Dr. Cavanagh holds a PhD in Social Sciences from Carleton University and an M.A. in Sociology from Queen’s University.

CONNECTUS Consulting Inc.
251 Loretta Avenue South
Ottawa, Ontario
K1S 4P6

613-729-8892

Richard@connectusinc.ca

Date modified:

2014-10-08