Legal/Technical Architectures of Cyberspace

Universal Access and Universal Service: Ensuring Usability and Affordability

Team Members
Matamba Austin
Peggy Chen
Jeff Doering
Hazel-Ann Mayers
Lars Oleson
Serrin Turner
Nadia Vinson
Executive summary by Peggy Chen
Oral presentation by Lars Oleson


"In a competitive global economy, our country does not have a single person to waste, opportunity must be open to everyone. I believe our entire nation will share in the economic and social benefits that will result from full participation of Americans with disabilities in our society."
-- President Clinton, 12/1/1992

Introduction

Society has an interest in maximizing the number of people engaged in activities such as communication, commerce, information retrieval and political participation to promote a global economy and uphold the principals of free speech and democracy. These goals are most efficiently and effectively accomplished in cyberspace. As a new form of communication that permits information and knowledge to flow across boundaries endlessly, the Web has emerged as the medium of choice for information exchange.

Cyberspace provides the opportunity to develop an information infrastructure that will connect people of all ages and descriptions - bringing them opportunities to interact with businesses, government agencies, entertainment sources, and social networks. Whether or not this chance is realized depends largely on interfaces - technologies by which people communicate with the computing systems [1]. The challenge to society is to ensure access to communication and information resources for every member, regardless of age, physical ability, race or ethnicity, education, ability, cognitive style, or economic level. The obstacle is therefore twofold: to ensure universal access and universal service.

Approximately 20% of the US population have some type of impairment or functional limitation. People with disabilities encounter barriers of all types, but obstacles such as mobility, hearing, speech, vision, and cognitive impairments should not be the limiting factor that prevents them from benefiting from opportunities in cyberspace. "Universal access" addresses these issues by promoting the usability of technologies to ensure that no one is left behind in the pre-internet era.

Physical and cognitive disabilities are not the only barriers that threaten to exclude certain groups from cyberspace. Poverty is a significant barrier as well. What can be done to dissolve the "digital divide" that presently separates the technology "haves" from the "have nots"? The "universal service" concept aims to resolve these questions and provide everyone with an opportunity utilize the benefits in cyberspace at an affordable price.

Just as "universal access" addresses the question of how to make cyberspace more usable, "universal service" addresses the question of how to make cyberspace more affordable. This paper will examine both issues. First it will evaluate the technological and legal aspects of universal access in the past, present and future highlighting the tradeoffs encountered when promoting advanced technologies and the externalities that arise from universal access measures. Then it compares accessibility issues in real space versus cyberspace and looks at how the problem is being address today and suggests how to approach accessibility issues in the future. Finally, this paper will review the origins of the universal service concept in the telephone industry and examine how the idea carries over into the context of the national information infrastructure.

Universal Access

Universal Access Technology

Background of Universal Access in Real Space

Universal access is not a foreign concept to society. In real-space, newspapers and publications were initially only available in a visual mode. This excluded customers who were visually impaired until auditory or Braille options were made available. Auditory impaired individuals were excluded from real time communication using auditory-mode-only telephones. It was not until TTY was developed that they could communicate live. Historic evidence demonstrates that society recognizes the need to ensure all members equal opportunity to communication and information exchange.

Manufacturers of technology do not always factor universal access into their designs. Usability is usually addressed in retrospect after recognizing the detrimental impact to a significant percentage of the population. After realizing that the hearing impaired could not fully benefit from the television broadcasts, closed captioning was developed. However, the late implementation meant the transition to closed captioning was expensive and slow, and at least at first, of dubious quality and availability. Retrofitting is an expensive expenditure that can be avoided with proper forethought. The actual costs of physically installing ramps, elevators, and other ADA mandated accommodations is much higher after the building is complete than when included in the initial construction.

In all the aforementioned instances, the price was paid and the lessons were learned. Better practices now help the disabled and are further complemented by externalities that benefit the rest of society. Closed captioning serves as a great tool to learn English as well as a handy alternative for tuning in to the content broadcasted in a noisy environment. Likewise, ramps are useful to movers with cars and mothers with strollers. Real space provides a model for universal access from which we can learn. The lack of designs that factor in accessibility results in barriers that are costly to break down in retrospect. These fundamental lessons should be carried over into cyberspace.

Transition from Realspace to Cyberspace: Cyberspace Changes Accessibility

Cyberspace presents new challenges to universal accessibility that cannot be resolved using existing technologies developed in real space. New forms of communication increase the means of information dissemination, but the trade-off for more advanced features and functionality results in a decrease in usability and a reduction in the audience served.

Postal and telephone services provided increased functionality resulting in the necessity to deliberate efforts to maintain accessibility. New technologies such as electronic mail and Internet telephony once again offer new benefits. They too threaten the accessibility to communication systems and require new efforts to ensure universal access.

HTML opens the door to complex web sites with graphics and interactive content. However, these aesthetic designs fail to work with existing solutions such as screen readers and Braille printers developed during the text only era. Although some users benefit from the improved functionality, the overall number of users decreases because many people with impairments can no longer access the content under the new presentation medium.

Cyberspace mandates a new approach to dealing with universal access issues. Taking into consideration the inefficiency of merging old technologies with new technologies when there is no backward compatibility, the opportunity exists now to look ahead and make improvements for the future. Cyberspace is not real-space, but the lessons learned from real-space are valuable. Just as universal access was addressed from scratch in real space, the same must hold true for cyberspace.

The Present : Retrofitting to Catch-up

Cyberspace introduces problems that previously did not exist. Since it renders existing solutions useless in many cases, additions and add-on packs are being developed to make cyberspace backwards compatible in hopes that screen readers will not become completely useless. The race to achieve universal access through retrofitting is a costly process that may never end because makers of adaptive technologies cannot keep up with the constant changes in the cyberspace.

The W3C recognizes the barriers created by the Web and is committed to developing authoring guidelines that will provide a high degree of usability to the disabled. Their Web Access Initiative is an attempt at breaking bad web authoring habits by educating users on how to comply with usability standards. If accessibility had been designed into HTML by making certain features such as ALT tags mandatory, retrofitting costs of trying to change old habits could have been reduced if not eliminated.

Most adaptive technologies were not designed to work with graphical user interfaces (GUIs) and Web browsers. Many text-only screen readers are available, but very few are compatible with cyberspace. Jaws 3.2 for Windows is one of the only screen readers that can "reformat complex web pages and list links alphabetically in an easy-to-use list box" [4]. However, this feature only works when using Internet Explorer 4.01 and may not work with future browsers.

Accessibility application programming interfaces (APIs) offer another solution to problems created by GUIs. By providing information about on-screen content to accessibility software in a uniform manner, APIs reduce the burden on accessibility software. However, they are being retrofitted onto existing software because it is a relatively new feature. Like in real-space, retrofitting remains a costly solution that will be functionally insufficient as newer technologies develop.

As new technologies develop, more retrofitting will be required in hopes of providing universal access. This process is costly, arduous, and does not guarantee access to all in the long run. Current practices must change to prevent one fifth of our society from participating in the common mode of communication.

The Future : A New Look at an Old Problem

The cost efficient solution to universal access in the long run places the burden on technology developers. By factoring accessibility into their initial designs, the unending retrofitting costs will be saved. Some sectors of industry are trying this new approach, but their success remains to be determined as their products face challenges imposed by the market, norms and legislation.

Extensible Markup Language (XML) is an improvement over SGML which provides more control of document content and will be most likely replace HTML as the code behind the web. With XML, it will be easier to design accessible pages that are aesthetically pleasing, thereby foregoing the trade-off that HTML possesses of choosing between ease and functionality. More control may entail a more time consuming design process, but the initial time spent will be time and money saved in the long run and a benefit to the entire society.

In the multimedia arena, SMIL and SAMI provide standards for on-line videos that will accommodate closed-captioning-type text and additional accessibility accommodations such as DVS, Descriptive Video Service. The potential for accessible media exists and its benefits must be utilized and instated by all common practices. By including the accommodation capability in the standard at inspection, the costs of retrofitting a large installed base will be avoided.

The accessibility APIs discussed earlier offer strong potential for the future. If included in new products from the beginning, retrofitting problems will be avoided. Widespread use of such APIs can dramatically increase the accessibility of software and provide adaptability to other computer environments such as mobile equipment. Because these APIs hold such promise, finding a method to achieve widespread support is an important concern.

The goal is therefore to educate the public on the why universal access is important, the benefits and externalities it creates and how they can readily achieve it with available technology. "Technological advancement only provides a competitive advantage for a short time; superior design and manufacturing doing it right for the customer and quickly the first time ensures true economic advantage in a customer driven, global economy." [1] Universal design practices must start immediately to avoid future retrofitting costs.

Universal Access Legislation

As cyberspace becomes the dominant platform for information exchange, the law must keep pace with the developing changes and not fall behind during this progression. Laws that address universal access in the context of real space exist, but they do not address the needs of cyberspace. Modifying existing will not achieve the desired outcome in the short or long run. Universal access legislation must be focused on the technology of today in the cyberspace realm to protect the rights of disabled persons.

In passing the American Disabilities Act, the government acknowledged the need to remove barriers of access in real space. Requiring ramps in buildings provides accessibility to many individuals with mobility impairments. This imposed an extra expenditure to renovate existing buildings, but it saved money in the long run and society is still benefiting from its externalities. Ramps have since been beneficial to mothers pushing strollers, rollerbladers and bikers.

Society's concern for the less fortunate in the realm of real space, as demonstrated in the community's willingness to comply with the ADA, should extend to the context of cyberspace. Statues demonstrating public concern in the cyberspace arena include Section 255 of the Telecommunications Act of 1996, Section 706 of the Telecommunications Act and Section 508 of the Rehabilitation Act Amendments of 1998. While the intent of these legislation support the concept of universal access, the means in which it attempts to achieve this end is insufficient or flawed.

Cyberspace imposes new challenges on accessibility that lawmakers did not encounter in real-space. Legislation that was geared towards the pre-internet world may no longer be applicable. The original intent of the ADA did not specifically address the Internet. However, the Department of Justice has issued an opinion stating that Title II and II of the ADA extends to the Internet. The fact that no cases have been brought pursuant to the DOJ opinion points to the shortcoming of this law. A more effective approach would be to scribe a completely new law specifically addressing the needs of the disabled in cyberspace.

Although laws exist in writing, they will not be truly effective without strong implementation by agencies. The government is unwilling to pressure the market under Section 255 because it may view a hands-off approach as the best means of ultimately attaining accessibility. However, such an approach does not force the industry begin making the changes necessary to ensure accessibility in the future. Unclear and vague definitions entail self-regulation that may lead to a delay in the consideration of accessibility issues during the design and development phases. As the statutes and agency guidelines only require accessibility where it is readily achievable, it is conceivable that the disabled community may be unable to take advantage of current and future technological advances which will be readily available to the rest of the cyberspace community.

Constantly modifying old laws to make them applicable to new developments will be a legislature's eternal nightmare because the desired results will not surface. To ensure universal access, legislation addressing cyberspace must not piggyback off of real-space laws. Instead, the situation must be thoroughly evaluated from scratch. Cyberspace deserves an equal treatment and attention in comparison to real-space. A clear understanding of how norms, markets, code and law affect universal access in cyberspace will pave the path to effective legislation and a more united society.

Universal Service

History

The idea of universal service originated as a justification for the Bell telephone monopoly when Theodore Vail, the chief architect of the Bell System, envisioned "one policy, one system, and universal service." [5] Congress drafted the idea into law with the passage of the Telecommunications Act of 1934. The effort was largely a success: by 1993, 94% of homes had telephone access, compared to only 35% in 1934.

Current Developments

Cyberspace offers new forms of communication that all members of society should be able to afford to access. The Telecommunications Act of 1996 codified universal service into law and expanded its scope by mandating discounts for "advanced telecommunications services" for schools and libraries. Moreover, it created an "evolving definition" of universal service, which the FCC may expand from time to time as telecommunications technology progresses. This Act also changes the universal service funding mechanism by requiring all telecommunications providers, as opposed to just telephone carriers to contribute to a Universal Service Fund, from which subsidies for universal service are to be drawn from.

Significant problems surround the treatment of Universal Service under the 1996 Act. First, the FCC may have exceeded its authority in requiring telecommunications carriers to subsidize advanced telecommunications services for schools and libraries. Second, requiring telecommunications providers to incur the costs of subsidizing universal service distorts prices, thereby interfering with competition, while the overall thrust of the 1996 Act is to promote competition. Third, given the rapid evolution of telecommunications technology, new industries will constantly emerge that do not fit neatly into the category of telecommunications service providers. "Bypass" problems are sure to result, as these industries will enjoy a competitive advantage over their competitors, who have to contribute toward the Universal Service Fund.

Future Possibilities : Proposals for Change

Universal Service applied in the context of cyberspace can be broken down into three goals: computers, telecommunication services, and on-line content must each be made available at affordable prices.

The solution to making access to computers affordable is twofold. First, market forces can be expected to drive down the costs of personal computers and to lead to the development of cheaper computing devices, such as NetPCs and Internet appliances. Second, the government can provide a sort of technological "safety net" by making computers available for free public use at "community access centers," such as schools and libraries.

The solution to making telecommunications affordable is twofold as well. First, a vibrant telecommunications industry can be expected to create low-cost means of providing services to those who traditionally have been hard to serve. For example, wireless technology in the form of "rooftop networks" and Internet radios may solve the problem of serving customers in rural or central city areas. Second, community access centers can offer free access to the Internet; however, funding for the necessary telecommunications links would best be drawn directly from general tax revenues, rather than passed onto telecommunications providers, as is done under the 1996 Act.

Finally, universal service requires that on-line content be affordable - a problem that does not exist now, but may arise in the future as increasing numbers of content providers charge for their services. The facilitation of price discrimination in cyberspace would enable all persons to purchase content at prices they can afford. This solution would draw upon the resources of code, the forces of the market, and limited intervention by the government. It may also require changes in social norms.

Conclusion

Both universal access and universal service are concepts that have previously been addressed in real space successfully. As new forms of communication develop in cyberspace providing a new information infrastructure, these issues need to be addressed immediately to avoid retrofitting costs and to ensure that all members of society are benefiting from the transition to cyberspace.

Real space provides a good example of one way of dealing with universal access and service, but because fundamental differences exist between the two spaces, technology and law are not transferable from one realm to the other. Nor can they be modified and patched to fit the other space.

The key to a successful universal access and service plan in cyberspace requires a careful analysis of the technological and legal elements of cyberspace. Only when there is a clear understanding of how markets, code, law and norms affect cyberspace, will universal access and universal service be achieved.

References

[1] More Than Screen Deep: Toward Every-Citizen Interfaces to the Nation's Information Infrastructure, National Research Council, National Academy Press, Bookstore, Description,

[2] Susan Brummel, People with Disabilities and NII: Breaking Down Barriers, Building Choice, excerpted from The Information Infrastructure: Reaching Society's Goals Report of the Information Infrastructure Task Force Committee on Applications and Technology, U.S. Department of Commerce, 1994

[3] Working Together: People with Disabilities and Computer Technology,

[4] JAWS 3.2 for Windows,

[5] Universal Service Policies for the Public Interest Sector, Susan G. Hadden,

[6] Inquiry on Universal Service and Open Access Issues; NTIA. 1994. Notice. Federal Registar Notices Vol. 59, No. 180, 48112-48121


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