In the matter of

CG Docket No. 10-145
Assessment of Barriers to Accessible Mobile Technology

12 October 2010

For further information, contact:

Dorrie Rush
Marketing Director for Accessible Technology
Lighthouse International
111 East 59th Street
New York New York 10022

My name is Dorrie Rush and I am Marketing Director for Accessible Technology at Lighthouse International. Lighthouse International was founded in 1905 and dedicated to fighting vision loss through prevention, treatment, advocacy and empowerment.

For some time now we have been communicating to telecom companies and mobile phone manufacturers about the need for built in accessibility options in mobile phones as a standard not an exception. As the world grows increasingly dependent on the use of cell phones for everyday tasks such as emailing, paying bills, searching for information on the internet, or increasingly for entertainment, mobile phone use is a paramount function in our daily lives, and will become ever more so in the years ahead. For this reason it is incumbent upon the cell phone industry to universally incorporate accessibility features into every product manufactured. Apple’s iPhone is a great example and proof that the key for all great products is --- Universal Access.

The addition of iPhone 3GS accessibility features Zoom and Voice Over (September 2009) was an enormous step forward, and a product that people with a visual impairment have long sought. Apple was not compelled by legislation, court order, or agency regulation, yet has set the standard for which all other companies should now aspire. Unfortunately many do not, and people with a visual impairment have been left with only one option for accessible cell phone service. The iPhone represents a fully accessible mobile device straight out from the box- something no other carriers provide. Despite the built in accessible features of the iPhone, its high pricing, considering a population that does not have great means to purchase, represents a major barrier to access.

Still the iPhone is a model for an accessible device with four essential components that should be required in all mobile devices as follows.

  1. Third party software. Third party software is an expensive addition that people with a visual impairment must purchase in order to make most mobile devices accessible. The high cost of special software is a major barrier to accessibility for people with visual impairment and it rarely works well and is available only in a small number of phones. The iPhone has proven that accessibility features built into the phones hardware are far more functional that third party applications.
  2. Enlarge, bold, and contrast capability. The iPhone provides important features for people with a visual impairment, such as the ability to enlarge or bold print, as well adjust the contrast of the on-screen text. This feature is critical to accessibility of mobile devices and provides versatility for people with varying degrees of visual impairment.
  3. Voice recognition. Voice activated applications which are built into the iPhone, also provide a much needed accessible feature for all mobile devices. This feature, we know, can be beneficial to everyone, but especially important to those who cannot see the screen.
  4. Speech Enabled On Screen Menus. Speech enabled on screen menus provide people with a visual impairment the software necessary to easily navigate through their mobile devices. Without accessible on-screen menus most mobile devices prove virtually inaccessible.

By expanding the number of products, and carriers that incorporate universally accessible features, people with a visual impairment will no longer have to rely on expensive third party software or be limited to one phone, provided by one carrier. I strongly urge the commission to require in its rule making the inclusion of these four basic components for all mobile devices and help to increase access to mobile devices for people with a visual impairment.



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