Nearly two years ago hundreds of blind persons wrote to the Access Board
with their experiences and problems using automatic teller machines that
had no speech functionality.  A few days ago the United States Access
Board issued draft final guidelines that explicitly call for talking
ATM's.  Thanks to everyone coming together on this one, we did it,
despite industry pressure and opposition.  As can be seen from the
article below, industry now accepts access for blind persons as fair and
reasonable.  this fall, the Access board is expected to publish the
guidelines in the Federal Register.  Then, it is up to the Justice
department to publish final regulations that would implement access.  As
described below, the most significant issue upcoming in this forum will
likely be the time frames for when the ATM access rules will take effect.

Kelly



atmmarketplace.com


ATM industry welcomes new ADA draft

by Ann All, editor .
11 April 2002

The ATM industry spoke and  the federal government seems to have
listened, based on the Access
Board's final draft of its proposed revisions to the ADA Accessibility
Guidelines (ADAAG).

"I think (the Access Board) tried to be accommodating and did a good job
of understanding what is truly a complex thing," said Nessa Feddis,
senior counsel, regulatory affairs for the American Bankers Association
(ABA).

Rob Evans, NCR's director, industry marketing, seconded Feddis' opinion.
"While we didn't get everything we might have liked, we feel that the
Access Board did a good job of listening to our concerns," he said.

"Most, actually almost all, of what's contained in the document is
consistent with the direction we're moving toward as a company and, I
believe, as an industry," said Alan Looney, director of terminal
engineering, Diebold North America.

ATM industry representatives, advocacy groups and others provided comment
after the Access Board published its first set of proposed changes to the
ADA/ABA, which has been in effect since 1992, in November of 1999. While
a final draft was expected last summer, the Access Board continued to
gather feedback until October of 2001.

There has been a great deal of industry confusion and consternation about
what would be required of ATM manufacturers, networks, deployers and
others. The draft does seem to clear up at least some of the major
issues, Feddis said.

Noting that there has been some "justifiable reluctance" on the part of
the industry to incorporate changes that might not comply with eventual
regulations, she said, "At least now, I think we can get into the
planning stages. This isn't going to happen overnight, as I think we've
seen by what some of the large financial institutions (who have already
introduced audio-enabled ATMs) have gone through."

Now hear this

As expected, the draft includes a requirement that ATMs be speech
enabled. However, Feddis said, the Access Board presented this
requirement in a "flexible format" that will likely encourage innovation
as the ATM industry moves forward on adding audio to machines.

"Speech shall be delivered through a mechanism that is readily available
to all users including, but not limited to, an industry standard
connector or a telephone handset. Speech shall be recorded or digitized
human, or synthesized."

Access Board final draft of proposed changes to ADAAG released April 2

According to the Access Board's final draft, released last week, "Speech
shall be delivered through a mechanism that is readily available to all
users including, but not limited to, an industry standard connector or a
telephone handset. Speech shall be recorded or digitized human, or
synthesized."

The wording leaves several options open to vendors, an important
consideration given the varying capabilities of different makes and
models of ATMs and the diverse needs of deployers.

"We wouldn't want to have to use the same solution on our CashSource Plus
200 cash dispensers as we do on our high-end ix ATMs," Diebold's Looney
said.

Noting that there have been many advances in audio technology since the
first voice-enabled ATMs were deployed, Looney said flexibility will
allow deployers to adopt the methods that work best for them.

Several deployers, for instance, have used voice synthesis software to
create WAV files, an option not available until recently. Looney said the
combination of voice synthesis and WAV results in a more natural-sounding
voice than can be produced with voice synthesis alone, yet avoids the
hassle and expense of hiring live "talent" to record WAV files.

Included in the audio requirement, according to the Access Board's final
draft, are operating instructions and orientation, visible transaction
prompts, user input verification, error messages and all displayed
information for full use.

Taking exception

The draft makes several key exceptions, however. Perhaps the most
important, Feddis said, is the Access Board's stipulation that dynamic
information such as account balances will not have to be audible on
machines that do not support speech synthesis. While most new ATMs
support voice synthesis, the majority of legacy ATMs do not.

The ABA is "very excited" about this exception, Feddis said. "The
technology obstacles to offering dynamic information on an ATM without
voice synthesis are significant."

NCR's Evans agreed that this exception showed that the Board had
considered information provided by NCR and other manufacturers on the
technical difficulties of audio enabling older ATMs based on IBM's OS/2
platform.

"I think it will be incumbent on the industry to perform in good faith as
technology continues to evolve," Evans added. "As it becomes easier to
integrate text-to-speech engines into Windows-based platforms, then I
think we better darn well start offering dynamic speech."

"We are excited about the continuing evolution of these guidelines as
this will mean that all deployers will need to get involved in providing
accessible ATM services."

Bank of America spokesman Brad Russell

The exception isn't entirely clear cut, however, and may just shift the
debate to what entails a machine capable of voice synthesis, Looney said.

"Offering voice synthesis is the sum of all of the various parts,
including terminal hardware, software, processing power and network
support," he said. "All of those parts have to come together for it to
work."

Bank of America spokesman Brad Russell said all of his institution's 465
audio ATMs are in compliance with the proposals detailed in the draft.
According to Russell, the bank is using several advanced capabilities,
including voice synthesis (the Bank of America ATMs do provide audio
account balances) and volume control.

"We are excited about the continuing evolution of these guidelines as
this will mean that all deployers will need to get involved in providing
accessible ATM services," Russell said. "Non-banks in particular have
been lagging the banking industry badly in this area. People complain
about our ATM fees, but we do invest back into the services for which we
charge."

Other issues

The Access Board draft addresses several other ATM accessibility issues
in addition to the requirement for audio.

Both Evans and Looney welcomed the Access Board's move away from a set of
highly detailed keyboard specifications to more general guidelines. The
final draft includes a requirement for specific tactile symbols on keys,
such as a raised circle for "enter" and raised left arrow for "clear,"
but it omits earlier requirements for specific key colors, sizes and
spaces between keys.

It would have been difficult to install the originally proposed keyboard
in most legacy ATMs, Looney said.

Another requirement specified in the draft is the lowering of maximum
height for side reaches from 54 inches to 48 inches. While Evans said NCR
can change the reach on its machines, he doesn't agree with the
adjustment.

"I think it's important to balance the needs of individuals approaching
the machine from the lower end of the profile against those people
approaching from the higher end of the profile, such as scoliosis
patients who have had rods inserted into their spine," Evans said. "In
the end, I think (the lower height requirement) will create more problems
than it will solve."

Moving forward

According to the ABA's Feddis, the Access Board's final draft will now be
considered by the Department of Justice, which will ultimately enforce
any revisions to ADAAG. Before adopting any changes, the DOJ will seek
additional public comment, a process that could take up to another year.

Answers to two of the most hotly-debated questions, when deployers will
be expected to comply with new guidelines and which if any existing
machines will be grandfathered, will be addressed by the DOJ, Feddis
said.

"The Access Board has answered the how, now it's up to the Department of
Justice to decide the when and the where," she said.


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