Below are my comments to the Access Board regarding the proposed rules for
automatic teller machines. I will list the proposed guidelines first
followed by the full text of my comments. If you want to skip directly to
the comments, simply search for a line of asterisks.
kelly
707 Automatic Teller Machines and Fare Machines
707.1 General. Automatic teller machines and fare machines
required to
be accessible shall comply with 707.
Advisory 707.1
If farecards have one tactually distinctive corner they may be
inserted with greater ease. Token collection devices that are
designed
to accommodate tokens which are perforated can allow a person
to
distinguish more readily between tokens and common coins.
Place
accessible gates and fare vending machines in close proximity
to other
accessible elements when feasible so the facility is easier to
use.
707.2 Clear Floor or Ground Space. A clear floor or ground
space
complying with 305 shall be provided.
EXCEPTION: Clear floor or ground space is not required at
drive-up
only automatic teller machines.
707.3 Operable Parts. Operable parts shall comply with 309.
Each
operable part shall be able to be differentiated by sound or
touch
without activation.
EXCEPTION: Drive-up only automatic teller machines shall not
be
required to comply with 309.2 and 309.3.
707.4 Input. Input devices shall comply with 707.4.
707.4.1 Privacy. The opportunity for the same degree of
privacy of
input shall be available to all individuals utilizing the
equipment.
707.4.2 Key Surfaces. All keys used to operate a machine shall
be
tactually discernible. Key surfaces shall be raised above the
surrounding surface by 1/25 inch (1 mm) minimum. The outer
edge of key
surfaces shall have a radius of 1/50 inch (0.5 mm) maximum.
EXCEPTION: The touch areas of video display screens shall not
be
required to be tactually discernible.
707.4.3 Separation Between Keys. Any key surface shall be
separated
from other key surfaces by 1/8 inch (3.2 mm) minimum. Function
keys
shall be separated from numeric keys by a distance that is not
less
than three times greater the distance between the numeric
keys.
707.4.4 Numeric Keys. Where provided, numeric keys shall
comply with
707.4.4.1 and 707.4.4.2.
707.4.4.1 Arrangement. Numeric keys shall be arranged in a 12-
key
telephone keypad layout with the number one key in the upper
left hand
corner.
707.4.4.2 Marking. The number five key shall have a single
raised dot.
707.4.5 Function Keys. Where provided, function keys shall
comply with
707.4.5.
707.4.5.1 Arrangement. Function keys shall be arranged in the
order of
enter, clear, cancel, add value and decrease value
horizontally from
left to right or vertically from top to bottom. Where
provided, add
value and decrease value function keys shall be grouped with
other
function keys.
707.4.5.2 Marking. Function keys shall be marked with tactile
characters as follows: Enter or proceed key: raised circle;
Clear or
correct key: raised vertical line or bar; Cancel key: raised
ex; Add
value key: raised plus sign; Decrease value key: raised minus
sign.
707.4.5.3 Color Coding. Where function keys are color coded,
they
shall be colored as follows: Enter or proceed key: green;
Clear or
correct key: black; Cancel key: red; Add value key: blue;
Decrease
value key: yellow.
707.5 Output. Output devices shall comply with 707.5.
Advisory 707.5
Speech output should be supplied for all displayed text and
labels.
For information which is presented in non-text form (e.g., a
picture
or graphic), consider using a verbal description unless the
graphic is
just decorative. When speech output is utilized, allow for the
spoken
message to be repeated if the message is very long.
707.5.1 Privacy. The opportunity for the same degree of
privacy of
output shall be available to all individuals utilizing the
equipment.
707.5.2 Transaction Prompts. All transaction prompts within
each
operation shall be provided.
707.5.3 Input Verification. Verification of all user inputs
shall be
provided.
Advisory 707.5.3
An audible beep may be used to indicate that personal
identification
numbers have been entered.
707.5.4 Operating Instructions. Machines shall provide visual
and
audible instructions for operation. Visual and audible
instructions
shall include all information required by 707.5.4.
707.5.4.1 Initiation. Instructions shall be able to be
initiated by
the user of the machine.
707.5.4.2 Expedited Process. After initiation, instructions
shall be
available for the experienced user to expedite the transaction.
707.5.4.3 Orientation. Orientation and assistance for
unfamiliar users
to the physical features of the machine, operational options,
and
details for each function shall be provided.
707.5.5 Audible Instruction. Audible instructions shall be
provided
through a standard audio mini jack, a telephone handset, a
wireless
transmission system or another mechanism that is readily
available to
all customers.
707.5.6 Video Display Screen. The video display screen shall
comply
with 707.5.6.
Advisory 707.5.6
For video display screens required to be accessible, the
screen should
be visible and usable by persons standing and sitting.
707.5.6.1 Visibility. The screen shall be visible from a point
located
40 inches (1015 mm) above the center of the clear floor space
in front
of the machine.
EXCEPTION: This requirement shall not apply to drive-up only
automatic
teller machines.
707.5.6.2 Characters. Characters displayed on the screen shall
be in a
sans serif font. Characters shall be 3/16 inch (4.8 mm)
minimum in
height based on the uppercase letter "I". Characters shall
contrast
with their background with either light characters on a dark
background or dark characters on a light background.
707.5.7 Dispensing of Bills. Machines that dispense paper
currency
shall dispense the currency in descending order with the
lowest
denomination on top.
707.5.8 Receipts and Verification. Where a receipt is
available and is
requested, the following options shall be provided: a printed
receipt,
audible presentation of the transaction information provided
on the
receipt, or both.
***************************
Office of Technical and Information Services
Architectural and Transportation Barriers Compliance Board
1331 F Street, NW.
Suite 1000
Washington, DC 20004-1111
ATM Accessibility Comments
9 May 2000
Below are comments from me, Kelly Pierce, in response to the proposed accessibility
guidelines in Section 7.07 for automatic teller machines.
I am a blind computer user and co-founder of digit-Eyes: the Chicago Blind Computer
User Network. Digit-Eyes is the largest user group of end users of assistive technology in
the United States. Additionally, I serve on the techwatch committee for the National
council on Disability, advising the agency on technology policy relating to people with
disabilities. Further, I am engaged in structured negotiations with Bank One Corporation
regarding usability of its ATMs for blind persons. Bank One is the fourth largest bank in
the United States with nearly 2,000 bank branches and more than 7,000 ATMs.
The proposed regulations are a significant step forward in ensuring access and equality to
financial services for blind persons and those with print impairments. The Access Board's
desire to enact ATM guidelines that specify the means for obtaining the goal stated in the
present regulation in Section 4.34.5 in the ADA
Accessibility Guidelines for automatic teller machines to have "Instructions and all
information for use. . . " to be made ". . . accessible to and independently usable by persons
with vision impairments" is appreciated and will build upon the Access Board's vision of
independent usability for all machine functions necessary for use.
Information Transaction Machines
One issue that the Access Board itself raised was the application of the proposed guidelines
to ATMs exclusively or to other transaction machines. Without question, it is entirely
feasible to provide independent usability for blind and other print impaired persons to
access information transaction machines. However, the same provision regulating the access
to both machines cannot support maximum access to both devices without compromising
the regulation so as to be overly vague and general.
It is laudable for the Access Board to seek to ensure that not only today's technology is
accessible but tomorrow's is as well. Extended deployment of electronic commerce, the
blending of financial services, and increased automation of the business sector are indeed
trends that suggest not only hybrid technology beyond the scope of the regulation but a
need to ensure that the public space of the digital economy is as accessible as the bricks and
mortar economy. The lines between an atm, point of sale terminal, and an information
kiosk are slowly blurring with features of each appearing in the next generation of ATMs.
Specifically, the next generation of ATMs and increased automation of the service
sector demand that the Access Board develop guidelines for information transaction
machines in addition to automatic teller machines.
Touch Screens
Section 707.4.2 specifies requirements for the size of key surfaces and that keys must be
"tactually discernible." At the same time, the Board proposes exempting "the touch areas
of video display screens" from being "tactually discernible." The advisory makes it unclear
if the Board wants to exempt touch screens altogether from the regulation or require tactile
borders around the touch areas. The advisory suggests that the proposed regulation does
not apply to touch screens. However, Section 707.3 requires each operable part to be able
to be differentiated by sound or touch without activation. This section clearly encompasses
touch screens and Section 707.4.2 should be written similarly to encompass touch screens
as well. Currently one of the nation's largest banks, Citibank, uses ATMs with touch
screens. It is conducting a pilot test of five ATMs with touch screens in California that
speak the contents of the video display to the blind end user. Specifically, the Access
Board should eliminate the touch screen advisory and replace the word key with the
word mechanism so that "all mechanisms used to operate a machine shall be tactually
discernible."
Human Body Contact
When considering access to touch screens, it is important to consider other disabilities as
well. Some devices require capacitance and do not simply require touch but the touch of
the human body to activate functions. Those with upper extremity prosthetics, such as
artificial hands or arms, and those that use assistive technology, such as reachers or head
or mouth sticks, would not be afforded access to ATMs in a touch screen environment if
the proposed regulations are adopted. Specifically, the Access Board should add a
section that prohibits capacitance and any other mechanism that requires human body
contact to operate machine functions.
Cancel Key Location
Section 707.4.4.2 calls for the numeric keys to be identified only by a consistent layout like
a 12-button telephone keypad. Additionally, Section 707.4.5.1 requires all function keys to
be grouped together. This proposal is a deviation from the current key layout on many
atm's, where the zero key is next to a cancel key on the bottom row of keys. The current
design allows someone to enter and correct numeric data without taking the hand from the
entry pad. The proposed guidelines would prohibit placing the cancel or any other key next
to the zero key. The finite detail of this requirement is government micromanagement at
its worst. The proposed guidelines already require a spoken orientation, which presumably
will include a description of key layout. The ATM industry is in the best position to
determine the efficiency and convenience of numeric and cancel key layout for its tens of
millions of users. Changing key layout from the current standard already in place on
hundreds of thousands of machines may cause more confusion than access, including among
those with disabilities. Specifically, the Access Board should place an advisory
following Section 707.4.4 stating that a cancel key may be placed next to the zero
key.
Key Mapping
The efficacy of grouping all function keys together and only providing tactile symbols to
certain functions is highly questionable for today's ATMs. Many machines have as many
as eight function keys that have uses different from those described in the regulation. A
better way to provide access to the dynamic uses of function keys has been employed on
all talking ATMs to date. This involves mapping all function keys to the numeric keypad
when it is feasible. This ensures the user has a consistent key entry location and all
functions can be entered through numeric voice prompting. Specifically, the Access
Board should place an advisory following Section 7.4.5 that recommends key mapping
when the machine offers 10 or fewer choices on the video display.
Braille Labels
These specific regulations also call for tactile markings on the function keys and on the
number five key that are not Braille. In fact, the regulations do not call for Braille
markings of any kind. It may be argued that the majority of blind people are not Braille
readers. The same argument is advanced about the proposed tactile identification system
for ATM functions: most blind persons are not familiar with what the tactile symbols
represent. Braille offers an international standard that has been in existence for nearly 70
years with many readers and a world-wide teaching network. Additionally, most ATM
manufacturers already use Braille to label keys and identify ATM functions. Braille already
offers the ability to label and identify keys and deliver orientational instructions directly on
the machine itself. Specifically, the Access Board should add a new section requiring
the current industry practice of using Braille for key identification and orientation
information.
Alphabet and Multiple Function Keyboards
The Access Board assumes that the functions of enter, clear, cancel, add value, and
decrease value will remain the functions in place for the next decade. Such thinking is
limiting as it does not contemplate increased functionality and new capabilities that
machines in the future will offer. The key mapping proposal above offers a limited
solution. With a number of function keys, a nominator key has been employed on
technology for the blind beginning with the first reading machine for the blind in 1976.
When the nominator key is pressed, the user can press any other key for it to be named by
voice without activation. The design was developed by Ray Kurzweil and a group of blind
engineers and the concept is still employed in reading systems for the blind today. The
concept recognizes the limited retention of providing highly detailed and complex
orientation information at the start of use. Further, the regulation does not address the use
of an alphabet keyboard for entry of letters and more complex data, as some ATMs could
be connected to the World Wide Web in the future for online banking or electronic
commerce. Specifically, The regulation should require that a qwerty keyboard layout
be used if an alphabet keyboard is employed and the use of a nominator key to
identify keys.
Voicing of All Information
It is troubling that the proposed regulations could be read as requiring less information to
be accessible than the current regulations. The regulations specify only transaction prompts,
imputed information, instructions, and orientation information as being required to be
voiced or presented audibly. The proposed regulation could very easily be interpreted as
not requiring the machine to speak other kinds of information, such as surcharge
explanations and error messages. The end user with a print impairment will not know
whether the transaction cannot be completed because the user pressed a wrong key, not
enough money is in the account, or the machine is not working altogether. If an ATM
operator narrowly interprets the proposed regulations as needing to speak only transaction
prompts and not the information needed to make a decision about the transaction, the
machine will likely speak only "please make your selection." The blind end user will have
no ability to understand what he is selecting or the nature of the transaction. If the
proposed regulation is adopted, it could be argued that no text needs to be spoken except
for prompts, input verification, and instructions.
The regulation should be changed to require voicing of all information necessary to use the
machine. The current regulation at 4.34.5 requires that "Instructions and all information for
use shall be made accessible to and independently usable by persons with vision
impairments." Although general in nature and not specific as to the means of providing
access, this language makes clear that essentially all information displayed on the video
monitor needs to be conveyed to the blind person. This simple but highly encompassing
statement has so far resulted in three of the nation's largest financial institutions--Bank of
America, Citibank, and Wells Fargo--committing to install thousands of talking automatic
teller machines in the next three years. Additionally, it has provided the entre to other
financial institutions to negotiate the deployment of talking ATMs. The Access Board must
unequivocally advance the expectation that audio output is to be provided to allow people
with vision impairments to independently access all the functions that a sighted person can
access and perform at the particular location. The failure of the proposed regulations to
make such a simple statement about the machine as a whole that is found in the current
guideline may result in limited access to machine functionality.
Making the speaking of certain kinds of information optional is similar to making optional
that access needs to be provided in all spaces of a public accommodation for people with
mobility impairments. The Access Board has taken the position that partial access to newly
constructed buildings is unacceptable and it should apply the same standard to information
access and people with print impairments. The Access Board neglects entirely to ensure
that all information needed to use the machine is voiced by the machine. The goal of
equality and equal access for people with disabilities demands that all of the information
needed to use the machine is available for the blind person to access, not just what the
members of the Access Board want to parse out to the blind person. Very specifically
then, the Access Board must without question carry forward and incorporate into the
final rule the current standard at 4.34.5 that requires that "Instructions and all
information for use shall be made accessible to and independently usable by persons
with vision impairments."
Machines With Different Functions
The proposed scoping requirements at 220.1 fail to consider developments in ATMs in the
past decade. Specifically, the proposed regulation states that "Where automatic teller
machines or self-service fare vending, collection, or adjustment machines are provided, at
least one machine of each type at each location where such machines are provided shall
comply with 707." The proposed regulation language focuses on machines, not all of the
combined functions and services of the machines at a particular location. The number of
ATMs and other machines providing automated services has grown immensely from 10
years ago when the current guidelines were written and upon which the proposed guidelines
are based. Many locations have more than one machine and the different machines often
offer different services. With multiple machines at a given location, the scoping
requirements fail to consider the maximum operational use of the ATM services at that
location. If two ATMs were at the same location and one allowed deposits and cash
withdrawals and the other only cash withdrawals, it could be argued that the ATM owner
or operator need only make the machine performing cash withdrawals accessible, as only
". . .one machine. . . at each location where such machines are provided shall comply with
707." Specifically, the Access Board must require that all functions available at a
location are accessible.
Hours of Use
With so many machines in use today, locations now have ATMs in different environments
with differing hours of availability at the same location. A bank branch could have ATMs
in a bank lobby, inside the bank itself, and in drive up bays. The proposed scoping
requirements could allow the talking ATM to be placed inside the bank and available only
during hours that the bank is open with teller service rather than inside the bank lobby,
which has ATMs available 24 hours a day for customer use. These scoping requirements
defeat the purpose of ATM access entirely. Specifically, the Access Board must require
that the machine made accessible be available for use the same number of hours as
non-accessible machines.
Indoor Placement of Machines
Further, the scoping requirements could be read as allowing the talking ATM to be placed
anywhere at the location, even outside at a drive up ATM in the middle of automobile
traffic. The bank in the example above could put the talking ATM outside at a walk up
location or in one of its drive up bays and be in full compliance with the scoping
requirements. Blind persons greatly rely on their sense of touch to perform many daily
tasks, including differentiating keys on an ATM or telephone. The scoping requirements
could be read as allowing installation of talking ATMs outdoors at a location when other
ATMs that offer the same services and are available for the same hours at the same
location are available in a heated, enclosed area indoors. Tactile sensitivity is significantly
reduced in below freezing and sub-zero weather, creating a barrier to ATM access that can
easily be avoided. Specifically, the Access Board should issue an advisory with the
scoping requirements recommending placement of the talking ATM indoors when all
other conditions are the same.
Location Definition
Consider further that blind people do not drive. Introducing blind pedestrians into
automobile traffic in sub-zero weather so they can use a talking ATM when other
pedestrian accessible ATMs are available during the same hours is beyond the pale of
comprehension. At the same time, it is rather common for drive up machines at a
particular address to be available 24 hours a day while walk up machines at the same
address are available for limited hours. Conditions and service environments among
different machines at an address can be so unique to turn them into different locations.
Specifically, the Access Board must clarify the term "location" to ensure that ATM
access is achieved at significantly different service environments at the same address.
This proceeding presents the Access Board with the opportunity to recognize and address
the changes in the ATM industry and the unique issues likely to be faced when talking
ATMs are introduced. The scoping requirements must be modified to ensure pedestrian
availability of talking ATMs, access to all functions, and access to ATMs at all hours at all
locations when they are available to nondisabled persons. These potential barriers exist in
today's ATM landscape. If the potential scoping barriers are not remedied, the
potential reality of the problem will devolve into a near certain eventuality once
talking ATMs are introduced.
Repeatability of Messages
An optional feature that should be required is the ability to repeat a spoken message. The
proposed standards listed as an advisory in Section 707.5 only allow for the spoken message
to be repeated "if the message is very long." This proposal assumes that all machines will
have audio output that can be clearly and completely understood at all times and the
machines will always be in quiet locations without the user ever being interrupted during
a transaction. This is of course not the reality for ATM users and print impaired persons.
Some people may have no or little experience using an atm, audio output of appliances or
both. New users may need to read a message over a second time to be certain of their
selection. ATMs are located in countless locations in a variety of environments, including
in busy retail establishments and outdoors. These locations have variable noise levels that
result in audible information being difficult to hear at times. It is a common occurrence to
not be able to hear every word spoken in a telephone conversation in a tavern or at an
outdoor public telephone. People can be distracted or interrupted in their transaction by
others. The ability to have all spoken output repeated is not simply a nice feature that
should be added but a fundamental feature in implementing an accommodation strategy for
ATMs. The issue is not the length or complexity of the text that may need a second read
but the ability, as nondisabled users have, to read any text again because of a number of
reasons that necessitate it. Specifically, the Access Board should require machines to
repeat a spoken message at the user's request and eliminate it as an advisory.
Extended Time
Coupled with the ability to repeat a message is the issue of extending time to complete a
transaction, which the Access Board asked responders to discuss. Sufficient time must be
available for the entire message to be spoken and the end user to input a response. If a
user does exceed time allotments, the user should be prompted for more time rather than
having the entire transaction canceled. After more time has been given, the user should be
returned to the place in the transaction before time expired without needing to re-enter
data previously entered. Otherwise the user will be in a continuous loop unable to enter
the total amount of data to complete a transaction. Similarly, if the end user requests
information to be repeated, the time allotment should begin again without canceling the
transaction or restarting at a beginning prompt. Specifically, the Access Board must
require that machines provide additional time to enter data without canceling
transactions, starting at a beginning prompt or requiring the user to re-enter data.
Volume Control
The proposed guidelines fail to provide volume control at accessible ATMs. Many would
be excluded from accessing the talking ATM by the proposed regulation because the
machine voice may be too quiet overall for them to hear, particularly at outdoor and retail
locations. Incorporating volume control into the final rule will open access to talking ATMs
to deaf-blind persons and those who are hard of hearing with vision impairments. The
Electronic and Information Technology Access Advisory Committee convened by the Access
Board to make recommendations for the federal government's purchase of technology
recommends that incremental volume control with output amplification up to a level of at
least 97 Db SPL with at least one intermediate step of 89 dB SPL be provided. If the
machine has the possibility of exceeding 120 dB SPL, the EITAAC suggests a mechanism
be included to automatically reset the volume to a safe level after every use for the safety
of other users. Specifically, the Access Board must incorporate into the final rule a
requirement for volume control with a minimum and maximum output level.
Voicing of Graphical Content
Another problem with the 707.5 advisory is the approach taken to information presented
graphically in a non-textual way. The advisory states that text and labels should be spoken
but nothing in the guidelines defines what a label is. For example, it is fairly common for
the logos of credit cards to be displayed instead of the words "Master Card" or "Visa." The
pictorial presentation of a charge card is as much a label as the name of the card in text.
Interpreting symbols and graphics are essential to the interactive use of the machine. The
word "decorative" is ambiguous and may be applied to many graphical elements necessary
to be interpreted to make interactive decisions with the ATM. Specifically The Access
Board should eliminate the phrase "just decorative" in the advisory and replace it
with the phrase "not necessary for machine use."
Expedited Process
Section 707.5.4.2 calls for an expedited process for instructions. It is unclear what is meant
by this provision. Some might interpret this provision to mean that a shorter, and
presumably faster, instruction set be delivered to the experienced end user and ATM
networks must track blind end users by experience level so as to be able to deliver
expedited instructions to them. Many people familiar with talking ATMs view the issue of
an "expedited process" as interruptive. If a user is familiar with most transaction prompts
and screen messages, he can quickly move on to the next menu of options by making a
selection while the machine is talking. This ability to interrupt, or bypass, any spoken
message allows the blind end user to complete the transaction much more quickly than a
new user. The proposed regulation applies the expedited process requirement only to
instructions and not prompts of any kind. Few experienced users would actually listen to
specific instructional and orientation information on a regular basis, which is why
interruptive ability of all spoken messages is important. Additionally, applying the
regulation only to instructions is problematic. Some might argue that prompts that guide
the user on what to do next is instructional while others will likely interpret the definition
of instructions more narrowly to mean a specific set of process statements. Specifically,
the Access Board must state clearly in the final rule that an expedited process means
a process that is interuptable, and it should apply the standard to all spoken messages
because it maximizes access and usability and eliminates ambiguity and confusion.
Single Means for Private Listening
Section 7.5.5.1 specifies how a particular kind of information should be delivered.
Conceivably, a single machine could require the user to use multiple means to listen to the
information, as the regulations do not require specific means or a single means be used on
a machine. Specifically, the Access Board should specify that a single means for
private listening be used on a machine.
Human Assistance
The regulations do not specify whether the audio output will be provided through
technology universally designed into the machine or delivered through human assistance.
Some large ATM operators have the ability to walk the user through all of the screen
sequences as they can display a particular machine configuration on their system. It is
conceivable that the blind end user could be connected to a centralized call center by a
telephone that is either wireless or at the machine so that a sighted person can read the
contents of the screen display by simulating the ATM session. The proposed regulations,
even viewed as a whole do not clearly state if such an approach would be considered access.
The limitations of the human assistance approach are obvious. Cellular telephones have
limited coverage. There are micro-locations, often a few hundred feet square, where
interference is so great that cellular service does not function. Cell phones need
maintenance, battery replacement and repair. Even if the difficulties of cell phones were
eliminated, as with corded telephones, there are limitations to using human assistance. Call
centers can become busy, people may be placed on hold for long periods of time, staff may
not be trained to use technology to view ATM screens or be knowledgeable about providing
this specialized accommodation. Using technology on the machine itself to read the video
display ensures full usability of the machine and eliminates the numerous human errors that
would result in a denial of access. Specifically, the Access Board must state in the final
rule that voicing of information on the display screen of the ATM must originate
from the machine itself.
Private Listening Methods
The proposed regulation at Section 707.5.5 offer the possibility of four options for private
listening: a standard audio mini jack, a telephone handset, a wireless transmission system
or another mechanism that is readily available to all customers. Knowledgeable experts
with whom I have consulted report that there is no wireless transmission system available
now or likely in the foreseeable future that can transmit data from an ATM screen to the
blind end user. Such systems are a number of years away and providing the flexibility for
such a system or related audio delivery method not yet invented or conceived of will only
delay access as ATM operators spend time and resources considering and possibly
experimenting with unproven and untested technology. Simply requiring a handset or mini
jack will not only meet access needs in a cost effective way but provide clarity and
direction. Specifically, the Access Board should only require private listening through
a standard audio mini jack or a telephone handset.
Audible Instruction
Section 707.5.5 refers to methods for delivering audible instructions. It is clear the Access
Board intends this section to include all of the voice output of the machine. However,
some may interpret the word "instruction" quite narrowly to mean a limited series of process
statements on how to use the machine rather than the entire audio output needed for
machine use. Specifically, the Access Board must delete the word "instruction" and
replace it with the word "output" in Section 707.5.5 to eliminate any confusion with
the Board's intent.
External Speakers
Section 707.5.1 requires that "the opportunity for the same degree of privacy of output shall
be available to all individuals utilizing the equipment." Further, Section 707.5.5 lists specific
methods for delivering audible instruction. Many owners and operators of not only
automatic teller machines but self-service fare vending, collection, or adjustment machines
may interpret these provisions as requiring only a headphone jack for audio output. There
is no requirement for an external speaker, or any other stand-alone means to hear the audio
output, so a blind person can use the machine without carrying around a headphone set.
The Access Board creates barriers to independence when it requires blind persons carry
around a headphone simply to ride mass transit, go to the movies, or wash clothes at a
laundromat, where purchasing fares, tickets, or tokens can only be done by machine in some
locations. When the Access Board applies the requirements equally to teller, fare, and
vending machines, high standards of privacy and security expected in handling large
amounts of cash or very personal financial transactions are applied to common daily
activities using small amounts of money, such as paying a $1.50 transit fare. Many transit
properties provide an external speaker to deliver synthetic speech so that blind persons can
purchase fare media from fare vending machines. The proposed regulation would require
private listening of audible information and allow transit agencies and others to eliminate
the voicing of visual displays unless one takes a headset to the subway station. Expecting
end users to carry around headphones to access fare, vending, collection or adjustment
machines is not only unduly burdensome but custodial, as members of the Access Board
have placed themselves in the position of dictating what lifestyle blind persons should live
in their own neighborhoods. Specifically, the Access Board should revise Section
707.5.5 to require, at a minimum, an external speaker in addition to a private
listening option at all self-service fare vending, collection, or adjustment machines.
External Speakers on ATMs
Automatic teller machines present similar accessibility concerns. In drafting the proposed
regulation, the Access Board rightfully considered issues of privacy, safety, and security
when it required that ATMs provide a means for private listening. While the proposed
regulation does not prohibit audio output to be available through a handset, an external
speaker or other means that do not require the user to supply a headphone, it does not
require such access either. The regulation denies access to ATMs when the blind end user
fails to bring a headphone with them to use the ATM. Such access is critical when a blind
parent is at a 24-hour pharmacy to get a prescription drug for a sick child or someone needs
cash immediately to purchase a bus ticket to see a dying relative. In the ideal world, these
and other users could have planned ahead, kept a headphone in their coat pocket, or used
a credit card. The real world outside Washington, D. C. conference rooms is different.
With an unemployment rate exceeding 70 percent, most blind persons live in poverty,
limiting access to credit or debit cards. Planning and thinking through one's accommodation
needs is important, but planning and general practice can be difficult in an emergency. A
stand alone solution for audio output is needed to ensure access to cash in times of
emergency or significant need. This could be accomplished through an external speaker or
a handset. It might be argued by some that an external speaker on an ATM places the
blind person at increased risk of crime victimization. Such an argument assumes that the
blind are incapable of conducting their own assessment of risk as non-disabled persons do
when deciding to use an ATM at certain locations or during certain hours of the day. The
blind are not little children in need of supervision and management of their lives. They are
independent adults and public policy must be fashioned to provide the blind with the same
opportunity to access services as those without disabilities. Specifically, the Access Board
must require a stand alone solution to listen to audio output in addition to providing
an earphone jack to ensure access to cash in times of emergency or significant need.
Receipts
Section 707.5.8 pertains to access to information printed on receipts. ATMs are beginning
to offer more functions than simply transferring funds, making deposits, and withdrawing
cash. ATMs are printing out coupons, tickets, and financial instruments such as money
orders in addition to transaction receipts. We are entering an era of synergies and increased
automation where the ATM may perform multiple functions. It is important to ensure
access to other materials printed by ATM machines in addition to receipts. The section
only covers receipts when one "is available and is requested." It is unclear if the Access
Board will require the option of an audible presentation of the receipt if the receipt is not
specifically requested by the end user. It will be argued by some that the contents of a
receipt will not be spoken if it is automatically printed upon completion of the transaction.
Again, this proposed policy limits access rather than promotes it. The contents of items
printed by an ATM will be available only in audio in a very limited number of transactions.
Specifically then, the Access Board should modify Section 707.5.8 should read:
"Where a receipt, coupon, ticket, or machine-printed matter is available for a sighted
user, the same information shall also be available for a vision impaired user, at the
user's option: a printed receipt, audible presentation of the transaction information
provided on the document or both."
Screen Blanking
There are additional items the Access Board should consider that were not included in
either the proposed ATM guidelines or questions the Board asked of responders. One of
these issues includes screen blanking, or the switching off of the video display once speech
is activated. Some have recommended this approach in designing an accessible ATM for
the blind. Providing the option for the screen to remain on ensures that a diverse number
of users can comfortably and easily use the atm. Newly blinded persons who are
unaccustomed to reader assistance, let alone artificial speech, can follow the speech while
reading the information from the video monitor with a magnifier. Others may use the
speech to confirm information on the monitor. Persons with learning disabilities often find
that comprehension of information is increased when two modes of communication are used
instead of one, such as reading and listening to the information at the same time. For these
users it could be argued that effective communication to them as mandated in Section
36.303 of title III has been denied. Requiring that the blind end user can keep the monitor
on during the transaction allows for a choice of access methods. If the concern exists that
others might view the contents of a screen without the knowledge of the blind end user,
non-technology options remain available. Explanations of what information is displayed
and how someone can block viewing by others can easily be incorporated into machine
orientation and instructions. Orientation and instructions of the machine can describe when
sensitive information, such as account balance or withdrawal amount, is displayed. The
blind person can move closer to the machine or place his hand over the monitor to block
views. Specifically, the Access Board should require that the video monitor remain
on during an ATM transaction if the end user so desires.
Biometrics
Another issue is that of biometrics. These are biological forms of user identification, such
as iris scanning, retinal
scanning, voiceprint analysis, and fingerprint scanning. The proposed regulation is silent on
this issue, but one bank is currently conducting a pilot test of an iris scanning system. Those
who cannot see because their eyes have been removed or those without hands, fingers, or
a voicebox need to have an
alternative form of identification that does not require the user to posses particular
biological characteristics. Specifically, the Access Board should require a card
identification with keyboard pin entry If biometrics are used.
I appreciate the opportunity to guide the Access Board in creating communities in which
people with disabilities can participate fully in a universe of accessible financial services.
With the proposed guidelines, the Board has gone an incredible distance to making one of
the most widely used financial services, automatic teller machines, available to the blind.
Now the Board must complete the journey by adopting suggestions in this response to its
proposal to fully liberate the blind and provide equality.
Kelly Pierce
Chicago, IL
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