E-reader makers request exemption from accessibility standards

[elf]

Only indirectly related to fandom (I know plenty of fen who've switched to ereaders for much of their reading), but strongly related to accessibility: Amazon, Kobo and Sony are requesting that the FCC exempt dedicated e-readers (PDF) from the requirement to be accessible.

"The public interest would be served by granting this petition because the theoretical ACS ability of e-readers is irrelevant to how the overwhelming majority of users actually use the devices," it says, as if any accessible features were granted because those were how the majority used them.

It goes on to say "E-readers simply are not designed, built, or marketed for ACS, and the public understands the distinction between e-readers and general-purpose tablets." I... have my doubts about that, especially since e-reader manufacturers work really hard to imply that there's no difference, just BW e-readers and color e-readers.

Most of the functions that would require ACS don't exist on many ereaders; I don't agree that means the rest of them shouldn't require it. I suspect this is a ploy to get Kindles into schools without having to be accessible to students with disabilities. Possibly, though, it's exactly what it says it is: an attempt to allow browsers and social media software on limited-use devices without holding them to the same standards as phones and tablets.

ETA1: changed link to the FCC page with embedded PDF.

ETA2: There's a request for comments that last through THIS MONTH. Comments Due: September 3, 2013

"Comments and oppositions are due within 30 days from the date of this Public Notice. Reply comments are due within 10 days after the time for filing comments and oppositions has expired."

Comments

[jesse_the_k]

That's totally horrifying.

Your "sneak it into the schools" is totally correct. (Think of the money school districts can save if they don't have to buy, store, repair textbooks!)

Advocates for people with print impairments made a loud noise on this matter when Princeton University proposed to equip their students with an Amazon Kindle DX. That was the first e-reader one could reasonable use to read a PDF. (Of course, reading a PDF with speech output requires doing OCR first, which is probably outside the reach of the cheap chips in the e-readers.)

One of the petitioners in that suit was the National Federation of the Blind, and that previous link takes you to their extensive Kindle coverage — including "how well the Kindle app on iOS, Mac OS, and Windows works."

[elf]

Ereaders won't be able to do OCR, but almost all commercially-produced PDFs have searchable text and would work with voice readers. (The Kindle's TTS doesn't work on PDFs, but that's Amazon's choice; several other ereaders have TTS that works on both epub and PDF files.)

They want a pass on having to provide accessibility for their limited web-browser functions (including, presumably, access to their ebook stores), and I'm guessing they want to use that as a wedge to get into schools--"Look, we already don't need accessibility on the web functions; that means we don't need to come up with a voice-based or braille-compatible navigation system!"

On the one hand, I can see some appeal; there are libraries that buy Kindles and loan them out instead of dealing with Overdrive's increasingly troublesome leasing system. On the other... um, no.

I find it especially interesting that the petition doesn't explain *why* they want this exemption; they're not talking about all the markets demanding their devices but being held up by these requirements, and they're not mentioning any lawsuit injunctions they're supposed to comply with.

(Also: I got the link from a post at Mobileread; I haven't been able to find any details in news or other blogs.)

[jesse_the_k]

Wow! Thanks for teaching me something new. So an "accessible PDF" simply saves the text along with the image, where a speech software on the destination machine can talks its head off?

IANAL and I couldn't figure out what the e-reader manufacturers were doing. But I was using 64K Apple IIs to read text with voice 30 years ago, so when they refer to talking e-reader as "advanced computing technology" I just want to know which way to aim the rocket launcher.

Thanks for keeping up with Mobileread! Their forums are outstanding for the nitty-gritty details of any text reader anywhere, but I sorta drown there.

[elf]

Accessible is a bit more than text with the images; it means the text is arranged properly (tables read each cell as a single unit instead of reading straight across, etc.) and the images have alt tags, like html does, and a couple of other navigation features.

I used to do manual accessibility tagging for PDFs; it's a pain. (The auto-features have gotten better over the years but the manual corrections haven't.) But almost all commercial PDFs--and anything produced from Word or InDesign or Powerpoint--will at least be able to be read out loud by a text reader. Complex books with charts may need more careful processing to be really accessible, but the main body text is *easy* to throw into speech software.

PDFs made from scanned images need to be OCR'd, and how well that works depends on the quality of the image and the complexity of the text. Scanned business documents? Work fine. Scanned art books with multiple columns and callout text boxes in weird fonts? Much less fine.

[lilacsigil]

E-readers simply are not designed, built, or marketed for ACS

Subtext: and we don't want to, waaah!

[elf]

It's very simple: people with visual disabilities don't NEED to read books. And if they do, they should be doing it on tablets or computers. And if they DO need to read them on e-readers, they DON'T need to access the internet or use VOIP or anything like that on e-readers, so we shouldn't have to change the hardware or software to accommodate them. Besides, it would cost money, and everyone knows people with disabilities don't have money, so there's no point in driving the price up for everyone else.

...

Actually, looking at the petition, I'm a bit worried. It was filed on 5/16/2013; I have no idea how a person or group would file a counter-statement saying "no, this is bogus; don't give Amazon, Kobo and Sony a free pass on the ADA because they don't want to spend money adding features to their devices that don't immediately result in swarms of money."

ETA: There's a request for comments that through THIS MONTH.

[lilacsigil]

Awesome! I'll check if they take comments from outside the US.

[tiamatschild]

...

....What EVEN.

(I'll write something up. I may not know a lot about the technology, but the history of accessibility standards is something I can do.)

[elf]

As soon as I'm through this week's homework (in six classes, eep), I want to look into this. I need to find out what the normal compliance standards are, and what exactly they're asking to be exempted from.

If it's a matter of "ACS devices need to provide captioning for videos"... no. E-readers of the type they're talking about don't have video support at all. However, I suspect they're trying to get away from the requirement to support text-to-speech for email and web browser--and, not incidentally, their own navigation functions--even though they provide TTS for the ebooks themselves.

I know the technology involved pretty well; I've owned and loved several e-ink devices. I can tell they've put together a slanted proposition, pushing the idea "these devices are for READING" (which they are) and not mentioning how much they advertise the other features of the devices. They're also not mentioning how much the public *doesn't* distinguish between reader-only and tablet devices.