STRATEGIC PARTNERS
Some of the ATM industry's waiting and wondering is over with the federal Access Board's final draft of proposed changes to the ADA Accessibility Guidelines (ADAAG). The document is now being considered by the Department of Justice.
April 14, 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'sdirector, 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, DieboldNorth 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." |
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 meanthat all deployers will need to get involved in providing accessible ATM services." |
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 meanthat 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 DOJwill 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.
