Through the E-Ink, Darkly

Peter Brantley -- August 20th, 2013

For the blinkd voter
In May 2013, three large ebook retailers and e-ink reading device manufacturers – Amazon, Kobo, and Sony – filed a petition with the U.S. Federal Communications Commission asking it to “waive the accessibility requirements for equipment used for advanced communications services (ACS) for a single class of equipment: e-readers.” In other words, dedicated e-ink devices are difficult to use for the blind, visually-handicapped, and reading disabled, so the manufacturers are asking to be relieved of the need to make them accessible. I find nothing in this pleading which will “advance the public interest.”

At first glance, it seems like it might be reasonable request. The petition observes that e-reader devices are typically low-powered to preserve battery life, have relatively low resolution screens with slow refresh rates, lack sound capability such as microphones and speakers, and cannot support full-featured web engines. As the counsel for the manufacturer coalition states, although these devices “have a similar shape and size to general-purpose tablet computers, e-readers lack many of tablets’ features for general-purpose computing, including ACS functions.” As some on Twitter caustically noted, these devices “suck” too much to support accessibility.

I can’t help but find the arguments of these retailers pathetic and depressing. As the retailers note, “This Petition demonstrates that e-readers are devices designed, built, and marketed for a single primary purpose: to read written material such as books, magazines, newspapers, and other text documents on a mobile electronic device.” I assert that the affordance the blind would most like obtain from increasingly powerful mobile technology is exactly this: to read text on a simple device. For ebook retailers to set up a straw man argument between blinged out retina-resolution tablets supporting complete software stacks and e-ink devices is poor logic and shameful conduct. The choice is not between a Model T and a Tesla – a Kickstarter project could likely find a happy engineering medium if large corporations cannot manage it.

This is an amazing market opportunity gone missing, and as many advocates of accessibility have noted, helping the blind also means helping a rather large number of individuals who have various incapacities, many of which inevitably arise or increase with age. Vast numbers of the blind do use smartphones and tablets to read – they are a vast improvement on the expensive, dedicated accessibility devices of years past. But they are often overkill, and their complexity frustrates as much as it aids, despite Apple’s long dedication to accessibility support. Building an e-reader device that is not a tablet or smartphone but which does support accessibility would be a huge boon to literally millions of readers whose reading is sharply restricted today.

Furthermore, as law professor James Grimmelmann noted in Twitter, this is not a war that ebook retailers should be fighting. If publishers want to disable text-to-speech and other accessibility functions, then they should petition the FCC, not Amazon, Kobo, or Sony. A cynical observer might think that despite Amazon’s recent acquisition of high-end text-to-speech (TTS) technology, the removal of TTS capability from the Kindle Paperwhite series – when it was present on prior Kindles – might suggest that they are simply forcing consumers upstream to tablets. Gasp: could it be possible that the petition to the FCC is motivated by their own financial interests, and not those of the public?

There is one other omission to note: the complete silence from the International Digital Publishing Forum. The IDPF has spent years working on its new EPUB3 standard, with a stated goal of enhancing accessibility. The EPUB3 specification document calls out: “It is important to note that while accessibility is important in its own right, accessible content is also more valuable content: an accessible Publication will be adaptable to more devices and be easier to reuse, in whole or in part, via human and automated workflows.” Even the American Association of Publishers’ newly launched EPUB3 Implementation Project notes that “Through EPUB 3’s innovative assistive features, people who are blind or have other print disabilities will have access to the same titles, at the same time, as all readers.”

Paradoxically, two of the members of the “Coalition of E-Reader Manufactures” – Sony and Kobo – are members of the IDPF. Although the BISG’s EPUB3 compliance table documents only partial readiness from reading system providers, both Sony and Kobo have publicly indicated more complete EPUB3 support by the end of 2013. Unfortunately, that endorsement seems to falter at one of the format’s core design features. Despite the manufacturers’ naked disrespect for the EPUB3 specification, as far as I can tell the IDPF has yet to issue a press release on the request for FCC waiver, or submit a filing in response to the petition. That is unfortunate if true; the board of a not-for-profit must carry some responsibility.

More fundamentally, corporations able to advance access to knowledge through innovative technology should take gracious pride in the opportunity to open horizons as a fortunate reciprocity for their charters. Instead, in this petition, I see hubris. Make your voice heard: the last date to submit comments to the FCC is September 3, 2013.

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