Disability Rights Advocates (DisabRA) is a non-profit law firm dedicated to protecting and advancing the civil rights of people with disabilities.

1
Disability Rights Advocates Customer
Outreach and Education Concerning the Limits of
the Telecommunications System During Power
Outages

• Disability Rights Advocates (DisabRA) is a
  non-profit law firm dedicated to protecting and
  advancing the civil rights of people with
  disabilities.
• DisabRA advocates for disability rights through
  high-impact litigation, as well as through
  raising the concerns of the disability community
  at proceedings before the California Public
  Utilities Commission.

2
Importance of Continued Connectivity
During Emergencies for People with Disabilities

• People with disabilities are more likely than
  average to need assistance in an emergency
  evacuation. They must be able to contact family,
  friends, and/or emergency services to ask for
  such assistance.
• Many people with disabilities need electricity to
  operate essential assistive equipment such as
  power wheelchairs or respirators. During a power
  failure, these people may find themselves in
  acute distress. This increased risk means that
  isolation is not an option.
• Individuals who have certain medical conditions
  such as multiple sclerosis must keep the air
  temperature in their environment within a narrow
  range. Power failures or other emergency
  situations may make this impossible, causing
  health complications. Again, these people must
  not be isolated in emergency situations.

3
Barriers Faced by People with DisabilitiesIn
Maintaining Emergency Connectivity

• People with disabilities are disproportionately
  low-income and thus among those least able to
  protect themselves in emergencies through
  redundancy. It is simply beyond their means to
  purchase multiple telecommunications devices,
  multiple battery packs, and other peripheral
  devices.
• Low-income Californians will benefit least from
  an outreach and education campaign that instructs
  consumers to protect themselves during an
  emergency through redundancy. For those without
  financial resources, such information is not
  helpful.
• Many people with disabilities face additional
  challenges and costs because they must have
  backup battery power for their assistive
  telecommunications devices such as TTYs as well
  as for telephones themselves in order to maintain
  connectivity.
• Many people with disabilities cannot obtain
  redundancy regardless of cost because their
  adaptive equipment only works with one type of
  telecommunications (most commonly wireline)
  service.

4
Assistive Telecommunications Equipment Used by
Disabled Individuals

• Examples of adaptive equipment that allows people
  who are deaf or hard of hearing to effectively
  use the telephone include
• Teletypewriters (TTYs, also known as TTDs)
• Videophones
• Telephone amplifiers
• Captioned telephones
• Loud ring signalers or visual ring signalers
  using flashing lights
• Examples of adaptive equipment used by people
  with other disabilities to effectively use the
  telephone include
• Cordless phones (to allow people with limited
  mobility to carry a phone with them and avoid
  having to get to a certain location quickly)
• Voice-activated phone dialers (for people with
  cognitive disabilities or those with mobility
  impairments that make dialing a phone difficult)
• Hands-free headsets or hands-free speaker phones
• Talking caller ID machines (for people who are
  blind or visually impaired)

5
Issues and Recommendations Regarding Educational
Outreach on Backup Power And Assistive
Telecommunications Equipment

• Any education campaign concerning emergency
  backup power should include targeted outreach to
  CBOs serving disabled and/or deaf individuals,
  targeted media, and listservs and Internet
  bulletin boards used by the deaf and/or disabled
  community.
• Virtually all telecommunications assistive
  devices use electricity and would require backup
  battery power in the event of a power failure.
  Some models or types of equipment may not support
  battery power at all.
• Consumers who use adaptive equipment must be
  informed of the need to obtain emergency backup
  battery power not only for their basic
  telecommunications service, but also for these
  assistive devices. Information about whether
  battery backup is available must also be provided
  for each device.
• As with the need for battery backups for phone
  service generally, educating disabled consumers
  about the need for battery backups for assistive
  equipment will not be effective for those
  low-income people who cannot afford to purchase
  this equipment themselves.
• The Commission may want to re-evaluate its policy
  under the Deaf and Disabled Telecommunications
  Program of providing only one TTY machine to each
  qualifying household, as backup TTY machines or
  other devices may be necessary in case of an
  emergency.

6
Battery Level Indicators and People with Sensory
Disabilities

• Low-battery indicators should be standardized
  across all equipment types to provide both an
  audible tone and a visual signal such as an LED.
• In the absence of such standardization, an
  outreach and education campaign on emergency
  backup power should include information about the
  battery indicators of different products so that
  people with sensory disabilities can make
  informed buying choices.
• The outreach and education campaign must also
  include information about where battery level
  indicators are located, so that people know where
  to look and/or listen for these warnings.
• Battery packs must also be located in an area of
  consumer homes where they will be noticed.
• Customers need options for other forms of low
  battery warnings, such as text messages, emails,
  or alerts sent via a vibrating pager, so that
  information regarding backup power is available
  in a usable format for all customers.

7
Considerations Regarding Backup BatteriesAnd
People with Mobility Disabilities

• People with mobility disabilities may not be able
  to install backup batteries for their
  telecommunications devices independently.
• If telecommunications devices or backup batteries
  are provided by carriers or by the Commission
  through a program such as DDTP, the carriers or
  the Commission should also identify customers who
  cannot change their batteries independently and
  develop procedures to provide assistance.
• Without a system for customer assistance, an
  outreach and education campaign must inform
  customers of the need to physically change their
  batteries and encourage people who cannot do so
  independently to make arrangements for obtaining
  assistance.
• This information should be included in outreach
  materials such as brochures and emergency
  preparedness checklists on informational
  websites, as well as through more targeted
  outreach to the disability community.
• Carrier representatives who install equipment
  should be trained to address the need for
  customers to obtain their own assistance in
  changing batteries when they observe that a
  customer has limited mobility.
• Carrier representatives performing home service
  visits should also inform customers of the
  potential need to reset or reconfigure their VOIP
  or other telecommunications systems after a power
  outage, and should ensure that customers with
  disabilities can perform such resets.

8
Producing Outreach Materials and Presentations
in Accessible Formats

• All printed materials made available as part of
  an outreach and education campaign on emergency
  backup power must be offered in alternative,
  accessible formats, including
• Large print
• Braille
• Audio (cassette or digital audio file)
• Electronic text readable by a screen reading
  program
• The standard print versions of outreach materials
  (such as bill inserts) should contain key
  information, such as who to contact for more
  information or to receive materials in
  alternative formats, in large print.
• All customer outreach materials should include
  TTY numbers with the same prominence as other
  customer service phone numbers.
• TTY numbers must also receive the same response,
  with the same degree of training, as voice
  customer service numbers.
• Any spoken presentations offered by carriers,
  either at time of sale or at another time, must
  include accessibility features for people who are
  deaf, such as sign language interpreters
  (including video interpreters over the Internet)
  or equivalent written and/or Internet-based
  materials.

9
Accessibility of Informational Websites

• Both the Commissions informational website,
  www.calphoneinfo.gov, and any Internet-based
  information provided by carriers must be
  formatted in a way that is accessible to screen
  reading technology.
• The standards for website accessibility are
  codified in the regulations to section 508 of the
  Rehabilitation Act, 29 U.S.C. 794d, and
  incorporated into California state law via
  California Govt. Code 11135(d)(2).
• The Internet cannot be the exclusive means of
  delivering any key information, because many
  Californians lack access to the Internet and
  people with disabilities are disproportionately
  likely to be on the wrong side of the digital
  divide.

10
Conclusions Essential Components of an
Accessible Outreach and Education Plan

• The essential substantive areas that an effective
  education and outreach plan must address
  specifically regarding the unique needs of people
  with disabilities are
• The need for backup power for assistive
  telecommunications devices as well as telephones
  themselves.
• The different backup power capabilities of
  various assistive telecommunications devices.
• The physical location and available sensory
  modalities (tone/light/vibration/text alert) for
  low-battery indicators.
• The process for installing backup batteries and
  the method for obtaining assistance with that
  process for those with mobility disabilities.

11
Conclusions Essential Components of an
Accessible Outreach and Education Plan (Continued)

• The essential procedural components that an
  outreach and education plan must contain in order
  to be effective for people with disabilities are
• Targeted outreach to CBOs serving the disability
  community, as well as publication of information
  in targeted media and on disability-specific
  listservs
• Materials available in accessible formats and in
  multiple languages, and key information in
  standard print materials displayed in large print
• TTY numbers displayed with equal prominence as
  other customer service numbers
• TTY calls given equal response by equally trained
  staff as voice calls
• Spoken presentations made available in formats
  accessible to people who are deaf or hard of
  hearing
• Informational websites accessible to screen
  readers using standards of section 508 of the
  Rehabilitation Act
• Information available in alternative formats for
  people who do not use the Internet