ACCESSIBILITY FOR ONTARIANS WITH DISABILITIES ACT ALLIANCE UPDATE

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United for a Barrier-Free Ontario

WAS THE ONTARIO GOVERNMENT FOREWARNED THAT THE PRESTO SMART CARD TECHNOLOGY FOR PAYING PUBLIC TRANSIT FARES HAS DISABILITY BARRIERS?

August 27, 2010

SUMMARY

Presto Systems, a part of the Ontario Government, has designed a Smart Card system to let public transit passengers load their money on one Smart Card and then use that Smart Card for paying fares on different public transit systems in Ontario. Presto Systems told the AODA Alliance it is committed to ensure its Smart Card technology is accessible to persons with disabilities.

Contradicting this, back on June 21, 2010, the AODA Alliance publicly revealed that the new Presto System Smart Card technology, financed by the Ontario Government and specially designed for the Government, includes new barriers against persons with disabilities which are being created using public money. See: http://www.aodaalliance.org/strong-effective-aoda/06212010.asp

On August 10, 2010 we called on the Government to halt deployment of this Presto Smart Card system, until the barriers in it are removed. See: http://www.aodaalliance.org/strong-effective-aoda/08122010.asp

The Government has not said that it is stopping or slowing deployment of the presto Smart Card technology in light of this. The AODA Alliance subsequently received information that suggests that the Government was warned as far back as two years ago that its design for the Presto Smart Card technology had barriers. The information we received also suggests that the Presto Smart Card technology has even more barriers than we identified earlier this year. We promptly forwarded this information to Transportation Minister Kathleen Wynne, by a letter dated August 15, 2010. That letter is set out below. It includes the full text of the information that was then provided to us by Mr. Craig Nichol.

Mr. Nichol indicates in his email to us and its attachments, which we forwarded to the Transportation Minister, that he has a vision impairment, that he was one of the people that was consulted on the accessibility of the Presto System Smart card, and that he identified a number of barriers in the design of that technology. These include, among others, barriers that the AODA Alliance had not known about. Mr. Nichol indicated that he alerted the Government to accessibility concerns as far back as 2008.

In our August 15, 2010 letter to Minister Wynne, we ask for the Government’s response to this information. To date, the Government has not replied to this letter or our earlier August 10, 2010 letter to Minister Wynne. To date, the Government has not disputed the accuracy of the information from Mr. Nichol that is included in our letter to Transportation Minister Wynne.

After we sent the August 15, 2010 letter to Minister Wynne, Mr. Nichol sent us additional information. It described information he provided to the Government in 2010, raising accessibility concerns regarding the Presto Smart Card system. We also set that information out below, right after the letter to Minister Wynne.

This entire situation is especially troubling for several reasons. First, the Government responded to our accessibility concerns by explaining that it consulted with people with vision loss on the Presto Smart Card system. We quote the August 12, 2010 Toronto Star article in our letter to Minister Wynne, set out below.

Second, the Government has not repudiated the dubious claim by Presto Systems, set out in the August 15, 2010 Toronto Star article, that public safety could be threatened if the Smart Card technology is fully accessible to persons with disabilities. The Toronto Star article states:

“Presto executive director Ernie Wallace says the new tap system is far more accessible than a token or cash one. Wallace says the alternatives - an audible balance announcement via speaker or plug-in - weren't deemed viable.

"It makes no sense ... both from a safety and privacy viewpoint, to get voice-activated plug-in pins at a TTC gate," he says. "It just operationally doesn't work. You can't have the gate stopped or the device stopped in the middle of rush hour."”

This “public safety” excuse assumes that the machine where a passenger checks his or her card balance is at the turnstiles where one pays to enter the transit system. In fact, it is our understanding that the Presto machine for checking one’s card balance need not be at the turnstiles. Even if it were designed to be situated at the turnstiles, it ought to be readily located somewhere else. Public transit systems are supposed to be designed to accommodate large volumes of people. That is why they are called “mass transit.”

Third, Presto’s stated privacy concern is not valid. An electronic kiosk such as this can have an earphone jack to enable a person to plug in earphones and privately listen to the audio information about his or her card balance. Accessible bank ATM’s are equipped with this feature. This is not rocket science.

You can read the entire August 12, 2010 Toronto Star article at: http://www.aodaalliance.org/strong-effective-aoda/08122010.asp

Send your feedback to us at: aodafeedback@gmail.com


ACCESSIBILITY FOR ONTARIANS WITH DISABILITIES ACT ALLIANCE
1929 Bayview Avenue
Toronto, Ontario M4G 3E8
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August 15, 2010

The Honourable Kathleen Wynne, Minister of Transportation
Ferguson Block
77 Wellesley Street West, 3rd Floor
Toronto M7A 1Z8
Fax (416) 327-9188
Kathleen.Wynne@Ontario.ca

Dear Minister Wynne,

Re: Inaccessibility for Passengers with Disabilities of Ontario Government-Sponsored Presto System Public Transit Smart Cards

I write as a follow-up to my August 10, 2010 letter to you about barriers impeding persons with disabilities from being able to make full and equal use of the new Government-financed Presto system Smart Card technology for paying transit fares on Ontario public transit systems.

In your office’s public response to our concerns, reported in the August 12, 2010 Toronto Star, and in Presto’s responses to our concerns, the Government has emphasized that in developing the Presto system Smart Card technology, it consulted on accessibility with persons with disabilities, including those with vision loss. The Toronto Star’s August 12, 2010 article states in part:

“Katherine King, spokeswoman for Transportation Minister Kathleen Wynne, said the Presto system meets accessibility standards.

"Presto has been working with an Accessibility Advisory Group, including representatives from the visually impaired community, as the Presto card was developed.

"Now that the devices are in service, Presto has been soliciting feedback on using the devices in the real transit environment," she said, adding that consultation will continue as the system moves forward.”

These claims can leave the reasonable impression that Presto not only consulted on these issues, but listened to and acted on the input they received. We have since been advised by Mr. Craig Nichol that he, a person with vision loss, was one of those consulted by the Presto system when they were developing this technology. He advised us in his August 13, 2010 email to us, set out below, that he identified for Presto not only barriers that we also identified, but other troubling barriers as well. He also attached to his email to us, his notes that he said documents the input he provided to Presto. These are also set out below.

We request your response to this information. We also reiterate our requests in our August 10, 2010 letter to you that the Government halt the roll-out of the Presto System Smart Card technology until all barriers are removed from it. The policy of your Government is, or should be, that no new barriers should be created against persons with disabilities, especially using tax dollars.

We repeat our request of your fellow Minister Madeleine Meilleur, Minister of Community and Social Services, that the forthcoming accessibility standards (to be enacted under the Accessibility for Ontarians with Disabilities Act) specifically require that electronic kiosks available for the public to make commercial transactions, like using a public transit system, be fully accessible to persons with disabilities. This incident is proof positive that it is essential for those new accessibility standards to explicitly and effectively address the accessibility of such electronic kiosk technology.

We request your response on this important issue at your earliest convenience.

Sincerely,

David Lepofsky, CM, O. Ont,
Chair, AODA Alliance

cc: Hon. Dalton McGuinty, Premier, fax 416-325-9895, email mcguinty.mpp.co@liberal.ola.org
Madeleine Meilleur, Minister, Community & Social Services, fax (416) 325-3347, email madeleine.meilleur@ontario.ca
Brad Duguid, Minister of Energy and Infrastructure fax (416) 327-6754 email brad.duguid@ontario.ca
Marguerite Rappolt, Deputy Minister, Community & Social Services, fax (416) 325-5240, email marg.rappolt@ontario.ca
Ellen Waxman, Assistant Deputy Minister, Accessibility Directorate, fax (416) 325-9620, email Ellen.Waxman@ontario.ca
Ernie Wallace, Executive Director PRESTO fax 647-789-0321 email Ernie.Wallace@prestocard.ca

Enclosure

August 13, 2010 Email from Craig Nichol to David Lepofsky
to: David Lepofsky, Chair Accessibility for Ontarians with Disabilities Act Alliance

David I am visually impaired and have participated as a member of the Presto accessibility testing group on three occasions between June 2008 and June 2010.

On August 10, 2010 you wrote, by email, to Mr. Ernie Wallace, Executive Director PRESTO.

* In the email to Mr. Wallace you stated "We are eager to know whether any of those you consulted raised the issue of the inaccessibility of video screens to people who have vision loss or dyslexia. Was the Presto project team unaware of the inaccessibility of this technology when it went ahead with it? Did it explore the option of including an accessible spoken-word audio output on the card readers, akin to that found in many automatic bank machines and on GPS devices used by many drivers?"

on every opportunity I have stated to the testing team and Presto staff that the devices are not accessible on several points including lack of audio and sub standard (non standard() tactile markings. On two occasions I followed up my verbal responses with written comments, it is impossible that the Presto team was not aware of the design deficiencies.

My written comment in June 2008 included:

- All devices use an LCD display and do not provide the same information in an audio format. I indicated the lack of audio is unacceptable, all users must be aforded the same ability to use the system.

* You also mentioned the process for choosing the tones which are to aid persons to determine if the transaction is successful.

"The tones or sound bites to be used on the Fare Payment devices were chosen through a lengthy process. The PRESTO Accessibility Advisory Group reviewed the sound bites and the Canadian Hearing Society confirmed the effectiveness of the selections. "

It is curious that persons who have a hearing disability but can read the display are advising on appropriate sounds for those who can not read the display. My experience as a member of the focus testing group is that the sounds have become less distinct with the involvement of the Canadian Hearing Society's input, all sounds are now much alike and thus the message is lost. At the testing session June 2010 the test team was still asking if the sounds provided a clear message and my response was no they are too much alike being concentrated in the mid tone range.

* There are many other factors in the Presto System concept which exacerbate the problem of concentrating the interface in a visual format. It is not just the problem of not knowing the balance on your card you are not permitted to know how much you are being charged for the ride as the amount is only displayed. In jurisdictions where the fare is distance based i.e. GO Transit and York Region Transit again you can not know what you are being charged or even if you will be stopped by transit police for not paying the correct fare since you did not have the opportunity to verify your transaction on boarding.

I was not the only focus testing participant to complain about the lack of audio and poor tactile markings on the equipment and I circulated my written comments to Presto, Metro Links and TTc staff.

I attach the written comments for those meetings to this email.

Craig Nicol


Notes re Presto focus June 2008

1.5 hour session at GO Transit boardroom 20 Bay St 6 th floor

For devices presented in the focus session see Presto Devices June 2008.kes.

General issues:

web site www.prestocard.ca provides contact info but the phone numbers do not lead to the Presto Team.


Notes re Presto focus April 2009

session at Presto office 130 Adelaide St. W.

Devices presented:

GO transit fare terminal, account query device, transit (bus) boarding swipe device, transit driver (fare box) device and turnstile retro fit device.

Note: The YRT zone payment device that was presented in June 2008 was not here.

General issues:

GO transit fare terminal:

Account query device, :

Transit driver (fare box) device :

Turnstile retro fit device:

Craig Nicol

21/04/09


NOTE THE FOLLOWING MATERIAL WAS RECEIVED BY THE AODA ALLIANCE FROM MR. CRAIG NICHOL AFTER WE SENT OUR AUGUST 15, 2010 LETTER TO TRANSPORTATION MINISTER WYNNE, SO IT WAS NOT INCLUDED IN THAT LETTER

AUGUST 17, 2010 EMAIL FROM CRAIG NICHOL TO AODA ALLIANCE

As you know there was a Presto focus testing session in June 2010. I have located my notes from the June 2010 session and attachthem to this email.

At the time of the test Presto employed a facilitator to gather and compile participants comments on the device tested. I have also sent a copy of my notes to Presto, Metro Links and the TTC today.

ATTACHMENT

PRESTO Accessibility Testing Session Wednesday, June 2nd session at Presto office 130 Adelaide St. W.

PRESTO DEVICE to be tested:

Bus Rapid Transit Fare Transaction Processor (BRT-FTP) Initially these will be installed for York Region Transit. They will allow for travel by zone distances and are intended to allow customers to check to see what is on their PRESTO contact-less cards and to obtain paper transfers.


My asessment (comments)

The session involved individuals testing the device with a facilitator. The routine was as follows:

- test for simple swipe and hearing tones to indicate success or failure of transaction

comment: the tones are in a low register and although they provide an ascending tone sound for success and a descending tone for failure a better success sound should be found that is commonly linked to the completion of a transaction, I suggested a cash register sound such as that produced when entering transactions in the Quicken register . The facilitator was familiar witht the sound suggested. The cash register sound was used on devices in the June 2008 test.

- asessment of the tactile ring around the swipe area

Comment: the raised ring does accentuate the intended swipe area but it is of minimal dimension as to height from the surface and may be somewhat thin in stroke width. I would suggest dimensions such as those for the tactile symbols used on the function keys of accessible automated banking machines or the raised dot on these machines (0.7 ± 0.1 mm

high and has a 1.5 mm base diameter)

- for those with sight asessment of display

Comment: No audio is provided for those who can not read the display, my response to this was that it is unacceptable that I am denied information on the transaction.

- testing for single, two and three zone transactions

Comment The single zone transaction simply requires that you swipe the card and listen for success or failure. The two and three zone transactions require that you locate and identify the correct button to press before swiping and then listen for a slightly different success tone. The tactile numerals on the face of the machine that are intended to identify the buttons are not satisfactory, they do not follow accepted standards for height, stroke width or form and are thus somewhat indistinct. The numeric characters need to follow proper standards and be supplemented by braille. The buttons when pressed seem to have a long travel and may result in people thinking that they have depressed the button when in fact no selection is made this will result in the card swipe being only for one zone which could result in problems when the transit police check the card.

- testing printing of transfer

Comment: To have a transfer printed it is necessary to first locate and press a button and then swipe the card. The printer button is identified by a graphic of a printer that is just barely tactile enough to indicate that something is there but not so that you can identify the symbol. A tactile letter "P" with braille may be the solution to providing identification however sighted persons may not appreciate that a "P" tells them that this is the printer button.

- General comments

1. No test was performed of the help key wich is marked with a raised question mark which is somewhat similar to the raised 2 that is used for zone transactions. This marking issue needs to be resolved with tactile characters which conform to recognized standards

2 No test was performed combining multi zone transaction and printing of transfer.

3 Input was given by more than one person into the idea of a hole in the card to attach to a lanyard or key chain. Also suggestion was made that the card needs to be tactilely identifyable from other cards in your wallet.

4 this was only the second time this device has been presented to me for test the other time was our first session in June 2008.

5 I indicated that tactile icons and braille become useless or very hard to use when not high enough or mounted at an angle which allows the user to have their hand below the tactile item. i.e. not require reading inverted.

6 Check comments provided in earlier test sessions as many are still valid having resulted in no improvements.

Craig Nicol

3/06/2010