(UPDATED) David Lepofsky, the man who single-handedly forced the TTC to call every stop, has made another mistake. He gets things wrong from time to time, as with his insistence (repeated recently on The Agenda) that every transit vehicle in the province can be made accessible to blind people instantly because every such vehicle has a driver with “a mouth,” to use the term he himself keeps using.

During the period between the requirement to announce stops and the full implementation of automated announcements, TTC found out the hard way that drivers cannot announce all stops and also drive and do everything else they need to do. As a totally blind person who doesn’t drive, Lepofsky seems unaware that the multitasking he thinks is trivial is in fact impossible. Anyway, human-voiced stop announcements will never come close to 100%, let alone the 98% actually required in his human-rights victory. To this day, when the stop-announcement system breaks, drivers are unable to call every, most, or, in some cases, any stops. (And you can’t hear them at the back of the bus.)

Lepofsky to Presto: Drop dead

Now let’s discuss another of his mistakes – this week’s near-hysterical claim that the Presto farecard system is inaccessible and has to be scrapped. Lepofsky insists that because sighted people can check their farecard balance on a display at a turnstile, blind people have to be able to do precisely the same thing right then and there.

We will set aside for the moment that all TTC turnstiles are already inaccessible to blind people. There’s a visible counter on each one that displays how many times the turnstile has been used. Even so-called full-height turnstiles and wheelchair gates have these displays, which only TTC staff use. (Watch what the guys in the money truck do.) In theory a sighted passenger could look at that display and a blind one couldn’t. But only TTC employees need to look at that number, and for that group, adequate vision is a bona fide occupational qualification (bfoq). Is that discrimination? Don’t cheapen the term, or insult our intelligence.

Any farecard system would have to provide equivalent facilitation. The term is used a lot in the accessibility business.

  • The experience with Web sites, where nobody accepts that a disabled person could just phone a call centre instead of using the site, has caused that term to evolve to mean that the method or location of delivering the service cannot change to accommodate disabled people.

    If you run a Web site, the Web site has to be accessible. If you run a subway station, the station has to be accessible.

  • Hence a blind person could use a freestanding balance reader in the same room as the turnstiles instead of the quick little display at the turnstile.

At any rate, making such a display accessible, as Lepofsky demands, would in fact block the turnstile for minutes at a time, which would constitute undue hardship by itself. So would the added design expense and size of any resulting system attached to a turnstile.

And again, don’t insult our intelligence: There is no such thing as a blind person who wants to stand inside or at a turnstile for seconds or minutes at a time, with people coming and going in all directions, some of them pushing from behind, just to check a balance.

Buying fares will be accessible

The whole problem will be solved anyway because the fare-purchasing process, even at in-station kiosks, has to be accessible to blind people.

  • Obviously every terminal will show you and tell you your balance.

  • You don’t have to check your balance at the turnstile. We don’t have to make that possible.

Even for a person committed to accessibility, the obvious way to solve the problem Lepofsky has brought into existence, above and beyond making farecard-sale kiosks accessible, is to simply remove the visual display of card balance from turnstiles. Then the function Lepofsky complains about has ceased to exist. To repeat, fare-vending machines would still be accessible and would still display your balance, but we can remove the display from turnstiles if that’s what we feel like doing.

A completely separate device that does nothing but display your balance also has to be accessible.

Don’t believe the government in this case

The blandishments from the government that Presto “meets current accessibility standards” are something of a joke, particularly since there are no accessible fare-vending kiosks in Toronto and the same bureaucrat went right on to contradict herself.

What about so-called open-payment farecards?

“Open payment” is a complete misnomer. As a catchphrase, it is almost as deceptive, harmful, and mealy-mouthed as the term “public option” when used in the American healthcare debate. Nonetheless, that is the term used to describe multi-vendor farecard systems that aren’t Presto. Will they have to be accessible?

Looking at the gigantic request for prequalification issued this week by the TTC, the answer is yes. Yet it is inconceivable that the winning bidder will get it right on the first go. Canada, Ontario, and Toronto have too much entrenched incompetence and mediocrity to accomplish these tasks. If we’re lucky, Version 2.0 is the one that’s gonna work.

In any event, the RFP requires:

  • That “[a]ll features, components, and systems… will comply with [the Accessibility for Ontarians with Disabilities Act, AODA], along with all applicable laws and regulations… regarding accessibility…. As required by law, or as necessitated by changes in standards and practices in the open standards of the financial services and payments industry, the Private Partner must modify, upgrade, or amend the… system, its business and operating-support systems, and all other aspects of the [system]” to guarantee compliance.

  • All online applications have to meet WCAG 2 (“General Level 2 and Colour Level 3”). There seems to be a requirement for testing to prove accessibility and usability, but this isn’t really clear. (The RFP all but demands the use of horrendously complex and expensive Microsoft systems, which are effectively impossible to make standards-compliant and which will incur needless costs in the tens of thousands to make accessible. Microsoft systems are turds you can’t shine.)

    There is nobody in town who can produce a WCAG 2–compliant site of this size and test it adequately. Further, the entire apparatus creating this system – the winning vendor and the TTC – will be so ignorant of what accessibility actually means that everyone will be fall into the trap of ticking boxes on a form and claiming compliance rather than making an actually accessible site. (TTC’s engineers and the winning vendor’s account managers, all of them using Windows XP, won’t know a thing about accessibility and can’t be trusted to produce accessible work.)

    As a reminder, here are two of my use cases for an online trip planner:

    • Prove to me I can do everything I want in your application using Safari, a Braille display, no speakers or headphones, and no monitor.
    • Unplug the mouse and do a demo of a planned trip from here to my house.

    Could I use this transit-fare system under similar circumstances? Having some hourly contractor, the kind of guy who thinks his netbook is really cool, download and pretend to use the demo version of Jaws isn’t gonna cut it.

    Really, I could go on with these examples all day. The problems are a complete lack of local competence; an enduring resentment of having to include accessibility in the first place; and the corrupting influence of daily Windows usage, which teaches you that computers are trying to hurt you. Windows users make atrocious systems in the broadest sense.

  • And finally, memo to David Lepofsky: Every fare-vending machine has to be fully accessible. (“All aspects of the [fare-media-vending-machine] design will comply with AODA standards.”)

In addition and as I mentioned before, farecards have to be tactually distinguishable – from other types of cards completely unrelated to transit and from other varieties of transit cards. There is as yet no published requirement for this kind of accessibility, but there will need to be.


(2010.09.16) I have printed out and read the repetitive list of grievances that is all but hidden on the AODA Alliance site.

First of all, yes, the whole system has to be accessible upon rollout. And it will be, though Metrolinx and Presto will be dragged kicking and screaming to that point. It is debatable that a beta system has to be accessible even under legal mandate. It is prudent for people like Lepofsky and me, and organizations like the AODA Alliance, to point out disability barriers. It is imprudent to go off the rails and call for the decapitation of the system, which is what they’re actually doing.

Where they’re right

  • The list of gripes actually accepts that one should really be checking one’s fare somewhere other than the turnstile. (Except later when it complains about inaccessibility at turnstiles.) Nonetheless, Lepofsky couldn’t stop complaining about how turnstile cardreaders are inaccessible. We won’t be locating accessible cardreaders there even if that is the current location.

  • Of course visual display aren’t accessible to blind people. Audio and/or Braille will have to be added. Tactile button markings will also be needed.

  • “The swipe area on all devices” has to be tactually discernible.

  • Farecards indeed will have to be tactually discernible from other kinds of cards and from other varieties of cards within the same system. Punching a hole for a key ring is more than a joke and makes me wonder if these people are still living in the 18th century when all they were deemed qualified to do was weave baskets.

  • Kiosks will have to be easy to locate for a totally blind person who’s never been to a particular station before. This is much easier said than done, but the problem can be mitigated if not solved in some cases. In other cases, as with 50-year-old subway stations, kiosks will be stuck in inconvenient locations blind people won’t be able to find without help. This may not actually represent discrimination.

Where they’re wrong

  • These people know nothing about auditory user interfaces, having, it seems, failed to read Auditory User Interfaces by T.V. Raman, who is, incidentally, blind. Their critiques of the sound design of the system barely credible; they seem to imply that everyone has to understand every sound on first hearing without training. (Or the implication is that nothing but out-loud speech will work.)

    There is a separate complaint that noise from adjoining kiosks will drown out the kiosk you’re using, which is of course nonsense for the simple reason you will have plugged in a headphone, as the gripe list acknowledges.

  • They’re not making any sense at all about angle of displays and readability, especially when they bring wheelchair access into the mix. Obviously kiosks at more than one height will be needed.

  • Volume should be user-adjustable. I don’t trust automated volume adjustment cued to ambient noise; I don’t want the system shouting in my ear all of a sudden.

Where they’re off-topic

  • It is irrelevant that “the Government has not disputed the accuracy of the information” the Alliance provided. This isn’t a fact-checking exercise and it sure as hell isn’t a gotcha.

  • Few of us, if anyone, will be “stopped by the transit police,” which, even if it happens, has nothing to do with system accessibility.

  • They actually complain about server traffic and time limits on transactions (accessibility-related only in edge cases and readily solvable).

  • They worry about paper transfers, which the system is meant to eliminate and which blind people can’t read anyway.

  • Accessibility is not related to “people with limited resources.” Don’t try to piggyback a demand to reduce transit fares on a discussion of transit accessibility. If you want cheaper fares, start a separate discussion. And don’t assume disabled people will be any less likely to afford a transit ride in the future than they are now.

  • “Multiple riders on a single card” may or may not be an intrinsic part of the system. An unregistered card is like a transferable pass and can by definition be used by anyone. None of this has to do with disability.

  • Do you know what “reading inverted” means? Do the writers?

The foregoing posting appeared on Joe Clark’s personal Weblog on 2010.08.13 14:38. This presentation was designed for printing and omits components that make sense only onscreen. (If you are seeing this on a screen, then the page stylesheet was not loaded or not loaded properly.) The permanent link is:

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None. I quit.

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