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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
New Email Address: aodafeedback@gmail.com
Visit: www.aodalliance.org

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:
– 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.
– For blind and low visioned people, Because of the lack of audio:
1. transaction information is not available;
2. it is impossible to select trip destinations for distance based fare systems;
3. transaction history and card balance are not available at the query device.
– Tactile icons for buttons were poor and not usable, braille (on YRT) device was not properly done (dot size and spacing incorrect) and placement made braille impossible to access. 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.
– The project team did not know what icons to use for universal understanding. Are we all going to need an icon dictionary? I suggested they look at B651.1.
– The swipe area on all devices is flush and so not clearly distinguishable by touch although it is indicated visually by the logo. I suggested framing the area either with a raised surround, by raising or recessing the surface of the swipe area from the surrounding area.
– For low vision the display seems to be vertical and so difficult to view when standing. The display is behind a protective plastic. Contrast and size of text seemed to be a problem. Duration of displayed information was also an issue.
– All interaction points and display are mounted vertically and at a convenient height for a seated user making access somewhat less convenient for a standing user. I suggested a better solution would be to angle surfaces to provide a compromise which would serve both seated and standing users equally well.
– The cards have no tactile surface indications as to their purpose, orientation is not an issue as they are proximity cards. I suggested that a hole be punched in the card to help identify it and allow attachment to a key ring.
– None of the devices allow addition of value by the user either with cash, debit or credit cards. One device allowed the bus driver to accept cash and add value to the card. What about the line ups when boarding the bus? What about kiosks allowing use of debit or credit cards to recharge the Presto Card?
– Buttons on the device are round and domed, aprox 3/4 inch diameter stainless steel. The buttons are arrayed above and to each side of the swipe (tap) area. I suggested looking at B651.1 for tactile identifiers and colour for buttons and to look at the quality of buttons on ABM keypads for durability. Size and shape could also be as ABM keypads.
– Devices which provide card history or add to value storred on the card require that the card stay in the proximity area during the process, for some people this may not be possible since the swipe surface area is vertical and has no shelf to rest the card on.
– The only audio was a “cash register” sound for a successful transaction and a “downbeat” noise for an unsuccessful transaction. The meaning of the “downbeat” noise was not self evident.
– The volume is not dynamic to respond to ambient noise. This is not good for a transit environment. I suggested this be changed.
– No contact information was provided so we could make further comments or keep abreast of developments. Later I found this information on the web site.
– The focus session was too short for the input required since we had not seen any of the equipment before the session. The fact that much of the testing of devices involved viewing the screen information made it difficult for me to assess equipment as no information about what was displayed was provided.

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:
– All devices use an LCD display and do not provide the same information in an audio format. The lack of audio is unacceptable, all users must be aforded the same ability to use the system.
– There is no way for a blind person to ensure that they have sufficient funds in the account to complete a trip without access to a telephone or computer while others can receive this information from the display on the devices.
– The “sounds” for successful, unsuccessful transaction and cancel and override are not adequately distinct .
– Why can’t the devices speak the amount charged for the trip to the card account?
– The swipe area was domed and thus well defined on the transit (bus) boarding swipe device but on other devices the raised ring was more time consuming to locate.
– Mounting heights need to comply with the mounting height for controls in CAN/CSA B651 Accessible Design for the Built Environment. The point for measurement on the device should be the centre of the swipe area.
– When several terminals are in use the transaction tones easily interfere with each other, this could result in persons boarding convinced they had a successful swipe and then being stopped by the transit police. Remember turnstiles are close together.
– Mounting of devices needs to consider approach for persons using scooters and wheel chairs. Consider side approach area requirements and also knee space.
– Remember devices need to be installed in a manner which allows blind travellers to locate the device i.e. associate with building features such as choke points, corridors etc.
– The card is only the account identification and does not contain the users acount balance. This situation means that every transaction must access the server creating a lot of traffic back and forth on data lines and for the server to handle. At peak times and serving multiple transit providers this could become a source of delay.
– Policies to handle various situations which may arise when a person falls through cracks do not seem to have been formulated. Some examples are what happens if a person forgets to tap off or a person on a defined (saved trip ) decides to extend the trip while onboard a train, or what happens when a person using a scooter or wheelchair finds the elevator out of service and of necessity must travel further to leave the system.
– If a person swipes to make a trip and then changes their mind is there any limit to the time they have to cancel the charge?
– If you swipe to make a trip and then delay that trip for several hours what happens?
– If on examining your account later you determine you have been incorrectly charged how is this handled?
– The card has no tactile identification to diferentiate it from other cards in your walet.
– Only the transit (bus) drivers fare box terminal is capable of issuing paper receipts or transfers.
– This system represents prepaid travel so how will people with limited resources make use of the system?

GO transit fare terminal:
– see general
– Push buttons were poorly identified with inadequate tactile characters above the buttons (some testers did not notice the tactile character. Suggestions were made to have the buttons flat to allow properly designed tactile markings on the buttons. Suggestions were made that the buttons could have a distinctive shape. For specifications for Visual and raised markings to identify the button function, refer to CAN/CSA B651 Accessible Design for the built Environment and/or ASME A17.1-2007/CSA B44-07 Safety Code for Elevators, both of these standards include raised character / icon specifications in an appendix.
If crisp tactile markings are used instead of actual raised alphanumeric characters (which may require too much space) then the character line stroke should be 0.7 ± 0.1 mm high and have a 1.5 mm base width, this is similar to a braille dot which is 0.7 ± 0.1 mm high and has a 1.5 mm base diameter. This crisp function key marking is what has been used on keypads complying with CAN/CSA B651.1 Accessile Design for Automated Banking Machines.
– The device provides no way for multiple riders to ride on a single card similar to the bus drivers terminal. At unmanned GO stations this is a problem.
– The process to cancel a transaction requires swiping during a timed period indicated by a light, how is a blind person to do this. Does this same issue apply to the over ride function.

Account query device, :
– This device, having no audio output is of no use to a blind person.

Transit driver (fare box) device :
– Will this device be used at points other than a bus drivers station?
– Will this device replace or be in addition to the regular fare box?

Turnstile retro fit device:
– The screen was easily mis identified as the place to swipe the card.
– When installed on a turnstile this device is too low, all interaction points on TTC turnstiles are currently on top and the device needs to be redesigned to be in this location. Turnstiles are not used by people in a seated position and thus have no need for the interaction point to be vertical or at a lower height.

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

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