Want read-aloud in Kindles and other readers? Use the FCC’s easy online form by Jan. 9

Updated 1:03 p.m. Jan. 5, 2015 to include additional information from the FCC. – D.R.

Michael W. Perry, a publisher-writer, was “too sick” to read “ether a paper or e-book.” Flat on his back, he could “do nothing about the pain” from sciatica. “Even holding the Kindle screen up and pushing the page-button was more than I wanted to endure.” But he owned a Kindle Keyboard e-reader with text to speech, so he could “beat the boredom. Without TTS, I I’m not sure what I would have done.”

The problem is, Amazon has deprived recent models of TTS, even the $200 Voyage. But relief might eventually be ahead for people with disabilities and sicknesses—and a desperate need for read-aloud capabilities of the Kindle and other E Ink machines. On Jan. 28, if the Federal Communications Commission makes the right choice, a regulatory waiver will expire, and perhaps related actions will also follow. Amazon, Sony and Kobo, members of the E-Reader Manufacturers Coalition, wanted the waiver from rules based on the 21st Century Communications and Video Accessibility Act signed by President Obama in 2010.

Perry, since recovered, said he would e-mail the FCC to argue for TTS and against a continuation of the one-year waiver, and I hope that you will, too. 

Last year, at the urging of the National Federation of the Blind, scores of blind people objected to the waiver. And the FCC listened to an extent. “We believe that, given the swift pace at which e-reader and tablet technologies are evolving and the expanding role of ACS in electronic devices, granting a waiver beyond this period is outweighed by the public interest and congressional intent to ensure that Americans with disabilities have access to advanced communications technologies.”

“ACS” means “advanced communication services,” and e-book-reader makers tried to use this technicality, saying that the Kindle and other readers deserve a waiver because they are not offering genuine ACS as a main function. This is tricky. And an FCC source says the waiver decision is still very much in the air. Furthermore, the law may not specifically address the book-reading functions per se. So even with a waiver extension denied, nirvana may not be at hand.

Just the same, not requiring TTS would certainly appear to be at least outside the spirit of the law, especially given the low cost of e-book manufacturers’ complying with its intent (Amazon even included TTS in earlier Kindles). The FCC, as a guardian of the public interest, should put the onus on the manufacturers to appeal a pro-consumer decision within the commission and within courts. Let’s think practicalities. Lawsuits generate publicity. Does Amazon really want a crowd of blind people picketing outside its headquarters? Do it and others in the e-book industry want this story stretched out over time into a slew of news cycles? Isn’t Jeff Bezos supposed to care about his customers? I’d love for him to act to restore TTS even with the legalities undecided. This would be both customer-friendly and great PR, while expanding Amazon’s market for content.

How to speak out to the FCC

So, yes, do write Jeff B. at Amazon. But by all means catch up with the FCC as well. A Word document of the FCC waiver order is here, and guidance on registering your opinions formally with the agency on Proceeding Number 10-213 is here.

Alas, the FCC says it will not consider informal correspondence, but if you do have trouble with the agency’s online form, you can reach FCC official Caitlin Vogus at “Caitlin.vogus@fcc.gov or at 202-418-1264.  She can submit the content of your e-mail message for you, but you must provide her with your full name and mailing address (street address, city, state, and zip code).  When filed, your name and mailing address, along with your ex parte communication, will be available to the public on the Internet.”

End of business on Jan. 9 is not an official FCC deadline, but because of Chairman Thomas Wheeler’s schedule, this will be soon enough for certain. No harm trying after that, if need be, of course.

For years, I’ve been publicly begging Amazon to stop muting its E Ink machines and restore text to speech in the future. I may even have been the first commentator to break the news about the Paperwhite’s lack of TTS. This isn’t mere rhetoric. I sold my Voyage on eBay in December because—despite some improvements over the Paperwhite—it just hadn’t given me my $200’s worth without text to speech. I like to listen to books while exercising or driving. Far more importantly, what about blind people and the print-impaired?

Read-aloud was in the Kindle 2 and some other models such as the DX and Michael Perry’s Keyboard. Why did Amazon mute it in the most recent Kindles? Don’t say, “Hey, the publishers selling human-narrated editions didn’t want it.” Amazon’s DRM lets them turn off TTS for individual titles.

In addition, I’ve been pushing something else accessibility-related—an increase in the perceived contrast between background and text for those needing it. I’m among them. So are more than a few other baby boomers with aging eyes.

A friendly note arrived from one of Jeff Bezo’s assistants after I wrote jeff@amazon.com about the need for all-text bold or a slider or radio buttons to vary font weights. Kobo E Ink readers have sliders to tweak the weight and even the sharpness; see image below. Why can’t Amazon’s current Kindles? And if Kobo itself can add TTS, so much the better. May the FCC encourage it!

Below is my reply to the Bezos assistant’s reply. I mentioned the missing TTS, too, and in fact, I’ve made the read-aloud issue the main one. Here’s hoping he’ll make a belated New Year’s resolution to add TTS to the Kindle line, especially the pricey Voyage. Same for addressing the font issue.

My reply to Amazon’s reply

“Hi, Carly. Many thanks for your note. My wife shares the same first name, so maybe it's a good omen that you responded—even if I am still hoping for an assurance that firmware updates in the near future can give Kindles and Fires the desired function of all-text bolding or variable font weights. The latter would be a better solution.

“I can't see a downside. Yes, I know the Amazon philosophy of ‘Keep It Simple, Stupid.’ But even the people not interested in all-bold now might discover they wanted the feature, once it existed. This isn't just an accessibility issue. With a greater perceived font weight, users would not have to crank up the brightness quite as much, and they would enjoy longer battery life with the Kindle's front light on.

“As long as we're in touch about accessibility, I'll also bring up the failure of Amazon to include text to speech in the newer E Ink devices–not even the $200 Voyage. This is an unfortunate mistake in a number of ways.

“Hasn't Amazon worked with the PTA to get Kindles into the hands of K-12 students and their families? Schools and libraries would prefer more accessibility, especially with Washington watching them. Amazon may see a market here, but it would be a bigger one with TTS, which, by the way, counts in the opinion of the CTO for the public schools here in Alexandria, VA (she and I were not discussing the Kindle in particular, but I'm sure she would say the same idea applied).

“Just as with the lack of all-text bolding, I suspect I know the main reason–in this case, marketers saying, "Oh, let's segment things and encourage people to buy a Fire, too, not just an E Ink machine, if they want TTS." But you know what? There are plenty of good reasons, such as the rich collection of videos for the Fire, to purchase both kinds of devices. Furthermore, while we're on the topic of market segmentation, wouldn't TTS be one more way to differentiate the Voyage from the much-cheaper Paperwhite.

“Even just a little lip for a headphone jack would be terrific. Imagine a Voyage with a TTS voice on par with Alexa's in Echo. At least make it as good as Amy, one of the best of the Ivona voices.

“For once, I hope that common sense can prevail over marketer-think. I'd suggest that you and Jeff Bezos read a few of the zillions of customer complaints about the AWOL TTS. Among other things, commenters have said in the related forum that no one is paying attention to them except to screen out inappropriate material. Amazon depicts itself as super-customer-friendly; and here's a chance to provide it. My own TTS thoughts, in the LibraryCity blog, are here and here.

“Needless to say, I hope you'll share this note with Jeff B. Over the years I've bought thousands of dollars in e-books and devices; and, especially among the boomers, I'm confident that more than a few Amazon regulars like me would appreciate the requested features. Please ignore the marketers and anyone else challenging the need for these essentials. Amazon should pay less attention to B school dogma and focus groups and more to actual customers. The best marketers and techies will look far beyond their personal needs and anticipate others'.

“Meanwhile, Carly, I'm going to say, ‘No,’ in response to the questionnaire asking whether you solved my problem. It is not your fault in the least. The rest is up to Jeff Bezos and the others working for him. Hey, I'll think good thoughts. Remember how Amazon folks listened and came through with Instant Video for Android?

“Thanks and happiest of holidays,

”David Rothman”

A New Year’s Resolution for Jeff Bezos

So how about it, Jeff? May the above be among your New Year’s resolutions! Given the accessibility issues and the related moral questions, you’ll feel better if you follow the suggestions here, and along the way you’ll boost your revenue and please shareholders along with customers.

Note #1: I’ve wondered in the past if the lack of TTS in the E Ink devices might be a deliberate way to pump up the sales of human-narrated books from Amazon’s Audible division. I’m not so sure now. Audio capabilities in Amazon’s future E Ink machines could open up a whole new market for Audible.

Furthermore, even TTS fans like me will on occasions pay extra for human-narrated books for enjoyment on read-aloud-capable devices. Nothing can substitute for both the text and the “sound track” of A Fighting Chance, as read so passionately by Elizabeth Warren herself (conservatives are very welcome to feel the same about their own favorites).

What’s more, as a Kindle Chronicles interview suggests, the creative folks at Audible are looking ahead to new approaches to add value to audiobooks.

Note #2: Because I’ve done so many updates, I’ve given the post a new date. It originally appeared Dec. 28, 2015.

Update, 1 p.m., Jan. 2, 2015: Both before and after Jeff Bezo’s purchase of the Washington Post, the newspaper has never run an item about the Paperwhite’s lack of text to speech, as best I can determine from Googling the newspaper’s site. Ditto for mention of TTS’s absence in the new Voyage. I’ll not speculate on the reasons. On December 29, I called this LibraryCity post to the attention of technology reporter Hayley Tsukayama and asked if it was possible she could follow up. No reply so far. I’ll retransmit the email to her later this week. Based on the ubiquity of the Paperwhite and the many complaints of the absence of TTS, as well as on its importance to the accessibility community, this topic in my opinion is undeniably newsworthy. Hayley, I  know you lead a busy life, writing so much of the tech section; but why not check out the lack of TTS? Even if it isn’t in the Paperwhite, it at least should be in the $200 Voyage.

Update, 1:20 p.m., Jan. 2, 2015: Via the FCC’s media relations office, I’ve queried Chair Thomas Wheeler on Kindle-related FCC issues. The agency in the past granted manufacturers a waiver, and on The Digital Reader site, you can find more background. In a post dated Feb. 7, 2014, TDR blogger Nate Hoffelder says TTS the waiver is a limited one and will be extended or expire Jan. 28, 2015. He notes there are other rules. Still, comment on this one would help. While it’s too late to make the official deadline, you should still write Rosaline Crawford at the FCC’s Consumer and Governmental Affairs Bureau. Her e-mail address is rosaline.crawford@fcc.gov. Let the FCC know how pathetic it would be for the waiver to apply even to a $200 machine.

“What is the current legal status of this matter?” I asked the FCC before running across Nate’s mention of the January 28th date. “Is there any chance that readers such as the Paperwhite and Voyage will need TTS in the future, under FCC requirements? While the manufacturers have raised price issues, the cost of a chip and headphone jack would be small. Furthermore, Amazon refuses to include TTS in the $200 Voyage E Ink device, hardly an economy machine. Does Chairman Wheeler have any thoughts on this issue? I'd also be curious if Mr. Wheeler would like to see a requirement for optional all-bolding or variable-weight fonts to increase perceived contrast—an issue especially of interest to some aging Americans with bad eyesight? Such features are in other machines like Kobo's but not in the most common series of readers, the Kindles; and Amazon's cost of adding them would be minuscule. Furthermore, note the all-bold capabilities of the Apple Web browser's readability mode. The inclusion of a typeface optimized for people with dyslexia also would be a good for e-reader devices and could happen at minimal cost. Meanwhile see https://www.librarycity.org/?p=11443. The same item will most likely be appearing in the next few days on the TeleRead e-book site.”

I’m following up with an e-mail asking about the January 28 expiration; almost surely the decision has not been made yet. I do see that the FCC on Sept. 29, 2014, asked for comment on the waiver extension, with a comment deadline of Oct. 27, 2014, and a deadline of Nov. 14, 2014, for replies to comments. Here is an anti-extension letter that an Ohio woman wrote apparently in time for the related deadline. Given the scarcity of publicity on this matter—are you listening, Ms. Tsukayama?—it’s hardly surprising that the legalities of the TTS issue have escaped the public’s notice.

Update, 3:20 p.m, Jan. 2, 2015:  I see the first note to the FCC somehow didn’t make it out of Gmail’s draft mode (probably my fault, not Gmail’s). I’ve sent the FCC a newer version. 

Update,  9:51 a.m., Jan. 3, 2015: Here’s one more thought on why Amazon’s marketers should not be able to get away with the saying, “Oh, text to speech is already in the Fire series.” The Fires are LCD machines. Some researchers—I won’t take sides here—maintain that the glow of a backlit LCD, at least when encountered too close to bedtime, can disrupt sleep cycles. By contrast, the new Kindles are front-lit, so you might as well be reading a paper book instead. That’s just one example of why we’re talking about two different kinds of machines. And don’t say, “Well, Fire owners can simply use TTS close to bedtime.” What if the users at the moment want to read their books the old-fashioned way? Simply put, e-readers are like hearing aids—the choice is a very personal one. Don’t let marketers get in the way, especially if Amazon cares about differentiating between the Voyage and the Paperwhite (although I still believe that the best solution morally and in business terms would TTS in both machines).

Update, 10:45 a.m., Jan. 3, 2015: Don’t neglect writing Amazon, either. Carly Rossi tells me the issues raised in my correspondence will be under discussion within the company. Start at the top and share your sentiments with jeff@amazon.com.

Update, 5:30  p.m., Jan. 3, 2015: In case you’re curious, the FCC requirement resulted from the 21st Century Communications and Video Accessibility Act signed by President Obama in 2010. It required “advanced communications services and equipment” to be accessible by people with disabilities (here and here). While the FCC has authority under the act to make exemptions, should it in this case? Most definitely not, given the cost-benefit ratio. Again, we’re not talking here about hardship to comply with the act in the case of a $200 Voyage—and almost surely not in the case of the Paperwhite, either. If nothing else, remember that Amazon sees e-readers as a way to encourage consumption of its content. So we’re looking beyond hardware manufacturing costs alone. In fact, more people reading on Kindles should be good for content consumption and add to the bottom line.

Update, 6:14, p.m. Jan. 3, 2015: I see that 125 blind people wrote the FCC early last year to oppose a permanent waiver. As quoted by the National Federation of the Blind, the FCC said at the time: “We limit the term of the waiver to one year…rather than grant the Coalition’s request for an indefinite waiver. We believe that, given the swift pace at which e-reader and tablet technologies are evolving and the expanding role of ACS in electronic devices, granting a waiver beyond this period is outweighed by the public interest and congressional intent to ensure that Americans with disabilities have access to advanced communications technologies.”

Update, 6:34 p.m., Jan. 3, 2015: Michael W. Perry, a long-time visitor to the TeleRead site, which also ran this post, offered oh-so-cogent comments there. I’ve just inserted a Perry quote at the top of the LibraryCity version and made other changes. His example of the need for TTS is more powerful than my own. And so are the arguments of the NFB on behalf of blind people. NFB President Marc Maurer has said that the ability to enjoy e-books and e-readers “is one of the most critical civil rights issues facing blind Americans in the twenty-first century, and we will do everything in our power to see that this right is secured.”

Update, 12:43, Jan. 5, 2015: Here’s the complete information I received from the FCC on the formal filing procedure for comments:

“The FCC’s rules require equipment used for advanced communications services (such as e-mail services) to be accessible to individuals with disabilities.   On January 28, 2014, the FCC waived those requirements for basic e-readers that have an Internet browser that can be used for advanced communications services.  A copy of that waiver order is available at https://apps.fcc.gov/edocs_public/attachmatch/DA-14-95A1.docx.
 
“The waiver will expire January 28, 2015.  A coalition of e-reader manufacturers petitioned the FCC to extend the waiver.  On September 26, 2014, the FCC released a public notice asking for public comment on the petition (https://apps.fcc.gov/edocs_public/attachmatch/DA-14-1403A1.docx).  Comments were due by October 27, 2014, and reply comment were due by November 5, 2014.
 
“As described in the public notice, the FCC will treat your message about e-readers as an “ex parte” communication because it was submitted after the comment and reply comment periods.  “Ex parte” communications must be filed in the FCC’s electronic comment filing system, which is available at http://apps.fcc.gov/ecfs/.  The FCC cannot consider “ex parte” communication in this proceeding that is not properly filed.  The “proceeding number” in this matter is 10-213.
 
“If you want the content of your e-mail message filed as an “ex parte” communication in this proceeding, please submit it electronically at http://apps.fcc.gov/ecfs/.  If you need assistance with the FCC’s electronic comment filing system, please let Caitlin Vogus know.  She can be reached at Caitlin.vogus@fcc.gov or at 202-418-1264.  She can submit the content of your e-mail message for you, but you must provide her with your full name and mailing address (street address, city, state, and zip code).  When filed, your name and mailing address, along with your ‘ex parte’ communication, will be available to the public on the Internet.”

Update, 3:46 p.m., Jan. 5: TeleRead commenter Frank Lowey has called attention to an overview of ADA-related laws. Is it possible that virtual bookstores and/or related devices could be "public accommodations" under the law? Perhaps somewhat like Web sites? Even if the FCC feels that this wouldn't apply here directly within its jurisdiction, perhaps Chairman Wheeler could broach the issue in a way that other parts of the US. government could follow up on. An option? If nothing else, this could help pave the way for a class action suit—or, even better, nudge Jeff Bezos into acting. Also, there is the issue of  employment. E-books will increasingly be part of job preparation and on-the-job training. That said, let’s hope that the FCC can act on behalf of TTS without other efforts being needed.

Similar Posts:

• Important: How to encourage Amazon to bring text to speech to the Kindle Paperwhite and other products where it’s AWOL
• National PTA asking Amazon about E Ink Kindles’ missing ‘read-aloud’; related Baltimore Sun op-ed now online
• How blind-friendly are Amazon’s Kindle apps for the iPhone and iPad? And what about those for other operating systems?
• No Paperwhite read-aloud for you! FCC again lets Amazon and friends diss people with disabilities
• No text to speech in Amazon’s new Paperwhite Kindles: Why? To push us toward Fire tablets and boost Amazon-owned Audible?