Hello, my name is Janice Schacter Lintz and I am the CEO of Hearing Access & Innovations (formerly known as the Hearing Access Program), which spearheaded most of the hearing induction loop projects around NYC, including subway information booths, taxis and museums. I am also the mother of a 20-year old daughter who is hard of hearing.
These bills are desperately needed. For the last 13 years, I have personally struggled as an advocate to get this access provided despite the ADA requiring it. Just as the Federal Civil Rights Act needed to be followed up with the Voter’s Rights Act, these bills are needed to ensure provision of effective communication. Without them, the burden is shifted to people like me to file complaints and sue.
• Intro 881: ADA Coordinator
Appointing an ADA coordinator is important for making sure that access is provided, and it is critical that a conscious effort be made to appoint someone who is hard of hearing. I would be hard pressed to name a single ADA coordinator who is hard of hearing, since ADA coordinators who have a hearing loss are usually, required to know sign language (ASL). This requirement doesn’t exist if the person has a disability other than hearing loss. Since most people with hearing loss are hard of hearing and seldom know ASL, it is absurd to solely make knowledge of sign language a requirement for people with hearing loss. The requirement should either be for everyone or no one. The lack of ADA coordinators who are hard of hearing is one reason why hearing access is often not implemented.
• Intro 883: Information on Disabilities
The bill is excellent but needs the following modifications:
Section 8-132 #2-Persons who are deaf should be changed to persons who are deaf or hard of hearing. CART is not solely used by people who are deaf but by the full spectrum of people with hearing loss.
Section8-132 #3- should include: “Neck loops must be available if an FM or infrared assistive listening system is provided instead of a hearing induction loop assistive listening system” to ensure that the full needs of the hearing loss spectrum are met: https://janiceslintz.files.wordpress.com/2015/05/effectiveaccess.pdf.
The ADA and technical installation term is “induction loop”. Some lay people use the term, “hearing loop.” The NYC TLC adopted “hearing induction loop” so it is clear to installers and users. Audio loop is never correct. The bill uses the term “induction loops” and not hearing loops. It is critical that the terms are all consistent to avoid confusion.
Section 8-132 #5-Contact information should include an email address for people who cannot use a phone.
• Intro 882: Induction Loop Bill
The hearing induction loop signal strength needs to be mandated. The proposed international ANSI standards should be achieved throughout the room:https://janiceslintz.files.wordpress.com/2015/10/proposal-7-19-a117-car_march-2013-complete-2.pdf This federal legislation is pending but I recommend it be included to ensure the systems installed work. Without it, shoddy contractors will see this as a golden opportunity. They will enter the field and install systems that fail to work. Systems that do not work are not effective access which is also why periodic testing needs to be required. Elevators are routinely tested and so should hearing induction loop systems.
Without a requirement that the full room be looped, some places will only loop part of the room, thus creating a “ghetto.” This is inappropriate. People with hearing loss should not be required to sit in certain sections rather than where they or their friends and family want to sit. Separate but equal is not appropriate for race nor for people with disabilities.
Attached is a more thorough explanation of telecoils that I wrote for the State of NJ and the Hearing Loss Association of America:
My comments about these bills are minor tweaks. The bills are fantastic and will be transformative for people who are hard of hearing. Thank you for your time.