Regulatory Filings FY 2016

Wireless RERC on the Record – Advancing Access Top Wireless Emergency Alerts

December 2016 - Georgia Tech’s Center for Advanced Communications Policy (CACP), in collaboration with the Wireless RERC, submitted comments to the FCC’s Further Notice of Proposed Rulemaking In the Matter of Wireless Emergency Alerts (WEA) [PS Docket. No. 15-91]. Wireless RERC and CACP survey research (2013-2015) on WEA informed the comments. Following is a sample of the recommendations:
- We support extending WEA rules to include tablets and other mobile devices, including wearable and other nontraditional communications devices. However, for WEA’s received on tablets and wearables to be effective, visual, haptic, and audio signaling capabilities will likely have to be incorporated into the technologies to support the WEA notification signal requirements.
- If the outcome of the rulemaking defines WEA participation, then all providers should be required to renew their elections to ensure congruence with the new definitions.
- With the increase in the maximum character length of WEA messages, the inclusion of URLs and dialable numbers, we anticipate an exponential increase in the need for people to be able to recall and review the message. As such, we agree with the FCC’s proposal to amend the rules to require that WEA messages be saved until the message expires.
- Before deploying the universal use of symbology in the WEA message, we echo CSRIC IV and V’s recommendation to conduct user-experience studies. However, we urge that the studies be inclusive of people with a variety of disabilities, whose primary language is non-English (spoken or signed), and people with varying levels of literacy. If the symbology is meant to improve message comprehension, the test participants need to reflect the users that stand to benefit the most.
- We recommend that mobile phone manufacturers design WEA-capable handsets with the capability to adjust the strength of the vibration and sound and to include a light feature (Center for Advanced Communications Policy, 2015).[1] The vibration motors in current WEA-capable handsets may not be strong enough to alert users of WEA messages reliably, and thus manufacturers would need to design phone models with the goal of increasing the effectiveness of vibration and the other signaling features in mind.
The recommendations made in the comments are intended to maximizing message diffusion and ensure the same timely and effective access to alerts and warnings for people with disabilities. The full document can be accessed via the link below.
Additional Information
Wireless RERC/CACP Comments [Word], [PDF]


Wireless RERC on the Record – Broadband Research Agenda

October 10, 2016 – The Wireless RERC, in collaboration with Georgia Tech’s Center for Advanced Communications Policy (CACP), submitted comments in response to the National Telecommunications and Information Administration (NTIA) and the National Science Foundation (NSF) request for public comments to inform the development of a National Broadband Research Agenda. Comments suggested several avenues of research to ensure that development and deployment of broadband connectivity and applications are accessible to and usable by people with disabilities. Some of the Wireless RERC and CACP suggestions for the national research agenda include:
- The collection of evidence-based statistical user needs data and conduct of summative research to understand not only technological but social, cultural and usage barriers to deployment and access for all citizens.
- Undertaking deep-dive research to examine the optimal speed of broadband transmission and deployment of broadband equipment, software, and content, and front-end consultation and testing with consumers is critical to improvements in both expanding broadband infrastructure as well as for accessible end products and services.
- Identify technological barriers to using these technologies as well as develop device prototypes and processes for inclusive technologies.
- Explore: 1) technology driven collaborative practices, 2) interoperability barriers, and 3) translation barriers between federally funded research, technology manufacturers and services providers.
The CACP and the Wireless RERC emphasized the importance of including accessibility for people with disabilities to the greatest extent possible as part of the conceptualization and articulation of the research agenda. We urged that 1) accessibility implications of future connected technologies be a high‐level consideration when planning federal level technology development strategies and policy, and 2) proactively consult people with disabilities throughout the development and implementation of the National Broadband Research Agenda.
Additional Information
Wireless RERC/CACP Comments [Word], [PDF]


Wireless RERC on the Record: FCC's Section 504 Compliance

October 3, 2016 - Georgia Tech’s Center for Advanced Communications Policy (CACP), in collaboration with the Wireless RERC, submitted comments to the Public Notice, Request for Comment on the Commission’s Policies and Practices to Ensure Compliance with Sections 504 of the Rehabilitation Act of 1973 [CG Docket No. 10-162]. Section 504 requires that federal agencies make their programs and activities accessible to people with disabilities. The FCC sought public input on their programmatic access. Wireless RERC comments asserted that baseline accessibility is consistently impacted by access to customer service and print and electronic materials furnished by industry and policy makers alike. To improve access to programs and services, we recommend addressing fundamental issues of awareness and accessible formats. The FCC’s American Sign Language (ASL) Consumer Support Line, launched to provide programmatic access to consumers who are deaf and hard of hearing whose primary language is ASL, was commended as a great step forward in providing parity of access. The support line enables the caller to make inquiries about disability-specific communications issues, as well as, obtain information that could impact any consumer, using their primary language. However, work remains to expand access to the rulemaking process. One part of the FCC’s Section 504 Handbook stipulated that the Commission will not transcribe or translate comments submitted in alternative formats. The Wireless RERC urged the Commission to reconsider this position. As it stands, the requirement that comments be filed in written English excludes people who rely on ASL from participating in the rulemaking process. Other comments addressed:
1. Ensuring the Accessibility Clearinghouse is prominently displayed on the website and its contents are reflective of consumer expectations and the evolution of technologies.
2. Adding a statement about relating to the person-first and using person-first language in written and verbal communications to the Section 504 Handbook’s Basic Principles of Access section.
3. Providing more detailed guidance on accessible print and electronic documents to improve FCC personnel’s awareness about and capability to deliver, accessible formats.
Additional Information
Wireless RERC Comments


Wireless RERC on the Record: Advancing Access to Emergency Alerting

June 8, 2016 - Georgia Tech’s Center for Advanced Communications Policy (CACP), in collaboration with the Wireless RERC, submitted comments to the Notice of Proposed Rulemaking (NPRM) In the Matter of Amendment of Part 11 of the Commission’s Rules Regarding the Emergency Alert System [15-94]; Wireless Emergency Alerts [PS Docket No.15-91]. The proposed changes in the NPRM are intended to strengthen the emergency alerting systems and to increase their effectiveness at prompting the public to take the appropriate protective actions.
Additional Information
Wireless RERC Comments


Wireless RERC on the Record: Potential Roles for the Government in Fostering the Advancement of the IoT

June 1, 2016 - The Wireless RERC, in collaboration with Georgia Tech’s Center for Advanced Communications Policy (CACP), and the Center for the Development and Application of Internet of Things Technologies (CDAIT), Georgia Tech Research Institute, filed comments to support to The National Telecommunications and Information Administration's (NTIA) inquiry: “Notice, Request for Public Comment, The Benefits, Challenges, and Potential Roles for the Government in Fostering the Advancement of the Internet of Things [Docket No. 160331306–6306–01], in which the National Telecommunications and Information Administration (NTIA) seeks broad input from all interested stakeholders—including the private industry, researchers, academia, and civil society on the potential benefits and challenges of the Internet of Things (IoT) and what role, if any, the U.S. Government should play in this area.
Additional Information
Wireless RERC Comments


Wireless RERC on the Record: Volume Control Standards for Hearing Aid Compatibility

February 26, 2016 - The Wireless RERC, in collaboration with Georgia Tech’s Center for Advanced Communications Policy (CACP) filed comments before the FCC in response to the Notice of Proposed Rulemaking (NPRM) In the Matter of Access to Telecommunications Equipment and Services by Persons with Disabilities [CG Docket No. 12-32]; Petition for Rulemaking Filed by the Telecommunication Industry Association Regarding Hearing Aid Compatibility Volume Control Requirements [CG Docket No.13-46]; Amendment of the Commission’s Rules Governing Hearing Aid-Compatible Mobile Handsets [WT Docket No. 07-250]; Comment Sought on 2010 Review of Hearing Aid Compatibility Regulations [WT Docket No. 10-254].
Additional Information
Wireless RERC Comments


Wireless RERC on the Record: Wireless Emergency Alerts & Accessibility

January 13, 2016 - The Wireless RERC, in collaboration with Georgia Tech’s Center for Advanced Communications Policy (CACP), added their expertise to support several of the proposed enhancements to the Wireless Emergency Alerts (WEA) system. In a Notice of Proposed Rulemaking released by the FCC In the Matter of Improving Wireless Emergency Alerts and Community Initiated Alerting [PS Docket 15-91], the FCC requested stakeholder input on several ways to enhance the effectiveness and content of WEA messages.
Additional Information
Wireless RERC Comments