May 3, 2018 – The Wireless RERC submitted comments to the Federal Communications Commission in response to their Public Notice In the Matter of The Accessibility of Communications Technologies for the 2018 Biennial Report Required by the Twenty-First Century Communications and Video Accessibility Act [CG Docket No. 10-213]. In anticipation of this Public Notice, the Wireless RERC conducted a 2017 Mobile Phone Accessibility Review (Accessibility Review/Review). The Review included mobile phone models available as of September 2017 from the top four wireless carriers, one prepaid carrier, and five Lifeline Carriers. Researchers, using the providers’ web pages as a reference, identified 214 mobile phones for evaluation. Data were collected on 24 accessibility features (or features that impact accessibility) available in each phone model. Wireless RERC comments shared the results of the Accessibility Review. Additionally, the comments were informed by recently conducted focus groups on the use of “new communications technologies” by people with disabilities. Overall, the comments indicate that the accessibility of advanced communications technologies is improving. More accessibility features are available, and many of these features are customizable (e.g., the rate of speech for voice output, vibration adjustment, font adjustment, and more). These are much-appreciated gains. However, a perennial barrier to access, device setup, which quite literally allows the user to gain entry to the device, requires addressing to move the needle forward on people with disabilities’ independently accessing advanced communications technologies and services. Following are a few specifics from the comments:
- The researchers encountered difficulty in locating information about certain features. Consumers with disabilities may experience a similar problem when comparing models and selecting a phone to purchase. While people without disabilities can compare phone models based on preferences alone, people with disabilities may have accessibility requirements for the phone to be usable by them (e.g., video calling, HAC, screen reader, AT connection).
- Of the 214 phones, 0% of devices had full, out-of-the-box accessibility. The benefit of full, out-of-the-box accessibility is that it simplifies phone selection for people with varying capabilities and functional levels. If all phones were fully accessible, then people with disabilities could select from all available models. As it stands now, people with disabilities have a more limited selection, and more research is required on the part of the consumer prior to purchase.
- Input type can raise barriers that people with various types of disabilities may encounter when attempting to use mobile phone devices both smart and non-smartphones. Many smartphones require a degree of sight and dexterity that can be a limiting factor to users.
- Various disability groups are increasingly adopting smart speakers with intelligent agents, particularly the Amazon Echo and Amazon Dot with Alexa. Consumers who are blind or who have low vision, for whom graphical interfaces may not be accessible, as well as people with dexterity or mobility-related disabilities, for whom button or touchscreen control may pose a barrier to use, have cited the voice control features of these devices as useful.
- Consumers with limited dexterity or impaired hand function, such as people with spinal cord injury or multiple sclerosis, have indicated the potential usefulness of wearables in their own lives. For example, the ability to use near-field communication (NFC) for payments often simplifies what is a complex task for many users who find handling cash or cards to be difficult. However, they also have noted that complex gestures, such as multi-finger swipes, complicate their use of the devices.
- Consumers with disabilities who use wearables such as the Apple Watch discussed in great detail the effect that operating system updates may have on otherwise accessible or usable apps and menu structures for these devices. In a manner similar to smartphone system updates, users of these devices have expressed a desire to understand the effect of operating system updates on app accessibility through some means other than “trial and error.”