12.17.2012 - The Wireless RERC filed comments with the Federal Communications Commission (FCC) in response to their Notice of Proposed Rulemaking In the Matter of Accessible Emergency Information, and Apparatus Requirements for Emergency Information and Video Description: Implementation of the Twenty-First Century Communications and Video Accessibility Act of 2010. The comments highlighted research findings of the Wireless RERC concerning the accessibility of emergency alerts, including that people with vision loss consistently encounter challenges in accessing the content of emergency information when there is no audio version of the on-screen information. Though the Wireless RERC endorsed the use of text-to-speech (TTS) technology to provide simultaneous audio of the text crawl, we recommended that the TTS be required to be of high quality to ensure that the audio information is clear and understandable. In order to provide guidance on TTS quality, we recommended that the Video Programming Accessibility Advisory Committee (VPAAC) be tasked with identifying and examining extant standards on the provision of TTS to determine quality assurance parameters.
Additionally, Wireless RERC comments addressed the use of abbreviations, describing non-text emergency information such as maps, alternate means of compliance, and the policy implications of live IP-delivered programming.
Comments of the Wireless RERC
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WIRELESS RERC GIVES INPUT ON THE TRANSITION TO NG9-1-1
12.11.2012 - The Wireless RERC filed comments with the Federal Communications Commission (FCC) in response to their Public Notice In the Matter of Public Safety and Homeland Security Bureau Seeks Comment on the Legal and Statutory Framework for Next Generation 9-1-1 Services Pursuant to the Next Generation 9-1-1 Advancement Act of 2012. The comments recommended state level coordination of the transition to NG9-1-1, noting such coordination would aid in outreach efforts once NG9-1-1 services are implemented, for example in streamlining the resources needed to create materials in alternate formats and modalities (Braille documents, captioned video, accessible electronic information). In addition the Wireless RERC pointed out that it would be more effective to execute a statewide campaign that educates citizens on NG9-1-1 capabilities and limitations, compared with local campaigns. The Wireless RERC also recommended that states be required to designate a state agency to oversee the transition, and ensure that a portion of funds collected from subscribers’ fees for 911 services be earmarked for efforts to facilitate the transition to NG9-1-1.
Beyond state level coordination, the Wireless RERC addressed the role of the federal government, recommending that it should make certain that NG9-1-1 be implemented in a manner that ensures the accessibility of the system to people with disabilities, as well as the accessibility of ancillary activities such as outreach. Federal ownership of the disability/accessibility implementation issues was urged for reasons of both efficiency and expertise. We recommended that the Consumer and Governmental Affairs Bureau’s (CGB) Emergency Access Advisory Committee (EAAC) be responsible for facilitating compliance with disability access requirements dictated not only by the Communications and Video Accessibility Act of 2010 (CVAA), but also by Title II and Title IV of the Americans with Disabilities Act. This would allow for cross-coordination of pro-active initiatives such as education, public outreach, and enforcement. Specific recommendations regarding compliance, enforcement, guidelines, and mapping are also detailed in the filing.
Wireless RERC Comments on Test of National EAS System
03.22.2012 – The Wireless RERC filed ex parte comments with the FCC regarding the national test of the Emergency Alert System (EAS) conducted on November 9, 2011. The comments were submitted in the form of the Wireless RERC’s Report on the National EAS Test On-line Survey and Focus Group Findings. From November 2, 2011 through November 18, 2011, the Wireless RERC conducted two surveys, one prior to the November 9th national EAS test and the other following the test. Four hundred and three (403) people responded to the pre and post-EAS test surveys. [Wireless RERC article]
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Wireless RERC Reply Comments to Facilitating the Deployment of Text-to-911 and Other Next Generation 911 Applications
Reply comments filed in response to Facilitating the Deployment of Text-to-911 and Other Next Generation 911 Applications [PS 11-153 and PS 10-255]. Federal Communications Commission: Washington, DC, January 10, 2012.
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WIRELESS RERC COMMENTS ON STRATEGIC PLAN FOR SECTION 508
On April 16, 2012 the Wireless RERC submitted comments with the Office of Public Engagement concerning the strategic plan for implementation and management of Section 508 of the Rehabilitation Act. Section 508 establishes standards in relation to various accessibility aspects of Information and Communication Technology (ICT) including functional performance, technical requirements, hardware and audio output functionality, real time simultaneous conversation via audio, text, and video, and product support and services. Comments by the Wireless RERC addressed various aspects of the plan and emphasized education of Section 508 compliance for employees. Recommendations included educating agency procurement officers on how to assess the accessibility of equipment and software; incorporating Section 508 compliance within IT departments, offering professional development classes for installation and maintenance of assistive technology, as well as offering quarterly webinars on Section 508 compliance, and recruiting Alternative Media Specialists to ensure the accessibility of electronic information. In order to increase transparency of government actions, the Wireless RERC recommended that all agencies place a link on their webpages informing users of the 508 complaint process as well as requiring the Department of Justice to make their Biennial Report on Federal Agency Section 508 compliance publically available.
Wireless RERC Section 508 Comments
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WIRELESS RERC RECOMMENDS ACCESSIBILITY CONCERNS BE INCLUDED IN THE NTIA CPS SUPPLEMENT
On May 31, 2012 the Wireless RERC filed comments with the Department of Commerce “In the Matter of Computer and Internet Use Supplement to the Census Bureau’s Current Population Survey” [FR Doc. 2012-8103]. The comments responded to a proposal by The Department of Commerce’s National Telecommunications and Information Administration to add twelve questions to the Current Population Survey (CPS) Computer and Internet Use Supplement. The comments highlight that broadband availability, affordability and accessibility are directly important for people with disabilities. Specifically, for many deaf and hard of hearing people, broadband applications encompassing text and video-based communications and data access are their most important broadband wireless device functions. Therefore, the Wireless RERC proposed that additional demographic questions should be added to the CPS asking respondents to self-identify if they have a disability, allowing for the determination of specific trends amongst disability populations. In addition, the comments proposed to include questions concerning if an individual utilizes assistive technology to access the Internet and its content, and if accessibility issues or the cost of assistive technology were concerns when purchasing broadband services or equipment.
Wireless RERC Comments
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WIRELESS RERC COMMENTS ON NIDRR LONG RANGE PLAN
On June 18, 2012 the Wireless RERC submitted comments to the Department of Education in response to their notice In the Matter of National Institute on Disability and Rehabilitation Research (NIDRR); Notice of Proposed Long-Range Plan for Fiscal Years 2013 - 2017 [FR Doc. No. 2012-9365]. The proposed Long-Range Plan included objectives such as ensuring that research, development and other activities are balanced between areas of focus including employment, community living, and health, and that supporting projects that have potential benefit for multiple groups of people with disabilities. Wireless RERC comments highlighted that mainstream wireless technologies are allowing for opportunities to enhance independence and improve community participation for people with disabilities and may have a direct impact on the areas of focus mentioned in the plan. Current trends demonstrate that not only do people with disabilities utilize wireless technologies at the same rates as people without disabilities but that many people with and without disabilities utilize wireless technologies in an assistive manner, such as in receiving turn-by-turn directions. Wireless RERC comments to the NIDRR Long-Range Plan thus suggested that certain objectives within the plan include explicit references to accessible mainstream technologies in addition to assistive technologies in order to impact how the objectives are interpreted by those responsible for implementation.
On April 4, 2013, the final version of the NIDRR Long-Range Plan for Fiscal Years 2013 – 2017 was published in the Federal register [FR Doc No: 2013-07879] and included Wireless RERC recommendation to “expressly acknowledge that individuals with disabilities interact with several environments, including specifically and increasingly a technological environment...[Hence] The technology for Access and Function section of the Plan has been revised to reflect the importance of the technology environment with which persons with disabilities interact.”
Wireless RERC Comments
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