The Wireless RERC filed reply comments in the FCC’s proceeding in the matter of Advanced Communication Provisions of the Twenty-First Century Communications and Video Accessibility Act of 2010 [CG Docket No. 10-213]; responding to comments filed by other stakeholders.
To view the filing.
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Wireless RERC Comments on Advanced Communications Technologies Rulemaking
The Wireless RERC filed comments with the FCC in the Notice of Proposed Rulemaking In The Matter of Implementation of Sections 716 and 717 of the Communications Act of 1934, as Enacted by the Twenty-First Century Communications and Video Accessibility Act of 2010 [CG Docket No. 10-213] Amendments to the Commission's Rules Implementing Sections 255 and 251(a)(2) of the Communications Act of 1934, as Enacted by the Telecommunications Act of 1996 [WT Docket No. 96-198] In the Matter of Accessible Mobile Phone Options for People who are Blind, Deaf-Blind, or Have Low Vision [CG Docket No. 10-145]. Some of the comments address circumstances under which manufacturers should be liable for the accessibility of third party Apps; the inclusion of text messaging functionality in social media services under the Commission’s definition of “electronic messaging services”; harmonization of Section 716 and Section 255 rules based on the Access Board Draft Guidelines; and ensuring Internet browsers on mobile phones are accessible to and usable by individuals who are blind or have a visual impairment. The Wireless RERC believes that the outcomes from this NPRM will benefit both people with disabilities and industry by reducing regulatory uncertainty through the harmonization of current and proposed accessibility rules, clearly defining the technologies/services that are covered under the CVAA, and updating important sections of the rules to ensure compatibility with current advanced communications modalities being used by people with disabilities. Read the full filing at [http://fjallfoss.fcc.gov/ecfs/document/view?id=7021340942]
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WiRERC Promotes Universal Design Mission in Comments to the FCC
The Wireless RERC filed reply comments in the FCC’s proceeding in the matter of Advanced Communication Provisions of the Twenty-First Century Communications and Video Accessibility Act of 2010 [CG Docket No. 10-213]. Comments addressed various sections of the proceeding, including defining Advanced Communication Service, the rules of construction, and the accessibility of information content. However, the main thrust of the Wireless RERC reply comments focused on ensuring that there is no technology that ends up falling outside the scope and intent of the Act; that all accessibility options are exhausted before a manufacturer determines that accessibility is not achievable, and that embracing universal design elements throughout all manufacturing stages is the optimal way of achieving accessibility for all. To access the full submission go to CG Docket No. 10-213
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Wireless RERC Weighs in on Accessible Mobile Phones Options
The Wireless RERC filed reply comments in Public Notice [CG 10-145] seeking comments on Accessible Mobile Phone Options for People who are Blind, Deaf-blind, or Have Low Vision. In the initial comment period, the FCC sought input on six questions that addressed the technical feasibility of accessibility solutions, features currently on the market place that are not accessible, cost of implementation, cost as an obstacle, and guidance on technical and policy solutions that would reduce barriers to mobile phone technology, service and information. The Wireless RERC replied to comments filed by CTIA – The Wireless Association, the American Foundation for the Blind, AT&T, and a consumer who identified himself as being blind. The comments, among other things, supported stakeholder involvement and awareness campaigns on accessible mobile phone options, recommended that information on accessible phone models be placed on the home page of companies’ websites, and addressed the impact that inaccessible cell phone features could have on the accessibility of the forthcoming Commercial Mobile Alert System. They also recommended that the software that provides voice control, speech-to-text, and text-to-speech/screenreader functionality become part of the standard (out-of-the-box) suite of capabilities of all wireless communication devices.
Wireless RERC Reply Comments
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Comments Filed Recommending EAS Rule Amendments
The State of Technology (SoT) Project of the Wireless RERC filed comments on May 14, 2010 in response to the FCC notice: Public Safety and Homeland Security Bureau Seeks Informal Comment Regarding Revisions to the FCC's Part 11 Rules Governing the Emergency Alert System Pending Adoption of the Common Alerting Protocol by the Federal Emergency Management Agency [EB Docket No. 04-296]. Comments emphasized the importance of including information for people with disabilities in all aspects of EAS alerts that reach the public, be it an actual emergency, or a test. Specifically recommending that Part 11 Rules amend 47 C.F.R. Part 11.51 to require EAS participants to transmit the portion of an EAS message as defined in paragraph 11.31(a)(3) both aurally and visually. The Wireless RERC is concerned that people who are hard of hearing or who are deaf are missing important visual information when they receive an EAS alert, because EAS participants are not required to present the audio portion of the EAS message visually. Additionally, comments addressed the development of state and local EAS plans, recommending that sections 11.20 (a) and (b) be amended to specify that any instructions that have been developed by emergency officials concerning people with disabilities be included in EAS plans. To access the full submission go to EB Docket No. 04-296
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WEC Files Comments Regarding Nationwide Testing of the Emergency Alert System
The State of Technology (SoT) Project of the Wireless RERC filed comments on February 18, 2010, in the FCC’s Second Further Notice of Proposed in the Matter of Review of the Emergency Alert System [EB Docket No. 04-296]. The FCC sought comments on revising Part 11 rules governing EAS to allow for periodic testing of EAS on a national scale. Though EAS was created to be a national alerting system, providing the president the capability to reach all US citizens simultaneously, it has never been used as such. Comments support the FCC’s efforts to revise the rules to explicitly require periodic nationwide testing, but emphasized that consideration of people with disabilities in all aspects of EAS, including testing, is necessary. Specifically, comments expressed concerns that EAS participants that are required to transmit both the audio and visual components of an EAN message, only have to transmit certain elements in the digital header portion of the EAN message visually. Persons who are deaf or hard of hearing will only see certain message elements and not hear the audio that this is a test. Comments suggested that those EAS participants that transmit video be required to transmit an open caption stating that this is a test. Other items addressed were reporting requirements of the nationwide test results and vulnerabilities to the system, especially how the alerts are made accessible to people with disabilities. To access the full submission go to EB Docket No. 04-296.
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WEC Files Comments Regarding Service Rules for Public Safety Spectrum
06.19.2008 – The Wireless Emergency Communications (WEC) Project of the Wireless RERC filed comments in the FCC’s Second Further Notice of Proposed Rulemaking regarding the service rules for the re-auction of the 700Mhz D-block spectrum [WT Docket No. 06-150 and PS Docket No. 06-229]. The D-block was set aside to be a public-private partnership between public safety and the commercial winner of the license. However, the initial auction of the D-block failed to receive a bid that met the reserve price. The FCC sought comment on service rules that would encourage a successful bid for public-private partnership that is mutually beneficial to public safety and the commercial provider and/or recommendations for achieving public safety goals without requiring a public-private partnership.
To access the full submission go to WT Docket No. 06-150 and PS Docket No. 06-229
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CACP filed comments in response to the FCC's Notice of Inquiry
In the Matter of A National Broadband Plan for Our Future, GN Docket No. 09-51, was adopted and released April 8, 2009. The NOI is seeking comment on (i) what it means for a person with disabilities to have access to and use of broadband networks; (ii) how broadband services impact persons with disabilities' ability to communicate; and (iii) how the needs of people with disabilities should be included in the national broadband plan. Comments, filed June 8, 2009: (1) urged FCC to analyze and seek to understand the availability, affordability and usability of broadband among people with disabilities; (2) suggested the FCC disaggregate broadband usage based on type of disability, income, employment status, level of education and race; (3) provided statistical input about the disability community for inclusion in the national broadband plan; (4) recommended the FCC include all stakeholder concerns by holding regional workshops for collaborative efforts in developing and implementing a national plan beyond the typical rulemaking and formation of special study groups. To access the full submission go to GN Docket No. 09-51.
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CACP submitted comments in response to the FCC’s Public Notice #4
CACP submitted comments in response to the FCC’s Public Notice #4, Broadband Accessibility for People with Disabilities Workshop II: Barriers, Opportunities, and Policy Recommendations, (GN Docket Nos. 09-47, 09-51, 09-137) released on September 18, 2009. Comments centered around issues regarding accessibility of equipment and services accessibility, public safety applications within a broadband environment and the role that industry could play in facilitating accessibility.
To access the full submission go to GN Docket Nos. 09-47, 09-51, 09-137.
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Federal Communications Commission, Washington, D.C. Filings on Regulatory Rulemakings:
Helena Mitchell, Frank Lucia and Ed Price filed comments in response to FCC Notice of Proposed Rulemaking regarding the Commercial Mobile Alert System Docket No. 02-857. Federal Communications Commission: Washington, DC, 4, February 2008. The comments specifically addressed recommendations on expediting the availability of the CMAS to the American public; ways to encourage wireless carriers’ participation in CMAS; and ensuring that the elderly and people with disabilities are included in any planning for emergency alerting systems.
To access the full submission go to Docket No. 02-857
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Wireless RERC files FCC comments on “Amendment of the Commission’s Rules Governing Hearing Aid Compatible Mobile Handsets”, WT Docket No. 07-250
On Dec. 16, 2007 the Wireless RERC filed comments to the FCC on Amendment of the Commission’s Rules Governing Hearing Aid Compatible Mobile Handsets, WT Docket No. 07-250. The Wireless RERC noted in response to the FCC’s solicitation that ongoing Wireless RERC research suggests that consumers continue to have problems with the interoperability of cell phones and hearing aids. In a recent Wireless RERC Delphi Policy study, an overwhelming majority of respondents identified “device incompatibility or poor interoperability,” as a very important or important issue with cell phones. Further, the Wireless RERC's Survey of User Needs (2002-present) continues to find evidence that consumers with hearing impairments have difficulty finding cell phones in the marketplace that are compatible enough with hearing aids. These findings reveal that cell phone users with hearing impairments are running up against barriers to full usability of their device, which could be addressed through the regulatory process.
To access the full submission go to WT Docket No. 07-250
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Filing on Reallocation of 30 MHz of 700 MHz Spectrum for Public Safety Use
The Wireless RERC submitted comments to the FCC on November 29, 2006, addressing issues involved with use and reallocation of a portion of the 700 MHz spectrum in response to a Petition for Rulemaking: Cyren Call Communications Corporation – Reallocation of 30 MHz of 700 MHz Spectrum from Commercial Use – Assignment of 30 MHz of 700 MHz Spectrum to the Public Safety Broadband Trust for Deployment of a Shared Public Safety/Commercial Next Generation Wireless Network. The proposal, by Cyren Call Communications Corporation was to reallocate 30 MHz of 700 MHz spectrum for deployment of a shared public safety/commercial next generation wireless network. The RERC comments raised several points including 1) support of the recommendations to reallocate additional spectrum for public/private use; 2) a recommendation that the design of any network as well as wireless emergency communications applications needed to consider the needs of people with disabilities; 3) a recommendation that any network developed should be in consultation with other stakeholders such as the Department of Homeland Security to ensure it interfaces with other critical warning networks; and 4) a statement that emphasized that spectrum allocation for public safety or any reallocation of spectrum for public safety take into account the accessibility requirements of people with disabilities. The filing will be available on the RERC website or via access from the FCC e-filing system.
To access the full submission go to Reallocation of 30 MHz of 700 MHz Spectrum for Public Safety Use
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First Report & Order and Further Notice of Proposed Rulemaking (FCC 04-296) about the future of the Emergency Alert System (EAS)
CACP comments recommended a major upgrade of EAS, including mandatory participation by broadcast stations, and an expansion of EAS rules to cover new digital technologies, and expanding EAS to new devices as essential an for providing emergency information to people with disabilities. New technological pathways for EAS communications include wireless data networks that reach millions of Americans in remote locations, both fixed and mobile. CACP also recommended more comprehensive planning and coordination among state and federal agencies and focused on the benefits of digital and alternative technologies for people with disabilities.
To access the full submission go to First Report & Order and Further Notice of Proposed Rulemaking (FCC 04-296)
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Notice of Proposed Rulemaking (FCC 04-296) about the future of the Emergency Alert System (EAS)
CACP recommended that the FCC further encourage and support IP Relay and comparable text messaging services for wireless devices, recommended making IP Relay mandatory for states, requiring services to be offered 24 hours per day, 7 days a week, and promoting open standards that will allow multiple platforms for text-to-text communication to flourish. The wireless RERC suggested that the FCC encourage wireless manufacturers to build in TTY capability so as to enable more reliable emergency communications for users with disabilities.
To access the full submission go to Notice of Proposed Rulemaking (FCC 04-296)
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Inquiry Concerning the Deployment of Advanced Telecommunications Capability to All Americans in a Reasonable and Timely Fashion, and Possible Steps to Accelerate Such deployment Pursuant to Section 706 of the Telecommunications Act of 1996, GN Docket No. 07-45
On May 16, 2007 the Wireless RERC submitted comments to the FCC in the above-referenced matter in response to the Notice of Inquiry adopted on March 12, 2007. In general the comments addressed the potential for advanced telecommunications to provide greater opportunities for people with disabilities to participate more fully in society (i.e., telework, telemedicine). On the same token, these same advanced telecommunication technologies have significant barriers to access by people with disabilities such as cost, awareness and proficiency factors, and technologically related barriers. Specifically comments address the availability of broadband connectivity, Video Relay Services, access to emergency communications, and the need for special consideration of the unique characteristics and specific needs of vulnerable populations by both public and private sector actors.
To access the full submission go to GN Docket No. 07-45
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Telecommunications Relay Services and Speech-to-Speech Services for Individuals with Hearing and Speech Disabilities, Second Report on Order, Order on Reconsideration and Notice of Proposed Rulemaking (FCC 03-123)
In responding to comments filed by various advocacy groups for the deaf and hard of hearing, CACP emphasized to the FCC the importance of providing parity of service with respect to emergency communications and expand TRS requirements so as to allow text messages to become a regular part of emergency communication services.
To access the full submission go to Notice of Proposed Rulemaking (FCC 03-123)
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