CACP on the Record: Gaps and Growth in Accessibility & Usability Advanced Communications Technologies

Filing Date
August 8th, 2022

The Center for Advanced Communications Policy (CACP) submitted comments to the Federal Communications Commission (FCC) in response to their Public Notice Consumer and Governmental Affairs Bureau Seeks Comment on Tentative Findings for the 2022 Twenty-First Century Communications and Video Accessibility Act (CVAA) Biennial Report [CG Docket No. 10-213]. In preparation for the 2022 CVAA Biennial Report, and request for comments, CACP conducted its 2022 Mobile Phone Accessibility Review (Review). The Review included mobile phone models available through April 2022 from the top four wireless carriers, one prepaid carrier, and five Lifeline carriers. Results indicated that, in the aggregate, growth has continued in the inclusion of accessibility features for people with a wide range of disabilities. After disaggregating this data, the sampled mobile phones in 2022 outperformed those in 2020 in most accessibility features. Despite this growth, CACP noted some challenges with manufacturers' compliance with the usability and accessibility of telecommunications and advanced communications equipment, as defined by the CVAA's Sections 255, 716, and 718. Based on the data presented in the comments, CACP offered the following recommendations:

  1. We urged the FCC to develop cohesive and defined standards for manufacturers' product instructions, information, and services, particularly those surrounding accessible feature information.
  2. There also is a need to standardize "usable" product information and instructions as manufacturers widely vary on what and how they share this vital information.
  3. There is also a need for standardization around "minimum" compliance for accessibility by Lifeline carriers receiving federal subsidies.
  4. We recommend increasing the percentage of phones with Braille display support.
  5. We recommend increasing the percentage of phones with an M4/T4 HAC rating to improve the quality of mobile phone accessibility for people who utilize hearing aids.
  6. As a result of the increase in Mirror Link indicating an increase in connected vehicle technology, the accessibility of in-vehicle technology extends to the accessibility of smartphones and vice versa. With 65% of persons with disabilities being drivers,[1] we recommend teasing out any accessibility gaps that may exist between the connected car technology and smartphones.
  7. Finally, as mobile manufacturers continue to progress, we urge the FCC and Congress to consider how the accessibility of mobile devices intersects with access to wireless emergency communications.

Read CACP's full comments here


[1] Bureau of Transportation Statistics (2011). Data Analysis.