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.
