Regulatory Impact: Wireless RERC Helps to Advance Access to Technology

Filing Date
January 1st, 2011

The Wireless RERC’s comments filed in the FCC Notice of Proposed Rulemaking concerning implementation of the Communications and Video Accessibility Act [CG Docket No. 10-213] [WT Docket No. 96-198] [CG Docket No. 10-145] were included in the recently released (R&O) concerning the same and helped to inform the final rules. Specifically, the Wireless RERC recommended that text messaging functionality in social media services fall under the Commission’s definition of "electronic messaging services." In the R&O the FCC concluded that electronic messaging services made available through social networking sites are covered by Sections 716 and 717. Additionally, the R&O agreed with Wireless RERC comments regarding harmonization of Section 716 and Section 255 rules based on the Access Board Draft Guidelines. “We agree with the Wireless RERC that this approach will “reduce both the potential for misunderstanding as well as the regulatory cost of compliance” and promote “the objective of consistency.” In total, Wireless RERC comments were included in the rulemaking text and/or cited ten times. This is noteworthy because it advances access to wireless technologies by people with disabilities and reinforces the importance of participating in the rulemaking process. To that end, we encourage all stakeholders to review and comment on the portion of the above-referenced document. The FNPRM seeks comment on small business exemptions, the accessibility of Internet browsers on mobile phones, how to achieve interoperability of video conferencing services; video mail coverage, information content accessibility; and other items. Initial comments are due 45 days after publication in the Federal Register and reply comments are due 75 days thereafter.