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.
