April 2020 - The Wireless RERC submitted comments to the Federal Communications Commission in response to their Public Notice In the Matter of The Accessibility of Communications Technologies for the 2020 Biennial Report Required by the Twenty-First Century Communications and Video Accessibility Act[CG Docket No. 10-213]. In anticipation of the Public Notice, the Wireless RERC conducted a 2019/20Mobile Phone Accessibility Review (Accessibility Review/Review). The Review included mobile phone models available up to February 2020 from the top four wireless carriers, one prepaid carrier, and five Lifeline Carriers. Data analysis for the Review is still underway and will inform future comments in response to the FCC's Preliminary Findings Report. For this filing, however, we provided input based on the analysis of the subsample of Lifeline-provided mobile phones. Additionally, the comments were informed by the results of our cornerstone survey on wireless technology use by people with disabilities, the Survey of User Needs (SUN). Overall, the comments indicated the industry's growth in the accessibility and affordability of advanced communications technologies, as evidenced by the increasing presence and richness of new accessibility features on Lifeline-provided mobile devices. Furthermore, SUN analysis found that a majority of respondents with disabilities indicated that both basic cell phones and smartphones were easy to use. However, some access gaps remain, particularly regarding new communications technologies. Based on the data presented in the comments, the Wireless RERC offered the following recommendations:
- To better ensure access to emergency alerts for users with disabilities that prefer non-smartphones, increase the percentage of non-smartphones that are WEA-capable.
- To improve total access to the systems and devices, companies should explore and develop solutions for how one who is blind would be able to independently set-up the technology.
- Increased attention should be paid to ensuring access by people who are Deaf to smart speaker technologies that have a screen (e.g., Amazon Echo Show), such as the development of a gesture interface that understands ASL.
- To improve access by those with non-standard speech to smart speakers and voice input on mobile devices, we encourage the inclusion of AI that has been trained to understand those with atypical speech patterns.
 Phone models were identified in October 2019, and again in February 2020, at which time, additional phone models were available.
 A random number generator was used to select five Lifeline carriers for inclusion in the review.