Wireless RERC Research Informs the FCC’s 2020 Biennial Report to Congress

Filing Date
October 7th, 2020

The FCC submitted their 2020 Biennial Report to Congress [CG Docket No. 10-213; DA 20-1164] required by the Twenty-First Century Communications and Video Accessibility Act of 2010 (CVAA). Wireless RERC comments have been referenced thirty-three times throughout the Report. The first set of Wireless RERC observations included in the Report concerned smartphone accessibility. The Wireless RERC is referenced regarding its comment that its study included people who have “vision, hearing, cognitive, and mobility disabilities” and that the accessibility and usability of devices have “steadily increased,” but that “some gaps remain.” The Wireless RERC observation that voice technology helps people with cognitive disabilities send texts and emails is also noted. Regarding smart speakers, the Wireless RERC statement that the “inability of smart speakers to understand atypical speech patterns presents an accessibility barrier” is quoted. Additionally, Wireless RERC observations on Google’s Project Euphonia are noted -- how the project is seeking to make speech recognition systems accessible to people with atypical speech patterns through improved speech-to-text transcription for people who have significantly slurred speech.

The next set of Wireless RERC comments included are about alternative smart technologies. The Wireless RERC finding that successful technologies developed on smartphones are being replicated in other use cases is included, noting that the Wireless RERC survey included questions on smart speakers, tablets, smartwatches, and smart eyeglasses. The Wireless RERC finding about the recent inclusion of voice assistants with smart devices is also noted. Next, the Report includes the Wireless RERC’s note that smart speakers can enable users who are blind to access news and information and control smart home technologies independently. However, the Report includes the Wireless RERC comment that despite this, some smart home devices still require users with vision disabilities to rely on sighted assistance and that improving voice controls to match in-app options would improve device accessibility. Finally, this section of the Report recognizes the Wireless RERC’s assertion that users need more guidance on the available features that can be activated through voice control.

In relation to pairing with peripheral devices and related functionality, Wireless RERC support for the continued incorporation of “device-to-device connectivity” is noted. As Wireless RERC states, inter-device connectivity allows people with disabilities to use external assistive technologies, boosting their use of Internet of Things (IoT) devices that advance independent living and social inclusion. The Wireless RERC observation that biometric login is being included more broadly and limits dependency on memory and mobility/dexterity when unlocking a device is also noted.

Following pairing, comments about improvements in accessibility are included. The Wireless RERC noted that accessibility and usability have generally improved for “people with vision disabilities.” Further, the Wireless RERC commented that feature phones include various accessibility features like built-in text-to-speech, full access screen reader, braille access, and more are included in the Report. With regards to software updates in feature phones, the Wireless RERC statement that system updates have negatively impacted the user’s configuration of accessibility options was included in the Report to Congress. Overall, the Wireless RERC findings highlighted that mobile phones' accessibility has continued to improve, with most smartphone users being able to use them without help from other people.

Regarding usability, the Wireless RERC statement that sometimes providers do not provide an easily discoverable way to locate relevant information about accessibility features. The Wireless RERC is quoted in saying that the “difficulty in locating information about specific features is in itself an important result, […] as people with disabilities may have functional limitations [in comparing phone models] that necessitate certain accessibility features for the phone to be usable by them (e.g., video calling capabilities, HAC, screen reader, AT connection.” To address this barrier, the Report includes the Wireless RERC recommendation to train in-store employees about disability etiquette and accessibility features and provide a stable method of in-store customer support for those with disabilities.

In conclusion, concerning continued industry partnerships, the Report highlights the Wireless RERC encouragement for mobile manufacturers “to continue to incorporate users with disabilities into all stages of the design process” to improve accessibility and usability.

Additional Information: