Policy Filings

July 6, 2021 – The Wireless RERC submitted reply comments in response to the FCC’s Public Notice Update on Commission's Fulfillment Of The Twenty-First Century Communications And Video Accessibility [GN Docket No. 21-140]. We agreed with the American Council of the Blind (ACB) statement that "The Commission should review how people with multiple disabilities are served by accessible communications technology and services. This should be done with a very wide lens to encompass all forms of sensory, cognitive, and physical disability." We cited that our studies have found that accessibility features are not uniformly available in all phone models, and gaps in the accessibility experience persist, especially for people with co-occurring disabilities. The comments of the Alliance of Automotive Innovation provided us the opportunity to state “that accessibility innovations should be co-created with consumers with disabilities and that the automotive industry adheres to CVAA requirements to include people with disabilities in the design and development phases of advanced communications features incorporated into connected and automated vehicles. It is essential to proactively include stakeholders within the disability community in AV design and development to enhance the utility of this technology for people with disabilities.”

In response to CTIA’s comments, we addressed ensuring that consumers with disabilities are aware of device features. At a recent focus group comprised of individuals who are blind, a participant, while discussing his use of the iPhone, stated he wanted to connect it to Alexa, "but I'm not sure if there is an Alexa app." We asserted that attending to issues of independent setup and accessible documentation and communication of device features speaks to the "usability" requirements of the CVAA. "A product or service is "usable" if it provides individuals with disabilities with the full functionality and documentation for the product or service, including instructions, product or service information (including accessible feature information), customer support, and technical support."^[1] Regarding technical support specifically, CTIA commented that "Recently, Apple announced new accessibility features, including AssistiveTouch to watchOS, which allows users with mobility limitations to control their device, and SignTime, which enables people who are deaf and hard of hearing to communicate with AppleCare and Apple Retail staff in sign language." Excellent!  We hope that such accessible and inclusive business practices become the industry standard.  [Source: Wireless RERC]

May 2021 — The Wireless RERC submitted reply comments to the FCC in response to their Notice of Proposed Rulemaking and Notice of Inquiry in The Matter of Amendment of Part II of the Commission’s Rules Regarding the Emergency Alert System and Wireless Emergency Alerts [PS Docket No. 15-94; 15-91]. In our reply comments, we indicated support for expanding the Presidential alert class to allow activation by FEMA. By expanding the alert class, agencies responsible for detecting the threat have the authority to issue the alert.  We also concurred with CTIA and NYCEM’s recommendations to relabel the alerts “Federal” instead of “Presidential” or “National” because of news response regarding public perceptions of this label. We also agree that the term presidential is unfortunately inflammatory and may elicit responses contrary to the intention of the emergency message specifically (e.g., protective action) and the system entirely (i.e., public trust) because a small qualitative study of Georgia Tech personnel in 2018 showed that mobile phone users mentioned a preference for receiving the WEA test without the title "Presidential Alert" and would like to have seen the notification titled along the lines of "National WEA Test." As asserted by CTIA, "the effectiveness of emergency alerting will be lost if people simply ignore or opt-out of receiving these critical messages." Finally, the WirelessRERC supported previous recommendations to alert the public about new alert labels based on our survey data on WEA response based on user knowledge.

September 2020 – The Wireless RERC, in collaboration with Georgia Tech’s Center for the Development and Application of Internet of Things Technologies and Center for Advanced Communications Policy submitted comments to the Department of Commerce on September 17^th in response to their Public Notice NTIA Internet Use Survey Questionnaire Development [Docket No. 200813-0218]. This survey is one of the NTIA’s long-standing questionnaires and is distributed to approximately 50,000 homes across the United States. It supplements the periodically administered Current Population Survey (CPS) that gauges national labor force statistics and provides information on digital use. The Wireless RERC’s comments noted concerns about the nature of some of the questions in survey that may cause respondents to provide less than accurate answers due to social standing. Other concerns related to the survey questions included wariness about the way in which questions are worded. They may not be clear to people with mild cognitive impairments, learning disabilities, or for whom English is a second language.

The RERC also recommended that NTIA should include additional questions to the NTIA Internet Use Survey. We argued that it would be useful to have questions related to Internet of Things (IoT) devices, services, and use cases. In our comments, we explicitly name one set of IoT-related devices that have not been assessed in the NTIA Survey: voice input devices (such as Amazon Echo or Apple Siri). These devices’ deployment is prominent particularly in smart homes and for those with disabilities who use the technology to navigate their environment. We suggested that NTIA probe into accessibility, perceptions, and barriers to adoption of these devices. Two other areas that we suggest the NTIA Survey expound on includes: characteristics of survey participants, accessibility and usability of technology, and accessibility of emergency and governmental services (such as IPAWS). Finally, the RERC suggests that questions about wearables, the complexity of their use, and the cost of devices are added to the survey. This invaluable information would allow neutral authorities to develop technological and policy interventions. Our comments to the Department of Commerce conclude by emphasizing how vital it is for surveys to be accessible to people with disabilities to ensure data collection is inclusive of these populations.

August 2020 - The Wireless RERC submitted comments to the FCC on August 4th in response to their Public Notice Consumer and Governmental Affairs Bureau Seeks Comment On Tentative Findings for the 2020 Twenty-First Century Communications and Video Accessibility Act Biennial Report [CG Docket No. 10-213]. The FCC's Tentative Findings Report cited the Wireless RERC nearly fifteen times based on our initial comments in April, which discussed the preliminary findings of the 2019/2020 Mobile Phone Accessibility review. In our latest comments, we provided the FCC with a complete analysis of mobile phone models available up to February 2020 from the top four wireless carriers, one prepaid carrier, and five Lifeline Carriers. Our review highlighted several interesting findings, which include the non-smartphone manufacturers integrating smartphone features into their core models and a significant increase in the presence of full access screen readers for all 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 mobile devices, which can also result in greater usability of these devices. The data indicate that consumers with disabilities seeking to purchase smartphones have more device options with a greater variety of accessibility features. Particularly, accessibility for people who use the voice output features and the alternative login as there was a significant increase in the presence of TTS, full access screen readers, and biometric login. 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:

• As new features are developed, mobile phone manufacturers are encouraged to continue to incorporate users with disabilities into all stages of the design process so that accessibility, and consequential usability, is intentional within digital designs instead of a fortuitous byproduct of innovative technology.
• Increasing the percentage of phones with excellent M and T ratings (M4/T4) would better ensure a quality experience with voice calls for people who use hearing aids and cochlear implants.
• Given the rate of people with disabilities reporting more than one disability, and the disparity between the availability of accessibility features based on disability type, increasing the percentage of more universally accessible devices would be good for manufacturers and end-users alike.
• Increasing the percentage of non-smartphones that are WEA-capable would better ensure access to emergency alerts for users with disabilities that prefer non-smartphones.
• For continuity of the accessibility experience through app and OS updates, more development efforts that would allow a way to ensure that systems updates are more transparent for the end-user by not resetting to the default status. If this could be overcome, it would not only impact accessibility, but also (1) the security of the device for people with disabilities, and (b) the optimal operation of the device or app, as it would have the latest fixes and features.
• Voice input devices such as digital assistants and smart speakers may be more capable than users believe is the case, suggesting the need for more informed or more expanded help/guidance functions. This speaks to the need for the design process to expand beyond minimal accessibility features to incorporate outcome-based design, such as increased usability.
• To address barriers experienced by customers with disabilities during point of sale transactions, we recommend (1) disability awareness/etiquette and information about accessibility features should be a standard part of sales associate training, and (2) providing a stable method for customers with disabilities to obtain in-store support (e.g., video remote interpreting services). 

ADDITIONAL INFORMATION:
Read the Wireless RERC's Comments at https://ecfsapi.fcc.gov/file/1080426285659/Aug%202020%20wRERC%20Comments-%20CVAA%20Preliminary%20Findings%20(Final).pdf        

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 2019/20^[1] Mobile 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.^[2] 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.

October 2019 - The Wireless RERC submitted a letter to the FCC responding to their notice regarding Information Collection Being Reviewed by the Federal Communications Commission: Enhanced Geo-Targeted Wireless Emergency Alerts [WT Docket No. 10-254: DA 12-1745]. We supported the FCC’s initiative to collect data on the geo-targeting capabilities of WEA messages using an embedded link to the survey within the message. The proposed data collection method will improve the ecological validity of the survey results, as the survey will be taken in an uncontrived setting. Our letter also recommended that the FCC, at a later date, consider collecting data on factors impacting WEA efficacy for people with disabilities.

September 2019 – The Wireless RERC submitted reply comments to the FCC’s Further Notice of Proposed Rulemaking Improving Video Relay Service and Direct Video Calling [CG Docket No. s 10-51 and 03-123]. The Wireless RERC supported consumer and provider stakeholders’ opposition to requiring a log-in for users of enterprise and public videophones. As asserted by the Consumer Groups, such a requirement runs counter to functional equivalency as defined by the Section 255 of the Americans with Disabilities Act, the Telecommunications Act of 1996, and the Twenty-First Century Communications and Video Accessibility Act of 2010.  To the Wireless RERC’s knowledge, no person without a disability in the workplace or public places such as a hospital or airport is required to log-in to use a business or public telephone.

Further, as stated by the Consumer Groups, “there are some VRS users whose cognitive abilities may not be sufficient to enter their VRS telephone number on demand, much less a PIN.^[1]”  In support of this assertion, the Wireless RERC noted that approximately 2,835,949 non-institutionalized civilians are living with comorbid hearing and cognitive disabilities.^[2] Cognitive domains impacted could include memory recall and memorizing ability. Also, the Wireless RERC agreed with and supported Convo’s assertion that “The best method to ensure that these public or enterprise devices are not misused remains what is already the current standard industry practice, VIs will disconnect a call when it is clear that the caller does not use or need ASL to telecommunicate.^[3]” Not only does this practice relieve the consumer of burden, but it is also a less costly solution, in time and capital, compared to implementing a password or PIN safeguard. To read the full document, visit: https://ecfsapi.fcc.gov/file/1090478182582/Wireless%20RERC_Reply%20Comments_Improving%20VRS.pdf