Policy Filings

June 2018 – The Wireless RERC submitted reply comments to the FCC in response to their Public Notice inviting stakeholder input to Refresh the Record on Facilitating Multimedia Content in Wireless Emergency Alerts (WEA) [PS Docket Nos. 15-91 and 15-94]. The Wireless RERC is in general agreement with comments that supported the inclusion of multimedia content in WEA messages. Despite sometimes having different rationales, many commenters indicated the importance of multimedia message content in motivating people to take appropriate protective actions, and/or advancing accessibility of WEAs to people with disabilities. The Wireless RERC's reply comments acknowledged the remarks of AT&T and CTIA that discussed the technical difficulty and level of effort and resources it would require of wireless industry stakeholders to realize embedded multimedia content. In our reply comments, we urged wireless stakeholders to continue to embrace the changing expectations of public safety officials and the public with regards to an expanded suite of WEA capabilities. The most recent updates allowing for increased character length and the inclusion of URLs are expected to have a positive impact on the accessibility of the message and by extension behavioral response. Adding embedded multimedia content would further enhance WEA messages for people with disabilities and language differences, allowing for multiple cognitive and sensory pathways (visual, auditory, and linguistic) to be automatically engaged for more efficient information processing and reaction.

The Wireless RERC also supported comments made by the Consumer Groups, California Coalition of Agencies Serving the Deaf and Hard of Hearing (CCASDHH), and Gallaudet University RERC on Technology for the Deaf and Hard of Hearing (joint filing) asserting that multimedia WEA messages would be particularly beneficial to people whose primary language is American Sign Language (ASL). In a recently published journal article, American Sign Language & Emergency Alerts: The Relationship between Language, Disability, and Accessible Emergency Messaging,^[1] extensive reasoning is provided as to why the provision of ASL-translated emergency messages is critical. In sum, WEA messages delivered as an ASL video would allow for immediate and independent access to the message content.

Though there are technical hurdles to address (network and device-based), the Wireless RERC is optimistic that industry, government, academic, and consumer stakeholders will together, develop the technical, policy and practice solutions that will bring accessible multimedia WEA content to fruition.

May 2018 – 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 2018 Biennial Report Required by the Twenty-First Century Communications and Video Accessibility Act [CG Docket No. 10-213].  In anticipation of this Public Notice, the Wireless RERC conducted a 2017 Mobile Phone Accessibility Review (Accessibility Review/Review). The Review included mobile phone models available as of September 2017 from the top four wireless carriers, one prepaid carrier, and five Lifeline Carriers. Researchers, using the providers’ web pages as a reference, identified 214 mobile phones for evaluation. Data were collected on 24 accessibility features (or features that impact accessibility) available in each phone model. Wireless RERC comments shared the results of the Accessibility Review.  Additionally, the comments were informed by recently conducted focus groups on the use of “new communications technologies” by people with disabilities. Overall, the comments indicate that the accessibility of advanced communications technologies is improving. More accessibility features are available, and many of these features are customizable (e.g., the rate of speech for voice output, vibration adjustment, font adjustment, and more). These are much-appreciated gains. However, a perennial barrier to access, device setup, which quite literally allows the user to gain entry to the device, requires addressing to move the needle forward on people with disabilities’ independently accessing advanced communications technologies and services. Following are a few specifics from the comments:

• The researchers encountered difficulty in locating information about certain features. Consumers with disabilities may experience a similar problem when comparing models and selecting a phone to purchase. While people without disabilities can compare phone models based on preferences alone, people with disabilities may have accessibility requirements for the phone to be usable by them (e.g., video calling, HAC, screen reader, AT connection).
• Of the 214 phones, 0% of devices had full, out-of-the-box accessibility. The benefit of full, out-of-the-box accessibility is that it simplifies phone selection for people with varying capabilities and functional levels. If all phones were fully accessible, then people with disabilities could select from all available models. As it stands now, people with disabilities have a more limited selection, and more research is required on the part of the consumer prior to purchase.
• Input type can raise barriers that people with various types of disabilities may encounter when attempting to use mobile phone devices both smart and non-smartphones. Many smartphones require a degree of sight and dexterity that can be a limiting factor to users.
• Various disability groups are increasingly adopting smart speakers with intelligent agents, particularly the Amazon Echo and Amazon Dot with Alexa. Consumers who are blind or who have low vision, for whom graphical interfaces may not be accessible, as well as people with dexterity or mobility-related disabilities, for whom button or touchscreen control may pose a barrier to use, have cited the voice control features of these devices as useful.
• Consumers with limited dexterity or impaired hand function, such as people with spinal cord injury or multiple sclerosis, have indicated the potential usefulness of wearables in their own lives. For example, the ability to use near-field communication (NFC) for payments often simplifies what is a complex task for many users who find handling cash or cards to be difficult. However, they also have noted that complex gestures, such as multi-finger swipes, complicate their use of the devices.
• Consumers with disabilities who use wearables such as the Apple Watch discussed in great detail the effect that operating system updates may have on otherwise accessible or usable apps and menu structures for these devices. In a manner similar to smartphone system updates, users of these devices have expressed a desire to understand the effect of operating system updates on app accessibility through some means other than “trial and error.”

February 7, 2018 – The Wireless RERC submitted Ex Parte comments replying to the FCC’s Hurricane Response Public Notice [PS Docket # 17-344]. The Public Notice sought input on the effectiveness of emergency communications technologies, procedures, and policies that were employed in response to hurricanes Harvey, Irma, Maria, and Nate and “additional information relevant to the 2017 hurricane season’s impact on communications generally.[i]” The Wireless RERC’s comments were submitted as near-future considerations for remediating communications access issues. The intent was to supply unbiased considerations to help ensure that individuals with disabilities and other populations disproportionately impacted by disasters have alternative and accessible means to receive emergency information when cell coverage is disrupted, and access to power is limited. The Wireless RERC initially addressed this topic in 2013, after several years of severe tornado season damage. We remain convinced that the FM chip capability holds great promise as a public safety application and agree with FCC Chairman Pai’s assessment that “Access to reliable communications services during times of emergency is critical.[ii]” Two documents were included in the submission, a short 2-page brief and a longer research brief elucidating the benefits of FM Radio chip activation for emergency response. The submission elaborates on the following three points:

• The Integrated Public Alert and Warning System(IPAWS) was created to reach the public during times of emergency using as many “communications pathways as practicable.”^[iii]  FM radio on mobile devices is a possible and pragmatic pathway that is not currently being utilized.
• A synergistic relationship between the traditional broadcast industry and the wireless industry could remedy emergency alert and information access concerns held by providers (network congestion), emergency managers (timeliness of message), and by citizens (full access in the most expedient modality).
• Americans living with disabilities are at greater risk of injury and harm during an emergency because the means of attaining information may not be conveyed in a way by which they can discern. A drastic reduction in the number of deaths and injuries could occur if proper communication coupled with accurate forecasting were implemented. We estimated $33 million of related medical expenses over the past ten years could have been avoided.^[iv]

On October 5, 2017, the Wireless RERC submitted reply comments in response to the Federal Communications Commission’s Notice of Inquiry Concerning Deployment of Advanced Telecommunications Capability to All Americans in a Reasonable and Timely Fashion [GN Docket No. 17-199]. The Inquiry sought stakeholder input on a number of issues, not the least of which were considerations on how to evaluate and include (a) deployment and use of mobile services, (b) the demographic characteristics of unserved areas, and (c) deployment based on demographic characteristics, independent of geographical location. Reply comments supported and elaborated on initial comments submitted separately by the Colorado State Broadband Office (SBO), the Communications Workers of America (CWA), Public Knowledge, et al., National Electrical Manufacturers Association (NEMA), National Rural Electric Cooperative Association (NRECA), the Multicultural Media, Telecom and Internet Council (MMTC), and others. The Wireless RERC concurred with comments made in support of the need for both fixed and mobile advanced telecommunications services in a community to be considered reasonably and timely delivered. Regarding the hot-button topic, Public Knowledge, et al. poignantly stated that “Because consumers who can afford [emphasis added] both mobile and fixed connections typically purchase both, they should be seen as complementary, not substitute products, that the Commission measures separately…if two products were truly “interchangeable,” no one would buy both.^[1]”

Wireless RERC reply comments also addressed underserved populations and areas. Our knowledge of wireless technology access and the need for both mobile and fixed broadband to deliver robust services to people with disabilities led us to recommend that data be collected on availability and usage amongst people with disabilities. A successful broadband deployment and adoption strategy must take into account availability, affordability, and usability. Further compounding the issue, as it relates to rural areas, is that there is a higher prevalence of disability in rural America compared to urban areas.^[2]  Placing rural residents with disabilities in a double jeopardy with regard to access to broadband services and the benefits said access affords. That said, we agreed with recommendations to collect and report data on the demographic characteristics of unserved and underserved areas and specified that disability status be included as a variable.

Many more recommendations and comments were made regarding closing the digital divide, mobile edge content, accessibility, and affordability. To read the full document, select the following link: https://www.fcc.gov/ecfs/filing/1005674827669

March 24, 2017 - The Wireless RERC submitted reply comments in response to the FCC’s Further Notice of Proposed Rulemaking In the Matter of the Transition from TTY to Real-Time Text Technology [CG Docket No. 16-145]; Petition for Rulemaking to Update Commission’s Rules for Access to Support the transition from TTY to Real-Time Text Technology, and Petition for Waiver of Rules Requiring Support of TTY Technology [GN Docket No. 15-178]. While the reply comments supported transitioning from Teletypewriter (TTY) to Real-Time Text (RTT) technology, we concurred with other stakeholder recommendations that the manner and speed in which it is done take into account those most at risk of losing all text communications access if TTY becomes unavailable. While most people with hearing and speech disabilities have a preference for text or video-based communications, there are still some that rely on TTY to place both emergency and non-emergency calls. For no one to be left behind, it is imperative that the transition process includes collecting data on network support, RTT-capable devices on the market, their accessibility levels, and end-user ownership rates. These data would shed light on both industry deployment rates and user adoption rates, users being both consumers and 911 call centers. 

March 20, 2017 – The Wireless RERC submitted comments in response to the National Institute on Disability, Independent Living, and Rehabilitation Research’s (NIDILRR) request for input concerning their Draft Long Range Plan, 2018-2023. NIDILRR is a Center within the Administration for Community Living (ACL), Department of Health and Human Services (HHS) that “sponsors grantees to generate new disability and rehabilitation knowledge and promote its use and adoption. To that end, Wireless RERC comments highlighted the considerable capabilities and functionality offered by smart devices and their ability to address important access and assistive technology needs of people with disabilities as a group. As new iterations of mobile wireless technology devices and networks are deployed, such as the Internet of Things (IoT), researchers, engineers, advocates, and the wireless industry must continue to push for parity of access to these essential technologies, especially through the adoption of inclusive design and development practices. Further, comments suggested that the combination of research, development, and policy activities can have an exponential impact on availability, accessibility, and usability of connected technologies. When working to improve access to technologies that are governed by federal agencies, the policy component is crucial to ensuring transfer of research knowledge into industry practice. Technologies to improve the quality of life, community integration, and the independence of individuals with disabilities are not confined to a single domain. Therefore, we strongly supported NIDILRR’s proposed model that accounts for cross-cutting research to provide a more flexible and versatile framework.

March 13, 2017 - The Wireless RERC, in collaboration with Georgia Tech’s Center for Advanced Communications Policy (CACP), submitted comments to the National Telecommunications and Information Administration’s Request for Comments on the Benefits, Challenges, and Potential Roles for the Government in Fostering the Advancement of the Internet of Things [IOT] [170105023-7023-01]. CACP and the Wireless RERC strongly recommend that NTIA specifically articulate policy recommendations that support early stage inclusion of people with disabilities to further accessibility and usability of IoT technology and services before development and deployment of the same. Properly designed and developed, the IoT can realize its potential to empower all citizens, including people with disabilities to achieve an improved quality of life and greater social and economic inclusion.  Comments also suggested that the federal government focus future policy initiatives as well as technological design on addressing the ability of IoT to apply “on demand” contextually aware information. This display of consumer-digestible information, coupled with the intelligence of devices and applications can meet and anticipate the needs of users with disabilities in ways which increase user independence, opening new opportunities in areas as broad as education, workforce participation, safety, e-health, and social engagement. Further, when implemented in the workplace, IoT technologies can profoundly change the experience of persons with disabilities, providing tools for independence and autonomy while at work.  But implementation is to some extent dependent on availability and suitability of current (or in development) devices and services. It is here that the NTIA could provide formidable leadership in driving the development of the IoT framework by supporting multi-stakeholder engagement, not only formally, regarding policymaking, standards setting and regulation, but also by supporting the formation of public-private partnerships and other multi-stakeholder collaborations to envision innovative types and uses of IoT.

To learn more about the benefits and challenges of advancing an inclusive IoT, click to open the comments of the Wireless RERC and CACP.

Georgia Tech’s Center for Advanced Communications Policy (CACP), in collaboration with the Wireless RERC, submitted comments to the Public Notice, Request for Comment on the Commission’s Policies and Practices to Ensure Compliance with Sections 504 of the Rehabilitation Act of 1973 [CG Docket No. 10-162].  Section 504 requires that federal agencies make their programs and activities accessible to people with disabilities. The FCC sought public input on their programmatic access. Wireless RERC comments asserted that baseline accessibility is consistently impacted by access to customer service and print and electronic materials furnished by industry and policy makers alike.  To improve access to programs and services, we recommend addressing fundamental issues of awareness and accessible formats. The FCC’s American Sign Language (ASL) Consumer Support Line, launched to provide programmatic access to consumers who are deaf and hard of hearing whose primary language is ASL, was commended as a great step forward in providing parity of access.  The support line enables the caller to make inquiries about disability-specific communications issues, as well as, obtain information that could impact any consumer, using their primary language. However, work remains to expand access to the rulemaking process.  One part of the FCC’s Section 504 Handbook stipulated that the Commission will not transcribe or translate comments submitted in alternative formats.  The Wireless RERC urged the Commission to reconsider this position.  As it stands, the requirement that comments be filed in written English excludes people who rely on ASL from participating in the rulemaking process.  Other comments addressed:

• Ensuring the Accessibility Clearinghouse is prominently displayed on the website and its contents are reflective of consumer expectations and the evolution of technologies.
• Adding a statement about relating to the person-first and using person-first language in written and verbal communications to the Section 504 Handbook’s Basic Principles of Access section.
• Providing more detailed guidance on accessible print and electronic documents to improve FCC personnel’s awareness about and capability to deliver, accessible formats.