Wireless RERC Files Reply Comments on Accessibility of Devices for Video Programming

February 2014 — The Wireless RERC submitted reply comment to the Federal Communication Commission’s (FCC) Further Notice of Proposed Rulemaking (FNPRM): In the Matter of Accessibility of User Interfaces, and Programming Guides and Menus and Accessible Emergency Information and Apparatus Requirements for Emergency Information and Video Description: Implementation of the Twenty-First Century Communications and Video Accessibility Act of 2010. The FNPRM requested input on defining the scope of Sections 204 and 205 of the Twenty First Communications and Video Accessibility Act of 2010 (CVAA) which require user interfaces and navigation devices for video programming to be accessible to people with vision loss. 

Wireless RERC comments highlighted that despite the presence of accessibility features on many devices, consumers are often unaware of these features.  Accordingly, in agreement with the Consumer Groups and Telecom RERC, the Wireless RERC recommends implementation of “information, documentation and training requirements” in accessible formats for consumers with and without disabilities. The accessibility of the devices, equipment and services should be conceived as a continuum that includes the technology itself and any support for using/accessing the technology.

Regarding a mechanism for activating accessibility features, the Wireless RERC notes that “a minimal step accessibility button, key or icon” should be used to ensure ease of activating and inactivating accessibility features such as closed captioning and video description.”  However, they acknowledged and concurred with the Consumer Groups and Telecom RERC that the minimal step accessibility activation and configuration recommended does not supplant the need for a single step activation/deactivation of closed captions.

Finally, Wireless RERC comments disagree with the National Cable and Telecommunications Association’s (NCTA) position that the FCC does not have the legal authority to require a mechanism by which may enable people with visual disabilities may access a secondary audio stream for emergency information.  Instead, the Wireless RERC stresses that the FCC’s basic mission is to “provide for the safety of life and property of Americans,” and accommodations for people with disabilities must be made to the fullest extent possible, including providing emergency information in the most accessible and effective format for each individual.