Wireless RERC on the Record: FCC’s Section 504 Compliance

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.