FCC Filing: Accessibility Priorities for New Administration

TDI FCC Filing

TELECOMMUNICATIONS

CG 03-123 — Telecommunication Relay Services and Speech-to-Speech Services for Individuals with Hearing and Speech Disabilities;
CG 10-51 — Structure and Practices of the Video Relay Service Program;
CG 13-24 — Misuse of Internet Protocol (IP) Captioned Telephone Service;
CG 16-145 — Transition from TTY to Real-Time Text Technology;
GN 15-178 — Petition for Rulemaking to Update the 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;
WC 09-197 — Telecommunication Carriers Eligible to Receive Universal Service Support;
WT 96-198  — Implementation of Section 255 of the Telecommunications Act of 1996;

CLOSED CAPTIONING

CG 05-231 — Closed Captioning of Video Programming;

ADVANCED COMMUNICATION SERVICES

CG 10-145 — Wireless Telecommunications Bureau and Consumer and Governmental Affairs Bureau Seek Comment on Accessible Mobile Phone Options for People who are Blind, DeafBlind, or have Low Vision;
MB 11-43 — In the Matter of Video Description: Implementation of the Twenty-First Century Communications and Video Accessibility Act of 2010;
MB 12-108 — User Interfaces, and Video Programming Guides and Menus;

EMERGENCY COMMUNICATIONS

CG 15-91   — Wireless Emergency Alerts;
PS 17-239 — Inquiry Concerning 911 Access, Routing, and Location in Enterprise Communications Systems;

OTHER

WC 10-90 — Connect America Fund a National Broadband Plan for Our Future High-Cost Universal Service Support;
WC 11-42 — Federal-State Joint Board on Universal Service Lifeline and Link Up Lifeline and Link Up Reform and Modernization;
WC 12-375 — Rates for Interstate Inmate Calling Services;
WC 20-445 — Emergency Broadband Benefit Program;

EX PARTE

TDI, along with the tagged consumer groups filed an Ex Parte with the Federal Communications Commission, about the Consumer Group’s Proposed Accessibility Priorities for the New FCC Administration

[see below, under Tags: for full list of signatories]

URL below is linked to the actual filing document on FCC’s Electronic Comment Filing System 

Special Thanks to:  COMMUNICATION & TECHNOLOGY LAW CLINC GEORGETOWN UNIVERSITY LAW CENTER, and SAMUELSON-GLUSHKO TECHNOLOGY LAW & POLICY CLINIC

Accessibility advocates met with several FCC officials to talk about the Group’s proposed accessibility priorities for the new FCC leadership.

We stressed the need to improve accessibility features in video conferencing services and relay interconnectivity, the transition to Real-Time Text (RTT), wireless handset accessibility, and video programming accessibility.

The pandemic has shifted to video conferencing as the main way of doing business and keeping in touch with families and friends and doctor appointments. There needs to be long-term modifications to improve video conferencing accessibility, including relay interconnectivity, captioning, and user interface settings.

We also urged the Commission to ensure all wireless vendors and carriers can support RTT functionality. There also needs to be wireline RTT; wireline technology is vital to older d/hh Americans and those in carceral facilities.  It is important that wireless and wireline RTT are interoperable. We must be able to connect to 911, 711, 988 and other n11 codes using RTT.

We asked the Commission to monitor the accessibly of wireless handset devices. Phones are becoming increasingly difficult to use for people who use hearing aids.We reinforced the need for  C63.19 standard (compatibility between hearing aids and wireless communications devices)  and the need to address RF interference. People want to hold the handset up to their hearing device for telephone communication.

We reminded the Commission that significant problems still persist in video captioning. Closed captioning quality contains to remain poor, especially in live programming. Automated speech recognition (ASR) is far more problematic as evident in the presidential inauguration and the Super Bowl. The FCC’s complaint process for captioning is difficult to navigate. To make matters worse, the are different rules for captioning on traditional television and streaming services, making it even more confusing for consumers. We also asked for more audio description, and ensure it remains with the program across all platforms.