Biennial CVAA 2022 Report

TDI, along with the listed consumer groups below, filed a comment in the response to the Federal Communications Commission’s Public Notice regarding the 2022 Biennial CVAA Report.

We appreciated the opportunity to revisit our previous 2020 comments and found that many of the accessibility points discussed still remains the same today. The Covid-19 pandemic revealed a lot of disadvantages that our communities suffered from such as inequitable access to emergency services, limited access in telehealth services, poor captions quality in video conferencing platforms including online videos, and limited access in apps to wifi. We recognized that the main problem is due to the Commission’s limitations in rules.

CVAA report only focused on a limited range of equipment and services, ignoring other inaccessible equipment and services that are outside of the report’s parameters. We believed that the Commission should expand its statutory authority to be able to address the broader picture of accessibility. We also noticed that the Commission has limited performance objectives that pose a problem in increasing accessibility.

Now, we wanted a few things that need Congress’s attention in the report.

  1. severe lack of direct access to 9-1-1 emergency services
  2. Podcasts and audiobooks are less accessible to the dhh communities due to a lack of transcripts or captions
  3. expanding the Commission’s authority to address the ever-changing advanced communications services and equipment

Next Steps in Response to the Biennial CVAA 2022 Report

The commenters would appreciate the Commission BOTH revisiting Section 225’s function equivalence mandate to facilitate the development of interoperable next-generation relay services and adapting its advanced communications services performance objectives for modern multimodal services, issues previously addressed in comments submitted to the Commission.

For more information about TDI’s filing addressing the Biennial CVAA 2022 Report, visit the filing and full list of signatories at the following link:

Biennial CVAA 2022 Report


CG 10-213 — Twenty-First Century Communications and Video Accessibility Act (CVAA) of 2019

Special Thanks to:



TDI. American Association of the DeafBlind (AADB), Association of Late Deafened Adults (ALDA), Communication Service for the Deaf (CSD), Conference of Educational Administrators of Schools and Programs for the Deaf (CEASD), Deaf Seniors of America (DSA), Hearing Loss Association of America (HLAA), National Association of the Deaf (NAD), Northern Virginia Resource Center (NVRC), Registry of Interpreters for the Deaf (RID), Rehabilitation Engineering Research Center on Technology for the Deaf and Hard of Hearing (DHH-RERC), RIT/NTID Center on Access Technology (CAT).

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We welcome all members of the deaf and hard of hearing community (DHH): deaf, hard of hearing, late-deafened, deafblind, lip-readers, cued-users, veterans with hearing loss, senior citizens, deafdisabled, and/or having additional sensory, mobility, cognitive or other communication disabilities.

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