Emergency Reliability and Resiliency during Disasters
TDI, along with the listed consumer groups, filed a Comment to the Federal Communications Commission in response to the Commission’s Notice of Proposed Rulemaking regarding the steps to improve the reliability, resiliency, and continuity of communications networks during emergencies, including but not limited to natural disasters such as Hurricane Ida and the recent tornado disaster in Kentucky.
The organizations commended the Commission’s continued commitment to improving the reliability and resiliency of communication networks during emergencies. Still, they strongly urged the Commission to consider the specific needs of the deaf and hard of hearing communities such as emergency alerts that has accessibility for them to use or have during emergencies. The emergency alerts mostly often are sound or voice-reliant. The deaf and hard of the hearing community rely on multiple sources for emergency communications, including local television, wireless emergency text alerts, and text to 911. Cellular phones and broadcasted television continue to be the principal means by which deaf and hard-of-hearing individuals receive emergency alerts. Thus, a resilient and reliable electrical, broadcast, broadband, and wireless network is critical to the safety and health of this community.
Next Steps for Emergency Reliability and Resiliency
The organizations hence asked the Commission to take several specific actions to ensure that wireless emergency communications are reliable and resilient for the deaf and hard of hearing community. First, the Commission can expand the options for the distribution of emergency alerts. Second, Commission must generally enhance the accessibility of emergency notifications. Third, the Commission should make sure that there is accessibility during and to prior the electrical grid failures by ensuring continued accessibility of wireline real-time text (RTT) and exploring the option of requiring communications networks to send out final alerts in anticipation of a power shutdown.
Not only these steps, but the organizations also recommended the Wireless Network Resiliency Cooperative Framework to the Commission and the Framework should generally include requirements for best practices education and information distribution to the deaf and hard of hearing community for preparedness before and during disasters.
Finally, the organizations emphasized that the Commission focuses on enhancing accessibility notification systems, outreach, instructions, and solutions that address the unique needs of the deaf and hard-of-hearing communities during disasters.
PS 21-346 — In the Matter of Resilient Networks
ET 04-35 — Concerning Disruption to Communications New Part 4 of the Commission’s Rules Concerning Disruption to Communications
PS 15-80 — Amendment to Part 4 of the Commission’s Rules
Special Thanks to:
AccesSOS, American Deafness and Rehabilitation Association (ADARA), Association of Late Deafened Adults (ALDA), California Coalition of Agencies Serving the Deaf and Hard of Hearing (CCASDHH), Cerebral Palsy and Deaf Organization (CPADO), Clear2Connect Coalition, 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), Helen Keller National Center for DeafBlind Youths and Adults (HKNC), National Association of State Agencies of the Deaf and Hard of Hearing (NASADHH), National Association of the Deaf (NAD), National Cued Speech Association (NCSA), 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), TDI
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