August 4, 2020 - The Wireless RERC submitted comments to the FCC on August 4th in response to their Public Notice Consumer and Governmental Affairs Bureau Seeks Comment On Tentative Findings for the 2020 Twenty-First Century Communications and Video Accessibility Act Biennial Report [CG Docket No. 10-213]. The FCC's Tentative Findings Report cited the Wireless RERC nearly fifteen times based on our initial comments in April, which discussed the preliminary findings of the 2019/2020 Mobile Phone Accessibility review. In our latest comments, we provided the FCC with a complete analysis of mobile phone models available up to February 2020 from the top four wireless carriers, one prepaid carrier, and five Lifeline Carriers. Our review highlighted several interesting findings, which include the non-smartphone manufacturers integrating smartphone features into their core models and a significant increase in the presence of full access screen readers for all mobile phones.
Additionally, the comments were informed by the results of our cornerstone survey on wireless technology use by people with disabilities, the Survey of User Needs (SUN). Overall, the comments indicated the industry's growth in the accessibility and affordability of advanced communications technologies, as evidenced by the increasing presence and richness of new accessibility features on mobile devices, which can also result in greater usability of these devices. The data indicate that consumers with disabilities seeking to purchase smartphones have more device options with a greater variety of accessibility features. Particularly, accessibility for people who use the voice output features and the alternative login as there was a significant increase in the presence of TTS, full access screen readers, and biometric login. Furthermore, SUN analysis found that a majority of respondents with disabilities indicated that both basic cell phones and smartphones were easy to use. However, some access gaps remain, particularly regarding new communications technologies. Based on the data presented in the comments, the Wireless RERC offered the following recommendations:
- As new features are developed, mobile phone manufacturers are encouraged to continue to incorporate users with disabilities into all stages of the design process so that accessibility, and consequential usability, is intentional within digital designs instead of a fortuitous byproduct of innovative technology.
- Increasing the percentage of phones with excellent M and T ratings (M4/T4) would better ensure a quality experience with voice calls for people who use hearing aids and cochlear implants.
- Given the rate of people with disabilities reporting more than one disability, and the disparity between the availability of accessibility features based on disability type, increasing the percentage of more universally accessible devices would be good for manufacturers and end-users alike.
- Increasing the percentage of non-smartphones that are WEA-capable would better ensure access to emergency alerts for users with disabilities that prefer non-smartphones.
- For continuity of the accessibility experience through app and OS updates, more development efforts that would allow a way to ensure that systems updates are more transparent for the end-user by not resetting to the default status. If this could be overcome, it would not only impact accessibility, but also (1) the security of the device for people with disabilities, and (b) the optimal operation of the device or app, as it would have the latest fixes and features.
- Voice input devices such as digital assistants and smart speakers may be more capable than users believe is the case, suggesting the need for more informed or more expanded help/guidance functions. This speaks to the need for the design process to expand beyond minimal accessibility features to incorporate outcome-based design, such as increased usability.
- To address barriers experienced by customers with disabilities during point of sale transactions, we recommend (1) disability awareness/etiquette and information about accessibility features should be a standard part of sales associate training, and (2) providing a stable method for customers with disabilities to obtain in-store support (e.g., video remote interpreting services).
ADDITIONAL INFORMATION: Read the Wireless RERC's Comments at https://ecfsapi.fcc.gov/file/1080426285659/Aug%202020%20wRERC%20Comments-%20CVAA%20Preliminary%20Findings%20(Final).pdf