July 6, 2021 – The Wireless RERC submitted reply comments in response to the FCC’s Public Notice Update on Commission's Fulfillment Of The Twenty-First Century Communications And Video Accessibility [GN Docket No. 21-140]. We agreed with the American Council of the Blind (ACB) statement that "The Commission should review how people with multiple disabilities are served by accessible communications technology and services. This should be done with a very wide lens to encompass all forms of sensory, cognitive, and physical disability." We cited that our studies have found that accessibility features are not uniformly available in all phone models, and gaps in the accessibility experience persist, especially for people with co-occurring disabilities. The comments of the Alliance of Automotive Innovation provided us the opportunity to state “that accessibility innovations should be co-created with consumers with disabilities and that the automotive industry adheres to CVAA requirements to include people with disabilities in the design and development phases of advanced communications features incorporated into connected and automated vehicles. It is essential to proactively include stakeholders within the disability community in AV design and development to enhance the utility of this technology for people with disabilities.”
In response to CTIA’s comments, we addressed ensuring that consumers with disabilities are aware of device features. At a recent focus group comprised of individuals who are blind, a participant, while discussing his use of the iPhone, stated he wanted to connect it to Alexa, "but I'm not sure if there is an Alexa app." We asserted that attending to issues of independent setup and accessible documentation and communication of device features speaks to the "usability" requirements of the CVAA. "A product or service is "usable" if it provides individuals with disabilities with the full functionality and documentation for the product or service, including instructions, product or service information (including accessible feature information), customer support, and technical support." Regarding technical support specifically, CTIA commented that "Recently, Apple announced new accessibility features, including AssistiveTouch to watchOS, which allows users with mobility limitations to control their device, and SignTime, which enables people who are deaf and hard of hearing to communicate with AppleCare and Apple Retail staff in sign language." Excellent! We hope that such accessible and inclusive business practices become the industry standard. [Source: Wireless RERC]
47 CFR §§ 6.3(l), 7.3(l), 14.21(c); see also 47 CFR §§ 6.11, 7.11, 14.20(d), 14.60(b)(4).