Wireless RERC Comments on Accessibility of Devices for Video Programming

August 2013 - The Wireless RERC submitted reply comments to the FCC’s Notice of Proposed Rulemaking (FPRM): In the Matter of Accessibility of User Interface, and Video Programming Guides and Menus [MB Docket No. 12-108]. The NPRM requested input on defining the scope of Sections 204 and 205 of the Twenty First Communications and Video Accessibility Act of 2010 (CVAA) which require user interfaces and navigation devices for video programming to be accessible to people with vision loss. Wireless RERC comments noted that with the advent of the “second screen” and mobile apps integration into the television viewing experience, it is imperative that rules are designed to cover the array of equipment, devices, software and features of all that constitute the video programming environment. Wireless RERC comments emphasized that video programming viewed on mobile devices may blur the distinction between digital apparatus and navigation devices and thus accessibility requirements “should not be limited to MVPD-supplied equipment.” Regarding required accessibility features the Wireless RERC asserted that the eleven functions outlined by the VPAAC Second Report on User Interfaces should not be relied upon as a safe harbor for Section 205 compliance, as there are many necessary features not listed, including diagnostic functions and digital video recording functions.  Finally, the Wireless RERC recommended co-locating all accessibility features within a “minimal step accessibility button, key and/or icon,” so as to streamline activation of accessibility features. Noting that positioning all of the accessibility features on the same menu would improve visibility of all the access features that may be applicable to users, as some people may want to activate more than one access feature.