The Wireless RERC filed comments with the Federal Communications Commission (FCC) in response to their Public Notice In the Matter of Public Safety and Homeland Security Bureau Seeks Comment on the Legal and Statutory Framework for Next Generation 9-1-1 Services Pursuant to the Next Generation 9-1-1 Advancement Act of 2012. The comments recommended state level coordination of the transition to NG9-1-1, noting such coordination would aid in outreach efforts once NG9-1-1 services are implemented, for example in streamlining the resources needed to create materials in alternate formats and modalities (Braille documents, captioned video, accessible electronic information). In addition the Wireless RERC pointed out that it would be more effective to execute a statewide campaign that educates citizens on NG9-1-1 capabilities and limitations, compared with local campaigns. The Wireless RERC also recommended that states be required to designate a state agency to oversee the transition, and ensure that a portion of funds collected from subscribers’ fees for 911 services be earmarked for efforts to facilitate the transition to NG9-1-1.
Beyond state level coordination, the Wireless RERC addressed the role of the federal government, recommending that it should make certain that NG9-1-1 be implemented in a manner that ensures the accessibility of the system to people with disabilities, as well as the accessibility of ancillary activities such as outreach. Federal ownership of the disability/accessibility implementation issues was urged for reasons of both efficiency and expertise. We recommended that the Consumer and Governmental Affairs Bureau’s (CGB) Emergency Access Advisory Committee (EAAC) be responsible for facilitating compliance with disability access requirements dictated not only by the Communications and Video Accessibility Act of 2010 (CVAA), but also by Title II and Title IV of the Americans with Disabilities Act. This would allow for cross-coordination of pro-active initiatives such as education, public outreach, and enforcement. Specific recommendations regarding compliance, enforcement, guidelines, and mapping are also detailed in the filing.
