Wireless RERC Comments on Accessibility of Emergency Information

August 2013 - The Wireless RERC filed reply comments with the FCC in response to their Further Notice of Proposed Rulemaking: In the Matter of Accessibility of Emergency Information and Apparatus Requirements for Emergency Information and Video Description: Implementation of the Twenty-First Century Communications and Video Accessibility Act of 2010 [MB Docket No. 12-107]. The FNPRM requested input on whether a multichannel video programming distributor (MVPD) service should be required to comply with rules to provide accessible aural emergency information when subscribers access linear video programming via alternative devices, and whether such entities should be required to assist individuals who are blind or visually impaired in traversing between main and secondary audio streams.

The Wireless RERC comments note that many content providers distribute programming via mobile, IP delivery, and consumers may expect emergency information to be present.  In order to ensure that emergency information is relevant to the consumer, the Wireless RERC emphasized that the rules should apply only to “programming that is simultaneously being provided to the home television,” not on-demand prgramming. The Wireless RERC also agreed with AT&T and CTIA in that MVPDs should comply with the FCC rules “regardless of the devices that are accessing the video programming” and that the rules should apply to the “entities that control the technology in question.”  In addressing accessible customer service options for people with vision loss, the Wireless RERC challenged the statements of CEA and TIA noting that anecdotally, customer service representatives have been unable to adequately address the needs of people with vision loss due to insufficient knowledge on accessibility features. Accordingly, the Wireless RERC recommended specific accessibility training to be mandated for customer service representatives.