Wireless RERC - Policy Filings

Wireless RERC on the Record: FCC’s Section 504 Compliance

mz22 — Wed, 05 Oct 2016 16:08:51 +0000

10.3.2016 – Comments of the Wireless RERC-Sec 504 Compliance

Publication Type:

Georgia Tech’s Center for Advanced Communications Policy (CACP), in collaboration with the Wireless RERC, submitted comments to the Public Notice, Request for Comment on the Commission’s Policies and Practices to Ensure Compliance with Sections 504 of the Rehabilitation Act of 1973 [CG Docket No. 10-162]. Section 504 requires that federal agencies make their programs and activities accessible to people with disabilities. The FCC sought public input on their programmatic access. Wireless RERC comments asserted that baseline accessibility is consistently impacted by access to customer service and print and electronic materials furnished by industry and policy makers alike. To improve access to programs and services, we recommend addressing fundamental issues of awareness and accessible formats. The FCC’s American Sign Language (ASL) Consumer Support Line, launched to provide programmatic access to consumers who are deaf and hard of hearing whose primary language is ASL, was commended as a great step forward in providing parity of access. The support line enables the caller to make inquiries about disability-specific communications issues, as well as, obtain information that could impact any consumer, using their primary language. However, work remains to expand access to the rulemaking process. One part of the FCC’s Section 504 Handbook stipulated that the Commission will not transcribe or translate comments submitted in alternative formats. The Wireless RERC urged the Commission to reconsider this position. As it stands, the requirement that comments be filed in written English excludes people who rely on ASL from participating in the rulemaking process. Other comments addressed:

Ensuring the Accessibility Clearinghouse is prominently displayed on the website and its contents are reflective of consumer expectations and the evolution of technologies.
Adding a statement about relating to the person-first and using person-first language in written and verbal communications to the Section 504 Handbook’s Basic Principles of Access section.
Providing more detailed guidance on accessible print and electronic documents to improve FCC personnel’s awareness about and capability to deliver, accessible formats.

Wireless RERC on the Record: Advancing Access to Emergency Alerting

mz22 — Thu, 04 Aug 2016 18:52:35 +0000

Wireless Emergency Alerts (WEA)

Emergency Alert System (EAS)

Wireless RERC Comments_June 8, 2016

Publication Type:

Policy Filings

Georgia Tech’s Center for Advanced Communications Policy (CACP), in collaboration with the Wireless RERC, submitted comments to the Notice of Proposed Rulemaking (NPRM) In the Matter of Amendment of Part 11 of the Commission’s Rules Regarding the Emergency Alert System [15-94]; Wireless Emergency Alerts [PS Docket No. 15-91]. The proposed changes in the NPRM are intended to strengthen the emergency alerting systems and to increase their effectiveness at prompting the public to take the appropriate protective actions. The major areas of change included improving alerting organization at the state level, bringing alerting tools up to date with advancements in technology, and developing community-based accessible public safety exercises. Wireless RERC comments contended that all communications received on digital devices should be accessible and concur that the proposed advancements for both WEA and EAS are a promising avenue for ensuring timely response and recognition of messages to safeguard all citizens. The recommendations made are intended to facilitate the maturation and modernization of both systems, empowering all to make informed choices that result in maximizing message diffusion and ensuring the same timely and effective access to alerts and warnings for people with disabilities.

Following are a sample of recommendations included in the comments:

To ensure that all members of the population understand the messages, emergency managers and those writing the plans should also be very specific in their instructions concerning emergency actions to be taken, eliminating jargon and abbreviations. Further, protective action instructions should be part of any State EAS Plan template, and that said template contains information ensuring that the needs of people with disabilities are included.
Crowdsourcing is proving to be a valuable tool for emergency managers in gathering and dispersing information. Nonetheless, the challenge of authenticating and verifying submitted information is a growing one, and currently only solved by the manual moderation of incoming reports. Continued review of agencies that utilize crowdsourcing technologies and social media during disaster response is recommended.
To ensure the accessibility of actual and test messages, EAS accessibility rules should apply across the board. The live code test presents an opportunity to gather data and feedback from the populace on the extent to which the accessibility requirements improve readability and comprehension of the message.
User data regarding the most frequent methods by which people receive emergency alerts supports the addition of State/Local WEA Testing in state-level preparedness procedures.
Comments supported the use of EAS and WEA public service announcements (PSAs). It was recommended that the PSAs present the information about the systems in several formats including audio, text, American Sign Language (ASL), and other languages with high usage in a particular area, and the symbol set provided by the IPAWS Symbology Plan approved by DHS and the National Alliance for Public Safety GIS Foundation.
Comments supported extending WEA rules to include tablets and other mobile devices, including wearable and other nontraditional communications devices. Given that wearable technology is a growing market and both people with and without disabilities have adopted its use, wearable technology should be integrated into the WEA/IPAWS environment.

Wireless RERC on the Record: Role of Government in the Advancement of IoT

mz22 — Thu, 09 Jun 2016 19:50:31 +0000

Internet of Things

Publication Type:

Policy Filings

The Wireless RERC, in collaboration with Georgia Tech’s Center for Advanced Communications Policy (CACP), and the Center for the Development and Application of Internet of Things Technologies (CDAIT), Georgia Tech Research Institute, filed comments in response to The National Telecommunications and Information Administration's (NTIA) inquiry: “Notice, Request for Public Comment, The Benefits, Challenges, and Potential Roles for the Government in Fostering the Advancement of the Internet of Things [Docket No. 160331306–6306–01]. NTIA sought broad input from all interested stakeholders—including the private industry, researchers, academia, and civil society on the potential benefits and challenges of the Internet of Things (IoT) and what role, if any, the U.S. Government should play in this area. The comments submitted address, among other things, IoT’s potential to advance the social inclusion and independent living of people with disabilities; and improve the dissemination of emergency information. The submission encouraged (a) the consultation of people with disabilities throughout the design and development phases of the IoT, and (b) the accessibility implications of future technologies become a high‐level consideration when planning Federal level technology development strategies and policy.

Related Files:

Attachment	Size
Comments to NTIA_IoT_June 2016.docx	135 KB

Wireless RERC on the Record: Volume Control Standards for Hearing Aid Compatibility

mz22 — Thu, 10 Mar 2016 14:33:38 +0000

Hearing Aid Compatibility (HAC)

Wireless RERC HAC 2016 Comments

Publication Type:

Policy Filings

The Wireless RERC, in collaboration with Georgia Tech’s Center for Advanced Communications Policy (CACP) filed comments before the FCC in response to the Notice of Proposed Rulemaking (NPRM) In the Matter of Access to Telecommunications Equipment and Services by Persons with Disabilities [CG Docket No. 12-32]; Petition for Rulemaking Filed by the Telecommunication Industry Association Regarding Hearing Aid Compatibility Volume Control Requirements [CG Docket No. 13-46]; Amendment of the Commission’s Rules Governing Hearing Aid-Compatible Mobile Handsets [WT Docket No. 07-250]; Comment Sought on 2010 Review of Hearing Aid Compatibility Regulations [WT Docket No. 10-254]. The comments, in large part, were informed by analyses of data collected via the Wireless RERC’s hearing aid compatibility (HAC) survey research. The 2014 HAC survey was designed to gather data from people who use hearing aids and cochlear implants on how well their hearing technology works with their wireless handsets. Answers to the survey questions have provided insight into the effectiveness of hearing aid compatibility requirements in the United States, as well as the need for any amendments to the rules.

The Wireless RERC’s comments supported the incorporation of the proposed 2012 ANSI Wireline Volume Control Standard, and further recommended extending any technology requirements for wireline phones to Voice over Internet Protocol (VoIP) phones, as well. Regarding applying the volume control standard to wireless devices, the comments took a more modified approach. While the Wireless RERC generally agrees with the FCC’s belief “that standards and requirements for manufacturers and service providers are needed for volume control in wireless handsets as well^{^[1]}” and respondents to the Wireless RERC’s 2014 HAC Survey indicated that volume control impacted the usability of their wireless handset; ultimately the Wireless RERC supported further investigation of whether it is necessary to incorporate a volume control standard for wireless handsets, recognizing that this might take longer than voluntary compliance via industry driven solutions. Given the complexity of interactions between increasingly sophisticated and powerful wireless handsets, telecom delivery services (i.e. VoIP), hearing aids and the variability of hearing loss amongst the users, the difficulty of crafting regulations that improves access for end-users is not overlooked by the Wireless RERC/CACP. Nevertheless, people with hearing loss deserve and are entitled to parity of access to telecommunications services, wireless, or otherwise.

[1] 1996 HAC R&O, 11 FCC Rcd at 8282 ¶ 78.

Wireless RERC on the Record: Wireless Emergency Alerts & Accessibility

mz22 — Thu, 11 Feb 2016 18:39:34 +0000

Wireless Emergency Alerts (WEA)

Read the Comments of the Wireless RERC and CACP

Publication Type:

Policy Filings

January 13, 2016 - The Wireless RERC, in collaboration with Georgia Tech’s Center for Advanced Communications Policy (CACP), added their expertise to support several of the proposed enhancements to the Wireless Emergency Alerts (WEA) system. In a Notice of Proposed Rulemaking released by the FCC In the Matter of Improving Wireless Emergency Alerts and Community Initiated Alerting [PS Docket 15-91], the FCC requested stakeholder input on several ways to enhance the effectiveness and content of WEA messages. Wireless RERC and CACP research on the accessibility of WEA messages for people with disabilities provided empirical data in support of their recommendations. From a regulatory review and literature review conducted under contract with the Integrated Public Alert & Warning System (IPAWS) Project Management Office (PMO), a framework was developed that identified influencing factors that, if not optimal, could negatively impact the effectiveness of WEA messages. For example, current WEA regulations limit the potential of the system. Most notably the 90 character maximum length and the geotargeting boundaries being too large (i.e., county wide). Additionally, the rules currently prohibit the use of URLs and dialable numbers. The accessibility provisions only addressed alert notification signals (i.e., vibration cadence and alert tone) but not access to the content of the message. For people with disabilities, these features would be especially useful as it would enable them to receive more information about the event in a format that is accessible to them, or made accessible via the assistive technology they have installed on their WEA capable device. Following are a few examples of the recommendations found in the comments:

Rules governing WEA should be updated to increase the character limitation. Doing so should decrease the need to rely on abbreviations and acronyms in order to stay within the character limitation.
Rules governing WEA should be updated to allow for the inclusion of URLs. This would be a step towards enabling the next-generation of WEA, as URLs can contain the additional information the public seeks, including American Sign Language (ASL) videos, emergency management websites or social media feeds, and more.
Improve the geotargeting capabilities of the WEA system. This should increase the relevance of WEA messages to the recipients and likewise, increase their trust of the message, encouraging them to take the desired protective actions.
Testing of the WEA system should extend beyond the providers’ infrastructure to the mobile devices in use by the public. This should increase public awareness of WEA, as many users learned of WEA only after receiving a WEA message for the first time. The test message could include a link to the IPAWS PMO’s frequently asked questions regarding WEA.

Wireless RERC Comments on Accessible Emergency Communications

mz22 — Thu, 19 Nov 2015 20:37:55 +0000

Emergency Alert System (EAS)

Wireless Emergency Alerts (WEA)

Publication Type:

Policy Filings

November 19, 2015 - The Wireless RERC submitted ex parte comments to the Federal Communications Commission in open proceedings concerning the Emergency Alert System [Docket Nos. 15-94 and 04-296] and Wireless Emergency Alerts (WEA) [Docket Nos. 15-91 and 07-287]. The document presents the background and results of research activities which were conducted to examine the effectiveness of EAS and WEA to provide alerts to people with disabilities. Specifically, the Wireless RERC conducted comparative analyses of the awareness of EAS and WEA messages, the accessibility of the two systems, as well as the types of protective actions taken as a result of the emergency messages. The survey research occurred between 2011 and 2014 and the results, analyses and recommendations were completed in 2015 and were submitted for consideration in the above-referenced rulemakings. This research is provided to government entities to supply unbiased data and evaluation to help ensure that individuals with disabilities have equal access to critical lifesaving information through digitally-based warning systems.

Related Files:

Attachment	Size
Ex Parte _WEA_EAS_ResearchBrief_FINAL.pdf	383.24 KB

Wireless RERC on the Record - Hearing Aid Compatibility Regulations

mz22 — Fri, 06 Feb 2015 15:41:18 +0000

deaf

Hard-of-Hearing

Hearing Aid Compatibility (HAC)

Wireless RERC/CACP Comments Filed in Response to Public Notice [WT Docket Nos. 07-250 and 10-254]

Publication Type:

Policy Filings

The Rehabilitation Engineering Research Center for Wireless Technologies (Wireless RERC), in collaboration with Georgia Tech’s Center for Advanced Communications Policy (CACP), submitted comments in response to the FCC’s Public Notice, Request for Updated Information And Comment On Wireless Hearing Aid Compatibility (HAC) Regulations [WT Docket Nos. 07-250 and 10-254]. Released on November 21, 2014, the Public Notice sought insight into the current consumer experience, technical or other barriers to the provision of hearing aid compatible mobile phones, and considerations to amend rules for Twenty-First Century Communications and Video Accessibility Act (CVAA) compliance. The Wireless RERC and CACP reaffirmed the belief that the accessibility of information and communications technology (ICT) and services are essential to enhancing inclusion and independence for people with disabilities. Comments were respectfully based on subject matter expertise developed over the past 14 years: findings from consumer surveys and focus groups, policy research, and development efforts. The comments were also largely informed by analyses of data collected via the Wireless RERC’s hearing aid compatibility (HAC) survey research.

The FCC sought to update the record on two principle issues: (1) Whether the FCC should revise the hearing aid compatibility requirement to apply in a technologically neutral manner to all mobile wireless devices; and (2) Whether the FCC should consider moving away from the fractional compliance benchmarks and implement a requirement that all mobile wireless devices must comply with the hearing aid compatibility rules. The Wireless RERC and CACP addressed both issues with the following assertions:

Ease of finding a compatible phone would be greatly improved if HAC requirements applied to all wireless handsets and would simplify phone selection for people with varying capabilities. For people with hearing loss, when purchasing a handset there are other mainstream and accessibility features to consider in conjunction with HAC compliance. One should not have to sacrifice other phone features to ensure they are purchasing a HAC compliant phone.
Phones are rapidly changing forms and technologies; the Commission should attempt to create a large tent to encompass as many technologies that might be used in devices with phone features. Most Wi-Fi phones and private internal phone networks interconnect with the public switched telephone network (PSTN) through a gateway so they can be used to make traditional phone calls. …a technologically neutral manner should be adopted.
Hearing aid users report little improvement in ease of finding a hearing aid compatible wireless handset over the course of implementation of the HAC Act requirements. Substantial proportions of hearing aid users still report their search as being difficult or very difficult. Furthermore, fractional deployment causes problems for consumers in today’s market as more and more consumers are opting to have wireless devices only. These factors indicate it might be time to phase out the fractional deployment rules.

In closing, the comments acknowledged the difficulty of crafting regulations due to the sometimes competing priorities of industry and consumers and the complexity of interaction between increasingly sophisticated and powerful wireless handsets. Nevertheless, they also maintained that people with hearing loss deserve and are entitled to having parity of access to telecommunications services, wireless, or otherwise.

Wireless RERC Comments on Impact of Federal Accessibility Mandates

mz22 — Fri, 17 Oct 2014 15:42:54 +0000

Federal Communications Commission (FCC)

Twenty-First Century Communications and Video Accessibility Act

Comments of Georgia Institute of Technology (Georgia Tech), Center for Advanced Communications Policy (CACP) and the Rehabilitat

Publication Type:

Policy Filings

Georgia Tech’s Center for Advanced Communications Policy (CACP), in collaboration with the Wireless RERC, submitted comments to an FCC Public Notice [CG Docket No. 10-213] asking for comments on the tentative findings about the accessibility of communication technologies. Released on August 28, 2014, the Public Notice requested comments assessing the extent to which telecommunications and advanced communications services and technology have complied with CVAA accessibility mandates, related recordkeeping and enforcement obligations effects, and the existing accessibility barriers for new communications technologies.

Georgia Tech’s CACP and the Wireless RERC submitted comments addressing various aspects of inclusive and accessible technologies, including:

Research supporting tentative findings that show an increase in readily available and accessible technologies;
Information concerning the staffing and training of people who are knowledgeable about assistive technologies and the people who use them;
Discrepancies among retail staff and retailer knowledge about assistive technologies and;
The lack of accessible alerting systems.

Wireless RERC Makes EAS Accessibility Standards Recommendations

mz22 — Thu, 28 Aug 2014 16:19:31 +0000

Emergency Alert System (EAS)

Comments of Rehabilitation Engineering Research Center for Wireless Technologies (Wireless RERC)

Publication Type:

Policy Filings

August 2014 – The Wireless RERC and Georgia Tech’s Center for Advanced Communications Policy (CACP) submitted comments to the FCC’s Notice of Proposed Rulemaking In the Matter of Review of the Emergency Alert System (EAS) [EB Docket No. 04-296]. As a result of the nationwide EAS test revealing issues with text crawls, the FCC requested public comments about the accessibility of EAS' visual and audio presentation of text.

CACP and Wireless RERC comments highlighted the need for EAS nationwide testing to account for human ability factors, as well as technical considerations when setting a national standard for text crawls. Their comments advised that any standards should consider the needs of people with vision disabilities, as well as those that simultaneously experience vision and hearing loss; noting a correlation between visual acuity and caption reading ability.

Further comments and recommendations concerning non-English alerts, text crawl placement, audio accessibility, and text-to-speech were made as well. For more information, please click the link below.

Wireless RERC Recommends ASL Translation of Emergency Messages

mz22 — Tue, 03 Jun 2014 20:21:38 +0000

American Sign Language

(ASL)

deaf

Emergency Alert System (EAS)

Wireless RERC Comments Regarding Multilingual EAS Messages

Publication Type:

Policy Filings

May 2014 – The Wireless RERC filed comments regarding EAS Rules to Support Multilingual EAS and Emergency Information [EB Docket No. 04-296] corroborating the work of the Minority Media and Telecommunications Council (MMTC) in their efforts to increase access to emergency information for people whose native language is not English, specifically noting the need for the inclusion of American Sign Language (ASL). ASL is a distinct language used by individuals of the deaf community and is fundamentally unlike English. Many deaf people are conversant only in ASL and have difficulty understanding written English. Currently, emergency alert messages are not accessible for deaf people that rely on ASL. This signifies that potentially millions of Americans are not adequately receiving, understanding, and reacting to emergency messages. There currently is a great need to provide these accessible messages for this population in the language they understand best.