FCC Filings
CACP continuously monitors the policy environment by tracking legislative, regulatory, judicial, and industry activities as they relate to advanced communications, information technology, technology access, and vulnerable populations. Pertinent items appear in our newsletters, result in filings before the FCC, or contribute to actions in other related venues. Several of our comments have been noted in FCC rulemakings. Efforts in this area serve to keep constituents in the technology, policy, academic and research communities well-informed on the latest developments and issues that impact the advanced communications policy landscape.
You may peruse our monthly Telecom/IT Policy Highlights which presents legislative, regulatory, legal and other items pertinent to advanced communications and related technology policy on the research page under newsletters.
Wireless RERC files FCC comments on “Amendment of the Commission’s Rules Governing Hearing Aid Compatible Mobile Handsets”, WT Docket No. 07-250
On Dec. 16, 2007 the Wireless RERC filed comments to the FCC on Amendment
of the Commission’s Rules Governing Hearing Aid Compatible Mobile Handsets,
WT Docket No. 07-250. The Wireless RERC noted in response to the FCC’s solicitation
that ongoing Wireless RERC research suggests that consumers continue to
have problems with the interoperability of cell phones and hearing aids.
In a recent Wireless RERC Delphi Policy study, an overwhelming majority of
respondents identified “device incompatibility or poor interoperability,” as
a very important or important issue with cell phones. Further, the Wireless
RERC's Survey of User Needs (2002-present) continues to find evidence that
consumers with hearing impairments have difficulty finding cell phones in
the marketplace that are compatible enough with hearing aids. These findings
reveal that cell phone users with hearing impairments are running up against
barriers to full usability of their device, which could be addressed through
the regulatory process.
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Filing on Reallocation of 30 MHz of 700 MHz Spectrum for Public Safety Use
The Wireless RERC submitted comments to the FCC on November 29, 2006, addressing issues involved with use and reallocation of a portion of the 700 MHz spectrum in response to a Petition for Rulemaking: Cyren Call Communications Corporation – Reallocation of 30 MHz of 700 MHz Spectrum from Commercial Use – Assignment of 30 MHz of 700 MHz Spectrum to the Public Safety Broadband Trust for Deployment of a Shared Public Safety/Commercial Next Generation Wireless Network. The proposal, by Cyren Call Communications Corporation was to reallocate 30 MHz of 700 MHz spectrum for deployment of a shared public safety/commercial next generation wireless network. The RERC comments raised several points including 1) support of the recommendations to reallocate additional spectrum for public/private use; 2) a recommendation that the design of any network as well as wireless emergency communications applications needed to consider the needs of people with disabilities; 3) a recommendation that any network developed should be in consultation with other stakeholders such as the Department of Homeland Security to ensure it interfaces with other critical warning networks; and 4) a statement that emphasized that spectrum allocation for public safety or any reallocation of spectrum for public safety take into account the accessibility requirements of people with disabilities. The filing will be available on the RERC website or via access from the FCC e-filing system.
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Notice of Proposed Rulemaking (FCC 04-296) about the future of the Emergency Alert System (EAS).
CACP comments recommended a major upgrade of EAS, including mandatory participation by broadcast
stations, and an expansion of EAS rules to cover new digital technologies, and expanding EAS to new devices as essential an for
providing emergency information to people with disabilities. New technological pathways for EAS communications include wireless data
networks that reach millions of Americans in remote locations, both fixed and mobile. CACP also recommended more comprehensive
planning and coordination among state and federal agencies and focused on the benefits of digital and alternative technologies for
people with disabilities.
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Notice of Proposed Rulemaking (FCC 04-296) about the future of the Emergency Alert System (EAS).
CACP recommended that the FCC further encourage and support IP Relay and comparable text messaging services for wireless devices, recommended making IP Relay mandatory for states, requiring services to be offered 24 hours per day, 7 days a week,
and promoting open standards that will allow multiple platforms for text-to-text communication to flourish. The wireless RERC suggested
that the FCC encourage wireless manufacturers to build in TTY capability so as to enable more reliable emergency communications for users
with disabilities.
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Telecommunications Relay Services and Speech-to-Speech Services for Individuals with Hearing and Speech Disabilities, Second Report on Order, Order on Reconsideration and Notice of Proposed Rulemaking (FCC 03-123)
In
responding to comments filed by various advocacy groups for the deaf and hard of hearing, CACP emphasized to the FCC the
importance of providing parity of service with respect to emergency communications and expand
TRS requirements so as to allow text messages to become a regular part of emergency communication services.
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