CACP addresses a wide range of advanced communications policy issues and related technology applications, particularly in the wireless and new technology arenas. These activities result in timely papers, reports, and articles, as well as advisories and published research filings before regulatory authorities.
Wireless RERC on the Record: Deployment of Advanced Telecommunications Capabilities
On October 5, 2017, the Wireless RERC submitted reply comments in response to the Federal Communications Commission’s Notice of Inquiry Concerning Deployment of Advanced Telecommunications Capability to All Americans in a Reasonable and Timely Fashion [GN Docket No. 17-199]. The Inquiry sought stakeholder input on a number of issues, not the least of which were considerations on how to evaluate and include (a) deployment and use of mobile services, (b) the demographic characteristics of unserved areas, and (c) deployment based on demographic characteristics, independent of geographical location. Reply comments supported and elaborated on initial comments submitted separately by the Colorado State Broadband Office (SBO), the Communications Workers of America (CWA), Public Knowledge, et al., National Electrical Manufacturers Association (NEMA), National Rural Electric Cooperative Association (NRECA), the Multicultural Media, Telecom and Internet Council (MMTC), and others. The Wireless RERC concurred with comments made in support of the need for both fixed and mobile advanced telecommunications services in a community to be considered reasonably and timely delivered. Regarding the hot-button topic, Public Knowledge, et al. poignantly stated that “Because consumers who can afford [emphasis added] both mobile and fixed connections typically purchase both, they should be seen as complementary, not substitute products, that the Commission measures separately…if two products were truly “interchangeable,” no one would buy both.
Wireless RERC Reply Comments
Wireless RERC on the Record: Transitioning to Real-Time Text Technology
March 24, 2017 - The Wireless RERC submitted reply comments in response to the FCC’s Further Notice of Proposed Rulemaking In the Matter of the Transition from TTY to Real-Time Text Technology [CG Docket No. 16-145]; Petition for Rulemaking to Update Commission’s Rules for Access to Support the transition from TTY to Real-Time Text Technology, and Petition for Waiver of Rules Requiring Support of TTY Technology [GN Docket No. 15-178]. While the reply comments supported transitioning from Teletypewriter (TTY) to Real-Time Text (RTT) technology, we concurred with other stakeholder recommendations that the manner and speed in which it is done take into account those most at risk of losing all text communications access if TTY becomes unavailable. While most people with hearing and speech disabilities have a preference for text or video-based communications, there are still some that rely on TTY to place both emergency and non-emergency calls. For no one to be left behind, it is imperative that the transition process includes collecting data on network support, RTT-capable devices on the market, their accessibility levels, and end-user ownership rates. These data would shed light on both industry deployment rates and user adoption rates, users being both consumers and 911 call centers.
Wireless RERC Reply Comments - Transitioning to Real-Time Text Technology
Wireless RERC on the Record: NIDILRR's Research Agenda
March 20, 2017 - The Wireless RERC submitted comments in response to the National Institute on Disability, Independent Living, and Rehabilitation Research’s (NIDILRR) request for input concerning their Draft Long Range Plan, 2018-2023. NIDILRR is a Center within the Administration for Community Living (ACL), Department of Health and Human Services (HHS) that “sponsors grantees to generate new disability and rehabilitation knowledge and promote its use and adoption. To that end, Wireless RERC comments highlighted the considerable capabilities and functionality offered by smart devices and their ability to address important access and assistive technology needs of people with disabilities as a group. As new iterations of mobile wireless technology devices and networks are deployed, such as the Internet of Things (IoT), researchers, engineers, advocates, and the wireless industry must continue to push for parity of access to these essential technologies, especially through the adoption of inclusive design and development practices. Further, comments suggested that the combination of research, development, and policy activities can have an exponential impact on availability, accessibility, and usability of connected technologies. When working to improve access to technologies that are governed by federal agencies, the policy component is crucial to ensuring transfer of research knowledge into industry practice. Technologies to improve the quality of life, community integration, and the independence of individuals with disabilities are not confined to a single domain. Therefore, we strongly supported NIDILRR’s proposed model that accounts for cross-cutting research to provide a more flexible and versatile framework.
Wireless RERC Comments - NIDILRR Long Range Plan
Wireless RERC on the Record: Advancing Access to an Inclusive Internet of Things
March 13, 2017 - The Wireless RERC, in collaboration with Georgia Tech’s Center for Advanced Communications Policy (CACP), submitted comments to the National Telecommunications and Information Administration’s Request for Comments on the Benefits, Challenges, and Potential Roles for the Government in Fostering the Advancement of the Internet of Things [IOT] [170105023-7023-01]. CACP and the Wireless RERC strongly recommend that NTIA specifically articulate policy recommendations that support early stage inclusion of people with disabilities to further accessibility and usability of IoT technology and services before development and deployment of the same. Properly designed and developed, the IoT can realize its potential to empower all citizens, including people with disabilities to achieve an improved quality of life and greater social and economic inclusion. Comments also suggested that the federal government focus future policy initiatives as well as technological design on addressing the ability of IoT to apply “on demand” contextually aware information. This display of consumer-digestible information, coupled with the intelligence of devices and applications can meet and anticipate the needs of users with disabilities in ways which increase user independence, opening new opportunities in areas as broad as education, workforce participation, safety, e-health, and social engagement. Further, when implemented in the workplace, IoT technologies can profoundly change the experience of persons with disabilities, providing tools for independence and autonomy while at work. But implementation is to some extent dependent on availability and suitability of current (or in development) devices and services. It is here that the NTIA could provide formidable leadership in driving the development of the IoT framework by supporting multi-stakeholder engagement, not only formally, regarding policymaking, standards setting and regulation, but also by supporting the formation of public-private partnerships and other multi-stakeholder collaborations to envision innovative types and uses of IoT.
Wireless RERC/CACP Comments
Wireless RERC on the Record: Benefits, Challenges, and Potential Roles for the Government in Fostering the Advancement of the Internet of Things
March 13, 2017 - Georgia Tech’s Center for Advanced Communications Policy (CACP) in collaboration with the Rehabilitation Engineering Research Center for Wireless Inclusive Technologies (Wireless RERC) filed comments in response to The National Telecommunications and Information Administration's (NTIA) Request for Comments on the Benefits, Challenges, and Potential Roles for the Government in Fostering the Advancement of the Internet of Things (IoT) [Docket No. 170105023-7023-01] in which the NTIA “seeks broad input from all interested stakeholders—including the private industry, researchers, academia, and civil society—on the issues and proposed approach, current initiatives, and next steps laid out in the NTIA green paper ‘‘Fostering the Advancement of the Internet of Things’. These comments will help inform Department leadership on possible future Department action regarding IoT.” The comments conclude: “If industry stakeholders incorporate inclusive design approaches and policy participation from the disability community into their development, the IoT will facilitate more independent living, personalized care, flexibility and mobility, and better employment and education outcomes. The future of IoT should be one in which all persons are able to participate as creative and productive members of their communities. It is more important than at any time in the past to ensure that current and future policies foster an innovative, adaptive and inclusive environment to realize the full potential of the Internet of Things.”
Wireless RERC/CACP Comments [PDF]