2013 Regulatory Filings

Wireless RERC Comments on Accessibility of Emergency Information

August 22, 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 programming. 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.
Additional Information:
Wireless RERC Comments
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Wireless RERC Comments on the Accessibility of Next Generation 911 Deployment and Application

April 9, 2013 — The Wireless RERC submitted reply comments to the Further Notice of Proposed Rulemaking: “Facilitating the Deployment of Text-to-911 and Other Next Generation 911 Applications” [PS Docket No. 11-153] and “Framework for Next Generation 911 Deployment” [PS Docket No. 10-255]. The Wireless RERC expressed their continued support for obligatory rules concerning the deployment of text-to-911. The Wireless RERC recommended that pre-installed messaging applications be included in any text-to-911 mandates, as it could help “pave the way for transitioning to an all-IP environment.” Regarding the timetable for text-to-911 deployment, the Wireless RERC agreed with the National Emergency Number Association’s (NENA’s) recommendation that the FCC make May 15, 2015 the deadline for small and rural carriers to meet the text-to-911 requirements. The Wireless RERC supported AT&T’s recommendation to officially require 911 to be used as the short-code and those devices that “cannot send a three digit short code should be phased out of the market.” Finally, the Wireless RERC concurred with NENA’s recommendation that a five year timeframe be established to further evaluate the implications of sun-setting mobile TTY requirements.
Additional Information:
Wireless RERC Comments
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WIRELESS RERC PROVIDES COMMENTS/RECOMMENDATIONS TO THE NATIONAL WEATHER SERVICE

On March 22, 2013, the Wireless RERC provided comments and recommendations to the National Weather Service (NWS) regarding its efforts to simplify and clarify the language used to convey emergency weather information. Through research with people experiencing hearing loss whose primary language is American Sign Language (ASL), the Wireless RERC has learned that the wording commonly used in emergency weather messages can be confusing when translated into ASL. According to participants in field trials conducted by the Wireless RERC, it is preferable to accommodate deaf individuals who utilize ASL as their primary language with ASL interpretation of written or spoken English. Since national, state and local alerting systems rely on the NWS for weather related emergency information and pass through identical verbiage, which may be translated by sign language interpreters, it is critical that the NWS language be clear and remove any jargon, truncated text or idiomatic expressions. To that end, the Wireless RERC recommended that the NWS contact organizations representing the interests of people who are Deaf and requested that the proposed language be vetted amongst people whose primary language is ASL. In addition, the Wireless RERC is developing an ASL Video Clip library of emergency terms that have been vetted by the ASL community, which will be shared with the NWS once complete.
Additional Information:
Wireless RERC Input _ NWS 2013
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WIRELESS RERC COMMENTS ON TEXT-TO-911 DEPLOYMENT

The Wireless RERC submitted reply comments in response to the Federal Communications Commission's Further Notice of Purposed Rulemaking: Facilitating the Deployment of Text-to-911 and Other Next Generation 911 Applications [PS Docket No. 11-153] and Framework for Next Generation 911 Deployment [PS Docket No. 10-255]. The Wireless RERC agreed with assertions that the regulations on the availability of text-to-911 and bounce back error messages should apply to all mobile service providers. For the latter, the Wireless RERC supported the National Emergency Number Association's (NENA) recommendations for standardized language and further suggested that the bounce back message phrasing be vetted by people whose primary language is American Sign Language. Finally, the Wireless RERC maintained that, while education and outreach efforts should be a collaborative effort, the federal government, specifically the FCC's Consumer and Governmental Affairs Bureau, should play a primary role by developing a nationwide PSA on text-to-911 and ensuring the accessibility of outreach activities and materials.
Additional Information:
Wireless RERC Comments
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WIRELESS RERC INCLUSION IN THE FCC REPORT ON NG911 SERVICES

On February 22, 2013 the Federal Communications Commission (FCC) released a Report to Congress in entitled Legal and Regulatory Framework for Next Generation 911 Services, in which the Wireless RERC was cited and referenced throughout the document. In preparation of the report, the FCC issued a Public Notice that sought public comments on the issues related to the legal and regulatory infrastructure needed for the transition from legacy 911 to Next Generation 911 (NG911). The Wireless RERC is referenced in regard to its support of NG911 deployment being governed at the state and local level and for favoring new 911 funding mechanisms, as the current system is thought to be outdated and inefficient for supporting the transition to NG911. In regard to how 911 funds should be collected, the Wireless RERC comment was included that noted the importance of a fee-based approach ensuring that “non-voice-enabled services contribute their fair share to 911 funding.” The Report also included Wireless RERC recommendations on specifically increasing the role and authority of the Emergency Access Advisory Committee (EAAC), expanding the Public Safety Interoperable Communications (PSIC) grant program to include technologies that advance NG911, and enhancing the Master Public Safety Advisory Point (PSAP) Registry to provide an interactive map showing each PSAP’s NG911 capability.
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WIRELESS RERC LETTER REQUESTING FCC QUESTIONS FOR THE HAC

On January 17, 2013 the Wireless RERC drafted and submitted a letter to the FCC in response to the Public Notice: “Updated Information and Comments Sought on Review of Hearing Aid Compatibility Regulations [WT Docket No. 10-254: DA 12-1745],” inviting the Wireless Telecommunications Bureau to submit questions to the Wireless to inform the update of our HAC Consumer Survey. They responded in the affirmative, and their questions have been included in the HAC survey of the Wireless RERC. The resultant data will be supplied to the FCC via exparte comments to the above-referenced Public Notice.
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