[nfbwatlk] FCC seeking public comments on cell phone accessibility

[Joanne Laurent]

I am forwarding a message I found on the Vision Rehab Therapist listserv
seeking public comments on cell phone accessibility. 
 
From: visionrehabtherapist-bounce at freelists.org
[mailto:visionrehabtherapist-bounce at freelists.org] On Behalf Of steve kelley
Sent: September 04, 2010 12:43 PM
To: visionrehabtherapist at freelists.org
Subject: [visionrehabtherapist] FCC seeking public comments on cell phone
accessibility
 
This is a copy of a post I submitted to lowvisiontech.com based on a Web
seminar at Serotalk.com last evening: Please take a moment to send along
your comments to the FCC by September 13.
 Hey FCC, Can You Hear Us Now?
Time is running out to tell the FCC what you think about accessible cell
phones. The FCC is seeking comments from consumers on their experiences with
accessible cell phones, and the deadline of September 13, 2010 is fast
approaching.
The more consumers weigh in on this important topic, the more seriously the
FCC will take their mandate to have cell phone providers comply with the
1996 law stipulating that wireless telephones be accessible.
The AFB's Web page on the FCC's public notice for comment, at
http://www.afb.org/Community.asp?AnnouncementID=922 highlights several
points consumers may wish to point out in their comments:
1. Gaps in the wireless technology preventing blind, low-vision, and
deaf-blind consumers access;
2. additional cost associated with additional software or technology to make
wireless phones accessible;
3. limited or non-existent selection of low-moderate cost wireless phones
with accessibility features;
4. compatability of wireless telephones and Braille displays.
A recent Web seminar on this subject hosted by Serotalk and archived as
Serotalk Tech Chat <http://accessibleevent.com/013064363/archive/1023/>  #67
also included these additional considerations:
1. lack of complete access to business wireless phones puts prospective
employees with a disability at a significant disadvantage;
2. well-meaning, but poorly trained sales personnel who often have no idea
of accessibility features available on the phones being sold;
3. section 255 of this communications act governing and providing for
accessibility now 14 years old, and little progress has been made;
4. accessibility of texting on basic phones;
5. documentation is often in PDF format that is only partially accessible;
6. limited options from the pay-as-you-go plans.
Of course if you'd rather wade your way through the actual public notice
issued in July by the FCC, it is at:
http://www.fcc.gov/Daily_Releases/Daily_Business/2010/db0722/DA-10-1324A1.do
c .
Comments may be posted electronically at the Commission's Electronic Comment
Filing System (ECFS), http://fjallfoss.fcc.gov/ecfs2/
<http://fjallfoss.fcc.gov/ecfs2>  or the Federal eRulemaking Portal,
www.regulations.gov <http://www.regulations.gov/> . Be sure where applicable
to include that comment is in reference to CG Docket number 10- 145.
Instructions for email will be forwarded to you by sending an email to
ecfs at fcc.gov with "get form (your email address)" written in the body of the
message. See my copy of these instructions below, with my comments.
According to the AFB article, paper comments may be mailed to: Commission's
Secretary Office of the Secretary FCC Headquarters at 445 12th St., SW.,
Room TW-A325, Washington, DC 20554.  For each filing, include one original,
four copies, and mail a copy to the FCC's duplicating contractor: Best Copy
and Printing, Inc., 445 12th Street, SW., Washington, DC 20554.
Here is what this writer forwarded using the email address ecfs at fcc.gov and
format provided (Please feel free to copy this and modify it to match your
own cell phone experiences more closely:
<PROCEEDING> CG Docket number 10- 145
<DATE> 09/02/10
<NAME> Steven Kelley
<ADDRESS1> 16 Myplace Way
<ADDRESS2>
<CITY> Kennebunk
<STATE>ME
<ZIP> 04043
<LAW-FIRM>
<ATTORNEY>
<FILE-NUMBER>
<DOCUMENT-TYPE> CO
<PHONE-NUMBER> 800-466-4411
<DESCRIPTION> Email Comment
<CONTACT-EMAIL> steve.kelley at public.com
<TEXT>
Dear FCC,
I wish to comment on the accessibility features found on most cell phones.
It has been my experience that few cell phones offer any accessibility
features, such as screen magnification or screen reading, out of the box. If
these eatures are available for the phone it is often an additional cost to
the consumer of several hundred dollars. This is an additional cost a blind
or low vision consumer must pay to use this device. In the few instances
there is basic accessibility, full access to the other phone features, such
as texting, calendar, address book, etc. remain inaccessible. Such an
inaccessible business phone puts the user with a vision impairment at a
distinct disadvantage over coworkers with complete access to the phone.
It has also been my experience that the options ofr accessible phones in the
low-mid price range, and among the pay-as-you-go providers are few or
non-existant. When available these options must be purchased with more
expensive, high-end phones. Basic accessible cell phone are virtually
non-existent.
Cell phone service providers often have well-meaning staff at retail stores
or managing help lines that have very little information about what cell
phone models have accessibility features available, and how these are used.
Documentation, if it exists, is often in a PDF format that is not completely
accessible, and rarely available in Braille.
With the dramatic increase in cell phone texting, and the importance of this
communication media for both personal and business use, few cellphone offer
accessible number pads or keyboards, making this feature often inaccessible
as well.
It is my understanding that Section 255 of the Telecommunications act of
1996 mandates that, manufacturers must make certain that their products are
"designed, developed, and fabricated to be accessible to and usable by
individuals with disabilities"  when this is readily achievable to do so. I
further understand that the FCC is responsible for rules and policies to
enforce the law. It seems clear that Section 255, after 14 years, requires
better regulated rules and policies, and stricter enforcement, to achieve
these goals.
Thank you,
Steven Kelley
Remember, the deadline here for submitting comments is September 13, 2010.
 
 
 
Steven Kelley, Vision Rehab Therapist
The Iris Network
189 Park Avenue
Portland, ME 04102
email: skelley at theiris.org <blocked::mailto:skelley at theiris.org> 
phone: 800-715-0097