[Ohio-talk] FW: URGENT: WE NEED LETTERS TO MAKE E-READERS ACCESSIBLE BY LABOR DAY

[Barbara Pierce]

I received this email with attachments this morning. I hope that people can
get to the attachments to read them. The third one is the bare bones of a
letter that people can use as a guide to write their own letter. The message
below explains that the letters must be sent to the National Center by
Monday, Labor Day. They will be gone over and fixed up if necessary so that
they can be handed in on Tuesday. College students and school kids need our
help. Those of us who would like to be able to use the book readers will
also benefit. I am dropping into this message the letter that I have written
so that you can get an idea of what is needed. Even if you can't read the
attachments, you can use my letter as your model and make changes as you see
fit. Please help.

Thanks,
Barbara

Barbara Pierce 
President Emerita, National Federation of the Blind of Ohio
237 Oak Street
Oberlin, Ohio 44074
bpierce at oberlin.net
September 3, 2013

Kris Monteith
Acting Bureau Chief
Consumer and Governmental Affairs Bureau
Federal Communications Commission
445 12th Street SW
Washington, DC 20554

Re: Reply to the Coalition of E-Reader Manufacturers' Petition for Waiver
from CVAA Accessibility Requirements, CG Docket No. 10-213

Dear Mr. Monteith: 

I am a blind woman, a volunteer advocate for blind people and parents of
blind children, an active member of my community, and a retired magazine
editor. In every way you can imagine, reading is vitally important to me. I
strongly oppose the Petition for Waiver submitted by the Coalition of
E-Reader Manufacturers, requesting that e-readers be exempt from the Twenty
First Century Communications and Video Accessibility Act (CVAA).  

The spirit of the CVAA is to increase the accessibility of mobile advanced
communications services (ACS), and e-readers are built with ACS
functionality.  Most e-reader users I know use them to post to Facebook and
exchange books with friends.  It would not make sense to grant a waiver for
a class of products that are clearly intended to be covered by the CVAA.

The Coalition claims that the primary purpose of e-readers is reading, not
ACS, but clearly the ACS found in e-readers is part of the intended purpose.
The ability to connect with friends, share content, and access the internet
are the very features that set e-readers apart from print books.  ACS
facilitates the reading experience and is, therefore, a co-primary purpose
of e-readers. My sighted children and friends use these features all the
time, and I would like to join them.

E-readers can easily be made accessible.  All digital content can be made
accessible to a blind person if the content is programmed to be read
audibly, audio output like speakers or a phone jack is added, and
accessibility is considered during the design phase.  The Coalition's claim
that to make e-readers accessible would require a fundamental overhaul of
the equipment is absurd.  

As it stands now, If I want to read a Kindle book, I have to buy an
expensive Apple iPad.  Then I can download the free Kindle app, but even
then that application is not fully accessible.  I want to be a mainstream
user and would happily buy an e-reader if one was accessible, but the
manufacturers continue to exclude me from their customer pool.  I reject the
Coalition's contention that making their product accessible would not
provide me with any substantial benefits.  In reality, doing so would give
me options as a consumer and equal access with my sighted peers.  

The Department of Justice and the Department of Education prohibit K-12
school districts and institutions of higher education from using
inaccessible e-readers, yet the Coalition continues knowingly to sell
inaccessible equipment to schools.  The CVAA is consistent with preexisting
legal requirements, and the FCC should not give the Coalition incentive to
continue resisting accessibility. 

My family has now converted to e-readers, but I am still limited to the
Library Of Congress offerings. I can't discuss recent books with my friends,
and I generally feel like a second-class citizen.

I strongly urge the FCC to reject the Coalition's petition and uphold the
spirit of the CVAA.  E-readers and the ACS features found in that equipment
must be made accessible, and granting a waiver would perpetuate the digital
divide and the discrimination in the marketplace that I face every day.  

Sincerely,
Barbara Pierce
 

-----Original Message-----
From: McLarney, Lauren [mailto:LMcLarney at nfb.org] 
Sent: Wednesday, August 28, 2013 5:07 PM
Subject: URGENT: WE NEED LETTERS TO MAKE E-READERS ACCESSIBLE BY LABOR DAY 
Importance: High

Hello Legislative Directors,

We need your help!  The Coalition of E-Reader Manufacturers has submitted a
Petition for Waiver to the FCC asking that e-readers be exempt from the
Twenty First Century Communications and Video Accessibility Act (CVAA)
accessibility requirements.  I have attached the Petition.  NFB has written
comments opposing the request, and we are asking other groups to sign on.  I
have also attached those comments.  But the FCC needs to hear from our
members - blind people who want access to e-readers - and the more people
they hear from, the better.  We are asking all Legislative Directors to find
people in their respective affiliates to edit the attached skeleton letter
and return it to us.  The letter is already formatted and has an outline,
but it is up to each person to make it personal and select which talking
points they want to use.  Finished letters should be sent to Valerie
Yingling at vyingling at nfb.org<mailto:vyingling at nfb.org> by 8pm on Monday,
September 2.  Valerie will proofread each document to make sure there are no
typos and the customized points are still on message, and then we will
submit the letters all at once when they are due on September 3rd.  We are
short on time, but I trust that this issue is pressing to our membership and
we will get a good amount of letters.

For some background:  The CVAA requires that all mobile devices with
advanced communications services (ACS) be accessible to blind people, but
the law allows manufacturers to request a waiver for equipment that is not
intended for ACS.  The Coalition (comprised of Amazon, Sony and Kobo) claims
that the primary purpose of e-readers is reading, and that the ACS found in
e-readers is so incidental and ancillary that it is not an intended purpose
of the device.  We know this is not true - e-readers are outfitted with
built-in web browsers and designed for social media.  The Coalition also
claims that to make e-readers accessible would require a fundamental
overhaul that would render e-readers obsolete, harm the public interest, and
not provide substantial benefit to blind people.  We know that this
offensive claim is also not true.  It is critical that the FCC hear from all
of us - it is the only thing that can defeat the petition.  Regulation is
legislation's sister, so I know we can count on all of you to get a good
amount of feedback to the FCC.  If you have any questions, don't hesitate to
email me or Valerie.   Looking forward to seeing everyone's letters.

Cheers,
Lauren

Lauren McLarney
Government Affairs Specialist
NATIONAL FEDERATION OF THE BLIND
200 East Wells St.
Baltimore, MD 21230
(410) 659 9314 ext. 2207
lmclarney at nfb.org<mailto:lmclarney at nfb.org>



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