NAD and Consumer Groups File Comments on Advanced Communications Services

On April 25, 2011, the NAD, along with other consumer organizations, submitted comments in response to a Notice of Proposed Rulemaking issued by the Federal Communications Commission (FCC) asking for comments about “advanced communications.” The Twenty-First Century Communications and Video Accessibility Act of 2010 (Accessibility Act), signed by President Obama last fall, requires that providers of advanced communications services (ACS) and manufacturers of equipment used for ACS make their services and products accessible to people with disabilities, unless it is not achievable to do so.

In our comments, the NAD and Consumer Groups urged the FCC to interpret the scope of coverage requirements of the Accessibility Act in a manner that maximizes the extent to which users with disabilities have access to advanced communication services and products. We emphasized that all the components of advanced communication services and products must be accessible. With closed captioning, many shows are not captioned due to incompatibility in the distribution chain. This must not happen with advanced communication services.

We also urged the FCC to interpret the Accessibility Act to require that all video communication services and equipment should be interoperable. This would mean that one could call a Video Phone (VP) or Video Relay Service (VRS) provider from any video conferencing software such as Skype, FaceTime, or ooVoo. Deaf and hard of hearing people should be able to make VP and VRS calls from any platform, such as on a hearing friend’s computer.

The NAD and Consumer Groups also filed reply comments on May 23, 2011 restating our positions in response to other comments. Many of the commenters asked the FCC for narrow interpretations of the scope of coverage requirements for the Accessibility Act. We replied explaining that these commenters have forgotten the purpose of the Accessibility Act which is “to help ensure that individuals with disabilities are able to fully utilize communications services and equipment and better access video programming.”