The Federal Communications Commission (“Commission”) voted unanimously at its Open Meeting on September 27, 2017 to approve a Notice of Proposed Rulemaking (“NPRM”) that proposes exempting certain types of wireless providers from the hearing aid compatibility (“HAC”) reporting requirements.  The NPRM outlines possible revisions to the wireless HAC rules that would “reduce unnecessary regulatory burdens, particularly for non-nationwide service providers.”  The reporting requirements currently apply to facilities-based and reseller wireless service providers of all sizes and this rulemaking represents a prime opportunity for smaller wireless carriers to remove some burdensome reporting obligations, which have led to enforcement actions in the past. Comments will be due 30 days after publication of the NPRM in the Federal Register and reply comments will be due 45 days after publication.

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This week, the Federal Communications Commission (“FCC” or “Commission”) released a Notice of Proposed Rulemaking (“NPRM”) to increase uniformity among several diverse sets of FCC complaint procedures.  Today, there are three different mechanisms for complaints handled by either the Market Disputes Resolution Division (“MDRD”) or the Telecommunications Consumers Division of the Enforcement Bureau regarding common

In advance of its July Open Meeting, the Federal Communications Commission (Commission) unanimously adopted a Report and Order (Order) that revises the rules requiring certain video programming providers to make video described programming available for access by Americans who are blind or visually impaired. The new rules expand the Commission’s existing requirements by increasing the

On March 16, 2017, the Federal Communications Commission’s Media Bureau (Bureau) released a Memorandum Opinion and Order (Order) addressing Honda Motor Co., Ltd’s (Honda) January 2017 petition for limited waiver of video accessibility rules for its in-vehicle rear entertainment systems. The Bureau granted Honda’s 20-month waiver request with the condition that Honda provide status update reports.

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On December 19, 2016, the Federal Communications Commission’s (Commission) Public Safety and Homeland Security Bureau (Bureau) issued a Public Notice (Notice) seeking comment on a letter from the National Association of State 911 Administrators (NASNA) that asks the Commission to initiate a proceeding to examine issues related to how mobile device 911 applications interface with 911 systems. Comments on the Notice are due by February 2, 2017 and reply comments by March 6, 2017.

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Last week, the Federal Communications Commission’s (FCC or Commission) Media Bureau released a Public Notice (Notice) seeking comment on a petition for limited waiver of the Commission’s rules filed by Honda Motor Company (Honda). Honda seeks a limited 20 month waiver of the requirement for the user interfaces on its rear entertainment systems to be accessible for people with disabilities. Comments on the Notice are due by January 11, 2017 and reply comments by January 23, 2017.

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Modern mobile devicesOn December 15, 2016, at the last Federal Communications Commission (FCC or Commission) Open Meeting under Chairman Tom Wheeler’s tenure, the Commission voted unanimously to adopt a Report and Order (Order) and Further Notice of Proposed Rulemaking (FNPRM) that permits wireless service providers and device manufacturers to support real-time text (RTT) technology instead of text telephony (TTY) to meet their obligations to provide reliable telephone communications options for people who are deaf, hard of hearing, deaf-blind or who have a speech disability. RTT technology uses IP-based networks and allows the user to send text immediately as it is typed without the need to press “send” and the other party receives the text to read as it is being created. The ability to use RTT to meet TTY obligations phases in starting in December 2017 and resellers have until June 2021 to comply.

The FNPRM seeks comment on issues including sun-setting the TTY backwards compatibility requirement and interaction with the telecommunications relay service (TRS). Comments are due 30 days after publication in the Federal Register and reply comments are due 30 days later.


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On October 7, 2016, the Federal Communications Commission (FCC) released the third iteration of its Biennial Report to Congress on the state of communications technology accessibility for people with disabilities as required by the Twenty-First Century Communications and Video Accessibility Act of 2010 (CVAA). To inform the conclusions in the 2016 CVAA Biennial Report, the FCC sought input by way of two Public Notices, one general and another outlining its tentative findings. One of the findings was that 31% of the requests for dispute assistance (RDA) involved lack of accessibility features in mobile phones provided by Lifeline service providers.

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On October 6, 2016, the Federal Communications Commission (FCC) released a White Paper entitled “Individuals with Cognitive Disabilities: Barriers to and Solutions for Accessible Information and Communication Technologies” containing best practices for equipment manufacturers and service providers looking to comply with the Twenty-First Century Communications and Video Accessibility Act and the FCC’s accessibility rules. This release teed up FCC Chairman Tom Wheeler’s remarks later that day at the Coleman Institute Conference on Cognitive Disabilities and Technology. These events come after the FCC hosted its first-ever Summit and Expo on Telecommunications Needs of People with Cognitive Disabilities in October 2015 and demonstrate a strong focus of the FCC on making sure communications equipment and services are accessible to people with all kinds of disabilities.

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On August 23, 2016, the FCC issued a Public Notice seeking comment on the Consumer and Governmental Affairs Bureau’s tentative findings about the accessibility of communications technologies, which will be included in this year’s biennial report to Congress on the 2010 Twenty-First Century Communications and Video Accessibility Act (CVAA) (Biennial Report).  This will be the third such report, following earlier reports in 2012 and 2014.  Comments are due September 7, 2016.

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