The FCC issued a Public Notice on December 26, 2018 seeking input on a petition from General Motors Holding LLC (“GM”) that requests partial waiver of the interoperability functionalities for accessible real-time text (“RTT”) technology, as defined by the FCC. GM intends to launch an autonomous vehicle (“AV”) ride-hailing service in the near future that will include real time voice communication capability that riders can use to communicate with customer support. GM will also use RTT for such communications and GM seeks to be exempted from certain required RTT interoperability features based on planned limitations of the communications.

Comments on the Public Notice are due by January 25, 2019; and reply comments are due by February 11, 2019.


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The Federal Communications Commission (“Commission” or “FCC”) recently released a Public Notice seeking comment on a petition filed by the Entertainment Software Association (“ESA”) seeking a one year final extension of its class waiver from the FCC’s accessibility requirements (“Petition”). Specifically, ESA seeks waiver from the 21st Century Communications and Video Accessibility Act’s (“CVAA”) requirement that advanced communications services (“ACS”), like voice and text communications, built into video game software be made accessible for people with disabilities. Comments on the Petition are due by December 1, 2017.


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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 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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On Monday, May 23, 2016, the Consumer and Government Affairs Bureau (CGB or Bureau) of the Federal Communications Commission (FCC or Commission) released a Public Notice seeking comment on the state of compliance with the Twenty-First Century Communications and Video Accessibility Act of 2010 (CVAA) and the FCC regulations implementing the law.  The comments will be used to prepare the third biennial report to Congress on CVAA compliance.  The report will assess compliance by telecommunications carriers, VoIP providers, providers of advance communications services (ACS) and manufacturers of equipment for such services, including mobile phones.  More specifically, the Commission seeks comment from interested parties on whether the services and devices covered are “accessible,” the degree to which manufacturers and providers are including people with disabilities in product design and market research, and the extent to which entities are working with disability-related organizations, among other questions.  The report will also include the extent to which accessibility barriers remain with respect to new communication technologies and the impact of the recordkeeping and enforcement provisions on the development and deployment of new communications technologies.

Comments are due to the Bureau by June 22, 2016.  The Commission will use these comments to inform tentative findings, which will then be open for another round of public comment.  The report to Congress is due by October 8, 2016.
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The Federal Communications Commission (FCC or Commission) has long-required regulated telecommunications service providers (as well as VoIP providers) and equipment manufacturers to make their services and devices accessible to individuals with disabilities.  These entities also must annually certify to the FCC their compliance with the disabilities access requirements.  These compliance measures have become fairly routine for most regulated entities.  As of 2016, however, broadband Internet access service (BIAS) providers are now among those that must comply with disabilities access requirements, and the FCC has taken affirmative steps to remind these entities of their obligations under the Communications Act and Commission rules.


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Late last week, the FCC released a Second Report and Order and Second Further Notice of Proposed Rulemaking imposing additional emergency alert accessibility obligations on both device manufacturers and multichannel video programming distributors (MVPDs) pursuant to the Twenty-First Century Communications and Video Accessibility Act of 2010 (CVAA).  The new requirements are designed to make access to emergency information easier for individuals who are blind or visually impaired.  The initial obligations will be effective at the end of 2016, and comments will be due on the FNPRM 30 days after publication in the Federal Register.

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iStock_000036215158LargeYesterday, the Federal Communications Commission (“FCC”) released a Public Notice reminding telecommunications service providers, VoIP providers and advanced communications service (“ACS”) providers and equipment manufacturers of their obligation to maintain records of their efforts to implement accessibility requirements, and to annual certify their recordkeeping efforts. The April 1, 2015 filing will certify to compliance during 2014.
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