September 19, 2025
Brendan Carr
Chairman
Federal Communications Commission
45 L Street, NE
Washington, DC 20554
RE: PS Docket No. 25-224, FCC 25-50
Dear Chairman Carr:
The National Federation of the Blind, the transformative membership and advocacy organization of blind Americans, appreciates the opportunity to comment on the Federal Communications Commission’s (FCC) notice of proposed rulemaking (NPRM) regarding Modernization of the Nation’s Alerting Systems.
In general, we believe the current guidelines pertaining to the nation’s Emergency Alert System (EAS) and Wireless Emergency Alert (WEA) systems are adequate for most people with disabilities, but as is the case with many things, there is room for improvement. While there is one question specifically related to accessibility of the EAS and WEA, it is disappointing to have to note an overall lack of discussion in the NPRM related to how blind, and in particular deafblind, individuals are expected to receive emergency alerts.
We would welcome a much more detailed and robust conversation specifically regarding the accessibility of the EAS and WEA prior to the publication of the final rule.
The specific areas in the NPRM that we would like to comment on will be listed below with the questions posed by the FCC in the document (in italics) followed by our answer.
The Commission seeks comment on whether the nation's alert and warning systems would be more effective if their design placed a greater focus on the capabilities of the end-user devices that receive and present alerts, rather than solely around the communications pathways that transmit them. For example, would EAS be more effective if consumer “smart” devices connected to the internet (e.g., radios, TVs, and other video displays) were able to directly receive EAS messages from alerting sources, regardless of the user's choice of programming at the time that the alert is received?
The National Federation of the Blind believes this is a promising concept regarding accessibility, particularly if those end-user devices are then able to relay alerts directly to a connected Braille display, which many deafblind people own. The ability to connect to a Braille display, either directly or through another connected “smart” device, is unquestionably the most effective way to reach deafblind individuals, who not only cannot see an emergency alert on a television or smartphone, but also cannot hear the audible details of the alert, which may contain life-saving information like evacuation routes or instructions to shelter in place. The ability of connected end-user devices to receive alerts directly from alerting sources should be actively and enthusiastically investigated by the FCC.
Would this allow for new alerting capabilities that the current design of EAS cannot technically support? Could introducing the capability to receive and present EAS messages into end user devices promote flexibility and consumer choice by allowing for greater tailoring as to how alerts are received and presented (e.g., language, locations, screen placement, font size, text-to-speech, and other accessibility options)?
We believe that the answer to both of these questions is “Yes.” The advent of the Wireless Emergency Alert system allowed for emergency alerts to be broadcast to all individuals with a smartphone in a specific geographic area regardless of whether they are in sight range of a television or hearing range of a radio. It broadened the ability of emergency alerts to reach the widest possible audience.
There is no reason why we should not be aggressively pursuing the same capabilities for individuals who cannot physically see a television or smartphone screen or those who cannot physically hear a radio or wireless emergency alert. If the goal is to reach the greatest number of people who may be affected by a local or national emergency, then we absolutely must explore alternative ways to reach blind and deafblind individuals, including the ability of end user devices to receive EAS messages directly, and the ability of the user to specifically tailor how those messages are received and presented (e.g. font size, text-to-speech, Braille).
Additionally, we strongly encourage research into the way the alert speech is generated, so that deafblind people with minimal useable hearing have a better chance of understanding the alert. Technologies that can now clone, rather than merely synthesize, a voice have the potential to be better understood by those who have severe difficulty hearing.
Would these changes allow EAS to better achieve its public safety objectives or be a more efficient way of distributing alerts to the public?
The answer to this question is, once again, a resounding “Yes.” The above changes to the EAS would, at the very least, create the opportunity for emergency alerts to reach more people, which would in turn provide the ability for those people to make independent and informed decisions regarding their safety and the safety of their families.
The concept of an alerting system has existed since the 1950s, with the intent being to quickly inform the largest possible number of people of a possible impending danger. The design and function of that system has changed numerous times since then, but the goal has remained the same: quickly inform the public of possible impending danger.
If the technology exists to expand the reach of that system so that it informs a greater number of people but we are choosing not to utilize it, then that system is failing in its purpose. I urge the Federal Communications Commission to investigate the ways to improve the EAS and WEA for blind and deafblind Americans that are outlined above, and welcome further discussion on this matter.
Sincerely,
Mark A. Riccobono, President
National Federation of the Blind