August 8, 2022
Alejandro Roark Bureau Chief
Consumer and Governmental Affairs Bureau Federal Communications Commission
45 L Street, NE Washington, DC 20554
RE: CG Docket No. 10-213, Public Notice Comments – 2022 CVAA Biennial Report Tentative Findings
Dear Mr. Roark:
The National Federation of the Blind appreciates the opportunity to comment on the Federal Communications Commission’s (Commission) Tentative Findings for the 2022 Twenty-First Century Communications and Video Accessibility Act Biennial Report. As the transformative organization of blind Americans, digital and electronic communications accessibility is consistently one of our top priorities in both the legislative and regulatory spaces because we know that equal access in this area can increase educational and employment opportunities, as well as overall quality of life, for blind and low-vision Americans. We have chosen to focus the scope of our comments on specific areas where we feel we can present the most cogent points.
In general, the National Federation of the Blind recognizes that the scope of telecommunications and advanced communication devices has changed in the aftermath of the pandemic, especially pertaining to accessibility for those who are blind, low vision, or deafblind. Smartphone accessibility using the iOS or Android OS platforms is constantly improving. However, there are still many barriers to access amongst the numerous third-party applications available for each of these platforms. There should be more emphasis placed on the manufacturers of these device platforms to make sure that all third-party applications released on their platform are fully accessible.
Furthermore, communication between devices is also constantly evolving. Unfortunately, accessibility is frequently an afterthought, and therefore not usually available when new devices become available in the marketplace. Many home appliances of various capabilities and models offer the ability to communicate with a desired smartphone through a third-party application. Many medical devices also offer communication with a desired mobile phone through this same method. When these devices reach the market, accessibility features are not generally offered, and do not appear to be considered, until the devices have been publicly available for some time.
Regarding paragraph three, the Commission indicated that it was seeking a response in the area of Braille readers and advanced communications services. Specific examples in this area that the National Federation of the Blind is aware of include the ability to pair a refreshable Braille display to a user’s streaming platform (Amazon Fire TV, Apple TV, etc.). The ability to connect a Braille device to these services improves menu navigation and selection for blind users, which provides a simpler and
more enjoyable experience overall. While this feature is available through Apple TV, Amazon only offers the feature through the Fire Tablet, not the Fire TV. Furthermore, as the Commission explores increasing Braille accessibility in these services, we suggest that it look into requiring subtitles on movies and television shows be accessible through a Braille display. This would be particularly beneficial for deafblind audience members, but also anyone who may want to hear the original soundtrack of the show or movie while also reading the dialogue via their Braille device.
Regarding paragraph eleven, we agree that entities have had increased engagement with people with disabilities in the design and development of their products and services. We at the Federation know, and have been advocating for years, that the process of making products and services accessible is significantly easier and more beneficial to users when people with disabilities are included during the early development phases. A common example that we use is the idea that it is easier to design a building knowing from the start that an elevator will be part of the blue prints rather than having to go back and try to make room for it once the building is finished. With this in mind, we are pleased to see more engagement between entities and people with disabilities, but we also believe there is room for improvement as inaccessible products and services are still being released.
Finally, regarding paragraph fifteen, we agree with the assessment that most popular video conferencing services are generally accessible. We also acknowledge that so-called “shared screens” within these services are inaccessible to screen reader users. Conversely, Microsoft’s Teams video conferencing service has taken measures to increase accessibility in this area by supporting accessible PowerPoint sharing, wherein the content of the individual slides is formatted in a way that can be processed by screen reading programs. PowerPoint and Teams are both programs in the Microsoft Office suite of products, so it makes sense that they would work this way with one another, but it does illustrate the point that accessibility is achievable, and we encourage other video conferencing services to follow Microsoft’s example. Additionally, third-party applications, such as Scribe for Meetings, when used in conjunction with certain video conferencing services, will monitor the content of the meeting and convert presentations or slides, which have been previously uploaded into the service, into an accessible version of the content displayed that can be accessed via a screen reader. While this is not a perfect solution, and we firmly believe it would be better to include this kind of feature into the video conferencing service from the start, we certainly appreciate the work being done by Pneuma Solutions, the creator of the Scribe for Meetings application.
The National Federation of the Blind will continue to partner with, and hold accountable, manufacturers and service providers to ensure that better and more accessibility is readily available to blind, low- vision, and deafblind consumers. It is our sincere hope that the Commission will also look to the National Federation of the Blind for continued guidance and as a partner.
Mark A. Riccobono, President National Federation of the Blind