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Hey FCC, Can You Hear Us Now?

Time is running out to tell the Federal Communication Commision (FCC) what you think about accessible cell phones. The FCC is seeking comments from consumers on their experiences with accessible cell phones, and the deadline of September 13, 2010 is fast approaching.

The more consumers weigh in on this important topic, the more seriously the FCC will take their mandate to have cell phone providers comply with the 1996 law stipulating that wireless telephones be accessible.

The American Foundation for the Blind  (AFB) Web page on the FCC’s public notice for comment, at highlights several points consumers may wish to point out in their comments:

1. Gaps in the wireless technology preventing blind, low-vision, and deaf-blind consumers access;
2. additional cost associated with additional software or technology to make wireless phones accessible;
3. limited or non-existent selection of low-moderate cost wireless phones with accessibility features;
4. compatability of wireless telephones and Braille displays.

A recent Web seminar on this subject hosted by Serotalk and archived as Serotalk Tech Chat #67 also included these additional considerations:
1. lack of complete access to business wireless phones puts prospective employees with a disability at a significant disadvantage;
2. well-meaning, but poorly trained sales personnel who often have no idea of accessibility features available on the phones being sold;
3. section 255 of this communications act governing and providing for accessibility now 14 years old, and little progress has been made;
4. accessibility of texting on basic phones;
5. documentation is often in PDF format that is only partially accessible;
6. limited options from the pay-as-you-go plans.

Of course if you’d rather wade your way through the actual public notice issued in July by the FCC, it is at: .

Comments may be posted electronically at the Commission’s Electronic Comment Filing System (ECFS), the Federal eRulemaking Portal, Be sure where applicable to include that comment is in reference to CG Docket number 10- 145. Instructions for email will be forwarded to you by sending an email to with “get form (your email address)” written in the body of the message. See my copy of these instructions below, with my comments.

According to the AFB article, paper comments may be mailed to: Commission’s Secretary Office of the Secretary FCC Headquarters at 445 12th St., SW., Room TW-A325, Washington, DC 20554.  For each filing, include one original, four copies, and mail a copy to the FCC’s duplicating contractor: Best Copy and Printing, Inc., 445 12th Street, SW., Washington, DC 20554.

Here is what this writer forwarded using the email address and format provided (Please feel free to copy this and modify it to match your own cell phone experiences more closely:

<PROCEEDING> CG Docket number 10- 145
<DATE> 09/02/10
<NAME> Steven Kelley
<ADDRESS1> 16 Myplace Way
<CITY> Kennebunk
<ZIP> 04043
<PHONE-NUMBER> 800-466-4411
<DESCRIPTION> Email Comment

Dear FCC,

I wish to comment on the accessibility features found on most cell phones. It has been my experience that few cell phones offer any accessibility features, such as screen magnification or screen reading, out of the box. If these eatures are available for the phone it is often an additional cost to the consumer of several hundred dollars. This is an additional cost a blind or low vision consumer must pay to use this device. In the few instances there is basic accessibility, full access to the other phone features, such as texting, calendar, address book, etc. remain inaccessible. Such an inaccessible business phone puts the user witha vision impairment at a distinct disadvantage over coworkers with complete access to the phone.

It has also been my experience that the options ofr accessible phones in the low-mid price range, and among the pay-as-you-go providers are few or non-existant. When available these options must be purchased with more expensive, high-end phones. Basic accessible cell phone are virtually non-existent.

Cell phone service providers often have well-meaning staff at retail stores or managing help lines that have very little information about what cell phone models have accessibility features available, and how these are used. Documentation, if it exists, is often in a PDF format that is not completely accessible, and rarely available in Braille.

With the dramatic increase in cell phone texting, and the importance of this communication media for both personal and business use, few cellphone offer accessible number pads or keyboards, making this feature often inaccessible as well.

It is my understanding that Section 255 of the Telecommunications act of 1996 mandates that, manufacturers must make certain that their products are “designed, developed, and fabricated to be accessible to and usable by individuals with disabilities”  when this is readily achievable to do so. I further understand that the FCC is responsible for rules and policies to enforce the law. It seems clear that Section 255, after 14 years, requires better regulated rules and policies, and stricter enforcement, to achieve these goals.

Thank you,

Steven Kelley

Remember, the deadline here for submitting comments is September 13, 2010.

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