Begin forwarded message:

From: peter altschul <[email protected]>
Date: July 3, 2012 4:50:49 PM CDT
To: Acb-l <[email protected]>
Subject: [acb-l] [leadership] Let the FCC hear from you



---- Original Message ------
From: Marlaina Lieberg <[email protected]
Subject: [leadership] Let the FCC hear from you
Date sent: Tue, 3 Jul 2012 13:47:07 -0700

Hello all.  Please read and feel free to share:

On June 21, 2012, the FCC released a public notice requesting comment on a 
petition filed by the National Cable & Telecommunications Association (NCTA), 
which request that the Commission waive its rules requiring advanced 
communications services (ACS) and equipment to be accessible by people with 
disabilities.
NCTA requests a waiver for set-top boxes leased by cable operators to their 
customers and manufactured before July 1, 2016.

This is a matter that needs your immediate attention.  The NCTA is requesting a 
waiver from the current provisions of the Communications and Video 
Accessibility Act which require that set-top boxes which offer advanced 
communication systems, i.e  e-mail, skype-to-skype, etc.  be made accessible by 
October 1, 2013.  Instead, they are asking for July 1, 2016 as a finish date.

NCTA argues that provision of advanced communication services is not the main 
function of the cable set-top box.  At the end of this post, you will find a 
quote from their waiver introduction.  We need to respond that if the box has 
advanced communication capabilities for those with sight, those services must 
be equally provided for those with limited or no sight.

While you may not now have, use or need access to advanced communication 
systems, this avenue of electronic communications is the way of the future; 
granting of this waiver will represent a chink in the armor of protection and 
accessibility mandated by the Communications and Video Accessibility Act as it 
currently stands.  Believe me when I tell you, industry does not want to comply 
with many of the provisions of this Act, and will continue to try to erode our 
rights and protections one waiver request at a time.

The NCTA is a huge industry with a lot of money behind it.  We as the blind 
community absolutely must now all speak out against granting the waiver they 
request.

I will help you file comments if you are unable to do so on your own.  We 
absolutely must make our voices heard.

The comments do not need to be long and fancy.  They do need to include your 
name and address, and email address.  Using phrases such as "why must blind 
Americans always be playing catch-up when we live in the most technologically 
advanced country in the world" or "this waiver, if granted, will further cement 
the status of blind people as second class citizens" or "this industry has 
shown little faith and desire to move forward with accessibility; the 
Commission must hold their feet to the fire and stand firmly by the mandates of 
the CVAA."  Tell your story, tell how this waiver request makes you feel.  The 
way of the future will be internet activity delivered via your set-top box; we 
absolutely must speak out now on this.

If you need assistance to comment, please e-mail me your comments, including 
your name, address and e-mail address.  Do not write to me, write as though you 
are e-mailing the FCC directly.  I'm willing to forward each one through the 
electronic filing system, but I don't want to have to edit your private 
comments directed to me.  My email is [email protected]

If you want to file on your own, and I encourage that you try before asking for 
assistance, here are some step-by-step instructions that should help you do so.

You will need this number; I refer to it as the docket number, but it will go 
into a box called proceedings number.
Docket #10-213

1.  Go to
http://apps.fcc.gov/ecfs/hotdocket/list

2.  On that page, you will see a number of links and a table which contains a 
calendar.  Do a search for the words docket number.  That should take you to a 
sentence that says, "If the docket you're looking for is not listed, click here 
to manually enter your docket number on the upload page."  the term "click 
here" is hyperlinked to the form for filing brief comments, so click on that 
phrase.

3.  Now you are on the actual page where you can file your comments.  Do a 
search for the term "proceeding number"; it is a level 3 heading.  Once you 
find that, locate the edit box and in that box, type 10-213.  Then, tab along 
and fill out the information they request which includes your name, address, 
e-mail address, etc.

4.  Once you have filled out the details fields, you are in the edit box to 
type your comments.  You may wish to type them ahead of time in the word 
processor of your choice, then simply copy and paste them into this edit box.

5.  Tab to continue and click that button.

6.  Now you are on a page where you can modify or confirm your submission.  If 
you are sure you have all the fields filled out and your comments are as you 
want them, search for confirm and click it; or, if you need to do some editing, 
search for modify.

I hope these instructions will help you to be a voice in advocating for our 
continued equality on the digital playing field.  I cannot request your 
participation strongly enough  The industry is big and rich; we need every 
voice raised from our community regarding this and other waivers that will 
certainly be requested by the industry in the near future.  Please raise your 
voice!

Marlaina



Excerpt from CTVA Waiver Introduction:
CABLE OPERATOR-SUPPLIED SET-TOP BOXES QUALIFY AS A DISTINCT
CLASS OF DEVICES
The ACS waiver standard under the statute and the Commission’s rules requires 
that
the
waiver be applicable to a “carefully defined” class of devices that “share 
common
defining
characteristics.”  Cable operator supplied set-top boxes satisfy this standard. 
 Specifically, set- top boxes are standalone devices that are primarily 
designed to convert the video signals delivered by cable systems to consumers’ 
homes and transmit the converted signal to television sets or other display 
devices for viewing.  These devices typically are manufactured  by third- party 
vendors, including, but not limited to, Motorola Mobility, Cisco, and Pace, and 
leased to end-user customers by the respective cable operator.
The Commission is familiar with cable operator-supplied set-top boxes and the 
“common characteristics” that they share as a class.  Set-top boxes are a form 
of “navigation device,” which the Commission has defined as “devices…used by 
consumers to access multichannel video programming and other services offered 
over multichannel video programming systems.”
Set-top boxes, as defined for purposes of this request, include limited 
functionality
devices, such as digital transport adapters, as well as more advanced devices 
that can support, among other things, video-on-demand and digital video 
recording capabilities.
Importantly, this request is time-limited in that it will not apply to set-top 
boxes
manufactured after July 1, 2016.  The development, manufacturing, and 
deployment cycle for set-top boxes typically lasts approximately six years, 
consisting of approximately two to three years of development work plus 
approximately three years of manufacturing and deployment of the devices.  For 
example, devices that cable operators will begin deploying to customers  later
this year have been in development since at least 2010, and likely will be 
deployed  to customers until early 2016.  Set-top box manufacturers and cable 
operators will soon turn to the task of developing the next generation of 
set-top boxes – devices that we can expect to see deployed sometime in mid-2016.
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