TLPC Files Comments and Reply Comments on Behalf of Accessibility Coalition Before FCC on Interoperable Video Conferencing Services

Today, the TLPC filed comments on behalf of its client, Telecommunications for the Deaf and Hard of Hearing, Inc. (TDI), and a coalition of more than 20 accessibility advocacy and research organizations before the Federal Commmunications Commission. The comments urge the FCC to proceed with ensuring the accessibility and usability of video conferencing services by finalizing a decade-long pending rulemaking on the scope of “interoperable video conferencing services” governed by the FCC’s rules under the Twenty-First Century Communications and Video Accessibility Act.

July 18, 2022 update: the TLPC filed reply comments on the same matter—see the bottom of the post.

TLPC Submits Comments and Reply Comments at FCC on Behalf of Accessibility Coalition

With the assistance of John Jang, Peter Troupe, and Victoria Venzor, the TLPC filed comments and reply comments on behalf of our client, Telecommunications for the Deaf and Hard of Hearing, Inc. (TDI) and a broad coalition of accessibility advocacy and research organizations urging the FCC to require improvements to the accessibility of closed captioning display settings. The comments and reply comments can be downloaded below.

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TLPC Submits Comments on Carceral Communications Accessibility for Accessibility Coalition

(by Cameron Benavides, TLPC Student Attorney)

In consultation with HEARD and on behalf of our client Telecommunications for the Deaf and Hard of Hearing, Inc. (TDI) and a coalition of numorous deaf and hard of hearing advocacy and research organizations, the TLPC filed comments and reply comments in the Federal Communications Commission’s pending proceeding on addressing the accessibility of communications systems in carceral facilities.

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TLPC Advocates Before the FCC for Equal Access to Communications and Video Programming

(by Dakotah Hamilton, TLPC Student Attorney)

On June 7th, the TLPC and the Communications and Technology Law Clinic (CTLC) at Georgetown Law filed a comment on behalf of 22 accessibility advocacy and research organizations, including TLPC and CTLC client Telecommunications for the Deaf and Hard of Hearing, Inc. (TDI), in response to the Federal Communications Commission’s public notice to revisit many of its rules under the Twenty-First Century Communications and Video Accessibility Act of 2010 (CVAA). The comment, drafted by Professor Blake E. Reid, TLPC Director, and Professor Laura Moy, CTLC Director, with assistance from TLPC student attorneys Dakotah Hamilton, Rachel Hersch, and Scott Goodstein and CTLC staff attorney Michael Rosenbloom and student attorney Ellen Gardiner, comprehensively reviewed the past decade of FCC proceedings implementing the CVAA as well as some dating back to the Telecommunications Act of 1996, spanning more than two dozen dockets.

The comment identifies numorous specific priorities the FCC should consider for the accessibility of video programming, communications, and hearing device accessibility, including bolstering the availability of interpretation and captioning for video conferencing platforms and expanding captioning requirements for video distributed online. The comment also calls for dedicated inquiries into accessibility barriers facing people who are deaf or hard of hearing and have multiple disabilities, older people who are deaf or hard of hearing, and people who are deaf or hard of hearing and living on rural or tribal lands or in U.S. territories. The comment also urges the Commission to emphasize supervised multistakeholderism, centering the civil rights of people with disabilities, vigorous enforcement, and reporting to Congress.

TLPC Releases White Paper for EFF Analyzing Municipal Rights of Way Franchising Authority in New York

(by Bethany Reece, Student Attorney)

Today the TLPC is releasing a white paper, prepared on behalf of and in collaboration with, the Electronic Frontier Foundation, which chronicles New York’s experience in the early 2000s with the telecommunications lobby’s efforts to replace historic municipal telecom franchising regimes with a centralized state franchising system. Given the increased leverage that localized franchising authority can afford to municipalities, this paper considers whether New York’s choices with respect to its regulatory regime may influence its outcomes with respect to achieving its FiOS buildout objectives, economic parity of high-speed broadband access across areas of varying income strata, and enforcing agreements with telecommunications providers.

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TLPC and Georgetown Communications and Technology Law Clinic Draft Accessibility Agenda for FCC Transition Team

In consultation with Telecommunications for the Deaf and Hard of Hearing, Inc. (TDI), the National Association of the Deaf (NAD), the American Council of the Blind (ACB), the Hearing Loss Association of America (HLAA), and the Technology Access Program (TAP) at Gallaudet University, the TLPC and our sister Communications and Technology Law Clinic (CTLC) at Georgetown Law developed an overview of critical technology accessibility priorities for a new administration at the Federal Communications Commission. The overview encourages the transition team and the FCC to:

  • Prioritize accessibility in agency leadership;
  • Relocate the Disability Rights Office to a new Office of Civil Rights;
  • Address videoconferencing accessibility problems in response to the pandemic;
  • Get the Real-Time Text transition back on track;
  • Bolster video programming accessibility; and
  • Improve the accessibility of wireless handsets.

TLPC Files Comments on Behalf of Disability Rights Advocates to Enforce Carceral Communications Accessibility

TLPC student attorneys Caitlin League, Michael Obregon, and Brandon Ward worked over the last month with a coalition of incarcerated deaf/disabled people and their advocates, consumer groups, including our client, Telecommunications for the Deaf and Hard of Hearing, Inc. (TDI), and accessibility researchers to file comments in response to a Further Notice of Proposed Rulemaking at the Federal Communications Commission (FCC) soliciting input on rates charged to incarcerated people for the use of telecommunication devices. Carceral facilities, including prisons and jails, have long denied incarcerated people with communications disabilities access to functionally equivalent communications services and equipment and charged exorbitant rates to maintain crucial connections between incarcerated people and their families, loved ones, and legal representatives.

Because the transition of the phone system from analog to Internet Protocol networks has largely broken compatibility with teletypewriters (TTYs), many carceral facilities essentially provide no accessible services or equipment. Among other remedies, the comments urge the FCC to require that inmate calling services (ICS) facilitate the provision of accessible services, including video relay service and Internet Protocol Captioned Telephone Service (IP CTS) and equipment, including videophones and captioned telephones, to carceral facilities.

TLPC Publishes White Paper on the 911 Accessibility Regulatory Framework- An Update of 2015 TLPC 911 Accessibility Whitepaper

(by Jake Stephens, Colorado Law 2L)

Student attorney Jake Stephens wrote a white paper updating federal and Colorado regulatory frameworks governing 911 accessibility, updating a white paper on the same topic published by the TLPC in 2015. This update covers recent developments in 911 access regulatory dockets at the FCC, a summary of a withdrawal of proposed updates to 911 accessibility regulations under the Americans with Disabilities Act by the Department of Justice, and a glimpse into state 911 accessibility regulations with Colorado as the case study.

TLPC Partners with Network Security Researchers and Public Interest Organizations to Call for Greater Cell Network Security

(by TLPC student attorneys Parker Nagle, Andrew Leddy, and Kennedy Smith)

On behalf of a coalition of independent network security researchers and public interest organizations, the Samuelson-Glushko Technology Law and Policy Clinic at Colorado Law filed reply comments on the FCC’s 2019 National Security Supply Chain Order and Further Notice of Proposed Rulemaking calling for greater cell network security. The TLPC worked with the coalition to draw attention to the many vulnerabilities plaguing cell networks that the Order did not address and to outline the broad but underutilized, authority the FCC has to advance meaningful solutions. The coalition included CU-Boulder researchers Dr. Eric Wustrow, Dr. Dirk Grunwald, and Dr. Sangtae Ha, mobile security researchers Joseph Hall, Yomna Nasser, Marcus Prem, and Ashley Wilson, and public interest organizations Electronic Frontier Foundation (EFF), Public Knowledge, and Eye on Surveillance.

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TLPC Partners with CU Engineering to Comment on New Satellite Regulations

The TLPC, partnering with Dr. Scott E. Palo and CU Engineering, worked in close collaboration to influence important national policy for small satellites at the Federal Communications Commission. The Samuelson-Glushko Tech Law and Policy Clinic at Colorado Law, led by Colorado student attorneys (now alums) Galen Pospisil and Megan Chavez, and Jake Stephens, accompanied by Stefan Tschimben a PhD candidate in the Technology, Cybersecurity, and Policy Program (TCP), worked under the supervision of Colorado Law Associate Clinical Professor Blake E. Reid to represent Dr. Palo, Professor in the Smead Aerospace Engineering Sciences Program to comment on the FCC’s rulemaking process.

The CU-led comment was the result of collaboration with distinguished small satellite researchers at universities across the U.S, including the University of Florida, the Massachusetts Institute of Technology, the University of Michigan, and others. The collaboration between TLPC and Palo allowed the comment to offer thoughtful commentary on a variety of complex issues, including satellite deployment heights, propulsion requirements, application fees, wireless spectrum requirements, and more.

The CU comment had a significant effect on the FCC’s rulemaking, helping lead the FCC to significantly lower deployment height, ensuring university researchers would maintain a range of small satellite licensing options, and more. For example, the comment successfully argued that the FCC’s proposed deployment rules would hinder university researchers from conducting important climate and space weather research.

“It’s critical that university researchers can launch critical scientific and other public interest missions that take advantage of the decreased size and cost of the small satellite form factor. It’s a privilege for the clinic to work with Dr. Palo and his colleagues to ensure the ability for university researchers to have access to space for their important work,” Professor Reid said.

“This project was a great example of how a collaboration between the College of Engineering and Law School can be impactful while educating student. As subject matter experts, the engineers provided specific details about the technical challenges and the law students used this information to create a convincing argument,” Dr. Palo said. “The TLPC took the lead on creating the filing and insured the documents were succinct and professional.”