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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.
Transition-and-2021-FCC-Priorities-for-Communications-AccessibilityDownload

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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.

2020.11.23-Accessibility-Coalition-Carceral-Communications-Comments-finalDownload

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TLPC Partners with CU Engineering, Coalition of Satellite Researchers to Advocate for Continued Access to Space

(by Michael Obregon, Colorado Law 2L)

The Technology Law and Policy Clinic at Colorado Law continued its work with Dr. Scott Palo and CU Engineering to influence national policy related to the regulation of small satellites by the Federal Communications Commission. The TLPC filed comments and reply comments on behalf of a coalition of researchers to argue for improvements to the FCC’s orbital debris rulemaking, which raises the possibility of legally and financially burdensome requirements on missions that could prevent academic researchers from participating in satellite-based research.

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TLPC Partners with CU Criminal Immigration Clinic to Prepare Report on Protecting Colorado DMV Photos, ICE, and Facial Recognition Tech

(by Conor May, Colorado Law 2L)

This year the TLPC and Colorado Criminal Immigration clinic looked at ways for the State of Colorado to prevent DMV records from being exploited by federal Immigration & Customs Enforcement (ICE). The clinics prepared a report to the Governor’s Office and Colorado DMV that highlights potential vulnerabilities and proposes policies to address those vulnerabilities.

The clinics’ report was sent to the Governor’s Office in March. On May 20th, Governor Polis issued a guidance document to all Colorado executive branch departments and agencies. This guidance on data privacy goes a long way toward addressing the vulernabilities raised in the clinics’ report, by placing restrictions on when state agencies can respond to requests for Personal Identifying Information (PII), which includes licenses and other DMV information.

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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 911 and Accessibility White Paper (PDF)Download

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TLPC and CIPPIC Samuelson-Glushko Clinics File OPC Comments for Privacy Researchers on the Regulation of Artificial Intelligence

(by Kelsey Fayer, Colorado Law 2L)

Today, the TLPC, in partnership with our sister Samuelson-Glushko Canadian Internet Policy and Public Interest Clinic (CIPPIC) at the University of Ottawa, filed comments drafted by Prof. Margot Kaminski (Colorado Law) and Prof. Vivek Krishnamurthy (University of Ottowa) on behalf of a coalition of privacy researchers before the
Office of the Privacy Commissioner of Canada (OPC).

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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.”

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TLPC Files Amicus Brief on Behalf of Print Disability Advocates in Georgia v. Public.Resource.Org

On October 16, 2019, the TLPC filed a brief of amici curiae in the matter of Georgia v. Public.Resource.Org, a case pending before the U.S. Supreme Court of the United States involving the copyrightability of annotations to state law. The TLPC filed the brief of amici curiae on behalf of print disability advocate organizations American Association of the Deaf-Blind, American Council of the Blind, Burton Blatt Institute, Disability Rights Advocates, National Federation of the Blind, World Institute on Disability, and individual print researcher and advocate Sina Bahram. The brief addresses concerns about Georgia’s failure to provide its laws to those with print disabilities in accessible forms as required by Title II of the Americans with Disabilities Act. As part of its wider project to promote free and open access to the law, Public.Resource.Org has undertaken to make the law accessible to those with print disabilities. The brief also raises concerns about Georgia’s use of copyright law to quash efforts to provide the accessible information which Georgia has itself failed to provide and underscored that making works accessible to those with disabilities is an uncontroversially non-infringing fair use.

Print Disability Advocates Brief (PDF)Download
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Deaf and Hard of Hearing Consumer Groups and Researchers Call on FCC to Improve the Quality of Live Captions

WASHINGTON – On July 31, the TLPC, on behalf of its client Telecommunications for the Deaf and Hard of Hearing, Inc. (TDI) and in partnership with the National Association of the Deaf (NAD), the Hearing Loss Association of America (HLAA), the Association of Late-Deafened Adults (ALDA), the Cerebral Palsy and Deaf Organization (CPADO), Deaf Seniors of America (DSA), the Deaf/Hard of Hearing Technology Rehabilitation Engineering Research Center (DHH-RERC), the Twenty-First Century Captioning Disability and Rehabilitation Research Project (Captioning DRRP), the Rehabilitation Engineering Research Center on Universal Interface & Information Technology Access (IT-RERC), and the National Technical Institute for the Deaf, supported by the American Association of the DeafBlind (AADB) petitioned the Federal Communications Commission (FCC) to address long-standing quality problems with captioning for live television programming.

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