PITTSBURGH, August 12, 2015 - The American Cable Association applauded the Federal Communications Commission's commitment to making visual emergency information in video programming audibly accessible to individuals who are blind or visually impaired, adding that ACA members stand willing to work with the FCC to ensure that subscribers have access to the full video programming experience.
ACA's comments were made in
response to an FCC rulemaking proposal to require multichannel video
programming distributors (MVPDs) to provide their customers with navigation
devices that contain a simple, easy-to-use mechanism for accessing visual
emergency information shown during non-newscast TV programming, such as an
on-screen crawl, through an aural representation on the secondary audio stream.
"Assuming the FCC imposes a requirement on MVPDs to provide navigation devices with a simple activation mechanism for accessing emergency information over the secondary audio stream, it should take steps to minimize the burden that such a requirement would place on small and medium-sized MVPDs," ACA President and CEO Matthew M. Polka said.
In comments filed with the FCC on Aug. 10, ACA outlined steps the FCC should take to account for the unique compliance challenges faced by smaller MVPDs:
First, the FCC should require MVPDs to provide such navigation devices to subscribers only upon request;
Second, the deadline for smaller MVPDs and smaller systems to comply with any new requirements should be simultaneous with the Dec. 20, 2018 deadline for compliance with the FCC's rules regarding audibly accessible video programming guides and menus;
Third, the FCC should make clear that it has the authority to provide an exemption from the rule for cable systems serving 20,000 or fewer subscribers if it later becomes apparent that compliance with the accessibility requirements is too burdensome for such systems;
Fourth, the FCC's Media Bureau should expand its upcoming review of the market for accessible navigation devices to include an examination of the burden on smaller MVPDs created by the new activation mechanism requirement and make recommendations as to whether any exemptions or alternative compliance methods are appropriate; and
Fifth, the FCC should clarify that any obligation to provide customers with navigation devices that contain a simple activation mechanism for accessing aural emergency information in a secondary audio stream applies only to MVPDs that sell or lease navigation devices to their subscribers.
"Implementing any accessibility solution requires considerable effort and is not simply a matter of distributing newly accessible navigation devices. To ensure that new devices are compatible with their systems, MVPDs must make upgrades to headend software and equipment. This process is more difficult for smaller MVPDs that often operate older systems and that typically cannot easily implement available upgrades that were designed and deemed reasonable for larger MVPDs," Polka said.
About the American Cable Association: Based in Pittsburgh, the American Cable Association is a trade organization representing nearly 850 smaller and medium-sized, independent cable companies who provide broadband services for nearly 7 million cable subscribers primarily located in rural and smaller suburban markets across America. Through active participation in the regulatory and legislative process in Washington, D.C., ACA's members work together to advance the interests of their customers and ensure the future competitiveness and viability of their business. For more information, visit http://www.americancable.org/
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