Hi All; I'm forwarding this note with updated info which allows people to send comments via email.
Please get involved as it just doesn't get any easier than this!… Smiles, Cara :) Begin forwarded message: From: Mika Pyyhkala <pyyhk...@gmail.com> Date: September 29, 2010 4:55:49 PM PDT To: viph...@googlegroups.com Subject: URGENT: Updated Information & Detailed Instructions FCC Cell Phone Accessibility Comments Due Thu 9/30 Agency Now Accepting Comments By Email Reply-To: viph...@googlegroups.com The comment filing instructions are also on the web page: http://twishort.com/abte6 Each section of this email is separated by ### Greetings, Over the past 2 days or so I have gotten a bit more information on the specific nuts and bolts of the procedures that should be used to file FCC comments regarding mobile phone accessibility. Hot off the presses, is that a senior manager at the FCC has now authorized official comments to be filed and received via standard email messages because some consumers have had difficulty working with the official FCC Electronic Comment Filing System ECFS. This message first contains detailed comment filing instructions, and then provides a detailed account of items you may wish to address in your comments. ###Detailed Comment Filing Instructions Method 1: FCC Express Electronic Comment Filing System This comment filing method is best suited for individuals submitting comments. *Access the web site: http://fjallfoss.fcc.gov/ecfs2/hotdocket/list *Look for the text that says "If the docket you're looking for is not listed," and then click on the link called "Click Here to manually enter the docket number on the upload page"; *Enter the following proceeding number when prompted: 10-145 *Enter your contact information, type in or paste your comments, and press the continue button; *follow any other instructions on subsequent screens to complete your submission. Method 2: File Comments by email *Compose a standard email message addressed to either pam.greg...@fcc.gov or jamal.maz...@fcc.gov *Include the docket number in your subject line: 10-145 *Include your comments either in the text body of your email or as an attached Microsoft Word 97/2000/2003 or PDF file; Method 3: FCC Electronic Comment Filing System This system allows you to upload a file attachment, such as a Microsoft Word 97/2000/2003 or PDF file, in order to submit comments. *Access the web site: http://fjallfoss.fcc.gov/ecfs/ *Click on the link called Submit A Filing *Enter the following proceeding number: 10-145 *Fill in the contact details, and other questions requested on the form. Specify the file(s) you want to upload, and press the Continue button; *Follow any subsequent instructions on next screens to ensure your filing is recorded. ###Ideas for comments on Mobile Phone Accessibility for the Blind Dozens or hundreds of pages of material have been written that might give you ideas and perspective on what to say in your comments. Your own real life stories are also invaluable. I for example include a real life story at the end of this message. Some items to consider addressing in your individual or affiliate comments are: *How accessible on a wide range of devices, especially entry level and prepaid phones, is sms text messaging to the blind? Had the telecommunications industry embraced accessibility such that these types of features are available on a broad spectrum of devices including inexpensive handsets? If you have 100 or 1,000 blind people in a room how many can text, let alone used advanced features on their cell phones? By the way, sms text messaging is something that has been available to the public at large for many years, and is no longer considered a cutting edge or advanced feature in the industry; *How well has the mobile telecommunications ecosystem addressed the cost of accessibility? Should device manufacturers be passing on the costs of accessibility to blind consumers who have a 70% unemployment rate? Or like Apple, should the device manufacturer assume the accessibility r&d and implementation cost? ###Microsoft Windows Phone 7 Inaccessible To the Blind *Are you aware that in October 2010 Microsoft will release a platform called Windows Phone 7 This platform strives to compete with the likes of Apple iOS eg iPhones, Blackberry devices, Android devices, etc. Microsoft has indicated that Windows Phone 7 will not have out-of-the-box accessibility, and furthermore, it has not been developed in such a way as to allow 3rd party access technology screen reader developers, like CodeFactory or Nuance, to add accessibility to the platform. The net result is that blind Americans will be excluded from the opportunity to participate and experience Windows Phone 7. Commenters might suggest that the FCC take enforcement action against Microsoft for its fflagrant disregard and negligent behavior as it relates to nonvisual access for people who are blind, or deaf blind in the development of this operating system and related hardware devices. ###Relaxed Apple App Development Standards May Cause Accessibility To Decrease *Did you know that in September 2010, Apple significantly relaxed restrictions in place as to what software development tools can be used to produce so-called iOS applications. The prior in place required software development tools largely had out-of-the-box accessibility components such that most applications would work with VoiceOver via speech or refreshable Braille. Among other tools, Apple will now allow Adobe Flash as a development platform for makers of applications. Commenters may wish to suggest that the FCC mandate accessibility with in current and emerging so-called application stores or marketplaces. All major platforms have these marketplaces including Apple, Android, BlackBerry, and likely Microsoft Windows Phone 7 ###Google, Device Manufacturers Turn Off Android Accessibility T-Mobile HTC *Did you know that Google allows mobile carriers to tweak and modify the operating system and user interface on Android handsets. Recently, T-Mobile in the US released an HTC Android cell phone. T-Mobile requested that HTC tweak the Android operating system such that the accessibility features were not available to consumers. These disservice consumers had to spend large amounts of time navigating the bureaucracy of the telecommunications mobile ecosystem, namely interfacing with T-Mobile and HTC. Neither T-Mobile or HTC addressed the accessibility shortcoming, and wireless carrier T-Mobile by its 1st level agents attempted to rigorously enforce contract terms on the disenfranchised class of consumers who were negatively impacted by the carrier and manufactuers lack of regard for blind and deaf blind Americans. The FCC could promulgate regulations to disallow carriers and device manufacturers from turning off accessibility features in the future. The FCC should also reprimand HTC and T-Mobile, and ensure that these entities follow the proposed regulations. ###Major Accessibility Issues On Nokia Devices *Did you know that Nokia produces a number of handsets including the Nokia N86 which is one device that powers the KNFB Reader? Many aspects of the user experience on modern Nokia mobile phone handsets are inaccessible by nonvisual means. For example, when a blind or deaf blind consumer unboxes a device like a Nokia N86 from the factory, there is no nonvisual access to the setup procedure. Similarly, the PC Suite software which is essential to use the device fully has largely not been accessible to pc screen readers. Nokia also has a store where consumers can buy applications and other media. The store is not accessible even with 3rd party screen readers such as Talks or Mobile Speaks. Finally for a long time the email client on the Nokia N86 and similar devices was not accessible via nonvisual means. This meant that business professionals and consumers who are blind could not access key features of the phone that sighted users take for granted. Nokia has failed to address these major and substantial accessibility issues in their products. Nokia has been made aware of these issues, and has failed to substantively address these issues. The FCC should initiate an enforcement action against Nokia for its wantan, negligent, and flagrant disregard of blind, and deaf blind consumers who require nonvisual means to access these kinds of devices and platforms. Nokia has failed to either provide an out-of-box fully accessible platform such as the Apple model, and it has failed to work with 3rd party screen reader developers to ensure that blind and deaf blind consumers can fully utilize the devices. ###Google Android Accessibility While some individuals have worked on nonvisual accessibility to Google Android devices, the devices remain largely inaccessible by typical blind consumers. Only savvy technology users have been able to gain access to parts of the Android experience. The nonvisual user experience has been articulated as similar to trying to access Lenux. Clearly the strategy that Google, carriers, and related device manufacturers have employed has nott produced a sufficient and meaningful nonvisual user experience. The FCC must compel Google, device manufacturers, and carriers to establish tangible accessibility to the Android platform quickly, and quickly doesn't mean 10 years from now. ###Do Blind People Just Want Access To Old and Boring Features? It is worth noting that, sometimes, carriers and device manufacturers, including but not limited to Nokia, trumpet very basic accessibility features. For example, spoken caller id, or a phone speaking the numbers that a user dials. The fact is that blind and deaf blind consumers don't just want access to old and boring features that were standard in the year 1999. Blind and deaf blind consumers have an inherent civil right to enjoy the full breath and depth that current and future mobile phone platforms currently do and will offer in the future. This includes, but is not limited too, full nonvisual access to basic calling features, phone management, phone menus, full contact management, web browsing, application marketplaces, applications provided by carriers, applications provided by 3rd party developers, media consumption services provided by the 2 aformentioned provider groups, etc. Again, this is not an exhaustive list. The list may sound long, however, this is the access that the general public enjoys and frankly takes for granted. I want to update my Facebook status, Twitter status, share music and other media, download podcasts, produce podcasts, find nearby restaurants, and get walking directions just as much as I want to use the phone to make calls. ###How Nonvisual Mobile Device Accessibility Is Achievable This type of nonvisual accessibility is also achieveable. The reason we have not moved forward much since 1996 is that carriers and device manufacturers have failed to devote sufficient resources to nonvisual access to their products and services. The industry has made disingeneous claims that accessibility is not achievable. The entire telecommunications ecosystem has not embraced nonvisual access and accessibility in to their corporate culture and corporate DNA at every level of their organizations from the CEO, their research and development efforts, standars for device manufacturers, right down to entry level sales and service staff. The telecommunications ecosystem and related industry should really take a page out of Apple's playbook. Apple is the only device manufacturer that I am aware of that takes accessibility seriously, and which provides consumers with a steady stream of positive innovations. Apple regularly and meaningfully participates in consumer and accessibility industry trade shows. The Boston Apple Store proactively reaches out to the blind community to foster a mutually beneficial positive relationship, and has devoted resources in its training programs who specialize in the built in VoiceOver nonvisual accessibility screen reading function. I often read that Apple hires accessibility engineers, testers, and others to ensure its products are accessible. Apple includes full nonvisual accessibility functions, not just a few old and boring basic features, in all its current iPhones at no additional cost to blind consumers! The National Federation of the Blind presented an award to Apple at our 2010 national convention for their trailblazing efforts in meaningfully and tangibly recognizing our technology civil rights. I can update my Facebook status, check in to FourSquare, buy music from iTunes, order a taxi electronically, look up and modify travel reservations, syncranize corporate Microsoft Exchange data, review nearby tweets on Twitter, or send a picture of something I need recognized to an innovative iOS application like OMobie. I can do all this because Apple takes nonvisual accessibility seriously! Other developments that the FCC can consider as proof of concept that full nonvisual accessibility is achieveable include but are not limited to closed captioning in televisions, the wide deployment of talking automatic teller machines, and the use of nonvisual accessible Kiosks at Amtrak which like an ATM provide a spoken user interface for blind consumers. -- You received this message because you are subscribed to the Google Groups "VIPhone" group. To post to this group, send email to viph...@googlegroups.com. To unsubscribe from this group, send email to viphone+unsubscr...@googlegroups.com. 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