In its ongoing implementation of the Twenty-First Century Communications and Video Accessibility Act of 2010 (CVAA), the FCC required MVPDs to make emergency visual info audible for the blind and sight-impaired, but asked in a further notice of proposed rulemaking whether that should extend to the device mandate.
While ACA told the FCC in comments this week that it applauded accessibility and was ready to work with the FCC, it suggested the FCC needed to reciprocate. It also was not sure that the mandate was the right way to go.
ACA said that nothing in the CVAA requires the FCC to require the navigation devices activation mechanism, and it isn't even sure the FCC has the authority to impose it, if the commission does, it needs to take into account the impact on the small and medium-sized operators it represents who "operate older systems that cannot easily implement upgrades that may be designed for and deemed reasonable to larger MVPDs."
ACA's consistent message across a host of proposed regs is that the FCC take into account the disproportionate logistical and financial impact on smaller operators.
ACA says the FCC should only require the boxes on request and that the deadline for the smallest systems should be the same as the deadline for audibly accessible video programming guides and menus (Dec. 20, 2018).
Among its other asks: The FCC should make it clear that it can exempt the smallest systems (20,000 or fewer) if it later concludes the accessibility requirements are too burdensome; have the Media Bureau review and weigh in on the issue, and "clarify" that the simple activation mechanism requirement only applies to MVPDs that sell or lease boxes.