Update to Verizon Using Disabilities to Fight Net Neutrality

In June I discussed rumors that Verizon was arguing, behind closed doors, that net neutrality harms those with disabilities.

Perhaps in reaction to the Verizon rumors, or just because the cause makes sense, on July 18 five different organizations related to accessibility filed their own joint comments with the FCC. The organizations are: Telecommunications for the Deaf and Hard of Hearing, Inc. (TDI), the National Association of the Deaf (NAD), the Hearing Loss Association of America (HLAA), the Deaf and Hard of Hearing Consumer Advocacy Network (DHHCAN)), and the Rehabilitation Engineering Research Center on Telecommunications Access (RERC-TA) along with Professor Clayton Lewis. Together they filed a brief, which you may read online (and which I have copied locally as I suspect this URL will be allowed to rot by the FCC), outlining their support of net neutrality. An excerpt:

[We] seek to promote equal access for the 48 million Americans who are deaf, hard of hearing, late-deafened, deaf-blind, or deaf with mobility or cognitive disabilities to the informational, educational, cultural, and societal opportunities afforded by the telecommunications revolution.

The letter outlines six arguments in particular, with far more detail in its sixteen pages:

  1. Retaining and improving transparency rules will improve the ability of consumers who are deaf or hard of hearing to access the Internet on equal terms.
  2. A no-blocking rule would help ensure the availability of accessible telecommunications services for consumers who are deaf or hard of hearing.
  3. The Commission should bar paid prioritization while ensuring that Internet-based services and applications are accessible to consumers who are deaf or head of hearing.
  4. Title II reclassification would afford the Commission additional flexibility to ensure that broadband services are accessible, and the Commission should exclude accessibility-related Title II provisions from forbearance if it reclassifies.
  5. The Commission should ensure that the enterprise services and premise operator exceptions avoid facilitating illegal discrimination against people who are deaf or hard of hearing.
  6. The Commission should ensure that the use of data caps do not result in discrimination against people who are deaf or hard of hearing.

The same day, the American Association of People with Disabilities and the National Council on Independent Living also filed their own joint letter with the FCC (also available from a non-FCC URL). In addition to an open internet, the letter argues for an ombudsman:

Over the past few years, Congress shifted the focus of universal service from mere availability to adoption and utilization. […] This important review of Open Internet policy provides an opportunity to ensure that people with disabilities have full and open access to broadband communications and enjoy the important consumer protections mentioned in our comments. […] An Ombudsman Office Can Monitor and Report on Access Issues Associated with Consumers with Disabilities

Ars covered the latter filing in its Tuesday, July 22 post, “Deaf advocacy groups to Verizon: Don’t kill net neutrality on our behalf.”

Hopefully these two are among the comments that will work their way to the top of the pile of the 1.1 million of comments the FCC has received (good luck finding them on your own). And then hopefully they’ll be read, and understood, as the FCC weighs the information in making a decision on net neutrality.

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