[governance] Amazon and Sony Are Requesting That The Accessibility Requirement Be Waved for E-Book Readers

Avri Doria avri at acm.org
Thu Aug 8 15:30:12 EDT 2013


Hi,

thanks for the explanation.

avri

On 8 Aug 2013, at 20:07, Catherine Roy wrote:

> Hi Avri,
> 
> Hereafter follows more information on the case[1]. I am not a lawyer but from what I gather, in a nutshell, the waiver request targets particularly the cost and technical issues with screen reading (a software used by visually impaired people to access digital content through sound) as a reason to waive all of the Twenty-First Century Communications and Video Accessibility Act (CVAA) requirements. So in reality however, not only would this exempt manufacturers of e-readers from making their devices accessible to the visually impaired but this could have broader implications for people with other types of disabilities, such as those with physical or hearing impairments. If granted, this request opens the door to exclusions. Some have argued[2] that people with disabilities can just use some other device (such as a tablet or other reading apps) to access the type of content supported by e-readers. But then it comes down to, among other things, limiting the choices people with disabilities have, perhaps excluding them from less costly alternatives.
> 
> One final note. Although some may feel this is a US related issue only, I think we need to keep in mind that, for example, a kindle is a kindle wherever you go. There may be slight differences with regards to language or power supply, but the device itself is sold all over the world regardless of what state or local legislation applies. It may prevent public institutions or agencies (like schools) from adopting those devices as part of a curriculum if their are specific accessibility requirements for said entities in terms of procurement, for example, but it will not prevent their sale in general.
> 
> Best regards,
> 
> Catherine
> 
> -- 
> Catherine Roy
> http://www.catherine-roy.net
> 
> 
> 
> [1] Copied from the W3C Web Accessibility Initiative mailing list:
> 
> Request for Comment on Petition for Class Waiver of Accessibility Rules for ACS
> 
> On August 1, 2013, the Federal Communication Commission (FCC) released a Public Notice requesting comment on a petition filed by the Coalition of E-Reader Manufacturers.  The Coalition requests that the Commission waive its rules requiring equipment used for advanced communications services (ACS) to be accessible by people with disabilities.  The Coalition states that, although e-readers are equipment that consumers can use for ACS, they are designed primarily for reading.
> 
> To distinguish e-readers from tablets and other devices that would not be subject to the waiver request, the Coalition requests a waiver for e-readers that have the following features:
> 
> (1) they have no LCD screen;
> (2) they have no camera;
> (3) they are not offered or shipped to consumers with built-in ACS client applications and their manufacturers do not develop ACS applications for their respective devices, though the devices may include a browser and social media applications; and
> (4) they are marketed to consumers as reading devices and promotional material does not tout the capability to access ACS.
> 
> Comment Deadline:  September 3, 2013
> Reply Comment Deadline:  September 13, 2013
> 
> Links to the Public Notice (including filing instructions):
> 
> (PDF)http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-13-1686A1.pdf
> (Word)http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-13-1686A1.doc
> (Text)http://hraunfoss.fcc.gov/edocs_public/attachmatch/DA-13-1686A1.txt
> 
> Link to the Coalition Petition (May 15, 2013):
> http://apps.fcc.gov/ecfs/document/view?id=7022314526
> 
> Link to the Letter Supplementing the Coalition Petition (July 17, 2013):http://apps.fcc.gov/ecfs/document/view?id=7520931307
> 
> For further information, please contact Eliot Greenwald at (202) 418-2235orEliot.Greenwald at fcc.gov<mailto:Eliot.Greenwald at fcc.gov>; or Rosaline Crawford at (202) 418-2075orRosaline.Crawford at fcc.gov<mailto:Rosaline.Crawford at fcc.gov>.
> 
> 
> [2] http://www.the-digital-reader.com/2013/08/07/debunked-amazon-kobo-and-sony-didnt-request-ereaders-be-exempt-from-accessibility-laws
> 
> 
> 
> 
> 
> On 08/08/2013 6:30 AM, Avri Doria wrote:
>> Hi,
>> 
>> I am not clear.  It this about adding Braille to e-books?
>> Or is it about their only partial ability to read the book to a person?
>> Or is it about the ability to use the book and have it be voice activated to turn the pages and activate other features for those who are paralyzed?
>> 
>> I am not sure what capabilities they want the exemption from.
>> 
>> thanks
>> 
>> avri
>> 
>> 
>> On 7 Aug 2013, at 17:22, Catherine Roy wrote:
>> 
>>> [Apologies for cross posting]
>>> 
>>> Forwarded from the Web Accessibility Initiative Interest Group mailing list. I find this development quite distressing.
>>> 
>>> Amazon and Sony Are Requesting That The Accessibility Requirement Be Waved for E-Book Readers
>>> 
>>> "The ) Twenty-First Century Communications and Video ) Accessibility Act of 2010 requires companies who make electronic devices to make them accessible to people with disabilities. At this time, none of the Ebook readers that are on the market meet this requirement. Since many companies feel that this requirement should not apply to Ebook readers, Amazon, Kobo, and Sony have submitted a petition to the FCC asking for a waiver. According to the petition, this is the definition of an Ebook reader: "E-readers, sometimes called e-book readers, are mobile electronic devices that are designed, marketed and used primarily for the purpose of reading digital documents, including e-books and periodicals." Since Ebook readers are primarily designed for print reading, the companies are arguing that the disabled community would not significantly benefit from these devices becoming accessible. They also argue that because the devices are so simple, making the changes to the devices to make them accessible, would cause them to be heavier, have poorer battery life, and raise the cost of the devices. Finally, these companies argue that since their apps are accessible on other devices such as the iPad and other full featured tablets, that they are already providing access to their content."
>>> 
>>> Source : http://www.blindbargains.com/bargains.php?m=9286
>>> 
>>> 
>>> 
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>> 
> 
> 
> 
> 
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