My letter to the FCC regarding waving basic accessibility standards for e-readers

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In an effort to share with the accessibility community; below is the letter I sent to the FCC regarding the petition filed by Amazon, Sony, and Cobo to exclude their e-readers from meeting basic accessibility standards.
The story I share is true. I think it highlights the dangers that arise if certain companies are allowed to be excluded from meeting accessibility standards. As a blind person in the technology field I rely on digital reading materials to access the thousands of mainstream books, magazines, and other materials to keep pace in the work place. Currently, I have to read e-books and other electronically produced materials on my iPhone or on a very expensive proprietary device designed for the blind. I cannot use the e-readers. This means, I often have to wait longer than my peers to read materials that are not yet available for my special device. /Some of these books and materials never become available. This puts me at a disadvantage in my career. This could all be changed if these companies are expected to comply with meeting basic accessibility standards.
A portion of my letter, not part of my story, was taken from a general letter provided by the National Federation of the Blind http://www.nfb.org/. It was made available as a template for use in submissions to the FCC to uphold the basic accessibility standards and ensure that they are followed by all companies.
Re: Reply to the Coalition of E-Reader Manufacturers’ Petition for Waiver from CVAA Accessibility Requirements, CG Docket No. 10-213

Dear. Mr. Monteith:

I am a blind professional working in the technology field. I have worked in this field for over twenty-years. I use digital books to keep up with my profession, learn about new technologies, learn to use new operating systems and software. Like many Americans I also enjoy using digital books for pleasure reading as well. I believe blind people are finally entering a time when we have access to many books, magazines, articles and other forms of reading materials on level with our sighted peers. Thanks in large part to the advent of digital publications and the ability of blind persons to use e-readers to access digital material. If the coalition is allowed to exclude their e-readers from meeting basic accessibility standards this would absolutely be a loss for me as a blind person, who relies on the ability to use an e-reader for my employment and to read with an e-reader on the go.
I strongly oppose the Petition for Waiver submitted by the Coalition of E-Reader Manufacturers’, requesting that e-readers be exempt from the Twenty First Century Communications and Video Accessibility Act (CVAA).
The spirit of the CVAA is to increase the accessibility of mobile advanced communications services (ACS) and e-readers have ACS functionality. Most e-reader users I know post to Facebook and exchange books with friends. It would not make sense to grant a waiver for a class of products that are clearly intended to be covered by the CVAA.
I want access to digital books. As a person working in the ever growing ever changing field of technology it is crucial to employment that I am able to read the same books at the same time as others in my field or I will be left behind in the job market. Currently, if I want to read a Kindle book, I have to buy a very-expensive Apple iPad or iPhone. Then I can download the free Kindle app, but that application is not fully accessible. I want to be a mainstream user and would happily buy an e-reader if one was accessible, but the manufacturers continue to exclude me from their customer pool. I reject the Coalition’s notion that to make their product accessible would not provide me with any substantial benefits. In reality, it will give me options as a consumer and equal access as my sighted peers.
The Coalition suggests that the waiver only apply to e-readers that do not have ACS capabilities, but then says that the products may have browsers and social media. It is my opinion, that this is not a meaningful limitation. The CVAA requires that ACS be accessible, and the FCC should not allow some services to be more important and others worthy of a waiver.
The Coalition fails to provide any details on the lifecycle of its products or a potential time frame for the waiver. I believe an indefinite, blanket waiver would harm the public, is inconsistent with the CVAA, and should not be granted in the face of these omissions.

Last year a week before Christmas, I was volunteering as a gift wrapper for a charity organization. The charity hosts the gift wrapping event at local book stores. Our table was next to the shelves full of e-readers available for sale. Many customers assumed I worked for the book store because I was wrapping purchases for those who wanted the service. Many customers tried to discuss the functions and usability of e-readers with me. I could not join in the discussions. Instead, I was faced with explaining that I could not use the devices or engage in discussions of which e-reader was the better choice. I, as a blind person could not use the e-readers that the store was selling. This got me to thinking that I probably couldn’t get a job at that book store as a real employee because I could not assist customers with the store’s big selling Christmas item. I also felt left out and isolated from the mainstream of shoppers because all the talk was about the different e-readers on the market and how much reading content was available on each platform.
I strongly urge the FCC to reject the Coalition’s petition and uphold the spirit of the CVAA. E-readers and the ACS features found in that equipment must be made accessible and granting a waiver would perpetuate the digital divide and discrimination in the marketplace that I face every day.

Sincerely,
Jeanine K. Lineback

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