Filed comments with the United States FCC on modernizing the 911 framework

A ten page comment in PS Docket No. 26-197, Modernizing the 911 Framework, asking the Commission to make accessibility part of the framework itself rather than a set of exceptions to it. It asks that "accessible" stay in the first core objective and mean that a person can reach 911 and converse in a modality they can use, with relay available but not required; that the voice criterion be replaced by real-time, two-way conversation by voice, text or video, including sign language; that the line between services that support 911 and services that merely facilitate it be drawn by capability, not label, with native 911 free of any enrollment requirement; that every 911 disclosure and education obligation require accessible formats; that automatically initiated 911 communications give a non-auditory notice, and that untested automated translation never be the sole path on a live call; that accessible modalities be treated as phased obligations with defined fallbacks rather than excluded; that any harmonized baseline include a text path, a callback the caller can answer, continuity across transfers and modality changes, and DeafBlind-compatible output; and that section 225 and the CVAA remain an independent basis for 911 accessibility rules.

• Read the comments as filed (PDF)
• The filing on the FCC public record (26110084363)