The Coalition of Organizations for Accessible Technology (COAT) was formed in 2007. The coalition's main advocacy work has been refreshing and modernizing the many federal laws that require greater accessibility of telecommunications. Motivating the coalition was the realization that many of these federal laws that we had worked so hard to enact over the past 20 years had not kept pace with many new technologies. For instance, lack of captioning of television shows also shown over the Internet, or in video programming shown on small TVs, cell phones, PDAs, and other mobile devices. Another impetus was the lack of ability of 9-1-1 emergency call centers to accept calls from people who need to communicate in video or via pagers. Another driver for change was to reinstate video description of television and to have it heard on digital television. Another aim was to ensure that different forms of relay service could be used together. Also, there was little or no requirements to address the communications services needs of people who are deaf-blind or to ensure that cable TV boxes, remote controls and TV programming information are accessible. Among its many activities, COAT also monitors and disseminates information about other accessibility issues in recognition that the digital ecosystem of TV, the Internet, Mobile Communications, Electronic and Information Technology, Social Media and Telephony continues to evolve rapidly and sometimes in unexpected ways, and in many cases, with little or no consideration for usability or accessibility.
From 2007 to 2010, COAT focused mainly on a legislative agenda to resolve many accessibility barriers; this work resulted in the stunning enactment of the Twenty-First Century Communications and Video Accessibility Act of 2010 ("21st CVAA"). Currently COAT disseminates information about the status of the 21st CVAA and related accessible technology topics via this website and other electronic social media such as a LinkedIn group, a Facebook group and a twitter @coataccess. While COAT no longer meets as an advocacy group, many member individuals and organizations in the COAT community remain very active working on different policy and activist agendas in communications, media and technology, and are active on many implementing task forces and committees that support the 21st CVAA and related accessible technology laws.
At this time, COAT is a free source of critical information on a variety of accessible technology and telecommunications topics. These include:
- reports on implementation of the 21st CVAA, such as when rules are issued for specific provisions;
- information about federal regulatory actions involving accessible technology and consumer usability such as Sec. 508 of the Rehab Act or related laws,;
- issues and news from key disability advocacy organizations as they relate to accessible technology including telecommunications, such as legal actions or research or events; and
- other public and private sector actions regarding accessible technology that impact consumers with disabilities.
COAT History and Purpose
During the spring of 2007, a new coalition, the Coalition of Organizations for Accessible Technology (COAT), was established to try to resolve many accessibility problems. Founding organizations included Communication Service for the Deaf (CSD), the National Association of the Deaf (NAD), the American Association of People with Disabilities (AAPD), the American Council of the Blind (ACB), and the American Foundation for the Blind (AFB). The COAT coalition reached a grand total of over 315 organizations by the time the legislative agenda was realized in October 2010. Below are listed the many national, regional, state or local organizations who affirmed COAT's policy agenda to achieve greater accessibility of telecommunications and who worked on passing the legislation.
COAT's Legislative Agenda
COAT's primary goal was, and remains, ensuring that legislative and regulatory safeguards are in place so people with disabilities have access to evolving high speed broadband, wireless, and other Internet-based technologies. To reach this objective, COAT identified two main areas for advocacy: Communication Access and Video Programming Access. COAT therefore targeted the Communications Act for some updates. Here is a summary list of some of the telecommunications public policy areas where COAT has acted and, in many cases, achieved what was needed. For a full discussion of what the 21st CVAA requires, please read document here.
1. Extend Hearing Aid Compatibility mandates to Internet-enabled voice telephone products. Federal law requires all wired and many wireless telephones to be hearing aid compatible. COAT wanted to make sure that new Internet-enabled phones ("smartphones") are covered by these mandates. COAT achieved this goal in passage and enactment of the 21st CVAA.
2. Extend Telephone Relay Service (TRS) obligations to Internet-based providers. Thanks to COAT's advocacy, the FCC issued a June 2007 order to require that providers of certain Internet-based voice communication services contribute to the TRS interstate fund and to fulfill other TRS obligations, just like other telephone companies do. COAT also requested Congress to similarly extend this requirement to all Internet-based providers that provide voice communication services. COAT achieved this goal in passage and enactment of the 21st CVAA.
3. Ensure Internet-based communication products and services are accessible. All telecommunications manufacturers and service providers are required by law to make their products and services accessible to people with disabilities, if "readily achievable" under Section 255 of the Communications Act. In June 2007, COAT succeeded in getting an order from the FCC to mandate the same requirements for certain Internet-based providers of voice communication services. COAT also requested Congress to similarly extend this requirement to all Internet-based providers and succeeded with this in passage and enactment of the 21st CVAA.
4. Ensure 9-1-1 calls can be made through the Internet and video communications. 9-1-1 emergency call centers or Public Service Answering Points (PSAPs) should be compatible not only with direct voice and TTY calls, but also with Internet and video communications. COAT requested that people have equal access to 9-1-1 emergency call centers through voice, text, the Internet, video, and any other new technologies. COAT succeeded with this objective through legislative language that ensures local PSAPs address accessibility as they "go digital." The 21st CVAA also included related requirements such as the formation of an Emergency Accessibility Advisory Committee, or the EAAC, which continues to meet and make recommendations to ensure that the next generation of 911 ("Next Gen 911") services are usable by people with disabilities.
5. Allow the Universal Service Fund (USF) to cover broadband. There are two federal programs that help low income consumers pay for telephone services and expenses: Lifeline and Link-Up both of which are funded by the USF. In 2007 these programs did not provide any funds for broadband services which are needed for videophone communication. Low income individuals should be allowed to use these programs to help fund the costs of their high speed broadband connections if they need those connections to make video calls. COAT advocated for modifying USF requirements to allow eligible low-income consumers to apply their Lifeline and Link-Up subsidies to broadband services. As the Federal Communications Commission (FCC) continues to address modernizing the USF via regulatory Orders, in many cases, people with disabilities have benefited.
6. Allow the USF to cover specialized equipment for deaf-blind consumers. Although the USF helps to lower the cost of telephone services, USF has never been available to help consumers purchase specialized equipment. While COAT advocated to allow eligible deaf-blind consumers to use USF funds to purchase specialized equipment to meet their unique telecommunications needs, when the 21st CVAA was enacted, it mandated a National Deaf Blind Equipment Distribution Program (NDBEDP) that was funded via the interstate telecommunications relay services fund, not from the USF. The NBDED program is another success story resulting from COAT advocacy.
Video Programming Access
1. Extend the Television Decoder Circuitry Act of 1990 (Decoder Act) to video devices of all sizes. First, this law required televisions to have built-in decoder circuitry for closed captioning capacity, but only for those television screens at least 13 inches. COAT became aware that screens much smaller than 13 inches can and should display captions. COAT pushed to have the 13 inches minimum requirement eliminated, so televisions with screens of any size are required to be capable of displaying captions. COAT succeeded with the objective in the 21st CVAA. Second, some playback and real-time recording devices, such as digital DVD players and Blu-Ray DVD players, may not be capable of decoding and displaying captions. Therefore, COAT advocated for expanding the scope of the Decoder Act to video programming devices of all sizes, including recording and playback devices that are designed to receive or display analog, digital, or Internet-based video programming. COAT succeeded with this objective, to a considerable degree, in the 21st CVAA.
2. Extend federal closed captioning obligations to certain Internet-based video programming. Closed captions are legally required for 100% of new, non-exempt, English television programs, some Spanish language programming, and some older television programs. Now, the Internet has many television programs, movies, video clips, and live video streaming, and the majority of this programming is not captioned because there was no legal requirement for Internet-based videos. COAT advocated for Congress to mandate closed captioning obligations for certain video programming broadcasted on the Internet and succeeded with this goal when the 21st CVAA was enacted. While this is a significant step forward in expanding captioning availability, much remains to be done to ensure more video material found on the Internet is accessible.
3. Restore the FCC's video description rules. Video description -- also referred to as "audio description" -- allows video programming to be accessible to blind people. Video description describes on-screen visual elements during natural pauses in dialogue. The FCC had mandated some video description previously but in 2002 a federal court said that the FCC did not have the authority to issue these rules and threw them out to advocates' dismay. COAT advocated for restoring the FCC's video description rules, in order to ensure access by blind and visually impaired people to television programming, including on-screen emergency warnings and information. COAT succeeded with this objective, ensuring also that the reinstated video description rules applied to digital TV as well and establishing a far-reaching schedule for implementation.
4. Require accessible user interfaces and easy access to accessibility features on all video programming devices. How many times have you tried to figure out how to turn on closed captions on a new or different television set and not been able to do so? It is often difficult or impossible to find the menu selections that turn on accessibility features, such as closed captions or video description. Therefore, COAT advocated for requiring easy ways to find and turn on accessibility features on all devices used to receive or display video programming. For example, COAT asked for accessibility of television controls, other video display devices, and on remote controls to turn on the closed captions, in addition to controls that could be used by people with vision disabilities. COAT succeeded with this objective to a large degree with enactment of the 21st CVAA.
For a fuller explanation of what is in the 21st CVAA, please read document here.
Current Status: Organizations that formed COAT and carried the bulk of the legislative work to influence Congress to develop the 21st CVAA remain actively involved in ensuring implementation during the 2011 and 2012 critical rule-making processes at the Federal Communications Commission. These organizations include ACB, AFB, NAD, TDI, HLAA, WGBH Media Access Center, and several others.
Belong to the COAT Community
For more information about the COAT story, please visit the COAT website at www.COATaccess.org or send an e-mail to info@COATaccess.org. COAT also maintains Facebook and LinkedIn groups, as well as a Twitter (@coataccess). These social media are used primarily by interested persons to follow up and discuss new and emerging accessibility issues. Join these other social media to stay a part of The COAT Community!