Recently, AT&T Inc. and BellSouth Corporation made the declaration of their intent to merge. The American Council of the Blind (ACB) filed comments with the Federal Communications Commission in response to this proposal. Although it sounds as if a company merger is not an ACB issue, it is important to remember that the AT&T Inc./BellSouth merger is perhaps one of the largest telecommunications mergers in history. This convergence would create a company that would have tremendous influence in all arenas of wireline, wireless and broadband communications and is likely to result in the convergence of technologies that result in new and improved features and functions across various services.
This may include television delivered by companies that were previously known as voice telephone providers, messaging services integrated across various technology platforms, enhancement and expansion of current services, and other services that are delivered using the integrated assets of the new entity. Considering the integral role that these services already play in our society, and considering the potential growth of these services in the future, it is imperative that these various features and functions are accessible to and usable by people with disabilities. As a result, ACB took the opportunity to “strike while the iron was hot.”
ACB urged that the Commission impose three disability-specific requirements on the merged entity:
1. Access to Television Services
No one questions the central role that television and television programming plays in American society, but the delivery mechanisms available today vary significantly from the past, and keeping in mind the vast resources that would be available, the merger proposal is likely to foster the growth of an already much prophesized, and eagerly awaited Internet-enabled television service. ACB asked that the Commission require any such IP video programming services that are delivered by the new entity to mass audiences to comply with closed captioning requirements.
The issue of access to television however, goes beyond closed captioning alone, but also includes the audio services that analog and digital video distributors are providing for people who are blind or visually impaired. These additional audio services, generally known as video description or descriptive video, are delivered to broadcast, cable and satellite TV consumers via the Secondary Audio Program (SAP) channel service or via a separate audio feed. When delivering video services to its clients, AT&T's new video service should assure ready availability of these audio services via a simple-to-use and accessible interface.
2. IP-Enabled Voice Services
It is also clear that voice over Internet protocol (VoIP) services, as well as other IP-enabled services, are likely to proliferate as a result of this merger. To ensure the accessibility of these already rapidly growing services, we asked the Commission to require that any VoIP service or other IP-enabled service that serves as a substitute for telephone service that is delivered by the new entity comply with the accessibility requirements of the Communications Act. Although the Commission has already extended other social obligations to interconnected VoIP providers – such as to handle emergency calls and contribute to the Universal Service Fund, it has not extended disability mandates to these providers.
As new Internet technologies change the way our nation communicates and receives information, people with disabilities will be presented with new opportunities to enhance their independence and productivity, but only if safeguards are put into place to ensure that these individuals are able to access these technologies to the same extent as people without disabilities. ACB asked that the merged entity should specifically be required to incorporate accessibility features into their services and products as required by Section 255, to make VoIP and other IP-enabled telephone-like devices hearing aid compatible.
3. Customer Service and Standards
ACB asked that the FCC require that the companies involved in the merger maintain or raise their standards for customer service and support for people with disabilities both during the period of the merger and following completion of the merger. It has been our experience that typically when companies merge, customers often find it difficult to get their needs met. ACB specifically commented about the effect that the transition would have on current and potential customers with disabilities needing assistance in resolving billing, technical or service concerns.
Historically, both AT&T Inc. and BellSouth have actually done much to provide accessible and useable services to people not only who are blind and visually impaired, but with any disability. ACB asked the Commission to require that this legacy continue and to guarantee, as new services and technologies created and supported by the merged company evolve, that the new company will provide accessible services that effectively address the future needs of people who are blind and visually impaired, and indeed, all persons with disabilities.
Day Al-Mohamed
Director of Advocacy and Governmental Affairs
American Council of the Blind
1155 15th St. NW
Washington DC 20005
Tel. 202-467-5081
dalmohamed@acb.org