The Association of Research Libraries (ARL) submitted reply comments to the Federal Communications Commission (FCC) opposing a petition filed by the Coalition of E-Reader Manufacturers on September 13, 2013. The manufacturers are requesting a waiver from the FCC that would exempt e-readers from the requirement that equipment used for advanced communication services (ACS) be accessible to, and usable by, individuals with disabilities.
In the initial round of comments, which closed on September 3, the FCC received more than 500 submissions, indicating that this issue is one of considerable interest and importance. Even more notable is the fact that all but a few of those 500 submissions opposed the petition. ARL agrees with the majority and urges the FCC to deny the waiver requested by the Coalition of E-Reader Manufacturers.
ARL's reply comments detail four main reasons the Association opposes the waiver. ARL believes that all users of e-readers are entitled to effective access to educational and scholarly resources in post-secondary education. At the most basic level, this issue is a matter of fulfilling existing legal requirements and important public policy goals. E-readers are being marketed to colleges and universities; however, these educational institutions risk violating the letter and spirit of the ADA by adopting technology that is not accessible to print-disabled students. The burden on manufacturers to make their devices ACS-accessible is minimal and would not outweigh the benefits to the print-disabled community.
ARL concludes, granting this waiver would be contrary to the public interest of the American people, long-standing US law, and would impede the member libraries of ARL in providing meaningful access to the widest variety of materials to all students and scholars.
