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ARL and ALA File Comments to FCC on E-Reader Accessibility

image © Terry Madeley

Earlier this month, ARL and the American Library Association (ALA) filed additional reply comments (PDF) to the Federal Communications Commission (FCC) regarding a request to waive e-reader access requirements for individuals with disabilities. In the comments, the Associations noted, “We are writing to reiterate our opposition to the waiver sought by the Coalition of E-Reader Manufacturers (‘the Manufacturers’) and present new information regarding the manner in which the e-readers covered by the Manufacturers’ petition (‘basic e-readers’) are utilized.”

The Associations stated, “The Manufacturers’ waiver request is based on the erroneous premise that basic e-readers do not have a co-primary purpose as a device that provides Advanced Communications Services (ACS) under the 21st Century Communications and Video Accessibility Act (CVAA). The use and marketing of basic e-readers demonstrates that Electronic Messaging Services (EMS), a type of ACS, is a co-primary purpose of such devices. Consequently, the Federal Communications Commission (FCC) should deny the Manufacturers’ request for a waiver.”

For background on this issue, read about the reply comments ARL submitted to the FCC in September 2013 opposing the waiver.


The Association of Research Libraries (ARL) is a nonprofit organization of 125 research libraries in the US and Canada. Its mission is to influence the changing environment of scholarly communication and the public policies that affect research libraries and the diverse communities they serve. ARL pursues this mission by advancing the goals of its member research libraries, providing leadership in public and information policy to the scholarly and higher education communities, fostering the exchange of ideas and expertise, facilitating the emergence of new roles for research libraries, and shaping a future environment that leverages its interests with those of allied organizations. ARL is on the web at https://www.arl.org/.

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