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ARL and ALA Urge FCC to Deny Waiver of E-Reader Accessibility Requirement

image © Terry Madeley

On October 27 and November 5, 2014, ARL along with the American Library Association (ALA) filed a letter and comments with the Federal Communications Commission (FCC) opposing the request by the Coalition of E-Book Manufacturers to waive compliance with disability law in manufacturing e-readers such as the Kindle. The law requires that equipment used for advanced communication services (ACS) be accessible to, and usable by, individuals with disabilities.

In 2013, ARL and ALA filed comments opposing a permanent waiver and in response the FCC imposed a one-year waiver whose term began on January 28, 2014. The Coalition of E-Book Manufacturers requested an extension of that waiver on September 4, 2014. In the November 2014 comments, the library associations stated:

At stake in this proceeding is the ability for millions of Americans to participate fully and freely in our communications system. The waiver extension proposed by the Coalition would make a difficult situation even worse. While disabled persons already must routinely (and unacceptably) wait several years before various mainstream technologies become accessible, the proposed waiver extension would leave basic e-readers in a near-permanent state of inaccessibility. The record contains ample evidence that basic e-readers are designed with, marketed, and used for advanced communications services (“ACS”). Furthermore, the arguments for denying the requested waiver appear even more compelling in light of the widely recognized public interest in making texts accessible to the print disabled. Fortunately, the Commission has the authority and opportunity to significantly correct this ongoing injustice to the print-disabled community. Rather than allow e-reader accessibility to continue to deteriorate, the Commission should deny the waiver proposed by the Coalition.

The October 2014 letter (PDF) and November 2014 comments (PDF) are available on the ARL website. Law students from the Glushko-Samuelson Intellectual Property Clinic, Washington College of Law, American University, filed the letter and comments on behalf of ARL and ALA.

For further discussion of this issue, see the recent ARL Policy Notes blog post, “ARL and ALA File Comments Opposing E-Reader Waiver Extension and Disability Tax.”


The Association of Research Libraries (ARL) is a nonprofit organization of 125 research libraries in the US and Canada. ARL’s 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 http://www.arl.org/.

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