Rather than adopt these additional requirements, the FCC should acknowledge that its current position of encouraging covered entities to provide customer service support remains an appropriately flexible and sufficient manner in which to address this issue, ACA said.
ACA stressed that the FCC did not offer any evidence of an existing problem that its proposed requirements would address. One reason for the sparse record may be that customers of MVPDs have not needed support from MVPDs to access these features; another reason may be that MVPDs are already satisfying the needs of their customers who request support accessing these services.
Another point ACA raised was that smaller MVPDs would likely find any prescriptive customer support mandates burdensome. ACA's membership, for one, primarily consists of smaller and midsize operators of varying sizes and capabilities; it would likely be very challenging for these operators to meet the same obligations as the country's largest cable operators. The thin margins that many smaller operators operate within mean that many do not have extra resources to specifically devote for this type of support. Absent any indication of need for such dedicated support, there is little justification for imposing such burdens on smaller providers.
"The FCC's current approach of encouraging MVPDs to remain generally capable of answering questions regarding access to the secondary audio stream with respect to the navigation devices each supports, and to provide contact information regarding accessibility questions, is entirely sufficient and appropriate," Polka said.
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