Public Comments

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International Deaf Emergency
A Deaf-led 501(c)(3) nonprofit · EIN 27-3191911 · Silver Spring, Maryland · ideafe.org

Before the Federal Communications Commission
Washington, DC 20554
In the Matter of Information Collections Being Reviewed by the Federal Communications
Commission Under Delegated Authority, OMB Control No. 3060-0175, Section 73.1250,
Broadcasting Emergency Information. Federal Register notice of September 1, 2026, FR Doc.
2026-17858; comments due November 2, 2026.

COMMENTS OF INTERNATIONAL DEAF EMERGENCY
1. Who we are. International Deaf Emergency, Inc. (IDE) is a Deaf-led nonprofit corporation
organized in Maryland in 2010 and recognized under section 501(c)(3). Its purpose is that
deaf, DeafBlind and hard of hearing people are reached by emergency information. IDE has
filed this year in PS Docket Nos. 15-91, 15-94 and 25-224 (comments of August 31, 2026,
ECFS 26110073861; a written ex parte of September 14, 2026, ECFS 26110076556; reply
comments of October 8, 2026, ECFS 26110079993) and in PS Docket Nos. 21-479 and 13-75
(reply comments of September 3, 2026, ECFS 26110075390). These comments respond to the
Paperwork Reduction Act notice and are confined to the practical utility, quality, clarity and
burden of the collection. IDE supports the extension of the collection and does not ask the
Commission to reopen section 73.1250 or section 79.2 here.
2. The collection. Section 73.1250(e) requires a report in letter form, forwarded to the FCC's
main office under 47 CFR 0.401(a) immediately upon cessation of an emergency during which
a station transmitted point-to-point messages at the request of public officials, or an AM
station used its daytime facilities at night. The report sets forth "the nature of the emergency,
the dates and hours of the broadcasting of emergency information, and a brief description of
the material carried during the emergency." The notice estimates 50 such reports a year.
Separately, paragraph (h) requires that emergency information transmitted by a TV or Class A
TV station "shall be transmitted both aurally and visually or only visually," by "any method of

visual presentation which results in a legible message conveying the essential emergency
information," and gives as examples "slides, electronic captioning, manual methods (e.g., hand
printing) or mechanical printing processes." (47 CFR 73.1250(e), (h).)
3. Practical utility. For the reports a TV or Class A TV station files, the collection records that
emergency information was broadcast, when, and what it said, but not how it was made
visible. Approximately 15 percent of American adults (37.5 million people ages 18 and over)
report some trouble hearing (National Institute on Deafness and Other Communication
Disorders, Quick Statistics About Hearing, Balance, and Dizziness), and for Deaf and
DeafBlind viewers the visual presentation required by paragraph (h) may be the only usable
channel. The rule already requires the visual presentation; the report simply does not ask
which one was used. IDE recognizes that the report is filed only in the circumstances
described in paragraph (e), so the gain is modest; but it costs almost nothing, and these are
exactly the emergencies in which stations relay messages to help rescue and aid.
4. Quality and utility. The collection has no standardized form (the notice lists "Form
Number: N/A"); the report is a letter whose content is set by paragraph (e). IDE therefore asks
the Commission to note in the Supporting Statement for this extension, and in any voluntary
filing guidance, that for a TV or Class A TV station the "brief description of the material
carried during the emergency" may usefully include: (i) which visual method carried the
essential emergency information (for example full-screen text, a crawl or captioning); (ii)
whether the visual presentation ran at the same time as the aural information; and (iii) whether
a sign language rendering was provided. Each is known at the station on the day; IDE expects
them to take only a few minutes to note and asks the Commission to assess any added time.
IDE does not ask for a new mandatory reporting element.
5. Clarity. Paragraph (h) states that the permitted visual methods "include, but are not
necessarily limited to" the four text methods it lists. To improve the clarity of the information
collected under paragraph (e), IDE asks that the Supporting Statement note that where a TV or
Class A TV station provided a sign language rendering alongside a legible text message during
an emergency covered by paragraph (e), identifying both in its brief description of the material
carried gives the Commission a clearer record of how the emergency information was
presented.
6. Burden. IDE takes no position on the Commission's estimate of 50 responses and one hour
per response. To minimize the burden of the collection through information technology, IDE
suggests that the Commission allow stations to submit paragraph (e) reports electronically, for

example to a designated FCC email address or through the Media Bureau's Licensing and
Management System, as an alternative to forwarding a letter to the main office under 47 CFR
0.401(a).
7. Why it matters. The Commission is examining the accessibility of emergency alerts in PS
Docket No. 25-224. Knowing how stations make emergency broadcasts visible, even in a
small number of reports, is a low-cost way to see whether the visual requirement of paragraph
(h) is reaching the people it exists to protect.
Respectfully submitted,
/s/ Emmanuel Jacq
President, International Deaf Emergency
9466 Georgia Avenue #1614, Silver Spring, MD 20910, United States
[email protected]
https://ideafe.org/
October 30, 2026