[Fopbc] Fwd: Letter to Members Concerning Section 508 Refresh and Comments Proposed Changes to ADA Accessibility Guidelines

[Lenora Marten]

Below, you will find further explanation concerning the proposed changes to
the ADA Accessibility Guidelies. Remember, your comments must be made by
midnight June 21.



Lenora J. Marten, President 
Florida Organization of Parents of Blind Children
NFB-Jacksonville Chapter Secretary 
Chairperson, FSDB/PAC
FOPBC at aol.com 
904-777-5976 / 904-229-9554
www.nfbflorida.org/parents
www.raceforindependence.org/goto/fopbc 
www.raceforindependence.org/goto/lenoramarten






Dear Federationists: 
 
As many of you may have already heard, the U.S. Access Board has asked the public for feedback on some proposed changes to the ADA Accessibility Guidelines, Rehabilitation Act, and Telecommunications Act. Specifically, the Access Board plans to update the standards and accessibility guidelines for electronic and information technology, as well as add kiosks to the ADA Accessibility Guidelines. We urge you to make your voices heard and e-mail, fax, or post on <http://www.regulations.gov/>www.regulations.gov your comments to these changes, as they have an enormous impact on a blind person's ability to access information. With a deadline of midnight on Monday, June 21, time is running out for us to influence the board. 
 
The National Federation of the Blind has been heavily involved with the formulation of these proposed standards and guidelines, but our role is not finished. It is important that we applaud the Access Board for the changes we support so they are not compromised, and that we highlight where the changes have not gone far enough to ensure full accessibility. More specifically, we have many concerns regarding both the definition of a "kiosk" and the kiosks that are exempted in the proposal. 
 
In the current proposal, the definition of "kiosk" is limiting. A kiosk is defined as a self-service unit used only for transportation (ticketing, seat assignments, boarding passes, etc.) or for ordering food. This definition should be expanded to include other types of services not mentioned, as kiosks are increasingly replacing customer service personnel in a wide range of services, including voting, jury service payments, and health care. The current definition is silent on whether a unit used for these services would be considered a kiosk, and also does not include visual display systems that are used solely for displaying information to users. Kiosks should have a comprehensive definition that leaves room for innovative ways kiosks may be incorporated into our society and eliminates any future debate over whether a different service is covered under the law and what standards may apply. 
 
In addition, the two exemptions for kiosks in the proposal will not ensure total accessibility. First, closed systems are exempted to comply with 302. This means a closed system does not have to provide spoken output, since it would not be required to be usable with "only the attachment of a personal headset." Under this assumption, there is no requirement for these systems to be accessible. Second, drive-up kiosks are exempted. Although people with certain disabilities are not drivers, they are all passengers who may encounter a drive-up kiosk; and exempting drive-up units is discriminatory to a disabled passenger. The NFB encourages the board to ensure that all kiosks be required to be accessible. 
 
These comments and others were compiled and formally submitted by the NFB to the Access Board. Now it is time for our members to make a statement and emphasize our concerns regarding kiosks. Your comments can be short--the act of sending in feedback is more important than the length of your remarks. You could say something as simple as "I think the definition of kiosks is too limited. Please expand the definition and remove the exemptions." You could also say "I think the definition of kiosks should be expanded and all exemptions removed to ensure full accessibility." You can call Tim Creagan at (202) 272-0016, e-mail your thoughts to <mailto:ictrule at access-board.gov>ictrule at access-board.gov with "2010-1" in the subject line, fax to (202) 272-0081, or post your comments on <http://www.regulations.gov/>www.regulations.gov. To view the full draft, visit <http://www.access-board.gov/sec508/refresh/draft-rule.htm>http://www.access-board.gov/sec508/refresh/draft-rule.htm.  
If you need more information, please contact Lauren McLarney at (410) 659-9314, extension 2207. 
 
Sincerely, 
 
Joanne Wilson 
Executive Director, Affiliate Action 
jwilson at nfb.org 
 
 
  






Dear Federationists: 
 
As many of you may have already heard, the U.S. Access Board has asked the public for feedback on some proposed changes to the ADA Accessibility Guidelines, Rehabilitation Act, and Telecommunications Act. Specifically, the Access Board plans to update the standards and accessibility guidelines for electronic and information technology, as well as add kiosks to the ADA Accessibility Guidelines. We urge you to make your voices heard and e-mail, fax, or post on <http://www.regulations.gov/>www.regulations.gov your comments to these changes, as they have an enormous impact on a blind person's ability to access information. With a deadline of midnight on Monday, June 21, time is running out for us to influence the board. 
 
The National Federation of the Blind has been heavily involved with the formulation of these proposed standards and guidelines, but our role is not finished. It is important that we applaud the Access Board for the changes we support so they are not compromised, and that we highlight where the changes have not gone far enough to ensure full accessibility. More specifically, we have many concerns regarding both the definition of a "kiosk" and the kiosks that are exempted in the proposal. 
 
In the current proposal, the definition of "kiosk" is limiting. A kiosk is defined as a self-service unit used only for transportation (ticketing, seat assignments, boarding passes, etc.) or for ordering food. This definition should be expanded to include other types of services not mentioned, as kiosks are increasingly replacing customer service personnel in a wide range of services, including voting, jury service payments, and health care. The current definition is silent on whether a unit used for these services would be considered a kiosk, and also does not include visual display systems that are used solely for displaying information to users. Kiosks should have a comprehensive definition that leaves room for innovative ways kiosks may be incorporated into our society and eliminates any future debate over whether a different service is covered under the law and what standards may apply. 
 
In addition, the two exemptions for kiosks in the proposal will not ensure total accessibility. First, closed systems are exempted to comply with 302. This means a closed system does not have to provide spoken output, since it would not be required to be usable with "only the attachment of a personal headset." Under this assumption, there is no requirement for these systems to be accessible. Second, drive-up kiosks are exempted. Although people with certain disabilities are not drivers, they are all passengers who may encounter a drive-up kiosk; and exempting drive-up units is discriminatory to a disabled passenger. The NFB encourages the board to ensure that all kiosks be required to be accessible. 
 
These comments and others were compiled and formally submitted by the NFB to the Access Board. Now it is time for our members to make a statement and emphasize our concerns regarding kiosks. Your comments can be short--the act of sending in feedback is more important than the length of your remarks. You could say something as simple as "I think the definition of kiosks is too limited. Please expand the definition and remove the exemptions." You could also say "I think the definition of kiosks should be expanded and all exemptions removed to ensure full accessibility." You can call Tim Creagan at (202) 272-0016, e-mail your thoughts to <mailto:ictrule at access-board.gov>ictrule at access-board.gov with "2010-1" in the subject line, fax to (202) 272-0081, or post your comments on <http://www.regulations.gov/>www.regulations.gov. To view the full draft, visit <http://www.access-board.gov/sec508/refresh/draft-rule.htm>http://www.access-board.gov/sec508/refresh/draft-rule.htm.  
If you need more information, please contact Lauren McLarney at (410) 659-9314, extension 2207. 
 
Sincerely, 
 
Joanne Wilson 
Executive Director, Affiliate Action 
jwilson at nfb.org 
 
 
  


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