[nfbcs] Section 508 Refresh

Wed May 19 17:47:02 UTC 2010

As I look at this, I see many definitions telling me about "this part will" or "this part does" but where in the world is the proposed standard.  

-----Original Message-----
From: nfbcs-bounces at nfbnet.org [mailto:nfbcs-bounces at nfbnet.org] On Behalf Of Stanzel, Susan - Kansas City, MO
Sent: Wednesday, May 19, 2010 9:41 AM
To: NFBnet NFBCS Mailing List
Subject: [nfbcs] Section 508 Refresh

Hi NFBCS Friends,

I am Susie Stanzel. I am looking forward to seeing all of you at our annual meeting of the Computer Science division of the NFB on Monday, July 5.
I work for the U.S.D.A. and many of you work in some level of government. Section 508 of the rehab act is being refreshed and the access board has a proposed document which is open for comment at

http://www.access-board.gov/sec508/refresh/draft-rule.htm

Here are some questions from the access board. If any of you have any input on this subject, comments are taken until June 21st.

Here are the questions:

Susie Stanzel

Question 1

The Board developed the draft using the organizational approach recommended by the Committee in which the provisions are organized primarily by the features or capabilities of a product, instead of discrete product types. The Board seeks comments on the usability and effectiveness of this approach, as well as alternative organizational approaches.

Question 2

The Board seeks input on what implementation time frames would be reasonable, specifically whether some provisions should have differing implementation dates.

Question 3

To improve usability, the Board titled each provision and located advisory notes next to the associated requirements. Are there any other format changes that will make the draft easier to use?

Question 4

The Board seeks feedback on the overall organization of the draft, especially how aspects of technology are addressed by the chapter organization. For example, should software (Chapter 4) and electronic documents (Chapter 5) be combined? Or, should all requirements for audio output, including conversation functionality and status indicator sounds (Chapter 8), be combined with text messaging capability (Chapter 9) into one chapter?

Question 5

The draft requirement which the Board is considering for access to electronic content in the draft is limited to certain official communications by Federal agencies. Other types of communications and electronic content are not addressed. The Board seeks comment on this draft requirement and what other types of content including social media (i.e., YouTube and Twitter) should be addressed and the benefits and costs of extending coverage to other forms of electronic content. The Board is interested in comments from agencies about how this provision could be implemented across large and diverse institutions. How should attachments to official email messages be handled? The Board is also interested in information on the benefits and costs associated with this change, particularly from Federal agencies. How should this provision apply to records requested from the National Archives and Records Administration who is prohibited from altering archival records?

Question 6

The Board seeks comment on removing these exceptions and the impact of removing them, including the benefits and costs associated with removing them. Should the exception concerning ICT acquired by a contractor incidental to a contract be repeated in this section and in section E103.4.2?

Question 7

The Board seeks comment on this approach to harmonization with WCAG 2.0 including suggestions for alternative approaches to achieving harmonization, and comments on the benefits and costs associated with the Board's approach.

Question 8

The Board is interested in comment on the definition of Information and Communication Technology.

Question 9

The Board is interested in comment on the proposed definitions.

Question 10

The Board is interested in comment on how the functional performance criteria should be implemented in relation to the technical provisions. Does the approach discussed in E103.5 and C103.6, as a statement of current practice, clarify or confuse the issue? If the approach is confusing, how could it be made less confusing?

Question 11

The Board is interested in comment on whether and the extent to which this change will sufficiently improve access for people with limited vision and the benefits and costs associated with this change.

Question 12

The Board is interested in comment on this proposed new provision, including information on the benefits and costs associated with this addition.

Question 13

The Board is interested in comment on the proposed change to improve access for individuals with hearing impairments, including information on the benefits and costs associated with this change.

Question 14

The Board is interested in comment on the proposed new provision to improve access for individuals who are unable to make contact with a product, including information on the benefits and costs associated with this change.

Question 15

The Board is seeking comment on whether cognitive disabilities are sufficiently addressed in the functional performance provisions and seeks suggestions on how the requirements might better address the accessibility needs of individuals with cognitive disabilities.

Question 16

The Board is interested in comments on how closed functionality is covered in the draft. Should other means of assistive technology besides personal headsets be permitted to provide access to ICT with closed functionality?

Question 17

The draft includes three provisions (406.2, 406.3, and 406.4) not included in the Committee report but that are consistent with WCAG 2.0. Are these provisions important enough for end-users to be included for the sake of harmonization with other standards? The Board seeks comment on the benefits and costs of these additions.

Question 18

The draft includes a requirement for ICT which provides an assistive technology function. Should the requirements apply to assistive technology? The Board seeks comment on the benefits and costs on including explicit requirements for assistive technology.

Question 19

Do the proposed provisions for authoring tools reflect features that many authoring tools already provide? If not, could such features be added to authoring tools relatively easily? The Board seeks comment on the benefits and costs of including such requirements for authoring tools.

Question 20

The Board seeks comment on whether there is a better way to distinguish between requirements for software applications covered by Chapter 4 and electronic documents covered by Chapter 5.

Question 21

The Board seeks comment on whether this proposed approach is successful in making the document more understandable and useful. The Board welcomes alternatives to this organizational approach. (Chapter 6)

Question 22

The Board is interested in comments on whether there is a voluntary consensus standard which could address some issues related to captioning quality, such as the degree of synchronization required and an allowable error rate.

Question 23

The Board seeks comment on any impact this approach may have on manufacturers of hardware or software for audio video players.

Question 24

The Board seeks comment on whether this change in terminology is sufficient, or if it will result in any confusion or unintended implementation issues. Should this term be defined?

Question 25

The Board is interested in comment on these provisions, including information on the benefits and costs associated with the proposed requirement for volume gain. In addition, the Board seeks comment on whether the specified volume gain for cellular and landline telephones should be consistent since the amplification needs of people who are hard of hearing are the same for both products.

Question 26

Is there a similar standard to the RFC-4103 standard that has been published by a standards development organization that the Board could reference?

Question 27

The Board seeks comment on this requirement. Are the specifications for video quality sufficient to support accessibility? Are there other ways of addressing video communications that are less complex?

Question 28

The Board seeks comment on the requirement that a signal be provided on all incoming calls on VoIP systems. Should the requirement be limited, or should it apply to all such calls? Should this feature be selectable by the user?

Question 29

The Board seeks comment on the benefits and costs of the increased requirements for documentation.

Question 30

The Board seeks comment from users and manufacturers of self-service machines on their experiences in using or designing accessible machines and the benefits and costs associated with the proposed requirements.

Question 31

The Board is interested in comment on the impact on small entities of the provisions implementing section 508 of the Rehabilitation Act for technology procured, developed, maintained, or used by or on behalf of Federal agencies. The phrase "or on behalf of agencies" covers technologies used by contractors under a contract with a Federal agency. How many contractors and subcontractors would be considered small entities under the SBA small business size standards? What types of compliance costs will these contractors and subcontractors face in developing the technologies covered by section 508? For example, will small contractors and subcontractors face capital costs for equipment, or hiring professional expertise or extra staff to comply with the requirements? Will the cost of implementation create a competitive disadvantage for small contractors versus large contractors? (i.e., will a small contractor become less likely to win a Federal contract based on price?) Should the Board establish different compliance or reporting requirements for small contractors and subcontractors? Does the Board need to clarify or simplify the compliance requirements for small contractors or exempt certain small contractors from these requirements?

Question 32

The Board is interested in comment on the impact on small entities (manufacturers of telecommunications products) of the provisions implementing section 255 of the Telecommunications Act of 1996. How many manufacturers of telecommunications products would be considered small entities, particularly with the application of this rule to interconnected VoIP products? What types of compliance costs will small manufacturers face? The Board is interested in small business estimates for services required by this rule such as providing access to information, documentation, and training of customers (for example through help desks and support services). Will this section require extra technology, professional expertise or extra staff? Are there alternative ways that small manufacturers can provide information and training at lower costs? Should the Board establish different compliance or reporting requirements for small manufacturers?

Question 33

The Board is interested in comment on the impact on small entities (places of public accommodations and state and local government entities) of the provisions for self-service machines under the Americans with Disabilities Act. How many and what types of small entities utilize self-service machines, and what types of machines do they use? How many small manufacturers make these types of machines? How many of the small entities that use or manufacture self-service machines have machines that are accessible? How much will it cost to develop and produce the technology that would meet the proposed provisions? Should the Board establish different compliance requirements for small entities to have accessible machines? Does the Board need to clarify or simplify the requirements for small entities or exempt certain types of machines from these requirements?

 *

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