[NFBMO] Our chance to get regulations making the ADA meaningful in 2023
Gary Wunder
gwunder at earthlink.net
Thu Sep 28 16:03:13 UTC 2023
Here is the response I wrote based on the comments the NFB submitted and the
request forwarded to us from Kyle Walls and our Advocacy and Policy Team.
3910 Tropical Lane
Columbia, MO 65202-6205
Dear Sir or Madam:
I write as a result of RIN 1190-AA79, Nondiscrimination on the Basis of
Disability; Accessibility of Web Information and Services of State and Local
Government Entities. I worked for thirty-one years as a computer programmer.
At first almost everything I dealt with came in print. Thankfully, things
became more electronic, and I could use the interactivity of a computer
terminal, the blessing of email, and to a more limited extent the vast
resources available to most people on the World Wide Web.
I believe it is high time for the World Wide Web to become as accessible as
we expect new buildings to be. The inability to efficiently use websites
cost me a demotion from project manager to senior programmer analyst, not
because I didn't know the data that needed to be filled in but because the
fields meeting information were not properly labeled and sometimes the
buttons to submit the forms were not identified at all. One of the places
that I worked used web technology to fill out a timesheet; since I was a
salaried employee, its function was not so much to decide what to pay me but
to decide how I was spending my work week. Even this website was
inaccessible, meaning that I had to turn to my manager and asked that he
transcribe what I was able to write into a word processing document the
information needed by management and ask my boss to put it in a form
acceptable to the company. He liked me but considered this an undue burden;
in his opinion, it would not have been an undue burden for the company to
fix the form but was a continuing demand he didn't need. It was also a
reminder to him that, no matter how valuable I might be, my blindness was
relevant to his workload, which made seeing me as an equal contributor more
difficult.
The rehabilitation program is founded on some very sound principles, those
being that it costs less to train people and put them to work than it does
to keep them on social welfare programs. Success relies on a blind person
working hard, getting good training, and then having the opportunity to
succeed. The third element of this process is highly dependent on the stance
of the federal government and whether it considers accessibility a nice
thing to do or an essential thing to do. Nowhere does the Americans with
Disabilities Act say that we should do what it requires because it is a nice
or a charitable thing. It says it should be done because blind and otherwise
disabled people are valuable and can bring tremendous value in our economic
struggle with the rest of the world.
Please say yes to meaningful regulations and no to exceptions that will keep
us forever dependent on the goodwill of charity and the unpredictability of
a safety net that can either help us or tie using knots, depending on how it
is written and interpreted. We have the opportunity as citizens of the
United States of America to design inclusively or to write off a large
portion of our population who have traditionally been seen as takers rather
than givers. The exceptions that you allow to pass through will determine
whether this continues or whether these regulations will in fact advance
opportunities for blind people.
Please be bold; please look at technological advances as something that
should be shared in expanding the opportunities for all. Passing these
exceptions will sideline people and make takers of would-be givers. If you
believe that America's success in the world depends on being competitive
with it, you must see that we design and implement technology that
eradicates barriers rather than creating them.
If I can help with more information, please contact me.
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From: NFBNet-Members-List nfbnet-members-list-bounces at nfbnet.org
<mailto:nfbnet-members-list-bounces at nfbnet.org> On Behalf Of Walls, Kyle
via NFBNet-Members-List
Sent: Wednesday, September 27, 2023 3:42 PM
To: nfbnet-members-list at nfbnet.org <mailto:nfbnet-members-list at nfbnet.org>
Subject: [Nfbnet-members-list] Regulatory Alert: September 27, 2023 -
Website Accessibility
Dear Federation Family:
As many of you likely know, on August 4, due in large part to the advocacy
of the National Federation of the Blind, the United States Department of
Justice (DOJ) published a notice of proposed rulemaking (NPRM) regarding ADA
Title II website and mobile app accessibility regulations
<https://protect-us.mimecast.com/s/Glv7C31K7zsp0BzWSgWr5N?domain=federalregi
ster.gov> . After thirteen years of waiting we were pleased to see the
Department of Justice release this long-anticipated proposed rule. However,
the introduction of seven new exceptions to the proposed accessibility
standard, which go far beyond the current defenses of undue burden and
fundamental alteration, was gravely concerning.
The National Federation of the Blind submitted our official comments
<https://nfb.org/programs-services/advocacy/policy-statements/comments-ada-t
itle-ii-website-and-mobile-app-notice> on September 19, but we believe the
Department of Justice needs to hear from as many blind Americans as possible
to fully understand how detrimental this proposed rule will be for the
nation's blind. That's why we're urging you to submit your own response to
the NPRM. Include a story about how you, or someone you know, was negatively
affected by an inaccessible state or local government-maintained website
(this includes any website for the state or local government, public school,
public college or university, city/county/state parks, public pool, public
community centers, etc.). A suggested template for your response is:
"I am writing in regard to RIN 1190-AA79, Nondiscrimination on the Basis of
Disability; Accessibility of Web Information and Services of State and Local
Government Entities.
[TELL YOUR PERSONAL STORY ABOUT STATE/LOCAL GOVERNMENT WEBSITE
INACCESSIBILITY]
If the proposed rule is published as is, with the seven new exceptions, I
may not be able to access vital information about my community or education.
It is almost certain that I will not be able to access government programs
and services. Therefore, I oppose any rule that may be published containing
any exceptions to accessibility other than the current defenses of undue
burden and fundamental alteration that were codified in the original
Americans with Disabilities Act."
You can post your comments to the DOJ by visiting
https://www.regulations.gov/commenton/DOJ-CRT-2023-0007-0001
<https://protect-us.mimecast.com/s/CzJwC4xYgATB3oKRCxBa_p?domain=regulations
.gov> . That is a link directly to the comment page for the Title II website
NPRM. Once there, you will have to enter your comment in the text box then
select that you are an individual, which will bring up a place for you to
enter your first and last name. Then you can click "Submit." No other
information is required. One suggestion is to formulate your comments ahead
of time in a word processor program, then simply cut and paste them into the
text box on the comment submission page. For those wanting to submit longer
comments, the system also offers the opportunity to upload documents in
docx, pdf, txt, rtf, and several other formats.
Comments are due prior to midnight Eastern time on Tuesday, October 3, 2023.
If you have any questions, please contact me at kwalls at nfb.org
<mailto:kwalls at nfb.org> . Thank you for all that you do.
Be great!
Kyle Walls
Research and Regulatory Specialist
200 East Wells Street, Baltimore, MD 21230
410-659-9314, extension 2223 | kwalls at nfb.org <mailto:kwalls at nfb.org>
<https://nfb.org/>
<https://protect-us.mimecast.com/s/PCOJC5y1jBUZ4vLwuylPpC?domain=facebook.co
m>
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>
<https://protect-us.mimecast.com/s/Bdv1C73WlECAoq1nTqhOPL?domain=youtube.com
>
The National Federation of the Blind is a community of members and friends
who believe in the hopes and dreams of the nation's blind. Every day we work
together to help blind people live the lives they want.
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