[Ohio-talk] Fwd: Alert!--Tell the Access Board to Wrap Up 508/255 ASAP!

Tue May 12 16:31:52 UTC 2015

I can't understand most of what this says because I am not a techy,
but I want everything computer related to be accessible and, I
believe, this is a step in that direction.

---------- Forwarded message ----------
From: AFB DirectConnect <MRichert at afb.net>
Date: Tue, 12 May 2015 11:35:50 -0400
Subject: Alert!--Tell the Access Board to Wrap Up 508/255 ASAP!
To: AFB Subscriber <afbweb at afb.net>

 AFB DirectConnect Letterhead

Time To Weigh In!
Tell the Access Board that The Clock is Ticking:
Get the 508 and 255 Rules Out ASAP!

For further information, contact:

Mark Richert, Esq.
Director, Public Policy, AFB
(202) 469-6833
MRichert at afb.net <mailto:mrichert at afb.net>

After more than 15 years and a revolution in electronic and information
technology, the U.S. Access Board has finally published its formal
proposal to refresh the Standards and Guidelines intended to ensure the
accessibility of much of the universe of so-called information and
communication technology (ICT). The Standards are to be used by agencies
of the federal government to comply with section 508 of the
Rehabilitation Act of 1973, as amended, and the Guidelines provide
direction for telecommunications equipment manufacturers and service
providers who must comply with section 255 of the Communications Act of
1934, as amended. To many observers, the process, begun in earnest in
2008, to make necessary tune-ups to these critical technical and
functional rubrics has been needlessly arduous and prolonged. This
protracted undertaking, many fear, has created a pretextual, if not
actual, climate of uncertainty among industry and government players
alike who have been able to point to the failure to conclude a refresh
of the Standards and Guidelines as a barrier to their "eagerness" to
comply with federal law and make accessible technology happen.

However, with the publication of these near-final Standards and
Guidelines, the disability community has yet one more chance to weigh in
both with specific concerns about individual provisions as well as our
overall plea that these Standards and Guidelines must be finalized at
the earliest possible opportunity. Groups from throughout the disability
community will be commenting on the details contained in the Access
Board's extensive proposal, but all advocates are encouraged to send
brief comments to the Access Board, and by extension the Obama
Administration, beseeching them to conclude all work on the 508 and 255
refresh by the end of this year.

To offer your comment, send an email to:

docket at access-board.gov <mailto:docket at access-board.gov>

All comments must be received by Thursday, May 28, and be sure to
include docket number ATBCB-2015-0002 in the subject line of the
message. Tell the Access Board that time is of the essence and that the
508/255 refresh must be finalized by the end of this year. Be sure to
identify yourself in your email, which can be as long or as brief as you
wish, but remember that all such comments received are a matter of
public record.

To learn more about the 508/255 refresh, and to review the entire Access
Board proposal, visit:

http://www.access-board.gov/guidelines-and-standards/communications-and-
it/about-the-ict-refresh

The following briefly outlines the major components of the 508/255
refresh proposal:

Proposed 508 Standards

The proposed standards replace the current product-based approach with a
functionality-based approach. The proposed technical requirements, which
are organized along the lines of ICT functionality, provide standards to
ensure that covered hardware, software, electronic content, and support
documentation and services are accessible to people with disabilities.
In addition, the proposed standards include functional performance
criteria, which are outcome-based provisions for cases in which the
proposed technical requirements do not address one or more features of
ICT. The four major changes in the proposed 508 Standards are:

• Broad application of WCAG 2.0: The proposed rule would incorporate by
reference the Web Content Accessibility Guidelines (WCAG) 2.0, a
voluntary consensus standard developed by ICT industry representatives
and other experts. It would also make WCAG 2.0 Success Criteria
applicable not only to content on the “World Wide Web” (hereafter, Web),
but also to non-Web electronic documents and software (e.g., word
processing documents, portable document format files, and project
management software). By applying a single set of requirements to Web
sites, electronic documents, and software, this proposed provision would
adapt the 508 Standards to reflect the newer multifunction technologies
(e.g., smartphones that have telecommunications functions, video
cameras, and computer-like data processing capabilities) and address the
accessibility challenges that these technologies pose for individuals
with disabilities.

• Delineation of covered electronic “content”: The proposed rule would
also specify that all types of public facing content, as well as eight
enumerated categories of non-public facing content that communicate
agency official business, would have to be accessible, with “content”
encompassing all forms of electronic information and data. The existing
standards require federal agencies to make electronic information and
data accessible, but do not delineate clearly the scope of covered
information and data; as a result, document accessibility has been
inconsistent across federal *10882 agencies. By focusing on public
facing content and certain types of agency official communications that
are not public facing, the proposed rule would bring needed clarity to
the scope of electronic content covered by the 508 Standards and,
thereby, help federal agencies make electronic content accessible more
consistently.

• Expanded interoperability requirements: The existing standards require
ICT to be compatible with assistive technology—that is, hardware or
software that increases or maintains functional capabilities of
individuals with disabilities (e.g., screen magnifiers or refreshable
braille displays). But, because this requirement has given rise to
ambiguity in application, the proposed rule would provide more
specificity about how operating systems, software development toolkits,
and software applications should interact with assistive technology.
These proposed requirements would allow assistive technology users to
take full advantage of the functionalities that ICT products provide.

• Requirement for RTT functionality: The proposed standards would
require real-time text (RTT) functionality wherever an ICT product
provides real-time, two-way voice communication. RTT is defined in the
proposed rule as text that is transmitted character by character as it
is being typed. An RTT recipient can read a message while it is being
written, without waiting for the message to be completed; this is
different from other message technologies such as “short messaging
service”, or SMS, which transmit the entire message only after typing is
complete. This proposed requirement would have an impact on federal
agencies as well as ICT providers, federal employees, and members of the
public.

Proposed 255 Guidelines

Given the trend toward convergence of technologies and ICT networks, the
Access Board is updating the 255 Guidelines at the same time that it is
updating the 508 Standards. The existing guidelines include detailed
requirements for the accessibility, usability, and compatibility of
telecommunications equipment and customer premises equipment. For
example, the guidelines require input, output, display, control, and
mechanical functions to be accessible to individuals with disabilities.
The compatibility requirements focus on the need for standard
connectors, compatibility of controls with prosthetics, and TTY
compatibility. The guidelines define “usable” as providing access to
information about how to use a product, and direct that instructions,
product information, documentation, and technical support for users with
disabilities be functionally equivalent to that provided to individuals
without disabilities. The proposed guidelines include many
non-substantive revisions to the existing requirements for clarity along
with a few important new provisions. Two notable proposed additions to
the proposed 255 Guidelines are:

• Requirement for RTT functionality: Just as the proposed 508 Standards
would require federal agencies to offer RTT functionality in certain
ICT, the proposed 255 Guidelines would require the manufacturers of
telecommunications equipment to provide RTT functionality wherever a
telecommunications product provides real-time, two-way voice
communication. This proposed requirement would allow people who are deaf
or hard of hearing to have faster and more natural conversations than
the current text-messaging functionality.

• Application of WCAG 2.0 to electronic documents: The proposed 255
Guidelines would preserve the current requirement that when a document
is provided in a non-electronic format, alternate formats (such as
large-print or braille) usable by individuals with vision impairments
need to be provided. The proposed guidelines also would require
documentation in electronic formats—including Web-based self-service
support and electronic documents—to conform to all Level A and AA
Success Criteria in WCAG 2.0 or ISO 14289-1 (PDF/UA-1). This proposal
for accessible electronic support documentation is derived from the
existing guidelines, but would newly require compliance with WCAG 2.0 or
PDF/UA-1. This proposal is intended to address the problem that many
online product (or support) documents for telecommunications equipment
are inaccessible to individuals with visual impairments.

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-- 
Marianne Denning, TVI, MA
Teacher of students who are blind or visually impaired
(513) 607-6053