[blindlaw] FOIA, § 508, and blind representation

[Sai]

Hello all.

The NARA / OGIS FOIA advisory committee is currently discussing
agencies' obligations under Rehab Act § 508 and their intersection
with federal FOIA law.


The underlying problem is that agencies have a process for processing
documents, especially redacting, that takes an originally electronic
document like a Word file, PDF, spreadsheet, etc, and turns it into a
rasterized PDF. Some agencies will literally print a file and then
scan it.

Aside from some old documents that were actually made on typewriters
or the like, the accessibility problem is entirely of the agencies'
own making. It violates both the Rehab Act § 508 and FOIA (which
mandates that agencies provide documents in the format requested,
including originals).


A structural issue is that there are, AFAICT, zero people on the
committee with actual personal experience or expertise about the need
for accessible documents. It is a classic example of people deciding
things for an entire swath of disabled people without bothering to
have any representation from that group in the decision.


The October 25, 2016 meeting was about this.

Transcript of the full meeting:

<https://ogis.archives.gov/Assets/October+25+2016+Meeting+Transcript.pdf>

Video of part 2 only:

<https://www.youtube.com/watch?v=dCD93wCAg8A&index=15&list=PLugwVCjzrJsWX2o94WrDBxASNVEajHJ_L>


There are relevant comments by Alex Howard of Sunlight Foundation at p
115-120, time 1:13:50-1:20:30; and by Michael Ravnitzky at p 120-128,
time 1:20:30-1:31:10.

There are also comments at 1:12:30 by a member of the advisory
committee suggesting that agencies should push the burden of making
documents accessible onto the public and individual requesters.
Personally, I find that rather offensive — especially coming from
someone who's supposed to be on a working group about § 508 best
practices, since it displays a lack of even "disability law 101" level
understanding.


So… if any of you are located in DC, would you be interested in
participating in the OGIS meetings about FOIA and § 508 accessibility?

Would you be interested in collaborating on written comments defending
our right to information in accessible formats?

Sincerely,
Sai