Comments Collection
Link to original request
A. Accessibility standards to apply to Web sites of covered titles II and III entities
As previously mentioned, the Web Accessibility Initiative (WAI) of the World Wide Web Consortium (W3C®) has created recognized voluntary international guidelines for Web accessibility. These guidelines, set out in the Web Content Accessibility Guidelines (WCAG), detail how to make Web content accessible to individuals with disabilities. The most recent and updated version of the WCAG, the WCAG 2.0, was published in December 2008 and is available at http://www.w3.org/TR/WCAG20/ (last visited June 29, 2010). According to the WAI, the WCAG 2.0 “applies broadly to more advanced technologies; is easier to use and understand; and is more precisely testable with automated testing and human evaluation.”See WAI, Web Content Accessibility Guidelines (WCAG) Overview, available at http://www.w3.org/WAI/intro/wcag.php (last visited June 29, 2010).Show citation box
The WCAG 2.0 contains 12 guidelines addressing Web accessibility. Each guideline contains testable criteria for objectively determining if Web content satisfies the guideline. In order for a Web page to conform to the WCAG 2.0, the Web page must satisfy the criteria for all 12 guidelines under one of three conformance levels: A, AA, or AAA. The three levels of conformance indicate a measure of accessibility and feasibility. Level A, which is the minimum level of conformance for access, contains criteria that provide basic Web accessibility and that are the most feasible for Web content developers. Level AA, which is the intermediate level for access, contains enhanced criteria that provide more comprehensive Web accessibility and yet are still feasible for Web content developers. Level AAA, which is the maximum level of access, contains criteria that may be less feasible for Web content developers. In fact, WAI does not recommend that Level AAA conformance be required as a general policy for entire Web sites because it is not possible to satisfy all Level AAA criteria for some content. See W3C®, Understanding WCAG 2.0: Understanding Conformance (Dec. 2008), http://www.w3.org/TR/UNDERSTANDING-WCAG20/conformance.html (last visited June 29, 2010).Show citation box
Standards for Web site accessibility also exist for Federal government agencies, which are required to make their Web sites accessible under section 508 of the Rehabilitation Act of 1973, 29 U.S.C. 794(d) (section 508). Specifically, the Web sites of Federal government agencies must comply with the Electronic and Information Technology Accessibility Standards (section 508 standards) published by the U.S. Access Board, 36 CFR 1194, available at http://www.access-board.gov/sec508/standards.htm (last visited June 29, 2010). The Access Board is currently revising the section 508 standards, in part to harmonize the standards with model guidelines, such as the WCAG.Show citation box
Question 1. Should the Department adopt the WCAG 2.0's “Level AA Success Criteria” as its standard for Web site accessibility for entities covered by titles II and III of the ADA? Is there any reason why the Department should consider adopting another success criteria level of the WCAG 2.0? Please explain your answer.Show citation box
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Response Jon Gunderson: Satisfying WCAG 2.0 Level AA should be considered sufficient to satisfy ADA standards, but the actual standards should be tied to revisions to the Section 508 requirements.
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Response Robert Crisler: I support in general the concept of adopting the WCAG 2.0 AA criteria as the standard for web accessibility under the ADA, as a start. But the web, and the technologies that underlie it, continue to evolve. The federal government should do a couple of things: take the specific rulesets for accessibility out of the realm of law and into the realm of regulatory rulemaking. And review them frequently; annually. Harmonize Section 508 and whatever ruleset is designated as 'ADA.' For a lot of reasons, the standards must be identical, and there's no reason that they should not be. And they should -- they MUST -- continue to evolve. Let the W3C's WAI group take the lead in evolving them, and let a regulatory body meet once a year to review and adopt any relevant new criteria.
Consider using the influence of Educause to work with the W3C and WAI to support the creation and ratification of a single standard for accessibility under the auspices of the International Standards Organization.
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Response Greg Kraus: Adopting the newly proposed Section 508 standards would be a better solution. However, looking strictly at WCAG 2.0, Level AA conformance should be adequate. The newly proposed 508 standards have been harmonized with Level AA. Requiring Level AAA, which would be going significantly beyond the proposed 508 standards, is also not recommended as a general policy for entire sites. See http://www.w3.org/TR/WCAG20/ in the section Conformance: Conformance Requirements: Conformance Level: Note 2. “It is not recommended that Level AAA conformance be required as a general policy for entire sites because it is not possible to satisfy all Level AAA Success Criteria for some content.”
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Response IU's ATAC Web Accessibility Team:
In general, WCAG 2.0 Level AA seems sufficient, but we'd vote for including WCAG SC 2.4.9 (Level AAA). This is the only place that WCAG 2.0 says a link’s purpose must be identifiable from the link text alone. WCAG SC 2.4.4 (Level A) allows the link text itself to be non-unique if the description of the link is “in the same sentence, paragraph, list item, the heading immediately preceding the link, or table cell as the link, or in the table header cell for a link in a data table”. Requiring unique and meaningful link text helps users choose which links to follow without requiring complicated strategies to understand the page.
No WCAG 2.0 Level AA Success Criteria exists that covers link texts and requires the link purpose to be determined by the link text alone.
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Ohio State Univ Group Response: Concur with JG and add that criteria be emphasized which can be tested in a fully or mostly automated way.
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Response Mike Elledge: I'm really of two minds about this. First, since it appears that Section 508 compliance will be based on WCAG 2.0 Levels A and AA, it seems to make sense for ADA’s standards to be the same. That way there will be one standard in effect, reducing confusion and facilitating compliance. On the other hand, WCAG 2.0 Level A is more stringent than WCAG 1.0 Level A, which is MSU’s current requirement, and, to me, represents a reasonable floor for accessibility, and one that may be more achievable. If I were writing the rules, then, my preference would be for both Section 508 and the ADA standard to require Level A conformance, with a recommendation for AA. Otherwise I would argue for consistency with both standards requiring WCAG 2.0 Level AA for compliance. ----------------------------------------------------------------------------------------------------------------------------------
Question 2. Should the Department adopt the section 508 standards instead of the WCAG guidelines as its standard for Web site accessibility under titles II and III of the ADA? Is there a difference in compliance burdens and costs between the two standards? Please explain your answer.
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Response Jon Gunderson: As long as the revised Section 508 standards include requirements for marking up changes in language of web pages they should be used as the standards.It would be confusing to have one standard for the Federal Government and a slightly different Standard for businesses and organizations covered under the ADA
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Response Robert Crisler: We need a single federal standard for web accessibility. The current version of WCAG is superior to (and more current than) the current version of 508.
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Response Greg Kraus: The current Section 508 standards are inadequate to handle accessibility issues with modern web technologies. The newly proposed Section 508 standards do provide a good framework for handling accessibility issues. Using the new Section 508 standards are preferable to just WCAG 2.0 AA because it gives developers one standard to adhere to and if the final version of 508 has requirements or recommendations beyond WCAG 2.0 AA, it will cause confusion to web developers. The proposed 508 standards also harmonize with ISO 9241-171, which may contain requirements different than just conforming to WCAG 2.0 AA, so if the DOJ simply requires adherence to WCAG 2.0, two Federal standards will be created. [Does anyone have insight in differences between ISO 9241-171 and WCAG 2.0 and how it relates to the proposed 508 standards?]
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Ohio State Univ Group Response: The current plan of the Access Board is for 508 to align with WCAG AA. It seems as though WCAG AA is the emerging benchmark. It is also an international standard. ADA modeling itself on or adopting an international standard has advantages with regard to compliance of sites that serve international audiences or do business internationally.
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Response Mike Elledge: Yes, so long as Section 508 is based on WCAG 2.0 critera. I think it would minimize confusion if there were a single standard to be followed.
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Response Lisa Fiedor, NC State University: I would advocate that the Department should adopt the proposed update of the 508 Standards and the Telecommunications Act Guidelines (http://www.access-board.gov/508.htm), which have been brought into alignment with WCAG 2.0 Level AA conformance standards. Having two different mandated standards for Federal entities could cause confusion for Web developers, especially where any divergence would be.
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Question 3. How should the Department address the ongoing changes to WCAG and section 508 standards? Should covered entities be given the option to comply with the latest requirements?
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Response Jon Gunderson: The standards should track the Section 508 requirements, to keep Federal, and business and organizations covered under ADA in synchronized.
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Response Robert Crisler: Refer to response, Question 1. Regulatory rulemaking, not law, and annual updating to acknowledge new technology.
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Response Greg Kraus: If “latest requirements” means the current version of Section 508, then no. They are inadequate to deal with accessibility issues with modern web technologies. If “latest requirements” means freezing the requirement to the version of WCAG or 508 that is current when the DOJ makes it’s ruling, that is not preferable either, as it would take a new ruling to update the requirements. Entities should be required to adhere to the most recent final version of either Section 508 or WCAG 2, and preferably Section 508 (see response to question 2). A grace period could be built in to deal with adhering to new requirements.
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Ohio State Univ Group Response: Compliance with "latest standards" makes sense only if the latest standards achieve better accessibility than previous standards. These seems the trend, anyway--we are not seeing easing of standards, at least with respect to WCAG and (if it tracks WCAG) 508. It was pointed out by a respondent, also, that rarely would any older, primarily static, "Web 1.0" site that was fully compliant be suddenly out of compliance when changes to standards are introduced, and, should some remediation be necessary, it is doubtful that that would be very costly, given the relative simplicity of making a Web 1.0 site accessible.
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Mike Elledge Response: Yes, so long as Section 508 is based on WCAG 2.0 critera. I think it would minimize confusion if there were a single standard to be followed.
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Response Lisa Fiedor, NC State University: No, there should not be option to comply, but a requirement to comply with the latest 508 standards--with the expectation that the proposed 508 update and alignment with WCAG 2.0 will be adopted. The Access Board already has a process for reevaluating the 508 standards, but it would be important to declare a regular time period for refreshing these standards. ----------------------------------------------------------------------------------------------------------------------------------
Question 4. Given the ever-changing nature of many Web sites, should the Department adopt performance standards instead of any set of specific technical standards for Web site accessibility? Please explain your support for or opposition to this option. If you support performance standards, please provide specific information on how such performance standards should be framed.
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Response Jon Gunderson
Both the WCAG 2.0 and proposed Section 508 revision for the most part are more functional requirement standards and are designed to the most part be technology neutral and able to be applied to existing and new technologies. The major problem comes when new technologies are developed that do not have the features and the capabilities to meet the accessibility requirements.
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Response Robert Crisler: No. Perhaps as guiding principles, but we need specific criteria to test against. Machine tests can handle many accessibility criteria; then human testing comes in. Performance standards alone are too vague to be implementable in any efficient accessibility compliance process.
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Response Greg Kraus: The current version of WCAG 2.0 and the proposed Section 508 standards are more functional in description, and thus abstracted from particular technological solutions. This is preferable since it allows more applicability to a wider range of technologies.
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Response IU's ATAC Web Accessibility Team:
If a set of specific technical standards were chosen, then a process for frequent revision of the technical standards would be required, or there is the risk that some standards would become irrelevant with time and not serve to best promote accessibility.
On the other hand, the WCAG 2.0 Guidelines and Success Criteria are written in a technology neutral fashion that makes constant vigilance for updates less necessary. Each Success Criteria given for Guidelines in WCAG 2.0 include a list of techniques, or combinations of techniques, to be used to meet each Success Criterion. In many cases, multiple sufficient techniques are available to choose from. As new techniques are identified that meet a given Success Criterion, they are added to the listing. This approach of adding new techniques as technology evolves allows the existing WCAG 2.0 Success Criteria to maintain its relevancy.
The proposed revisions to Section 508 provide for adaptation to new technologies as well:
It states in E107 that web pages that conform to level AA of WCAG 2.0 will be considered to meet all of the rules in Chapters 4, 5, and 6 except for some extra requirements covering user preferences, authoring tools, and multi-media. This appears to mean that techniques listed as sufficient for SC in WCAG 2.0 apply for the proposed revisions to Section 508 as well.
In E106 the proposed revisions provide for “Equivalent Facilitation” where technologies that provide for equivalent or greater access can be used instead of the rules.
It goes further in E103.5.2 to state that if the proposed rules do not fully cover a product’s features, that a broader functional performance criteria can be used (supplied in Chapter 2) to evaluate compliance.
Language that is inclusive of the WCAG 2.0’s techniques for meeting the Guidelines/Success Criteria and of the proposed revision to Section 508’s Equivalent Facilitation and Functional Performance Criteria would give the ADA’s update lasting relevancy.
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Ohio State Univ Group Response: Concur with JG and add that standards be chosen with an eye toward automate-able testability wherever possible, in order to better be able to quickly and accurately determine compliance.
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Response Mike Elledge: Adopting Section 508 standards should be sufficient, since the WCAG 2.0 requirements are based on performance.
B. Coverage limitations
It is the Department's intention to regulate only governmental entities and public accommodations covered by the ADA that provide goods, services, programs, or activities to the public via Web sites on the Internet. Although some litigants have asserted that “the Internet” itself should be considered a place of public accommodation, the Department does not address this issue here. The Department believes that title III reaches the Web sites of entities that provide goods or services that fall within the 12 categories of “public accommodations,” as defined by the statute and regulations. Because the Department is focused on the goods and services of public accommodations that operate exclusively or through some type of presence on the Web—whether hosting their own Web site or participating in a host's Web site—the Department wishes to make clear the limited scope of its regulations. For example, the Department is considering proposing explicit regulatory language that makes clear that Web content created or posted by Web site users for personal, noncommercial use is not covered, even if that content is posted on the Web site of a public accommodation or a public entity. This would include individual participation in popular online communities, forums, or networks in which people upload personal videos or photos or engage in exchanges with other users. The Department could also make clear that public accommodations and public entities are not liable for inaccessible content posted to their sites by individuals not under their control as long as they provide their Web site users the ability to make their posts accessible.Show citation box
In addition, the Department does not intend to propose regulatory text that reaches the informal or occasional trading, selling, or bartering of goods or services by private individuals in the context of an online marketplace. The Department could distinguish such occasional trading activity by individuals acting in a private capacity from legally established business entities, ranging from sole proprietorships to limited liability companies and corporations. As long as these business entities offer the goods or services of a public accommodation online, they would be responsible for making such offerings accessible to individuals with disabilities. Lastly, a public accommodation or public entity would not be required to ensure the accessibility of Web sites that are linked to its site, but that it does not operate or control. However, to the extent an entity requires users of its Web site to utilize another Web site in order to take part in its goods and services (e.g., payment for items on one Web site must be processed through another Web site), the entity may be liable for the accessibility of other sites it requires its patrons to use even if it does not operate or control the site.Show citation box
Question 5. The Department seeks specific feedback on the limitations for coverage that it is considering. Should the Department adopt any specific parameters regarding its proposed coverage limitations? How should the Department distinguish, in the context of an online marketplace, between informal or occasional trading, selling, or bartering of goods or services by private individuals and activities that are formal and more than occasional? Are there other areas or matters regarding which the Department should consider adopting additional coverage limitations? Please provide as much detail as possible in your response.
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Response Jon Gunderson
Any exemptions should be based on how the website is used and resources needed to maintain and develop the website. Facebook maybe considered a system for personal expression and at face value could be considered a potential exemption, but many Facebook pages are designed to communicate and share information for a educational or public service. So even though Facebook accounts are free and are considered pages for personal expression and exchange of information they are often used for both education and commercial purposes.
Possible Exemption Criteria:
Small businesses with online sales below a certain amount of gross revenue
Non profit organization websites with gross revenues below a certain amount
Personal websites maintained by individuals or families for non-commercial purposes
Social clubs with membership below a certain number of people that have a website to promote club ideas and values
Response Robert Crisler: There might be certain thresholds of activity under which enforcement could be relaxed. There is the list of inclusions (and exclusions) under the ADA, and one could imagine a similar list. There would need to be much discussion.
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Ohio State Univ Group Response: Concur with JG, esp. exemption criteria. Add that size and composition of known audience be taken as a factor in all exemption criteria.
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Response Mike Elledge: DOJ should provide a carve-out for personal websites and websites of businesses with fewer than 15 employees (reflecting other small-business exemptions).
C. Compliance Issues
Question 6. What resources and services are available to public accommodations and public entities to make their Web sites accessible? What is the ability of covered entities to make their Web sites accessible with in-house staff? What technical assistance should the Department make available to public entities and public accommodations to assist them with complying with this rule?
Response JG: There a number of resources that the Department could support to improve implementation. One of the biggest issues is that technology is constantly evolving. Assistive Technology, browser technology and web design. So there are always new and better techniques to improve accessibility of a website and on the other hand new ways to make a web site accessibility.
Response Robert Crisler: One rationalized set of federal standards, preferably wholly in-step with international standards, updated to stay in step with evolving technology, will allow software developers to provide better tools to meet those standards. Web developers must achieve higher levels of knowledge and ability and be accorded professional standing. Direct technical assistance is not something I would support the federal government having a role in.
Response Lisa Fiedor, NC State University: If entities are creating their web content and managing their websites internally, then it would be expected that their Web developers, with education, be able to create accessible Web pages, They should be expected to know, or be taught about, properly coding HTML pages according to Web standards, especially Section 508 and WCAG 2.0. If contracting with an external Web development service, then the requirement for accessibility, needs to be made up front in the contract. The Department could provide a resource list or online training in making Web pages accessible.
Ohio State Univ Group Response: While it’s true that excellent web access requires some forethought and planning, it is not true that it requires special degrees or a decade of experience in web page creation. Even relatively small organizations could likely find expertise in-house sufficient to produce accessible pages. In a manner similar to its compilation of information relative to the Americans with Disabilities Act, the department could compile links to third-party guidelines, tutorials, and other training information that would enhance compliance and make it easier to do. The proliferation of online conferencing tools means the department could provide seminars and other online educational tools at a relatively low cost.
Response Mike Elledge: There are many free and/or open source print and online tools and resources available to public accommodations and public entities to make their sites accessible, including those provided by the W3C, WebAIM, Mozilla/FireFox, NVDA, SAToGo, etc. DOJ could make a list available on a resource site, without having to repurpose that content themselves.
Question 7. Are there distinct or specialized features used on Web sites that render compliance with accessibility requirements difficult or impossible?
Response JG: There will be certain types of specialized websites that would be difficult or impossible for people with certain types of disabilities to use.
For example some scientific data visualizations or geographical maps that are highly visual may be difficult to make accessible to people with visual impairments and blindness.
But could still be made more accessible to people with physical disabilities.
The Department has taken the position that covered entities with inaccessible Web sites may comply with the ADA's requirement for access by providing an accessible alternative, such as a staffed telephone line, for individuals to access the information, goods, and services of their Web site. See Accessibility of State and Local Government Web sites to People with Disabilities, available at http://www.ada.gov/Web sites2.htm. In order for an entity to meet its legal obligation under the ADA, an entity's alternative must provide an equal degree of access in terms of hours of operations and range of information, options, and services available. For example, a department store that has an inaccessible Web site that allows customers to access their credit accounts 24 hours a day, 7 days a week in order to review their statements and make payments would need to provide access to the same information and provide the same payment options in its accessible alternative.Show citation box
Response Robert Crisler: Yes, there are. But that's really a question more about choices of technologies -- there are more than enough technologies that allow accessible websites -- than about difficulty.
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Response IU's ATAC Web Accessibility Team:
The cost and time required to generate accurate synchronized captions, audio descriptions, etc. for video content or transcripts for podcasts on sites dependent on presenting large volumes of content through video or audio can be prohibitive if required for every instance. The same applies for production of alternative media such as tactile diagrams of complex charts and diagrams, Braille encoding of music scores, math, or chemical equations where a simple alternate text description does not suffice. A provision to meet such requirements on an as-requested/on-demand basis should be made for cases where requiring alternate media generation for all such instances would create an undue burden. An example of this might be a school that wishes to make video podcasts of every lecture available to students.
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Ohio State Univ Group Response: Certain specialized features of web sites can be inaccessible to people with certain sorts of disability. However, standards and regulations should insist that thought, planning, and, when appropriate, effort be put into providing acceptable alternative means of access in those cases, to the degree that such efforts can be verified to be worthwhile for users and achieve some level of equivalence (with regard to performance of functionality or acquisition of pertinent information).
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Response Mike Elledge: In most cases website content and functionality can be made accessible, or alternative features or content can be presented. Captioning can be time-consuming and expensive.
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Response Lisa Fiedor, NC State University: It can be expected that there will always be new, emerging, and/or specialized technologies that inhibit Web accessibility, and creative solutions should be encouraged. It would behoove the Department to mandate that the Standards adopted be updated at some regular interval to catch up with the changing technologies.
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Question 8. Given that most Web sites today provide significant amounts of services and information in a dynamic, evolving setting that would be difficult, if not impossible, to replicate through alternative, accessible means, to what extent can accessible alternatives still be provided? Might viable accessible alternatives still exist for simple, non-dynamic Web sites?Show citation box
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Response IU's ATAC Web Accessibility Team:
We would argue that the premise of this question, that it is difficult or impossible to provide dynamic services or content accessibly, is incorrect. Inaccessibility in such settings demonstrates a lack of consideration of accessibility personas in the design stage. Accessibility needs to be considered in the very beginning design stages. It should not wait to appear until the final QA stages where it is too late to make significant changes to the design. When accessibility issues are considered in the personas used in design, creative designers can easily provide dynamic content and services in an accessible manor.
Software that attempts to automatically generate a one-size-fits-all “text only” or other similar accessible alternative cannot provide more access to a site than a well-designed, user selected adaptive technology (like a screen-reader) that is configured to meet the specific needs of its user. Automatically generated accessible alternatives frequently do not provide an equal experience. For example, if a site contains an exercise like a quiz, the accessible alternative most likely will not provide the original site’s interactivity from which a student gets feedback and skills/knowledge reinforcement. Manually generated accessible alternatives frequently are forgotten/ignored and therefore are often not up-to-date. Giving content providers the option of providing a non-dynamic accessible alternative will be doing the disabled community a disservice.
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Response Robert Crisler: "Viable accessible alternatives" brings to mind another once-legal construct: "Separate but equal." That was a bad idea in another legal realm. I don't think it's a good idea here.
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Ohio State Univ Group Response: As a general rule, we should work toward dynamic, "rich" sites and web applications that are accessible, rather than providing alternatives, however, successful, fully up-to-date and maintained alternatives do exist. A good example of this is Amazon's mobile site, which is preferred by many screen reader users, due to its limiting of extraneous information and its clear organization. It may be the case that some of this question will be easier to address as more of the web accommodates itself to the paradigms that arise in mobile development. In all cases, it is imperative that an alternative site/interface be have access to functionality and contain data that is fully equivalent to the "main" site/interface.
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Response Mike Elledge: In most cases website content and functionality can be made accessible, or alternative features or content can be presented. Captioning can be time-consuming and expensive.
In general accessible alternatives have not been very effective in providing access to the web by people with disabilities. Alternative websites are usually considered a poor cousin of the primary website and is often out of date and lacks the information on the primary website. New technologies like the W3C Accessible Rich Internet Application Accessibility specification and HTML5 accessibility features should make it unnecessary to have accessible alternatives.
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Response Lisa Fiedor, NC State University: With ARIA, Web developers should be able to make much dynamic content and many interactions accessible.
According to the WAI-ARIA website (http://www.w3.org/WAI/intro/aria):
"The Accessible Rich Internet Applications Suite, defines a way to make Web content and Web applications more accessible to people with disabilities. It especially helps with dynamic content and advanced user interface controls developed with Ajax, HTML, JavaScript, and related technologies. Currently certain functionality used in Web sites is not available to some users with disabilities, especially people who rely on screen readers and people who cannot use a mouse. WAI-ARIA addresses these accessibility challenges, for example, by defining new ways for functionality to be provided to assistive technology. With WAI-ARIA, developers can make advanced Web applications accessible and usable to people with disabilities."
The Department should draw awareness to these techniques, and encourage their use.
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D. Effective Date
Following the publication of a final rule, the Department must set an effective date for the application of any new title II or title III regulations requiring the Web sites of entities covered by the ADA to be accessible. When the ADA was enacted, the effective dates for various provisions were delayed in order to provide time for covered entities to become familiar with their new obligations. Under the 1991 regulations, new construction under title II and alterations under either title II or title III had to comply with the design standards of the Department's new regulations by January 26, 1992, six months after the regulations were published. See 28 CFR 35.151(a)-(b); 28 CFR 36.402(a). For new construction under title III, the ADA requirements applied to facilities of public accommodations designed and constructed for first occupancy after January 26, 1993—-eighteen months after the ADA Standards were published by the Department. See 28 CFR 36.401(a).Show citation box
The Department is considering an effective date of six months after the publication of the final rule for newly created Web sites or pages, i.e., those that have been placed online for the first time six months after the publication of the final rule. Under such a proposal, newly created or completely redesigned Web sites will have to come into total compliance with any Web access requirements adopted by the Department. New pages on existing Web sites would need to comply with the Web access requirements to the maximum extent feasible. The Department is considering this provision for new pages on existing Web sites because the Department recognizes that certain features on existing Web sites—such as navigation components or use of integrated Web technology with limited capacity for accessibility—cannot be completely altered or replaced without a complete redesign of the entire site. For this reason, the Department is considering requiring new pages on existing Web sites to comply with the accessibility requirements to the maximum extent feasible. The Department recognizes, however, that in some cases this may result in incomplete accessibility of new pages. For existing Web sites or pages, the Department is considering having the Web site access requirement apply two years after the date of publication of the final rule. The Department is considering this period of time for existing Web sites because it recognizes that many Web sites have hundreds (and some thousands) of pages that will need to be made accessible.Show citation box
Question 9. The Department seeks comment on the proposed time frames for compliance. Are the proposed effective dates for the regulations reasonable or should the Department adopt shorter or longer periods for compliance? Please provide as much detail as possible in support of your view.Show citation box
Response Robert Crisler: Two years sounds reasonable, as long as decisionmakers are made well aware of the issue and the gravity with which the DoJ views it. Many web developers have been leaders in issues of accessibility for many years now. But web developers, even ones who have been leaders in accessible web development, have not in most cases been successful in making web accessibility a priority for large institutions or enterprises. DoJ will need to communicate in clear and certain terms to key decisionmakers in order to create the momentum to make sites compliant under an aggressive schedule.
Response Dean Brusnighan/David Schwarte: With "maximum extent feasible" in place for newly created Web sites or pages, 6 months is appropriate. Our belief is that a 12- or 18-month effective date will not improve compliance with additional time, but will only delay implementation of required accessibility improvements. Human nature is strong to procrastinate. For existing Web sites or pages, the proposed two years would be acceptable. An approach implemented at Purdue University could also be used in this situation. Our web accessibility policy requires 25% of existing pages (in order of most visited) to be made accessible each year for four years. Campus web developers advised us that existing pages would need to be updated anyway within that 4-year period, and accessibility changes could be incorporated with the update.
Ohio State Univ Group Response: Although some web sites are voluminous in nature and include a variety of features that could be somewhat time consuming to make accessible, a two-year compliance period seems excessively long. Even assuming the existence of a learning curve for those tasked with altering existing sites to enhance their accessibility, it seems that an 18-month period of compliance should be enough. Indeed, the department could even create a two-tiered system in which compliance for sites with a specific number of pages or higher could be done in 18 months; those with fewer than the specific number listed in the regulation should be expected to comply within a 12-month period. The Department should also consider a rubric for priortization of compliance--high-traffic/impact takes the shorter calendar, etc.
Response Mike Elledge: I would lengthen the time from six months to twelve months for new or substantially revised sites to become compliant. This would enable developers and designers of websites and adaptive technology additional time to create accessible alternatives to interactive (aka “Web 2.0”) features, perhaps including persons with disabilities in the design and development process.
Question 10. The Department seeks comment regarding whether such a requirement would cause some businesses to remove older material rather than change the content into an accessible format. Should the Department adopt a safe harbor for such content so long as it is not updated or modified?Show citation box
Response Robert Crisler: Any safe harbor provision should only apply to old, lightly-trafficked material.
Response Dean Brusnighan/David Schwarte: There is no clear best alternative, in our opinion. Providing a safe harbor has both advantages and liabilities. It is an obvious benefit for individuals who are seeking the information for it to remain available rather than be removed. At the same time, providing a safe harbor creates a disincentive for the information to be updated by the page owner; likely, many will choose not to update older material so as to avoid making accessibility changes. In some situations, old information is unusable.
Ohio State Univ Group Response: Allowing for older material to remain inaccessible simply because it remains unmodified or is not updated seems inappropriate and seems to be antithetical to the existence of the web itself. Sites die and are visited far less frequently when they are not updated. Giving organizations a pass by simply allowing them to not update their pages could inadvertently create an unfortunate escape clause that would render pages useless to an ever-growing group of visitors until the business is left with no choice but to update it. Alternatively/additionally, the Department might consider requiring a "remediate on demand" clause: Require a "report accessibility issues" button that sets into motion timely remediation. If safe harbor is implemented, it should be granted only upon evidence that traffic to the resource is very low or limited to a known constituency that would not be affected by poor accessibility.
Response Mike Elledge: Yes, ADA website accessibility requirements should not be retroactive, since websites typically are revised every 3-4 years. Existing requirements under Title II and III, however, that require educational institutions to accommodate the needs of persons with disabilities should remain in effect and not be subordinate to this rule.
Question 11. Should the Department take an incremental approach in adopting accessibility regulations applicable to Web sites and adopt a different effective date for covered entities based on certain criteria? For instance, should the Department's regulation initially apply to entities of a certain size (e.g., entities with 15 or more employees or earning a certain amount of revenue) or certain categories of entities (e.g., retail Web sites)? Please provide as much detail and information as possible in support of your view.Show citation box
Response Robert Crisler: Yes, this might make sense, although larger entities will in most cases have more work to do, as their sites tend to be larger as well.
Response Dean Brusnighan/David Schwarte: We do not support an incremental approach. If only some entities are covered initially, then the focus and energy of a company or entity could be placed on finding ways to declare itself not covered so as to avoid making accessibility changes. If every company or entity is covered at the same time, then it is more likely that their focus and energy will be on learning accessible Web design techniques. For example, if the policy used number of employees as the basis for an incremental approach—large companies could argue that this division or that unit is independent, so falls below the criteria set for coverage by the policy.
Ohio State Group Univ Response: The department should consider careful incremental implementation. It could reasonably and appropriately prioritize regulation compliance based on a variety of things, including the mission of the site. Those organizations which provide essential services such as banking, public utility bill payments and other financial services transactions should be expected to comply early on. This could also include organizations of a specific size or purpose such as a retailer, an insurer, and even a private health care organization. It makes sense to incrementally implement the regulation in terms of deadlines for compliance. A one-person technical writing small business should probably not be expected to comply on the same date as a large bank with offices in multiple states.
Response Mike Elledge: DOJ should provide a carve-out for personal websites and websites of businesses with fewer than 15 employees (reflecting other small-business exemptions). Beyond that, I do not see a need to adjust requirements.
Response by Hadi Rangin: It is unrealistic to require all private entity of public accommodation to comply with the accessibility standards in one step. The adaptation of regulation should be prioritized and implemented in multiple steps based on importance of the services and how much they affect the lives of people with disabilities. It is very difficult to measure the severity of such services on the lives of people with disabilities and prioritize them because every person with disabilities lives in a unique environment and depending on their needs and interests they use different services at different frequencies. For example, a married person with children will be more interested in the related public services in elementary schools, museums, and retail stores whereas a young students might be interested in related services in bars, gold courses, and transportations. It is also important if the related service is the only option in the area where people with disabilities live. Consider you live in a small village with only one small grocery store that provides online coupons and online shopping/home delivery. While this service is very essential for people with disabilities in that village, it might not be very essential for people with disabilities living in a big city with access to multiple grocery stores. So it doesn't matter how the prioritization is defined at the end of the road someone will be unhappy.
Here's my suggestion:
Every new public entity must be accessible from the beginning.
For already established entities, if an entity is the only public providers (defined in the ADA 12 public service categories) in a village/town/city/country, they need to comply with the regulation within one year.
3. In the case of multiple providers within specified region, larger entities (entities with more than 10 employees) must comply within a year and the smaller entities within 2 years.
4. The public services in the category 7, 10, and 11 must comply within a year regardless they are the only one in the region or not.
ADA public service categories:
An inn, hotel, motel, or other place of lodging, except for an establishment located within a building that contains not more than five rooms for rent or hire and that is actually occupied by the proprietor of the establishment as the residence of the proprietor;
A restaurant, bar, or other establishment serving food or drink;
A motion picture house, theater, concert hall, stadium, or other place of exhibition or entertainment;
An auditorium, convention center, lecture hall, or other place of public gathering;
A bakery, grocery store, clothing store, hardware store, shopping center, or other sales or rental establishment;
A laundromat, dry-cleaner, bank, barber shop, beauty shop, travel service, shoe repair service, funeral parlor, gas station, office of an accountant or lawyer, pharmacy, insurance office, professional office of a health care provider, hospital, or other service establishment;
A terminal, depot, or other station used for specified public transportation;
A museum, library, gallery, or other place of public display or collection;
A park, zoo, amusement park, or other place of recreation;
A nursery, elementary, secondary, undergraduate, or postgraduate private school, or other place of education;
A day care center, senior citizen center, homeless shelter, food bank, adoption agency, or other social service center establishment; and
A gymnasium, health spa, bowling alley, golf course, or other place of exercise or recreation.
E. Cost and Benefits of Web Site Regulations
Executive Order 12866 requires Federal agencies to submit “significant regulatory action” to the Office of Management and Budget's (OMB) Office of Information and Regulatory Affairs (OIRA) for review and approval prior to publication in the Federal Register. See E.O. 12866, 58 FR 51735 (Sept. 30, 1993), as amended; OMB Budget Circular A 4, http://www.whitehouse.gov/OMB/circulars/a004/a-4.pdf (Sept. 17, 2003) (last visited June 29, 2010). A proposed regulatory action is deemed to be “economically significant” under section 3(f)(1) of Executive Order 12866 if it has an annual effect on the economy of $100 million or more. Id. Regulatory actions that are deemed to be economically significant must include a formal regulatory analysis--a report analyzing the economic costs and benefits of the regulatory action. A formal cost-benefit analysis must include both qualitative and quantitative measurements of the benefits and costs of the proposed rule as well as a discussion of each potentially effective and reasonably feasible alternative. Since this is an ANPRM, the Department is not required to conduct certain economic analyses or written assessments that otherwise may be required for other more formal types of agency regulatory actions (e.g., notices of proposed rulemaking or final rules). If any proposed rule the Department issues regarding Web access is likely to have an economically significant impact on the economy, the Department will prepare a formal regulatory analysis.Show citation box
Question 13. What are the annual costs generally associated with creating, maintaining, operating, and updating a Web site? What additional costs are associated with creating and maintaining an accessible Web site? Please include estimates of specific compliance and maintenance costs (software, hardware, contracting, employee time, etc.). What, if any, unquantifiable costs can be anticipated from amendments to the ADA regulations regarding Web site access?Show citation box
Response Robert Crisler: There are so many factors in this question that it's essentially unanswerable. But I would say this: the cost difference between an inaccessible website and an accessible one is largely the difference between having the site production in the hands of professional web developers for whom accessibility is simply part of the job, or in the hands of well-intentioned people for whom web development is peripheral to their 'main' job, or even under the heading 'other duties as assigned.' Accessible web development is professional web development, period. It is much more expensive to 'correct' websites for accessibility than to implement accessibility along with the other features of the site from the very beginning.
Response Tommy Brassfield: The efforts to improve the accessibility of unsatisfactory web sites should focus primarily on one-time costs beyond normal maintenance costs. Secondarily, the continued investment necessary for the professional development of current staff should also be accounted for. After those considerations are met, ensuring that an institution’s web sites remain accessible should be simple and cost effective. In many instances, informal and inappropriate training of web developers has led to significant accessibility issues. If web accessibility is considered from the beginning of the creation process, rather than as an after thought, web sites will have much higher success rates in the automated testing systems as well as in production use by users who rely on alternative viewing practices.
Exact numbers depend entirely upon the site’s information architecture, the site’s size, the site’s maintenance schedule, current employees, and other factors that may or may not be easily calculated. The larger an institution’s audience, the higher the cost for maintenance; however, the resources for maintaining the site and the potential impact are also generally greater. Upon initial accessibility compliance and assuming proper training, the cost should only include employee time, not to be in excess of that which was provided before the site was made accessible. Employees will need a professional development budget to ensure that they are keeping up with new standards and the constantly evolving testing protocols.
In the long run, the changes to ADA regarding web accessibility will impact future generations of web programmers and managers. Currently, too many web practitioners use skills that they developed from inconsistent standards and training. If a developer has no idea what web accessibility is, how can he or she know how to create websites that are accessible? Even worse, if a web developer has no formal training and relies solely on their own knowledge, he or she may not even know how to properly code, meaning he or she is not fit for the position. After all, standards of practice apply to a vast number of trades; for example, someone seeking to become an electrician would need training from a licensed electrician to ensure that he or she would learn the appropriate procedures. In the future, if institutions and businesses were to require a certain level of training in the applicable field of web site development, then training at all levels will be standardized to meet a variety of requirements, including accessibility. Once accessibility is a goal from the beginning of the process (and hopefully, eventually, an assumed one), implementation will not be an extra cost.
Ohio State Univ Group Response: Costs are dependent on number of pages, variety of templates for pages, and complexity of individual pages/forms/applications. A large site that uses a uniform template for pages and has defined patterns for content may have very low costs; whereas, a small site that is highly dynamic and has a lot of diversity of pages or extensively uses multimedia could incur high costs. If accessibility is a factor in the concept and implementation of the site from the beginning and criteria are established for adding content to the site after it reaches production, costs will be nominal. If the Department decides to recommend best practices (rather than just establishing requirements) then it might be emphasized that growing accessibility knowledge internally among designers, developers, and content providers will minimize long term costs that might be incurred regularly by companies having to go to external accessibility consultants. In all cases, it will be less expensive to foster accessibility knowledge widely internally than it will be to have to rely on external consulting. Organizations would benefit from spidering/crawling software packages that include the ability to monitor and report on the health of their web sites, including accessibility. Though some of these packages are very expensive, others can be purchased for $200 or less (e.g., SortSite). We know of one free spidering, accessibility-only checker (Functional Accessibility Evaluator). There are a number of free tools that will do a very good job checking individual pages (e.g., Deque FireEyes, WAVE Toolbar).
Response Mike Elledge: Costs will vary according to the complexity of the site, and the skill and knowledge of developers and designers with respect to accessibility. Including accessibility in the design and development process is significantly less expensive than retrofitting a website. Although I am not aware of an existing standard, an additional 10 to 15 percent cost in time would not be unreasonable.
Question 14. What are the benefits that can be anticipated from action by the Department to amend the ADA regulations to address Web site accessibility? Please include anticipated benefits for individuals with disabilities, businesses, and other affected parties, including benefits that cannot be fully monetized or otherwise quantified.Show citation box
Response Robert Crisler: Persons with disabilities gain the full measure of the enormous benefit to knowledge, society and commerce embodied in the Internet. Enterprises and institutions gain from the collective intelligence and perspective of these currently-underserved populations. The plain intent of the ADA, that public accommodations must be open to persons with disabilities, is in itself a reflection of the country's best vision of itself embodied in the Declaration of Independence: "We hold these truths to be self-evident, that all men are created equal, that they are endowed by their Creator with certain unalienable Rights, that among these are Life, Liberty and the pursuit of Happiness." Where some may argue that "equality of access" may not be an inalienable right, it is hard to argue that without equality of access, the inalienable rights that Jefferson listed in the Declaration -- each of them -- are diminished.
Response Tommy Brassfield:If a user cannot reach the information he needs because it was not written in a way his viewing device can understand it, it will either limit his ability to carry out his intended action or divert him from his original goal. Knowledge should be easily accessible by all, and the right to pursue it should be protected by the federal government just as physical access is currently protected by the ADA.
Universal access should be something both our government and its people should rejoice in and businesses should value. Just as easy as it is for someone to point and click into your site, it is just as easy for them to click “Back” and navigate away and to your competition. Jacob Nielsen states in his book Designing Web Usability, “The Web is the ultimate customer-empowering environment. He or she who clicks the mouse gets to decide everything. It is so easy to go elsewhere; all the competitors in the world are but a mouse click away”. The opportunity to find a larger customer base is something few would shy away from, and many institutions may not understand the importance and benefits of equal access.
Response Mike Elledge: Greater access to online communication and commerce for persons with disabilities, in keeping with the objectives of greater physical access as defined in the current ADA regulations.
Question 15. What, if any, are the likely or potential unintended consequences (positive or negative) of Web site accessibility requirements? For example, would the costs of a requirement to provide captioning to videos cause covered entities to provide fewer videos on their Web sites?Show citation box
Response Robert Crisler: A requirement to provide captioning on videos will cause enterprising developers of video-authoring applications to invest in speech-to-text technologies to deliver first-draft captions into an editing workflow alongside the video. Short-term, yes, it may cause displacement of some online video while technologies are brought to bear on the problem. But much of the captioning problem is solvable with new applications of existing technology.
Ohio State Univ Group Response: While the example of the cost of captioning and/or providing audio description for videos or transcription of audio is real, it is one of the few areas of accessibility where there is additional cost (and even these examples will lose pertinence as technologies improve and free or low cost tools proliferate). Overall, the benefits of creating accessible web sites are far reaching. For one, in general, accessible sites are better optimized to be discovered and accurately indexed by search engines. Also, the more accessible a site is, the more likely it will be of use to a larger number of devices running on a larger number of platforms. And the human resources benefits are great. As the population of the nation ages and changes, creating accessible sites will ensure that more individuals will be able to remain productive for longer periods of time. The availability of accessible sites can enhance the job market for individuals with disabilities and even those Americans who are traditionally under served in rural areas where transportation to a job site is difficult if not impossible. Also, as the world becomes increasingly connected and as geographic borders shrink, those with language difficulties and those dealing with literacy issues could benefit hugely from accessible sites. To have a site’s information spoken aloud, for example, could bring that information to a large cadre of Americans who have been locked out of such places up to now for reasons that can include literacy, reading disabilities, and even linguistic barriers.
Mike Elledge Response: I believe the new regulations will accelerate innovation, since the competitive nature of the market will continue to put pressure on institutions and individuals to provide compelling, yet accessible, online experiences. @font-face { font-family: "Times";}@font-face { font-family: "Cambria";}p.MsoNormal, li.MsoNormal, div.MsoNormal { margin: 0in 0in 10pt; font-size: 12pt; font-family: "Times New Roman"; }p { margin: 0in 0in 0.0001pt; font-size: 10pt; font-family: "Times New Roman"; }div.Section1 { page: Section1; }
Response Lisa Fiedor, NC State University: Another positive consequence of making one's site accessible is the benefit it brings to those with mobile devices. Much of what you do for Web accessibility and Universal Design enables easier and more reliable access for those using mobile devices to browse the Web.
Question 16. Are there any other effective and reasonably feasible alternatives to making the Web sites of public accommodations accessible that the Department should consider? If so, please provide as much detail about these alternatives, including information regarding their costs and effectiveness in your answer.Show citation box
Response Robert Crisler: I would say that there aren't any alternatives that provide the same level of access, regardless of location or hour, that Internet technologies can deliver to non-disabled populations. And without that flexibility of access through time and space, access cannot be equal.
Response Tommy Brassfield: (was looking at both 15/16 for this response) Some types of information are extremely difficult to convey in methods accessible by those who require alternative web rendering devices. Geographical information, such as maps, falls into this category. Making these fully accessible to users may limit the information received by a normal user. Consequently, the use of alternatives could still be unfortunately necessary, especially for those of who cannot afford the fullest level of implementation, but still want to be friendly to those with disabilities who require alternative web formatting.
The introduction of a new mandate will undoubtedly motivate and inspire many entrepreneurial and creative minds, leading to a renaissance of new solutions. Presently, it may be hard for a company to find a mapping program they can embed into their site that will be accessible straight out of the box, but the opportunity to create a superior product will entice entrepreneurs and contractors, increase competition, and eventually demand a very high standard of effectiveness.
Response Mike Elledge: No. This is an instance where the free market will not address the needs of a minority of the population in a timely, orderly or efficient way without a government mandate.
Response Hadi Rangin: During the transition to full compliance all the available services, discounts, or coupons should be provided via telephone/TTY at no charge to potential customers. Accessing the services via the phone should be as easily as accessing those services online. Customer service should be easily reachable within a reasonable time if accessing potential services can't be automated.
F. Impact on Small Entities
Consistent with the Regulatory Flexibility Act of 1980 and Executive Order 13272, the Department must consider the impacts of any proposed rule on small entities, including small businesses, small nonprofit organizations, and small governmental jurisdictions. See 5 U.S.C. 603-04 (2006); E.O. 13272, 67 FR 53461 (Aug. 13, 2002). The Department will make an initial determination as to whether any rule it proposes is likely to have a significant economic impact on a substantial number of small entities, and if so, the Department will prepare an initial regulatory flexibility analysis analyzing the economic impacts on small entities and regulatory alternatives that reduce the regulatory burden on small entities while achieving the goals of the regulation. In response to this ANPRM, the Department encourages small entities to provide cost data on the potential economic impact of adopting a specific requirement for Web site accessibility and recommendations on less burdensome alternatives, with cost information.Show citation box
Question 17. The Department seeks input regarding the impact the measures being contemplated by the Department with regard to Web accessibility will have on small entities if adopted by the Department. The Department encourages you to include any cost data on the potential economic impact on small entities with your response. Please provide information on capital costs for equipment, such as hardware and software needed to meet the regulatory requirements; costs of modifying existing processes and procedures; any affects to sales and profits, including increases in business due to tapping markets not previously reached; changes in market competition as a result of the rule; and cost for hiring web professionals for to assistance in making existing Web sites accessible.
Response Robert Crisler: If the small entities, however "small" might be defined, are handling their own web development, they will likely have to upgrade software as accessibility-supporting features are implemented in new versions. Web development businesses with experience in accessible web development will clearly benefit. There will likely be a shortage of workers experienced in accessible web development, and a resultant inflation in their salaries.
Response Mike Elledge: The initial costs of adopting the rule will be exceeded by the subsequent increase in revenues for organizations and institutions, resulting from the increased usability of websites for all users and additional online expenditures of persons with disabilities.
Question 18. Are there alternatives that the Department can adopt, which were not previously discussed in response to Questions 11 or 16, that will alleviate the burden on small entities? Should there be different compliance requirements or timetables for small entities that take into account the resources available to small entities or should the Department adopt an exemption for certain or all small entities from coverage of the rule, in whole or in part. Please provide as much detail as possible in your response.Show citation box
Response Robert Crisler: Alternatives could include a later timetable for conformance for small entities, but eventual full compliance with the ADA should remain the goal. After a certain date, any new web development, or any pages that were modified, might be required to be in compliance with the adopted success criteria. The federal government's fiscal role in this arena might be to provide some material support for the World Wide Web Consortium/Web Accessibility Initiative, or WebAIM, or another qualified entity, to make available a reference machine-testing resource for ADA accessibility and to maintain the infrastructure on which that resource might run. It is imperative for the efficiency and effectiveness of the conversion to accessible websites that developers are given one set of standards (it is imperative that the federal government specifies a single ADA/508 standard for accessibility, identical in all respects), and a reference machine-testing resource by which sites can be tested prior to analyzing checkpoints that require human evaluation.
G. Other Issues
Question 19. The Department is interested in gathering other information or data relating to the Department's objective to provide requirements for Web accessibility under titles II and III of the ADA.Show citation box
Are there additional issues or information not addressed by the Department's questions that are important for the Department to consider? Please provide as much detail as possible in your response.
Response Mike Elledge: It is appropriate to require website accessibility for economic, social and moral reasons.