Re: Fwd: [Blindmath] Letter to Members Concerning Section 508 Refresh and Comments

Hi,

There are lots of good things published in the public comments areas as well as some significant improvements within the new proposed regulations, standards and guidelines that weren't around for the past decade. The Free Software Foundation will be posting our commentary this weekend and hope some of you will have time to make comments on our work after it goes online. NFB, Trace and lots of others have also made excellent submissions but I think ours goes farther in pursuit of total accessibility than anything I've seen there so far. I believe that some of our comments will probably be dismissed out of hand as they are very strongly in favor of accessibility above all which will likely ruffle feathers in some other areas of the software sales process.

Unlike NFB, we didn't focus on stand-alone systems as FSF isn't really involved with such in any meaningful way. We do, however, raise a lot of issues the Access Board did not include in its draft at all and I hope you will enjoy and support our work.

I don't know the schedule but there will be a second round of public comments before the refresh is adopted. We'll keep people aware of such as it approaches - this round we got into the process a bit late and had to get our stuff done without much distraction so I got to work with some friends who were working on comments and we shared ideas and then got them all written and then edited separately so as to ensure they reflected the values of our particular organizations. I think a lot of good stuff came out of this collaborative effort.

If anyone wants a .txt copy of our complete statement, please write to me off-list and I'll mail it to you or if Jamal or Elf want to post it on their web sites I can send it to them as well.

cdh

On 06/19/2010 07:12 AM, Jamal Mazrui wrote:
-------- Forwarded Message --------
Subject: [Blindmath] Letter to Members Concerning Section 508 Refresh and Comments
Date: Fri, 18 Jun 2010 21:55:56 -0500
From: David Andrews <dandrews@xxxxxxxx>
Reply-To: Blind Math list for those interested in mathematics <blindmath@xxxxxxxxxx>

Dear Federationists:

As many of you may have already heard, the U.S. Access Board has
asked the public for feedback on some proposed changes to the ADA
Accessibility Guidelines, Rehabilitation Act, and Telecommunications
Act.  Specifically, the Access Board plans to update the standards
and accessibility guidelines for electronic and information
technology, as well as add kiosks to the ADA Accessibility
Guidelines.  We urge you to make your voices heard and e-mail, fax,
or post on <http://www.regulations.gov/>www.regulations.gov your
comments to these changes, as they have an enormous impact on a blind
person's ability to access information.  With a deadline of midnight
on Monday, June 21, time is running out for us to influence the board.

The National Federation of the Blind has been heavily involved with
the formulation of these proposed standards and guidelines, but our
role is not finished.  It is important that we applaud the Access
Board for the changes we support so they are not compromised, and
that we highlight where the changes have not gone far enough to
ensure full accessibility.  More specifically, we have many concerns
regarding both the definition of a "kiosk" and the kiosks that are
exempted in the proposal.

In the current proposal, the definition of "kiosk" is limiting.  A
kiosk is defined as a self-service unit used only for transportation
(ticketing, seat assignments, boarding passes, etc.) or for ordering
food.  This definition should be expanded to include other types of
services not mentioned, as kiosks are increasingly replacing customer
service personnel in a wide range of services, including voting, jury
service payments, and health care.  The current definition is silent
on whether a unit used for these services would be considered a
kiosk, and also does not include visual display systems that are used
solely for displaying information to users.  Kiosks should have a
comprehensive definition that leaves room for innovative ways kiosks
may be incorporated into our society and eliminates any future debate
over whether a different service is covered under the law and what
standards may apply.

In addition, the two exemptions for kiosks in the proposal will not
ensure total accessibility.  First, closed systems are exempted to
comply with 302.  This means a closed system does not have to provide
spoken output, since it would not be required to be usable with "only
the attachment of a personal headset."  Under this assumption, there
is no requirement for these systems to be accessible.  Second,
drive-up kiosks are exempted.  Although people with certain
disabilities are not drivers, they are all passengers who may
encounter a drive-up kiosk; and exempting drive-up units is
discriminatory to a disabled passenger.  The NFB encourages the board
to ensure that all kiosks be required to be accessible.

These comments and others were compiled and formally submitted by the
NFB to the Access Board.  Now it is time for our members to make a
statement and emphasize our concerns regarding kiosks.  Your comments
can be short--the act of sending in feedback is more important than
the length of your remarks.  You could say something as simple as "I
think the definition of kiosks is too limited.  Please expand the
definition and remove the exemptions."  You could also say "I think
the definition of kiosks should be expanded and all exemptions
removed to ensure full accessibility."  You can call Tim Creagan at
(202) 272-0016, e-mail your thoughts to
<mailto:ictrule@xxxxxxxxxxxxxxxx>ictrule@xxxxxxxxxxxxxxxx with
"2010-1" in the subject line, fax to (202) 272-0081, or post your
comments on <http://www.regulations.gov/>www.regulations.gov.  To
view the full draft, visit
<http://www.access-board.gov/sec508/refresh/draft-rule.htm>http://www.access-board.gov/sec508/refresh/draft-rule.htm.


If you need more information, please contact Lauren McLarney at (410)
659-9314, extension 2207.

Sincerely,

Joanne Wilson
Executive Director, Affiliate Action
jwilson@xxxxxxx



                        David Andrews:  dandrews@xxxxxxxx
Follow me on Twitter:  http://www.twitter.com/dandrews920
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