National Association of the Deaf

Earlier this month, the Architectural and Transportation Barriers Board (Access Board) released proposed guidelines for Section 255 (accessible telecommunications products and services) and Section 508 (requirement for federal government accessible electronic and information technology). The National Association of the Deaf (NAD) applauds the Access Board for its efforts to update Section 255 and 508 guidelines. The NAD submitted comments to the Access Board expressing our thanks for their efforts as well as some concerns we have about the proposed guidelines. We hope our comments will help the Access Board to make these new guidelines as strong and effective as possible.

The NAD has been a longstanding and powerful advocate for access to information and communication technology for people who are deaf or hard of hearing.

Gaining Ground

The NAD is pleased with the efforts of the Telecommunications and Electronic and Information Technology Advisory Committee (TEITAC) and the Access Board to update Section 255 and 508 guidelines to reflect new technologies which have become common since the rules were last changed in 1998. The proposed guidelines harmonize Section 508 with Section 255 and with the Web Content Accessibility Guidelines. These three sets of rules sometimes overlap, and they need to make sense together in order for the law to be clear and easily enforceable. The proposed guidelines also make the rules easier to understand by providing advisories and examples.

However, there are places in which the new rules are unclear or do not cover products or services completely enough to provide deaf and hard of hearing people equal access to electronic information and technology. Our concerns with the new rules include the following:

• Definition of “comparable access” should include these factors: timeliness, accuracy, completeness, and efficiency.
• “Conversation” should be defined as the exchange of text, voice, or video content, between or among two or more participants.
• A provision should be added to require that all information presented in audio also be available visually.
• Include a standard for text interoperability specified for Real Time Text functionality.
• Require Internet-based phones and other voice devices that have displays be capable of displaying Real Time Text.
   

We also responded to Access Board questions about the following:

• definition of “Voice over Internet Protocol” service;
• providing options which improves clarity, reduces background noise, or allows the user control of volume shall be provided;
• application to assistive technology;
• synchronization and accuracy rate for captions;
• user controls for captions and video description;
• audio track and volume control;
• volume control and magnetic coupling for devices typically held to the ear;
• quality and interoperability of video communications; and
• extending the guidelines to cover self-service machines in addition to ATMs.

The NAD is hopeful that these new guidelines, when complete, will help manufacturers, service providers, and federal agencies to comply with Sections 255 and 508.  We appreciate the opportunity to comment on the proposed guidelines.  We urge the Access Board to continue the process towards approval of these guidelines as quickly as possible and we look forward to additional opportunities to provide further input as that process moves forward.