Archived comments from Sec 508 Santa Clara hearing March 25, 2010

I am archiving this excerpt from the transcript of a US Access Board 
hearing on the "refresh" of US Section 508, 255, and the ADA that was 
held in Santa Clara, California, USA, on March 25, 2010. The full 
transcript of the hearing is available at: 
http://www.regulations.gov/search/Regs/home.html#documentDetail?R=0900006480ae8db1 
.
Please also note the subsequent set of comments from the Washington 
DC hearing on May 12.

- Judy Brewer


SHADI ABOU-ZAHRA:  Thank you for the opportunity to testify with the 
United States Access Board on Section 508, Section 255, and the 
Americans with Disabilities Act guidelines.  My name is Shadi 
Abou-Zahra, at World Wide Web Consortium, and I am myself activity 
lead of the International Program Office.  Our comments today are 
preliminary as I've had just a few days to study the Advanced Notice 
of Proposed Rulemaking in the ANPRM.  We would like to provide more 
detail, public comments within the coming months.

We appreciate the Access Board, and preparation of this ANPRM.  We 
appreciate the consideration given to the harmonization, harmonizing 
existing requirements in the United States with international 
standards developed by the World Wide Web consortium.  Harmonization 
of standards is crucial for achieving more rapid progress in make the 
web accessible for people with disabilities.  This can prevent 
conflict and technical requirements for developers and prevent 
contradictory expectations for consumers.  We're looking closely at 
section, at sub-section E107, on harmonization.  With the standard 
the approach is intended to support harmonization on existing 
requirements; however, we want to carefully assess the impact of this 
section as currently proposed, which includes the number of 
requirements in addition to Level AA ("double A").  In addition, we 
want to assess the impact of a number of significantly diverging 
requirements with provisions in Chapters 4, 5 and 6.  These chapters 
cover platforms, applications, interactive content, electronic 
documents and synchronized media content and players.  For instance, 
could the requirements that have been added to section E107 create 
confusion for developers and monitors?  Might present diversions in 
Chapters 4, 5 and 6 inadvertently set the standards in other countries?

We commend the Access Board for including provisions in section 413 
Authoring Tools that would ensure support for the production of 
accessible content.  There has been insufficient attention paid to 
the role tools can play in enabling more efficient access in enabling 
web content, that authoring tools merit consideration in these 
provisions.  We'll be looking at proposed requirements in the ANPRM 
in relation to the guidance of W3C's Accessibility Guidelines.

Finally, we welcome the attention to a number of important user 
interface issues in Chapter 4 that apply to browsers and media 
players and we'll be examining proposed requirements in the ANPRM in 
relation to guidance and the latest draft of the User Agent and 
Accessibility Guidelines.  I would like to thank the U.S. Access 
Board for making available the ARPRM.  We will send further comments 
in further review.  Thank you.

--
Judy Brewer    +1.617.258.9741    http://www.w3.org/WAI
Director, Web Accessibility Initiative (WAI), World Wide Web Consortium (W3C)
MIT/CSAIL Building 32-G526
32 Vassar Street
Cambridge, MA,  02139,  USA

Received on Friday, 18 June 2010 21:24:22 UTC