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Subject:
From:
Kelly Pierce <[log in to unmask]>
Reply To:
Kelly Pierce <[log in to unmask]>
Date:
Sat, 27 Nov 1999 07:45:12 -0600
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TEXT/PLAIN (2642 lines)
URL: http://www.HTCTU.FHDA.EDU/dlguidelines/final%20dl%20guidelines.htm


                            Distance Education:

              Access Guidelines for Students with Disabilities

                                August 1999


                          Chancellor's Office logo


                            Chancellor's Office
                       California Community Colleges


                               Developed By:

                     The High Tech Center Training Unit
    In Collaboration with the Distance Education Accessibility Workgroup

                            Chancellor's Office
                       California Community Colleges

     _________________________________________________________________

   Distance Education and Accessibility Guidelines Task Force Members

   Name: Ralph Black, Esq.
   Title: General Counsel
   Affiliation: Chancellor's Office, CCC

   Name: Carl Brown
   Title: Director, High Tech Center Training Unit
   Affiliation: De Anza College

   Name: Laurie Vasquez
   Title: Assistive Technology Specialist
   Affiliation: Santa Barbara City College

   Name: Cris Mora Lopez
   Title: Distance Education Coordinator
   Affiliation: Chancellor's Office, CCC
   Instructional Resources and Technology Division, Distance Education

   Name: Brain Haley
   Title: Dean of Library/Learning Resource Center
   Affiliation: Sierra College

   Name: Jay Thompson
   Title: Executive Director
   Affiliation: Consortium for Distance Learning

   Name: Nancy Glock-Gruenich
   Title: Specialist in System Advancement
   Affiliation: California Virtual University/COCCC

   Name: Catherine McKenzie
   Title: Telecommunications Mgr. - Specialist
   Affiliation: Chancellor's Office, CCC
   Instructional Resources and Technology Unit, Office of
   Telecommunications and Technology

   Name: Cheryl Chapman
   Title: Instructor, Faculty Trainer, Academic Senate
   Affiliation: Coastline College

   Name: Catherine Campisi
   Title: Dean, Student Support Programs
   Affiliation: Chancellor's Office, CCC

   Name: Jose Michel
   Title: Senior Coordinator Distance Education
   Affiliation: Chancellor's Office, CCC
   _________________________________________________________________

   Table of Contents

   Preface
   Legal Requirements
   Basic Requirements For Providing Access
   Access Guidelines for Specific Modes of Distance Education
   Instructional Delivery
   Print Media
   Audio Conferencing
   Video Conferencing/Video Transmission (Live)
   Video Transmission (Pre Recorded)
   World Wide Web
   Instructional Software, Laser Video Disc, CD ROM, DVD
   Trace Research & Development Center Accessibility Guidelines
   Appendix I
   Copyright Issues
   Braille
   Braille Production Facilities
   A Guide To Large Print For People With Low Vision

   Appendix II
   Telephone Relay Services
   Real-Time Transcription
   Interpreter Services

   Appendix III
   Captioning
   Basic Captioning Terms
   Captioning Service Providers

   Appendix IV
   WAI Guidelines for Accessible Web Site Design

   Appendix V
   Microsoft's Checklist of Accessibility Design Guidelines
   Software Design Guidelines (TRACE Research Center)

   _________________________________________________________________

                                  Preface

   In March 1996, the U.S. Department of Education, Office of Civil
   Rights notified Chancellor Thomas J. Nussbaum that it was about to
   begin a statewide compliance review under Title II of the Americans
   with Disabilities Act of 1990. The compliance review would focus on
   the status of community colleges in meeting their obligation under
   Title II and Section 504 to provide students with visual impairments
   access to print and computer-based information. The review was to
   examine whether students with visual impairments, particularly blind
   students, were accorded an equal educational opportunity by California
   Community Colleges or whether they were being discriminated against on
   the basis of their disability. Specifically, OCR wished to consider
   whether the Chancellor's Office employed "methods of administration"
   which substantially impaired accomplishment of the objectives of the
   California Community College educational programs with respect to
   students with visual impairments.

   As an outcome of this review, OCR offered nine suggestions for
   addressing areas of concern identified by the review. Among the
   suggestions/concerned voiced by OCR was the need for development of
   system-wide access guidelines for distance learning and campus Web
   pages. In a January 22, 1998 letter to Chancellor Nussbaum, Stefan
   Rosenzweig, Regional Director of OCR stated:

   "California Community Colleges, individually and collectively as part
       of the California Virtual University, are rapidly developing their
       capacity to deliver educational programs to offsite students
       through technology. Little attention is being given to ensure that
       these distance learning programs are accessible to students with
       disabilities, especially students with visual impairments."

   He further added:

   "The need for guidelines regarding distance learning has been
       recognized by several different entities in the California
       Community College system, including the Academic Senate which in
       Fall 1997, adopted "Guidelines for Good Practice: Technology
       Mediated Instruction." It is OCRs understanding that four regional
       distance learning centers to assist in development of program and
       course materials will be set-up in 1998-99. The concept of
       accessibility should be firmly integrated into such development."

   In responding to the Regional Director's suggestions regarding
   development of system-wide access guidelines for distance learning and
   campus Web pages, in a letter dated March 13, 1998, Chancellor
   Nussbaum replied:

   "We concur with the strategies related to this issue. I will
       immediately direct that the Chancellor's Office Task Forces
       related to distance learning as well as California Virtual
       University have persons on them to specifically address access
       issues for persons with disabilities...To assure that the
       necessary guidance to colleges is available, I will specifically
       ask Vice Chancellor of Educational Services and Economic
       Development, Rita Cepeda, whose staff oversees the distance
       learning issues, to develop in cooperation with the DSP&S Unit and
       the High Tech Center Training Unit (HTCTU), guidelines for
       distance learning to assure it is accessible to and usable by
       persons with disabilities."

   The guidelines which follow are the result of Chancellor Nussbaum's
   directive.
   _________________________________________________________________

                             Legal Requirements

   Both state and federal law require community colleges to operate all
   programs and activities in a manner which is accessible to students
   with disabilities. Accordingly, as the system develops its capacity
   for creation of technology based instructional resources and the
   delivery of distance learning; it must proceed with the needs of all
   students in mind, including the unique needs of students with
   disabilities.

   At the federal level, requirements for access for persons with
   disabilities were first imposed on recipients of federal funding by
   Section 504 of the Rehabilitation Act of 1973, as amended (29 U.S.C.
   794) and its accompanying regulations set forth at 34 C.F.R. 104.
   Similar requirements were later imposed on all public entities,
   regardless of whether or not they receive federal funding, by the
   Americans with Disabilities Act (42 U.S.C. Sec. 12100 et seq) and the
   regulations implementing Title II of the ADA which appear at 28 C.F.R.
   35.

   In particular, the Section 504 regulations and the regulations
   implementing Title II of the ADA contain nearly identical provisions
   stating that recipients of federal funds and public entities in
   providing any aid, benefit or service, may not afford a qualified
   individual with a disability an opportunity to participate that is not
   as effective as that provided to others. (See 34 C.F.R. 104.4 (b)(1)
   (iii) and 28 C.F.R. 35.130(b) (1) (iii)). Title II recognizes the
   special importance of communication, which includes access to
   information, in its implementing regulation at 28 C.F.R. 35.160 (a).
   The regulation requires that a public entity, such as a community
   college, take appropriate steps to ensure that communications with
   persons with disabilities are as effective as communications with
   others.

   The United States Department of Education, Office for Civil Rights
   (OCR) is responsible for ensuring that all educational institutions
   comply with the requirements of all federal civil rights laws,
   including Section 504 and Title II of the ADA. As a result, the
   opinions of OCR are generally accorded considerable weight by the
   courts in interpreting the requirements of these laws. OCR has had
   occasion to issue several opinions applying the requirements of the
   Section 504 and ADA regulations to situations involving access to
   distance education and/or computer-based instruction.

   In responding to a complaint by a student with a disability alleging
   that a university had not provided access to the Internet, OCR noted
   that:

   [T]he issue is not whether the student with the disability is merely
   provided access, but the issue is rather the extent to which the
   communication is actually as effective as that provided to others.
   Title II [of the Americans with Disabilities Act of 1990] also
   strongly affirms the important role that computer technology is
   expected to play as an auxiliary aid by which communication is made
   effective for persons with disabilities.

   (OCR Docket No. 09-95-2206, January 25, 1996)

   Adding additional clarity to the meaning of "effective communication,"
   OCR has held that the three basic components of effective
   communication are: "timeliness of delivery, accuracy of the
   translation, and provision in a manner and medium appropriate to the
   significance of the message and the abilities of the individual with
   the disability."

   (OCR Docket No. 09-97-2145, January 9, 1998)

   OCR also points out that the courts have held that a public entity
   violates its obligations under the ADA when it only responds on an
   ad-hoc basis to individual requests for accommodation. There is an
   affirmative duty to develop a comprehensive policy in advance of any
   request for auxiliary aids or services.

   Finally, in considering the magnitude and responsibility of this task,
   OCR states:

   [T]he magnitude of the task public entities now face in developing
   systems for becoming accessible to individuals with disabilities,
   especially with respect to making printed materials accessible to
   persons with visual impairments, is comparable to the task previously
   undertaken in developing a process by which buildings were to be
   brought up to specific architectural standards for access. Buildings
   in existence at the time the new architectural standards were
   promulgated are governed by "program access" standards. However,
   buildings erected after the enactment of the new architectural
   standards are strictly held to the new standards on the premise that
   the builder is on-notice that such standards apply. One who builds in
   disregard of those standards is ordinarily liable for the subsequent
   high cost of retrofitting.

   Similarly, from the date of the enactment of Title II onwards, when
   making purchases and when designing its resources, a public entity is
   expected to take into account its legal obligation to provide
   communication to persons with disabilities that is "as effective as"
   communication provided to non-disabled persons. At a minimum, a public
   entity has a duty to solve barriers to information access that the
   public entity's purchasing choices create, particularly with regard to
   materials that with minimal thought and cost may be acquired in a
   manner facilitating provision in alternative formats. When a public
   institution selects software programs and/or hardware equipment that
   are not adaptable for access by persons with disabilities, the
   subsequent substantial expense of providing access is not generally
   regarded as an undue burden when such cost could have been
   significantly reduced by considering the issue of accessibility at the
   time of the initial selection.

   (OCR Docket No. 09-97-2002, April 7, 1997)

   There are also state laws and regulations which require community
   colleges to make their distance education offerings accessible to
   students with disabilities.

   Government Code Section 11135 et seq. prohibits discrimination on
   various grounds, including mental or physical disability, by entities
   receiving funding from the State of California. The Board of Governors
   has adopted regulations at Title 5, California Code of Regulations,
   Section 59300 et seq. to implement these requirements with respect to
   funds received by community college districts from the Board of
   Governors or Chancellor's Office. These regulations require community
   college districts and the Chancellor's Office to investigate and
   attempt to resolve discrimination complaints filed by students or
   employees.

   In addition, the Board of Governors has adopted Title 5 regulations
   setting forth the general requirements applicable to all independent
   study (Sections 55300 et seq.) and those requirements specific to
   distance education courses (Sections 55370 et seq.). Section 55370
   expressly states that the requirements of the Americans with
   Disabilities Act are applicable to distance education courses.

   The remainder of this document sets forth guidelines developed by the
   Chancellor's Office to address specific issues community college
   districts will face in meeting their legal obligation to make distance
   education courses accessible to students with disabilities. These
   guidelines are not legally binding on districts, but the Chancellor's
   Office will apply these guidelines in determining whether a district
   has met its obligations under Title 5, Section 55370 and 59300 et seq.
   Districts which follow these guidelines will generally be regarded as
   having met those obligations. Districts which do not follow these
   guidelines will bear the burden of demonstrating that they have
   achieved compliance with their legal obligation to provide access to
   distance education for students with disabilities by other means.
   _________________________________________________________________

                  Basic Requirements for Providing Access

   The following are general principles that should be followed in
   ensuring that distance education courses are accessible to students
   with disabilities. They represent the general concepts of the ADA and
   its regulations but do not provide a detailed legal analysis of the
   ADA requirements. Persons utilizing this document who are unfamiliar
   with the ADA may wish to consult the campus ADA Coordinator or DSP&S
   Coordinator for further interpretation. In the remainder of this
   document, specific guidelines will be provided for resolving access
   issues with respect to particular delivery modes commonly used in
   distance education.

   1. One of the primary concepts of distance education is to offer
       students "Learning anytime, anywhere." Therefore, all distance
       education resources must be designed to afford students with
       disabilities maximum opportunity to access distance education
       resources "anytime, anywhere" without the need for outside
       assistance (i.e. sign language interpreters, aides, etc.).
       2. Distance education resources must be designed to provide
       "built-in" accommodation where possible (i.e. closed captioning,
       descriptive narration) and/or interface design/content layout
       which is accessible to "industry standard" assistive computer
       technology in common use by persons with disabilities.
       3. Whenever possible, information should be provided in the
       alternative format preferred by the student (i.e. sign language
       interpreter, closed captioning, descriptive narration, Braille,
       audio tape, large print, electronic text). When choosing between
       possible alternative formats or methods of delivery, consideration
       should be given to the fact that methods which are adequate for
       short, simple or less important communications may not be equally
       effective or appropriate for longer, more complex, or more
       critical material (Example: Use of a telephone relay service may
       be an acceptable method for a faculty member to respond to a brief
       question from a deaf student during his/her office hours, but
       probably would not be appropriate as a means of permitting that
       same student to participate in a class discussions in a course
       conducted by teleconference.) Issues concerning accommodation
       should be resolved through appropriate campus procedures as
       defined under Title 5, Section 56027.
       4. Adoption of access solutions which include assigning assistants
       (i.e. sign language interpreters, readers) to work with an
       individual student to provide access to distance education
       resources should only be considered as a last resort when all
       efforts to enhance the native accessibility of the course material
       have failed.
       5. Access to distance education courses, resources and materials
       include the audio, video and text components of courses or
       communication delivered via satellite, Instructional Television
       Fixed Services (ITFS), cable, compressed video, Local Area
       Network/Wide Area Network (LAN/WAN networks), Internet, telephone
       or any other form of electronic transmission. Access to resources
       and materials include the audio, video, multimedia and text
       components of Web sites, electronic chat rooms, e-mail,
       instructional software, CD-ROM, DVD, laser disc, video tape, audio
       tape, electronic text and print materials. Where access to Web
       sites not controlled by the college is required or realistically
       necessary to completion of a course, the college must take steps
       to ensure that such sites are accessible or provide the same
       material by another means that is accessible.
       6. Distance education courses, resources and materials must be
       designed and delivered in such a way that the level of
       communication and course taking experience is the same for
       students with or without disabilities.
       7. After the adoption date of these guidelines, any distance
       education courses, resources or materials purchased or leased from
       a third-party provider or created or substantially modified
       "in-house" must be accessible to students with disabilities unless
       doing so would fundamentally alter the nature of the instructional
       activity or result in undue financial and administrative burdens
       on the district.
       8. Colleges are encouraged to review all existing distance
       education curriculum, materials and resources as quickly as
       possible and make necessary modifications to ensure access for
       students with disabilities. At a minimum, the Chancellor's Office
       will expect that the curriculum for each distance education course
       and its associated materials and resources will be reviewed and
       revised as necessary when the course undergoes curriculum review
       pursuant to Title 5, Sections 55002 and 55378, every six years as
       part of the accreditation process. In the event that a student
       with a disability enrolls in an existing distance education course
       before this review is completed, the college will be responsible
       for acting in a timely manner to making any requested
       modifications to the curriculum, materials or resources used in
       the course, unless doing so would fundamentally alter the nature
       of the instructional activity or result in undue financial and
       administrative burdens on the district.
       9. In the event that a discrimination complaint is filed alleging
       that a college has selected software and/or hardware that is not
       accessible for persons with disabilities, the Chancellor's Office
       and the U.S. Department of Education , Office for Civil Rights
       will not generally accept a claim of undue burden based on the
       subsequent substantial expense of providing access, when such
       costs could have been significantly reduced by considering the
       issue of accessibility at the time of initial selection.
       10. In all cases, even where the college can demonstrate that a
       requested accommodation would involve a fundamental alteration in
       the nature of the instructional activity or would impose an undue
       financial and administrative burden, it must nevertheless provide
       an alternative accommodation which is equally effective for the
       student if such an accommodation is available.
       11. Ensuring that distance education courses, materials and
       resources are accessible to students with disabilities is a shared
       college responsibility. All college administrators, faculty and
       staff who are involved in the use of this instructional mode share
       this obligation. The Chancellor's Office will make every effort to
       provide technical support and training for faculty and staff
       involved in the creation of accessible distance education courses,
       resources and materials through: campus representative(s) to the
       California Virtual University (CVU) Regional Distance Education
       Center, staff from the local Regional Distance Education
       Center(s), campus High Tech Center staff and High Tech Center
       Training Unit staff.
   _________________________________________________________________

                  Access Guidelines for Specific Modes of

                 Distance Education Instructional Delivery

   1. Print Media

   The use of "correspondence" has a long history in distance education
       and will likely continue as an element of some courses.
       Print-based materials are easy to handle, modify, distribute and
       store. Print materials allow students to work at their own pace.

                       Delivery Medium - Print Medium
       Access Issue
       Students who are blind or have low vision will be unable to read
       print material. Some students with severe learning disabilities
       may also be unable to effectively read print materials.
       Remedies
       Provide print material in alternate formats including: Braille,
       large print, audiotape, digital sound files and e-text. Whenever
       possible, information should be provided in the alternative format
       preferred by the student.
       Analysis:
       Braille
       Braille can be produced in a variety of formats designed to
       accommodate specialized needs such as scientific notation and
       music scores. For general text production, materials should be
       provided in Grade 2 Braille. Grade 2 Braille is the format most
       commonly used by persons who are blind.
       Braille can be produced "in-house" using readily available Braille
       translation software and specialized Braille printers or
       out-sourced to agencies and organizations which produce Braille
       documents commercially. As of 1999, colleges wishing to produce
       Braille documents in-house should expect to pay around $5000 for
       the necessary printer hardware and software. Commercial production
       costs average about one dollar per Braille page with one single
       spaced print page equaling approximately two print Braille pages.
       Production time through commercial providers can vary from days to
       weeks.
       In either case, Braille documents should be formatted to preserve
       critical page layout elements (i.e. columns, tabular data, etc.)
       and proofed for accuracy.
       Large Print
       Large print documents printed from electronic files should be
       produced using a font size of 14 point (or larger) and sans serif
       type faces such as Helvetica for visual clarity. Documents should
       be reformatted as necessary to preserve critical page layout
       elements. All colors should be set for maximum print contrast.
       Audio Tape
       Audio taped materials can be produced in-house if recording studio
       resources are available or outsourced to commercial providers such
       as Recordings for the Blind and Dyslexic. For in-house recording,
       readers should be familiar with the vocabulary of the source
       material and the taped material proofed for accuracy. These media
       are typically used by both visually impaired and learning disabled
       students.
       Electronic Text
       Electronic text should be available in multiple operating system
       formats (i.e. Windows, Macintosh), plain text, and industry
       standard word processing formats (i.e. Word, WordPerfect, etc.).
       These media are typically used by both visually impaired and
       learning disabled students.
       Resource Material
       Please see Appendix I for supplemental information about copyright
       issues, Braille and large print.

   2. Audio Conferencing

   Telephones remain the technology of choice for simple phone calls
       between a teacher and a student as well as for scheduled,
       multi-point sessions between a teacher and students at many
       locations. Telephones are also used in "one-way video, two-way
       audio" teleconferencing/instructional delivery systems often used
       by community colleges for microwave delivery of courses to
       surrounding community sites. The telephone system is ubiquitous,
       reliable, easy to use and of sufficient quality for delivery of
       voice content.

                    Delivery Medium - Audio Conferencing
       Access Issue
       Students who are deaf or hard-of-hearing will not be able to hear
       conversations. Students with speech impediments will not be able
       to respond to conversations.
       Remedies
       Provide a text telephones (TTY) link in the studio or classroom,
       provide TRS service, provide a dedicated, electronic chat room and
       real-time transcription of conversations, provide on-site
       interpreter at the student's location.
       Analysis:
       Text Telephones (TTY), sometimes called a TDD or Telecommunication
       Devices for the Deaf, are widely used by people who are deaf or
       have speech impediments. A TTY is a combination telephone,
       keyboard and display which allows for direct, point-to-point text
       based communication between two people. Communication rates are
       only constrained by typing speed of the two users. TTYs work over
       ordinary phone lines and require no set-up or configuration. TTYs
       may be used for one-on-one telephone conversations between faculty
       and student.
       Faculty can communicate with students who are deaf, hard of
       hearing, or speech-impaired using the Telecommunications Relay
       Service (TRS). A TRS special operator types whatever the
       instructor says and the words appear on the students TTY display.
       Student responses are typed back to the TRS operator who reads
       them aloud to the instructor. Toll free TRS services are available
       24 hours a day, 365 days a year. Use of a TRS may be an acceptable
       method for a faculty member to respond to a brief question from a
       deaf student during his/her office hours, but probably would not
       be appropriate as a means of permitting that same student to
       participate in a class discussions in a course conducted by
       teleconference.
       A variety of commercial and public domain Web-based "chat"
       software is presently available. Using these tools, the college
       may create a private chat room where deaf, hard-of-hearing or
       speech impaired students can read, and type responses to, the
       content of the conversation as it is input by a "real-time"
       transcriptionist. The instructor also views the transcribed text
       and shares with the telephone audience any comments typed by
       students using the chat room. Chat rooms may be used for
       one-on-one conversations between faculty and student as well as
       for multi-point group conversations.
       In keeping with the basic requirements defined earlier, in the
       event that all other efforts to make the distance education
       resource accessible as delivered have failed, as a last resort,
       colleges may provide an on-site interpreter(s) at the student's
       location.
       Please see Appendix II for supplemental information about TRS,
       TTY, chat, real-time transcription and interpreter services.

   3. Video Conferencing/Video Transmission (Live)

   Video conferencing can include satellite broadcast, TV cable,
       Instructional Television Fixed Service (ITFS) or compressed video
       (ISDN). It may include real-time, two-way video and audio or
       one-way video/two-way audio. Pre recorded video transmission,
       described in Item 4, generally involves the rebroadcast of a
       course segment which has been videotaped and includes no real-time
       interaction between student and instructor.

       Delivery Medium - Video Conferencing/Video Transmission (Live)

       Access Issue
       Students who are deaf or hard-of-hearing will not be able to hear
       conversations. Students who are blind or have low vision will not
       be able to see instructional materials.
       Remedies
       Provide real-time closed or open captioning, an on-screen
       interpreter or (as a last resort) an interpreter at the student's
       location. To facilitate communication from the student, provide a
       TTY link in the studio or classroom, provide TRS service or
       provide a dedicated, electronic chat room for real-time
       conversation exchange.
       For blind and low vision, provide all print materials in
       alternative formats and include descriptive video narration as
       needed.
       Analysis:
       On August 7th, 1997, the Federal Communications Commission (FCC)
       unanimously approved a new law which mandates captioning on
       virtually all television programming in the United States. Section
       305 of the Telecommunications Act of 1996 is being implemented as
       a new section (Section 713) of the existing Communications Act.
       There are a variety of existing technologies which will allow
       colleges transmitting via satellite Ku or C band, microwave (ITFS)
       or cable and with moderately sophisticated video editing and
       broadcast capabilities to add captioning to live broadcasts in
       real-time in closed or open format. Average cost for these systems
       is about $10,000. Hourly rates for real-time transcriptionists
       average $75 to $100/hour. Real-time captioning can also be
       provided through outsourcing to commercial services.
       Colleges may also provide access to the audio component of live
       broadcasts for deaf or hard-of-hearing students by including a
       sign language interpreter in a small video window superimposed
       over the main video.
       To facilitate communication from the student, the college may
       employ:
       Text Telephones (TTY), a combination telephone, keyboard and
       display which allows for direct, point-to-point text based
       communication between two people. TTYs work over ordinary phone
       lines and require no set-up or configuration and may be used for
       one-on-one telephone conversations between faculty and student.
       The faculty would read the student's response from the TTY to the
       listening audience.
       Deaf, hard of hearing, or speech-impaired students can also
       communicate with the faculty member using the Telecommunications
       Relay Service (TRS). Student responses are typed back to the TRS
       operator who reads them aloud to the instructor. The faculty would
       share the student's response with the listening audience. Toll
       free TRS services are available 24 hours a day, 365 days a year.
       Use of a TRS may be an acceptable method for a faculty member to
       respond to a brief question from a deaf student during his/her
       office hours, but probably would not be appropriate as a means of
       permitting that same student to participate in a class discussions
       in a course conducted by teleconference.
       A variety of commercial available and public domain Web-based
       "chat" software is presently available. Using these tools, the
       college may create a private chat room where deaf, hard-of-hearing
       or speech impaired students can type responses to the content of
       the video as presented via captioning or on-screen interpreter.
       The instructor monitors the chat room and shares with the audience
       any comments typed by students using the chat room. Chat rooms may
       be used by one or more students simultaneously. Colleges may also
       provide an on-site interpreter(s) at the student's location as an
       alternative to captioning, TTY, TRS or chat rooms.
       Supplemental course material in print media must also be provided
       in alternative formats (Braille, large print, audio tape and/or
       electronic text) to provide access for students who are blind or
       have low vision. Please see the discussion of Print Media for
       details.
       Descriptive narration on the Second Audio Programming (SAP)
       channel provides a mechanism through which students who are blind
       or have low vision can receive auditory descriptions of important
       visual elements of the video presentation. Real time descriptive
       narration requires the services of a trained narrator and the
       ability of the college to transmit a SAP channel. As an
       alternative, colleges should train faculty who teach via real-time
       broadcast to include descriptions of visual objects which have
       significant instructional content in their course dialogue.
       Please see Appendix III for supplemental information about
       real-time captioning.

   4. Video Transmission (Pre Recorded)

   Passive video transmission generally involves the rebroadcast of a
       course segment which has been videotaped and includes no real-time
       interaction between student and instructor.

            Delivery Medium - Video Transmission (Pre Recorded)

       Access Issue
       Students who are deaf or hard-of-hearing will not be able to hear
       conversations. Students who are blind or have low vision will not
       be able to see instructional materials.
       Remedies
       Provide closed or open captioning, an on-screen interpreter or (as
       a last resort) an interpreter at the student's location. For blind
       and low vision, provide all print materials in alternative
       formats. Provide real-time descriptive narration of significant
       visual elements
       Analysis:
       As mentioned in Item 3, on August 7th, 1997, the FCC unanimously
       approved a new law which mandates captioning on virtually all
       television programming in the United States. Section 305 of the
       Telecommunications Act of 1996 is being implemented as a new
       section (Section 713) of the existing Communications Act. There
       are a variety of existing technologies which will allow colleges
       to provide "off-line" captioning to existing libraries of
       instructional video and course materials. There are a variety of
       technologies available for off-line addition of captioning in
       closed or open format. Average cost for these systems is about
       $10,000. Costs for keying in of captioning are comparable to
       clerical word-processing rates. Off-line captioning can also be
       provided through outsourcing to commercial services for reasonable
       rates.
       Colleges may also provide access to the audio component of a video
       for deaf or hard-of-hearing students by adding a sign language
       interpreter in a small video window superimposed over the main
       video as a post-production activity.
       Supplemental course material in print media must also be provided
       in alternative formats (Braille, large print, audio tape and/or
       electronic text) to provide access for students who are blind or
       have low vision. Please see the discussion of Print Media for
       details.
       Descriptive narration on the Second Audio Programming (SAP)
       channel provides a mechanism through which students who are blind
       or have low vision can receive auditory descriptions of important
       visual elements of the video presentation. Post-production
       descriptive narration requires the services of a trained narrator
       and the ability of the college to encode a SAP channel on the
       videotape. Colleges should train faculty who teach via videotaped
       courses to include descriptions of visual objects which have
       significant instructional content in their course dialogue.
       Please see Appendices I for supplemental information about
       copyright issues, Braille, large print, audiotape and electronic
       text and III for supplemental information about real-time
       captioning.

   5. World Wide Web

   The Web is rapidly becoming one of the most widely used media for
   delivery of distance education. The relatively low cost of delivery,
   ease of resource development and wide availability of student access
   make it an ideal instructional delivery resource. Although presently
   constrained by bandwidth considerations, the Web is fully capable of
   delivering a variety of multimedia and interactive instructional
   resources including audio, video and real-time chat services.


                      Delivery Medium - World Wide Web

   Access Issue

   Students who are blind will be unable to access graphic images, text
   formatted in complex ways, Java applets and video clips. Students who
   are deaf or hard-of-hearing will not be able to hear the auditory
   content of the Web site. Some students with severe learning
   disabilities may be unable to process large amounts of text
   information without the use of assistive technologies.

   In addition, documents created using Adobe Portable Document Format
   (PDF) are difficult, if not impossible, to read using screen readers
   and/or refreshable braille displays. Thus, if materials are provided
   on a website in PDF format, an alternative version should also be
   available in plain text or HTML format. Of course, this is only
   feasible for textual information and would not apply to materials, or
   portions of materials, that are inherently graphic in nature such as
   pictures, graphs and maps.

   Remedies

   A comprehensive set of guidelines for meeting the Web access needs of
   persons with disabilities have been developed by the Web Accessibility
   Initiative (WAI) (http://www.w3.org/WAI/) as a working group of the
   World Wide Web Consortium (W3C).


   Analysis:
       The intent of these guidelines is to foster the creation of Web
       sites which provide equal access to information when viewed using
       typical, industry standard assistive computer technologies in wide
       use today by students with disabilities. Over the past two years,
       the international body of the World Wide Web Consortium (W3C) has
       sponsored the work of the Web Accessibility Initiative (WAI) in
       developing a set of international access guidelines for the Web.
       Although the WAI guidelines remain in draft format, they satisfy
       the access requirements identified under Title II of the Americans
       with Disabilities Act (ADA). In order to resolve compliance issues
       raised by OCR and to comply with Title II of the ADA, these
       guidelines have been adopted by the California Community Colleges
       Chancellor's Office. They apply to use of Web based instructional
       resources created by the college or other Web-based resources
       students are required to use for course completion. They will be
       reviewed/modified as necessitated by future revisions of the WAI
       guidelines by W3C.
       The WAI guidelines excerpted below fall into three priority
       levels:
       Priority 1
       This guideline must be followed by an author, or one or more
       groups of users will find it impossible to access information in
       the document. Implementing this guideline is a basic requirement
       for some groups to be able to use Web documents.

     Provide alternative text for images, applets, and image maps.

     Provide descriptions for important graphics, scripts, or applets if
   they are not fully described through alternative text or in the
   document's content.

     Provide textual equivalents for audio information (captioning).

     Provide verbal descriptions of moving visual information in both
   auditory and text form.

     Ensure that text and graphics are perceivable and understandable
   when viewed without color.

     Ensure that moving, blinking, scrolling, or auto-updating objects or
   pages may be paused or frozen.

     Ensure that pages using newer HTML features (i.e. style sheets,
   forms, tables) will transform gracefully into an accessible form.

     Use features that enable activation of page elements via input
   devices other than a pointing device (e.g., via keyboard, voice,
   etc.).

     For frames, provide sufficient information to determine the purpose
   of the frames and how they relate to each other.

     Ensure that tables (not used for layout) have necessary markup to be
   properly restructured or presented by accessible browsers and other
   user agents.

     Only use technologies defined in a W3C specification and use them in
   an accessible manner. Where not possible, provide an accessible
   alternative page that does.

       Priority 2
       This guideline should be followed by an author, or one or more
       groups of users will find it difficult to access information in
       the document. Implementing this guideline will significantly
       improve access to Web documents.

     Indicate structure with structural elements, and control
   presentation with presentation elements and style sheets.

     Provide supplemental information needed to pronounce or interpret
   abbreviated or foreign text.

     Elements that contain their own user interface should have
   accessibility built in.

     Use interim accessibility solutions so that assistive technologies
   and older browsers will operate correctly.

     Group controls, selections, and labels into semantic units.

     Wherever possible, create good link phrases.

       Priority 3
       This guideline may be followed by an author to make it easier for
       one or more groups of users to access information in the document.
       Implementing this guideline will improve access to Web documents.

     Provide mechanisms that facilitate navigation within your site.

     Create a single downloadable file for documents that exist as a
   series of separate pages.
       Complete text of the WAI accessibility guidelines as well as
       useful tutorials and extensive technical support can be found at:
       http://www.w3.org/WAI/
       Additionally, a fully automated Web accessibility evaluation tool
       called BOBBY is available for use by California community
       colleges. BOBBY will evaluate a local Website incorporating the
       current WAI guidelines in its Website accessibility analysis and
       provide a detailed report of accessibility problems and
       recommended changes arranged by priority of importance.
       It is required that all California community college instructional
       Web sites created or substantially modified after adoption of
       these guidelines be Priority 1 compliant. It is strongly
       recommended that all California community college instructional
       Web sites created or substantially modified after adoption of
       these guidelines be Priority 2 compliant.
       BOBBY can be found at: http://www.cast.org/bobby/
       Please see Appendix IV for supplemental information about
       development of accessible Web pages.


   6. Instructional Software, Laser Video Disc, CD ROM, DVD


   Courses presented through distance education may also include
       supplemental materials offered in a variety of electronic formats
       including computer assisted instruction (CAI) software, materials
       on video disc, CD ROM or DVD.

          Delivery Medium - CAI software, video disc, CD ROM, DVD


   Access Issue
       Students who are blind will be unable to access graphic images,
       text formatted in complex ways, Java applets and video clips.
       Students who are deaf or hard-of-hearing will not be able to hear
       the auditory content of these resources. Students with physical
       disabilities may have difficulty using a touch screen video disc
       interface. Some students with severe learning disabilities may be
       unable to process large amounts of text information without the
       use of assistive technologies.
       Remedies
       The Trace Research & Development Center at the University of
       Wisconsin-Madison has designed a comprehensive set of software
       development guidelines which address these issues. These
       guidelines should be used in combination with the guidelines for
       multimedia access developed by the Web Accessibility Initiative.
       Analysis:
       The California Community Colleges Chancellor's Office gratefully
       acknowledges the work of Dr. Gregg C. Vanderheiden, Ph.D. and the
       Trace Research & Development Center at the University of
       Wisconsin-Madison for the development of the following software
       accessibility development guidelines which have been excerpted for
       inclusion.
       In order to comply with Title II of the Americans with
       Disabilities Act (ADA), the Chancellor's Office strongly
       recommends that California community colleges abide by the
       guidelines excerpted below when purchasing existing software,
       contracting for the development of software or developing software
       in-house.

   Excerpted from the Trace Research & Development Center Accessibility
   Guidelines

   There are many people who need to be able to use standard software
   programs in their jobs, schools or homes but are unable to because of
   the design of the programs or their interfaces. These people, because
   of accident, illness, congenital condition or aging have reduced
   visual, hearing, physical or cognitive/language abilities. The current
   estimate of people with disabilities is over 40 million people - a
   sizable portion of our population.


   Purpose of the guidelines

   The purpose of these guidelines is to document what application
   developers can do (or need to do) in order to make their software
   accessible and usable by people who have disabilities or reduced
   abilities due to aging.

   The guidelines document does this by providing information on the
   problems faced by people with disabilities in using current software
   and documenting ways in which application software can be made more
   accessible and usable by them.


   Basic Component

   Basically, making application software more accessible consists of
   three complementary components

   1. Designing your software so that it is as usable as possible to the
   greatest number of people - without requiring them to use special
   adaptive software or hardware. (This is referred to as Direct
   Accessibility).

   2. Designing your software in such a way that it will work with
   special access features built into the operating system or attached to
   it by users who require them. (i.e., Compatibility with operating
   system or third-party access features / software / devices for those
   people who will not be able to use your software directly.)

   3. Making sure that your documentation, training, and customer support
   systems are accessible.


   A brief summary of the guidelines by disability area follows.


   For people with physical disabilities

   People with physical disabilities can have a wide range of abilities
   and limitations. Some people may have complete paralysis below the
   waist but may have no disability at all with their upper body. Others
   may have weakness overall. Some may have very limited range of motion,
   but may have very fine movement control within that range. Others may
   have little control of any of their limbs, or may have uncontrolled,
   sporadic movements which accompany their purposeful movements. Some
   with arthritis may find that hand and other joint movement is both
   physically limited and limited by pain.

   A physical disability, by itself, does not usually affect a person's
   ability to perceive information displayed on the computer screen.
   Access is generally dependent on being able to manipulate the
   interface.

   Therefore, you can increase the accessibility of your software (both
   direct and via access features/software and hardware):
     * by avoiding timed responses (less than 5-8 sec.) or allowing the
       response time to be changed;
     * by providing keyboard access to all toolbars, menus, and dialog
       boxes (whose functions are not also in the menu);
     * by not interfering with access features built into the operating
       system (e.g. StickyKeys, SlowKeys, Key Repeating etc.).


   For people who are hard of hearing or deaf

   Many users with hearing impairments need to have some method for
   adjusting the volume or for linking sounds more directly to their
   hearing aids. Both of these are hardware considerations and can be met
   with systems having volume controls and headphone or audio jacks.
   Users who have more severe hearing impairments may also use a
   combination of these techniques, as well as techniques for people who
   are deaf. Such techniques generally involve the visual display of
   auditory information.

   Therefore, you can increase the accessibility of your software to
   users with hearing impairments:
     * by providing all auditory information in a visual form as well;
     * by ensuring that all visual cues are noticeable if one is not
       looking at the screen;
     * by having a mode of operation that will work in noisy environments
       or if sound is turned off;
     * by using the ShowSounds feature of the operating system of your
       computer, the user can specify that all sound should be
       accompanied by a visual event including a caption for any spoken
       text which is not already presented on screen.

   In addition, you should make sure that product support people are
   reachable via Text Telephones (also called TDD's or Telecommunications
   Devices for the Deaf).


   For people with color blindness

   You can increase the compatibility of your software with access
   features/software:
     * by making color coding redundant with other means of conveying
       information;
     * by making sure that your program can operate in monochrome mode;
     * by using colors which differ in darkness so that they can be
       distinguished by this as well as color.


   For people with low vision

   People with low vision may have any one of a number of problems with
   their vision ranging from poor acuity (blurred or fogged vision) to
   loss of all central vision (only see with edges of their eyes) to
   tunnel vision (like looking through a tube or soda straw) to loss of
   vision in different parts of their visual field, as well as other
   problems (glare, night blindness, etc.).

   For people with low vision, a common way to access the information on
   the screen is to enlarge or otherwise enhance the current area of
   focus. Given this, you can increase the direct accessibility of your
   software:
     * by allowing the user to adjust the fonts, colors and cursors used
       in your program to make them more visible;
     * by using a high contrast between text and background;
     * by not placing text over a patterned background where the two
       might interfere with each other;
     * by using a consistent or predictable layout for screens and
       dialogs within the program;
     * by providing access to tools, etc., via menu bar;
     * by using recommended line width information when drawing lines (if
       such information is provided by the system).

   In addition, you can increase the compatibility of your software with
   low vision access features/software by using the system pointers
   wherever possible, as well as the system caret or insertion bar if one
   is available.

   If you use your own highlight/focus indicator, drag the system cursor
   with you even if it is invisible. This makes tracking the focus much
   easier for screen enlargement or "pan and zoom" features. If the
   operating system has a High Contrast setting, support it.


   For people who are blind

   Many people who are legally blind have some residual vision. This may
   vary from just an ability to perceive light to an ability to view
   things that are magnified. The best design is for this group is
   therefore one that doesn't assume any vision but allows a person to
   make use of whatever residual vision they may have.

   Access by people who are blind is usually accomplished using special
   screen reading software to access and read the contents of the screen,
   which is then sent to a voice synthesizer or dynamic Braille display.

   On computers which use a graphic user interface this is a bit tricky,
   but there are a number of things that application software developers
   can do to make it possible for people using screen readers to detect
   and figure out what is on the screen. These include:
     * using the system tools wherever you can to; 1) draw and erase all
       text on the screen; 2) display all cursors and pointers;
     * using the system standard controls whenever possible;
     * drawing tools in tool bars, palettes and menus that are separate
       items (rather than one big graphic of toolbar) as this makes it
       possible for screen readers to identify the number, location and
       shape of the individual tools so that they can be identified and
       named.


   You can also increase the compatibility of your software with screen
   readers using the following considerations:
     * if text is embedded in a graphic image, using a special technique
       to make the text known to screen reading software (see detailed
       notes);
     * if you use your own highlight or focus techniques, dragging system
       cursors with you (even if invisible);
     * using consistent or predictable screen and dialog layouts;
     * not using popup help balloons that disappear if the focus changes
       unless there is a way to lock them in place so that the focus
       (e.g., cursor) can be moved there to read them;
     * using single column text whenever possible;
     * giving controls logical names, even if the name is not visible on
       screen (screen readers can access this information and use it to
       describe the type and function of the control on the screen);
     * providing keyboard access to all tools, menus, and dialog boxes.


   Since screen readers can only read text (or give names to separately
   identifiable icons or tools) it is a good idea to:
     * avoid unlabeled "hot spots" on pictures as a control scheme
       (unless redundant with menu selection);
     * avoid non-text menu items when possible or incorporate cues
       (visible or invisible) (screen readers can `see' text that is
       written to screen in an invisible color);
     * avoid non-redundant graphic tool bars if possible.


   Finally, you can make your documentation and training materials more
   accessible:
     * by designing all documentation and on line help so that it can be
       understood by reading the text only (e.g. information presented in
       pictures and graphics is also presented with a description in
       text);
     * by providing synchronized running audio descriptions for all
       information presented as an animated graphic or movie (descriptive
       narration).


   For people with language or cognitive disabilities

   This is perhaps one of the most difficult areas to address. Part of
   the difficulty lies in the tremendous diversity that this category of
   persons with disabilities represents. It includes individuals with
   general processing difficulties (developmental disabilities, brain
   injury, etc.), people with very specific types of deficits (short term
   memory, inability to remember proper names, etc.), learning
   disabilities, language delays, and more. In addition, the range of
   impairment within each of the categories can (like all disabilities)
   vary from minimal to severe, with all points in between. In general,
   software that is designed to be very user friendly can facilitate
   access to people with language or cognitive impairments.

   Somewhat more specifically, you can increase the accessibility of your
   software without reducing academic rigor:
     * by making sure that all messages and alerts stay on screen until
       they are dismissed;
     * by making language as straightforward as possible, both on screen
       and in the documentation;
     * by using simple and consistent screen layouts.

   In addition, because print disabilities are more common among people
   with language and cognitive impairments, you can increase the
   accessibility of your software by ensuring that it is compatible with
   screen reading software.


   For people with disabilities in general


   Finally, you can increase the overall accessibility of your software
   without reducing academic rigor:
     * by making sure that your documentation is available in electronic
       form (that can be accessed by screen reading software) so that it
       is available to people who cannot handle or read your printed
       manuals;
     * by making sure that your product support people are aware of
       disability access issues and are aware that people with
       disabilities routinely use your products;
     * by having particular product support people identified who
       specialize in handling any incompatibility associated with the use
       of your product with disability access products (all support
       people should be able to handle regular product use questions of
       people who have disabilities, but it is usually helpful to focus
       incompatibility problems to a few people who can become more
       familiar with the issues and work arounds);
     * by forwarding any access or compatibility problems identified by
       product support people to product designers (and setting lower
       trigger levels for incidence vs. priority for fixing).


   The complete text of these guidelines can be found at:
   http://www.trace.wisc.edu/docs/software_guidelines/toc.htm

   Please see Appendix V for supplemental information about development
   of accessible software.


   _________________________________________________________________

   Appendix I



   Copyright Issues


   Copyright Law Amendment, 1996
   PL 104-197
   December 1996

   Background

   The free national library program of reading materials for visually
   handicapped adults administered by the National Library Service for
   the Blind and Physically Handicapped (NLS), Library of Congress, was
   established by an act of Congress in 1931. The program was expanded in
   1952 to include blind children, in 1962 to include music materials,
   and in 1966 to include individuals with physical impairments that
   prevent the reading of standard print.

   From the beginning, this program was dependent upon the cooperation of
   authors and publishers who granted NLS permission to select and
   reproduce in special formats copyrighted works without royalty.
   Although many factors influence the length of time it takes to make a
   print book accessible in a specialized format, the period required to
   obtain permission from the copyright holder has sometimes been
   significant.

   Public Law 104-197

   Under the Legislative Branch Appropriations Bill, H.R. 3754, Congress
   approved a measure, introduced by Senator John H. Chafee (R-R.I.) on
   July 29, 1996, that provides for an exemption affecting the NLS
   program. On September 16, 1996, the bill was signed into law by
   President Clinton.

   The Chafee amendment to chapter 1 of title 17, United States Code,
   adds section 121, establishing a limitation on the exclusive rights in
   copyrighted works. The amendment allows authorized entities to
   reproduce or distribute copies or phonorecords of previously published
   nondramatic literary works in specialized formats exclusively for use
   by blind or other persons with disabilities.

   The act making appropriations for the Legislative Branch for the
   fiscal year ending September 30, 1997, sets forth the Chafee amendment
   as follows:


   Be it enacted by the Senate and House of Representatives of the United
   States of America in Congress assembled, that .

   . . and for other purposes, namely:

   (a) IN GENERAL-Chapter 1 of title 17, United States Code, is amended
   by adding after section 120 the following new section:

   "SEC.121. Limitations on exclusive rights: reproduction for blind or
   other people with disabilities

   "(a) Notwithstanding the provisions of sections 106 and 710, it is not
   an infringement of copyright for an authorized entity to reproduce or
   to distribute copies or phonorecords of a previously published,
   nondramatic literary work if such copies or phonorecords are
   reproduced or distributed in specialized formats exclusively for use
   by blind or other persons with disabilities.

   "(b)

   (1) Copies or phonorecords to which this section applies shall-

   "(A) not be reproduced or distributed in a format other than a
   specialized format exclusively for use by blind or other persons with
   disabilities;

   "(B) bear a notice that any further reproduction or distribution in a
   format other than a specialized format is an infringement; and

   "(C) include a copyright notice identifying the copyright owner and
   the date of the original publication.

   "(2) The provisions of this subsection shall not apply to
   standardized, secure, or norm-referenced tests and related testing
   material, or to computer programs, except the portions thereof that
   are in conventional human language (including descriptions of
   pictorial works) and displayed to users in the ordinary course of
   using the computer programs.

   "(c) For purposes of this section, the term-

   "(1) `authorized entity' means a nonprofit organization or a
   governmental agency that has a primary mission to provide specialized
   services relating to training, education, or adaptive reading or
   information access needs of blind or other persons with disabilities;

   "(2) `blind or other persons with disabilities' means individuals who
   are eligible or who may qualify in accordance with the Act entitled
   `An Act to provide books for the adult blind,' approved March 3, 1931
   (2 U.S.C. 35a; 46 Stat. 1487) to receive books and other publications
   produced in specialized formats; and

   "(3) `specialized formats' means Braille, audio, or digital text which
   is exclusively for use by blind or other persons with disabilities."

   (b) TECHNICAL AND CONFORMING AMENDMENT-The table of sections for
   chapter 1 of title 17, United States Code, is amended by adding after
   the item relating to section 120 the following:

   "121. Limitations on exclusive rights: reproduction for blind or other
   people with disabilities."


   _________________________________________________________________



   Braille

   Braille is a system of reading and writing for blind individuals. The
   basic unit of Braille is the Braille cell. It is composed of six dots:
   the upper left dot is dot 1, the middle left dot is dot 2, the lower
   left dot is dot 3, the upper right dot is dot 4, the middle right dot
   is dot 5, and the lower right dot is dot 6. From these six dots you
   can get 64 possible combinations.

   dot 1 ** dot 4

   dot 2 ** dot 5

   dot 3 ** dot 6


   There are many more inkprint symbols than the 64 Braille symbols. For
   example, most computer systems handle about 96 different inkprint
   symbols. Braille can show a wide number of different inkprint symbols
   by using one or more Braille cells for each inkprint symbol.

   Braille only has one set of letters. By itself, a Braille letter is
   assumed to be in lower case. To show an uppercase letter, put the
   capitalization indicator (dot 6) in front of a Braille letter. To show
   an uppercase word, you put two capitalization indicators in front of
   the word. The number sign (used to indicate a number) is dots 3-4-5-6.
   This symbol comes just before the number.

   An important thing to realize about Braille is that you cannot write
   the dot patterns smaller or larger. An 11-1/2 by 11 inch piece of
   Braille paper contains about 900 Braille cells. The Braille Planets
   cause Braille volumes to be much bulkier than inkprint.

   To reduce the bulkiness of Braille there is a system of Braille
   contractions, or abbreviations. A Braille contraction is a combination
   of one or more cells used to shorten the length of a word. For
   example, to write the word "mother", you would use a two-cell
   contraction rather than spelling out the word "mother". Just because a
   contraction can be used does not mean it should be used. The word
   "chemotherapy" contains the sequence "mother". Some Braille
   translation programs are smart enough to know not to use the
   contraction for "mother" in "chemotherapy" (most of the Braille rules
   are based on pronunciation; you do use the "mother" contraction in
   "smother", since this is pronounced like "mother").

   In Braille, if you have the letter "d" with a space or punctuation on
   either side, the "d" stands for the word "do". To show you really mean
   the isolated letter "d", precede it with a Braille cell called the
   letter sign, dots 5-6. This alerts the Braille reader to the fact that
   the next letter is to be read as a letter of the alphabet rather than
   an abbreviation.

   Decoding Braille by comparing inkprint and Braille sequences can be
   tricky. The words "to", "into", and "by" are jammed up against the
   next word in Braille. The words "a", "the", "for", "of", and, "and"
   within Braille are single cells which can be jammed up against each
   other. For example, "with" is a single cell with spaces on either
   side, but "withthe" comes out as two cells jammed together. Numbers
   use the number sign followed by the letters a-j (312 comes out as
   #cab). One Braille cell means "dis" if it shows up in the beginning of
   a word, means "dd" if it shows up in the middle of a word, and is used
   for the period punctuation symbol if it shows up at the end of a word.

   There are several grades of Braille. Grade I Braille does not contain
   any contractions (abbreviations), but it does represent
   capitalization, numbers, and punctuation with the correct Braille
   symbols. Grade I Braille is used only for specialized applications
   where the Braille contractions might be confusing, such as in spelling
   lists. Grade II Braille is the most commonly used in North America. It
   not only represents capitalization, numbers, and punctuation marks
   with the proper symbols, but it uses the various contractions.


   Braille Format

   Another component of Braille is format. When material is laid out on
   paper for the sighted reader, it is done so for visual effect. The
   reader is attracted to what is pleasing to the eye. However, in
   Braille the object is maximization of space. Due to the bulkiness of
   Braille volumes, you want to put as much material as possible on the
   page, while at the same time maintaining readability.

   According to the Library of Congress, which oversees standards and
   trains Braille transcribers for Braille production, there are certain
   criteria for the output page. A page of Braille contains a maximum of
   about 40 characters per line and 25 lines per page. For normal
   literary format (style sheet LITERARY) the Braille page number appears
   at the upper right-hand corner of each page. However, you may need to
   change these values according to the specifications of your Brailler.

   Because of the physical (rather than visual) nature of Braille, format
   standards are especially important. Small differences in where text is
   placed on the page can tell the Braille reader a lot about what they
   are reading. In any Braille format, with or without a Braille
   translation program, certain elements are especially crucial
   components of page layout. These include treatment of indent and
   runover, Braille page numbers, inkprint page indicators, and running
   heads.

   One of the major differences between Braille and print format pertains
   to paragraphs. Rather than having an indent of five spaces, Braille
   paragraphs have a two cell indent. The first character of the
   paragraph begins in cell three. There are no blank lines between
   paragraphs. Except in special circumstances, you do not put two or
   more spaces in a row in Braille. Thus only one space is used between
   sentences.

   When material is underlined or emphasized in print, there are
   different ways of indicating it. In Braille there are italics marks
   which indicate something is being emphasized. A special symbol of dots
   4-6 is placed before each word to be emphasized if there are three or
   fewer words in a row. If four or more words are emphasized, a double
   italics sign (dots 4-6, dots 4-6) is placed before the first word. A
   single italics sign (dots 4-6) is placed in front of the last
   emphasized word. Please note that you do not show all uses of inkprint
   emphasis in Braille. Emphasis is only used in headings when it is
   necessary to preserve the distinctions shown in inkprint.


   Indent and Runover

   Instructions for Braille transcribing often say indent to cell #. The
   farthest left position in which a cell may appear is cell 1. The
   farthest right position ranges from cell 30 to cell 40, depending on
   the carriage width of your Brailler.

   The placement of the first cell in a paragraph is called the indent.
   When transcribing instructions say, Indent to cell 3, put the first
   cell of that segment in cell 3, regardless of where the preceding line
   began. The position at which all subsequent lines of the same segment
   begin is the runover. When instructions say, Runover to cell 1, begin
   all subsequent lines of that segment in cell 1. If instructions say,
   Indent to cell 7, runover to cell 5, begin the first line of that
   segment of text in cell 7, and all subsequent lines in cell 5.

   Sometimes, the indent is a smaller number than the runover, as in,
   Indent to cell 1, runover to cell 5. In print, this is called
   outdenting, or a hanging indent. In Braille, the position of the first
   cell of a segment of text is always called the indent, regardless of
   whether it is to the left or the right of the remaining text.

   Another common Braille instruction is block, as in, Block to cell 5.
   This simply means that the indent and the runover are equal to each
   other. It is the same as saying, Indent to cell 5, runover to cell 5.


   Headings

   There are three kinds of headings in Braille: major headings, minor
   headings, and paragraph headings

   A major heading is centered, with a blank line before the heading, and
   a blank line after it. Some Braille groups do not put a blank line
   after a major heading. Technically, this is a violation of the rules
   for Braille.

   A minor heading is blocked to cell five. This means that the heading
   starts on the fifth cell of the line. Any runover also starts on the
   fifth cell of the line. Usually, there is a skipped line before a
   minor heading, but not after a minor heading.

   A paragraph heading is a line or phrase in italics (or some other
   emphasis) that labels a paragraph and is immediately followed by text
   on the same line. If this is done in inkprint, do the same in Braille,
   using italics.

   Braille rules require that there be at least one line of body text
   after a heading or headings on the same page. If there is not enough
   room on the page for the heading(s) and a line of body text, then the
   heading(s) need to be postponed to the top of the next Braille page.

   Before you start a Braille project, you need to structure the
   document. You need to analyze how many levels of headings there are.
   You need to decide which of these should be done as a major heading,
   and which should be done as a minor heading.


   Braille Page Numbers

   As in print, each physical page in a Braille volume is given a
   sequential page number. This Braille page number merely orders the
   pages in the book. It does not provide the reader with any information
   about the pagination of the inkprint original. The Braille page
   numbers appear in different spots in different formats.

   Print Page Indicators

   Many Braille formats consider the Braille reader's need to know where
   each inkprint page begins. When required, inkprint page indicators
   appear in addition to the sequential Braille page numbers. Textbooks
   are one instance where this information is essential. With it, the
   Braille reader can follow class discussion, locate homework
   assignments, and generally keep up with the users of the inkprint
   original.

   A single print page usually occupies several Braille pages. For
   example, if inkprint page 87 is found on three Braille pages, then
   these are marked with inkprint page indicators 87, a87, and b87.

   Inkprint page indicators are also extremely useful when transcribing
   anything that has a table of contents or an index. When inkprint page
   indicators are not included on the Braille page, indexes and such must
   be completely rewritten to refer to the Braille page numbers. When
   inkprint page indicators are included, then page numbers may be
   transcribed exactly as they appear in print.

   Running Heads

   Many Braille formats require that the title of the work being
   transcribed appear on the first line of every page, with an
   appropriate page number. When the title is too long to fit on one
   line, it is abbreviated. The running head never uses more than one
   line.

   Literary vs. Textbook Format

   Whenever you begin a new transcribing project, with or without a
   Braille translation program, there is some planning to do before you
   start data entry. There are a number of things to look for in the
   first scan through the book: Check to see if there are a large number
   of foreign words, a table of contents or index, and graphs or pictures
   in the book.

   One of the first things you must decide is whether to use textbook or
   literary format. Sometimes, the agency that assigns the transcribing
   job makes this decision for you. Here are some guidelines for when you
   have to decide yourself. Textbook format uses inkprint page
   indicators; literary format does not. When there is any possibility
   that the Braille reader needs inkprint page indicators, use textbook
   format. Both formats may be used with or without running heads.
   Textbook and literary formats are also different from each other in
   the way they handle preliminary pages, indexes, and certain special
   cases such as tables and graphs.

   In general, literary format allows the transcriber a certain amount of
   latitude. The overriding concern of textbook format is to represent
   things in Braille EXACTLY as they appear in print. Anything added or
   omitted in the transcribing process must be explained in a
   transcriber's note.


   Literary Format

   In literary format without a running head, text appears on every line
   of the Braille page. The Braille page number appears in the rightmost
   cells of the first line, with at least three blank cells before the
   number. Text on the first line must break to allow room for this.

   Literary format with a running head has text on lines 2 through 25.
   Line 1 begins with at least three blank cells, followed by the running
   head, at least three more blank cells, and the Braille page number.

   Textbook Format

   The major difference between textbook and literary formats in the main
   body of text is inkprint page indicators. Textbook format has them;
   literary format doesn't. For textbook format with no running head,
   text appears on every line. On line 1, the inkprint page indicator
   appears in the rightmost cells with at least three blank cells before
   it. The Braille page number appears in the rightmost cells of the last
   line on the page. Again, at least three blank cells are placed before
   the Braille page number.

   Textbook format with a running head has text on lines 2 through 25.
   Line 1 begins with at least three blank cells, followed by the running
   head, at least three more blank cells, and the inkprint page
   indicator. Line 25 breaks the text to allow room for three blank cells
   and the Braille page number at the end of the line.

   The California Community Colleges Chancellor's Office gratefully
   acknowledges the work of Braille Planet in creating this excellent
   overview of Braille.



   Braille Production Facilities

   Dozens of commercial Braille production companies are available to
   colleges wishing to outsource. The majority of these resources have
   Web addresses and accept electronic submission of materials to be
   Brailled. Prices, production times and quality vary. Three of the
   largest are:


   National Braille Press
   88 St. Stephen Street
   Boston, MA 02115
   Phone: (617) 266-6160
   Toll-free: (800) 548-7323
   Fax: (617) 437-0456
   http://www.nbp.org/


   The American Printing House for the Blind, Inc.
   1839 Frankfort Avenue
   Mailing Address: P.O. Box 6085
   Louisville, Kentucky 40206-0085
   U.S.A.
   Phone: 502-895-2405
   Toll Free Customer Service: 800-223-1839 (U.S. and Canada)
   Fax: 502-899-2274
   http://www.aph.org/contact.htm


   Braille Institute
   741 N. Vermont Avenue
   Los Angeles, CA 90029
   (323) 663-1111
   FAX: (323) 663-0867
   http://www.brailleinstitute.org/Press.html


    Other Braille Transcriber Services

   Braille Transcribers
   http://www.spedex.com/directories/braille.htm

   Braille Jymico Inc.
   http://www.braillejymico.qc.ca/products.htm

   NMSU List of Braille Transcription Resources
   http://www.nmsu.edu/Resources_References/access/public_html/trans.html

   Quik-Scrybe
   http://www.quikscrybe.com/


   _________________________________________________________________

   BRAILLE INSTITUTE
   EDUCATION AND AWARENES

   A Guide To Large Print For People With Low Vision


   Many people with visual impairments beyond those correctable by
   prescription lenses still read, often with the assistance of special
   aids such as lighting or magnification devices. People with reduced
   sight often find that conventional print appears blurred, dim and very
   difficult, if not impossible, to read. Central damage to the retina,
   for example, prevents some people from seeing small print clearly and
   reduces their ability to move their eyes in the ways needed for
   reading. Text can be made more legible for some of these readers
   through the use of large print. There are many factors to consider
   when producing large-print material, and it is important to note that
   the variety of visual impairment and subsequent impact on the ability
   to read is extensive.

   CONTRAST: Text should be printed with the highest possible contrast.
   Use of boldface type generally provides greater legibility, as the
   letters are darker and thicker. Black or dark blue inks are preferable
   to lighter colors. Color backgrounds generally should be avoided,
   although some studies suggest that black ink on a bright yellow
   background is easy to read. Buff, cream or light yellow backgrounds
   usually are acceptable, but not dark or bright color backgrounds. Some
   visually impaired people are unable to distinguish type at all with
   black ink on a dark red background.

   REVERSE type-"white" type on a dark background-improves readability
   for some. Reverse type often is an available option with some
   computers and special closed-circuit cameras used for reading, and
   might be good for some signs or other items with limited text.
   Backgrounds should be solid.

   SIZE: Type often is measured in points and should be as large as
   practical. Text should be 14 points or larger, preferably 18 points.
   Headlines should be at least 24 points, larger if possible.

   LEADING: The spacing between lines of text, called leading, should be
   greater than that traditionally used in regular text. Many people with
   Iow vision have difficulty finding the beginning of the next line when
   reading if the lines of type are too close together. A ratio of 150
   percent (12-point type receives 18-point leading) is a good guideline
   for text.

   STYLE: An ordinary typeface, such as this one (Helvetica), a
   sans-serif font (one without the fine lines projecting from the main
   strokes of letters found on some fonts, such as Palatino or Times,
   usually is the best choice for large print. Other styles of type
   frequently used in regular print are not easily read by people with
   Iow vision. These include ALL CAPS, SMALL CAPS, italics and ornate,
   decorative fonts like this. Text should be in Upper and Lower Case,
   with wider spacing between lines, for maximum readability.

   LETTER SPACING: The spacing (track) between individual letters on each
   line should be wider than usual whenever possible. Text with close
   letter spacing is particularly difficult for partially sighted readers
   who have central visual field defects.

   MARGINS: Extra-wide binding margins are very helpful in large-print
   books and other bound material because they make the volumes easier to
   hold flat. Many visual aids, such as stand and video magnifiers, are
   easier to use on a flat surface.

   PAPER: Paper with a glossy finish can interfere with legibility
   because it tends to catch and reflect the glare of lights in a room.
   Glare is a common problem for many readers who are partially sighted.
   Print on paper with a matte (dull) finish whenever possible. Those
   wishing to use recycled paper will find a good selection of paper
   stock. Ink type-petroleum-based versus soy-based-is not a factor.

   ALIGNMENT of text, hyphenation of words and other factors can slow a
   reader who is visually impaired and are worth considering when
   producing materials for this audience. Text created "flush left" is
   easiest to read. Paragraphs indented too far (.125 inches is a
   suggested maximum) might be replaced by paragraphs with extra space
   between them.

   Text that is centered is harder to follow because the reader must
   search for the start of each line.

   Text created "flush right" also is a potential problem.

   Text that is "justified" appears to create no special problems,
   although many computer programs typically compact some type when this
   alignment is used, which can reduce the readability. Justified type
   also uses a lot of hyphenation, which can slow the reading process for
   someone who is visually impaired to a greater degree than it does for
   sighted readers.

   When producing large-print materials for people with reduced sight,
   keep the above principles in mind and your readers will be able to
   make full use of their remaining vision.


   Los Angeles Sight Center (213) 663-1111
   Desert Center (760) 321-1111
   San Diego Center (619) 452-1111
   Santa Barbara Center (805) 682-6222
   Orange County Center (714) 821-5000
   Youth Center (213) 851-5695
   www. brailleinstitute.org


   _________________________________________________________________

    Appendix II


   Telephone Relay Services

   Telephone Relay Services (TRS) link people using a standard (voice)
   telephone with people using a device called either a Text Telephone
   (TTY) or Telecommunications Device for the Deaf (TDD). This device
   generally consists of a keyboard and display screen. Calls are routed
   through a communications operator who has both sets of equipment and
   who acts as the intermediary between callers. Such services eliminate
   communications barriers between people with and without hearing/speech
   impairments, and between the different telephone equipment they
   typically use. Tip: Relay service calls take longer due to the
   communications operator's "translation" to/from voice and text. It
   helps to organize your thoughts and any material you will need,
   beforehand.

   Dialing Instructions:

   TTY/TDD Origin
     * Dial the TTY/TDD number of the relay services.
     * The communications operator will answer by typing his/her personal
       ID number. (relay call conventions will be explained if you have
       not used them before).
     * Type the voice number you wish to call. The operator will connect
       you.


   Voice Origin
     * Dial the voice number of the relay service.
     * The communications operator will answer by speaking his/her
       personal ID number. (relay call conventions will be explained if
       you have not used them before).
     * Speak the TTY/TDD number you wish to call. The operator will
       connect you.


   Nationwide Long Distance Relay Services

   AT&T

   800-855-2880 (TTY/TDD)
   800-855-2881 (Voice)
   800-855-2882 (Computer)
   800-855-2883 (Telebraille)
   800-855-2884 (Spanish-TTY/TDD)
   800-855-2885 (Spanish-Voice)
   800-855-855-2886 (Spanish-Computer)

   MCI

   800-688-4889 (TTY/TDD)
   800-947-8642 (Voice)

   Sprint

   800-877-8973 (Voice & TTY/TDD)


   Real-Time Transcription

   On-Site Classroom Captioning

   Rapidtext is a leading provider of qualified classroom captioning or
   interpreting. Transcribers attend class and write the spoken word on a
   steno machine. This process instantly creates English text so that one
   or more hearing impaired students may not only see what is being said,
   but non-oral students can utilize the keyboard to ask questions. These
   questions are usually read aloud by the Rapidtext captionist. At the
   end of the class session, the hearing impaired students can have a
   diskette or hard copy of the class notes. This solution is
   unparalleled for even the most technical classes and graduate studies.
   This meets ADA requirements for the hearing impaired and is extremely
   effective for learning disabled and English as a Second Language (ESL)
   students.

   Remote Captioning

   The benefits are identical to the Classroom Captioning description
   except that the captionist/steno interpreter is located remote to the
   class setting. The captionist can be located in another building,
   another city, or in our office. The captionist hears what is being
   said via a telephone line, and sends back the captions to a computer
   in the classroom or to the Rapidtext Infosign for the instant display
   of the spoken work. This can work very simply by using a speakerphone
   in the classroom or a lapel microphone on the teacher. Also, the class
   notes are available at the end of the class session. This solution
   meets ADA requirements for the hearing impaired and can be very easy
   to staff for the erratic class schedule by dealing only with
   Rapidtext.

   Captioning for Public Events, Seminars, Meetings

   Rapidtext can provide either on-site or remote captioning/interpreting
   for any event. Captions can be displayed on one or more computer
   monitors, video monitors, projection televisions, or Rapidtext
   Infosigns. Even special interfaces can be developed for sports arena
   scoreboards or special display devices. Rapidtext has captioned events
   of all sizes, including our president's speech, and that was outdoors.
   Transcripts can be provided of the events or seminars. Ensure that you
   meet ADA requirements for your next event.

   RapidText
   http://www.rapidtext.com/


   Interpreter Services

   What is Interpreting?

   Interpreting, simply stated, is receiving a message in one language
   and delivering it in another. Not as simple as it sounds, interpreting
   is a complex process that requires a high degree of linguistic,
   cognitive and technical skills.

   Professional sign language interpreters develop interpreting skills
   through extensive training and practice over a long period of time.
   Interpreters continue to actively improve their skills, knowledge, and
   professionalism through membership in RID. An increasing number of
   interpreters have completed college or university interpreter
   education programs, earning associates, bachelors, and/or masters
   degrees in interpreting. Some interpreters have also obtained advanced
   degrees in related fields such as linguistics or cultural studies.

   Sign language interpreting is a highly specialized field; simply
   knowing both sign language and English does not qualify a person as an
   interpreter. The professional sign language interpreter is able to
   adjust to a broad range of deaf consumer preferences and/or needs for
   interpretation. Some deaf individuals use American Sign Language, a
   natural language with its own grammar and structure that is distinct
   from English. Others prefer a form of signing that more closely
   follows the grammar and structure of spoken English. The professional
   interpreter is expected to work comfortably along this wide spectrum.
   Sometimes it is necessary to have two or more interpreters working
   simultaneously in order to satisfy the preferences and needs of a
   varied audience. On occasion, one of the interpreters may be a deaf
   individual or a person fluent in a language other than English or
   American Sign Language. Interpreters should be aware of and sensitive
   to ethnic/cultural and linguistic concerns.

   Where professional interpreters work

   Interpreters work in a variety of settings and situations. Many
   interpreters work in private practice; they are self-employed. From
   scheduling assignments to handling billing, the interpreter is
   responsible for all business aspects. The private practice interpreter
   may also receive assignments through interpreter service agencies.
   Other interpreters are salaried staff of an agency, institution, or
   corporation. Still others interpret in educational settings from
   pre-school to graduate school and any level in between. Interpreters
   work in settings as intimate as a private therapy session or as public
   as a televised address at a national political convention. The
   interpreter must be a versatile, flexible, skilled professional.


   Interpreter Ethics

   The Registry of Interpreters for the Deaf, Inc. has set forth the
   following principles of ethical behavior to protect and guide
   interpreters and transliterators and hearing and deaf consumers.
   Underlying these principles is the desire to insure for all the right
   to communicate.

   This Code of Ethics applies to all members of the Registry of
   Interpreters for the Deaf, Inc. and to all certified non-members.
     * Interpreters/transliterators shall keep all assignment-related
       information strictly confidential.
     * Interpreters/transliterators shall render the message faithfully,
       always conveying the content and spirit of the speaker using
       language most readily understood by the person(s) whom they serve.
     * Interpreters/transliterators shall not counsel, advise or
       interject personal opinions.
     * Interpreters/transliterators shall accept assignments using
       discretion with regard to skill, setting, and the consumers
       involved.
     * Interpreters/transliterators shall request compensation for
       services in a professional and judicious manner.
     * Interpreters/transliterators shall function in a manner
       appropriate to the situation.
     * Interpreters/transliterators shall strive to further knowledge and
       skills through participation in workshops, professional meetings,
       interaction with professional colleagues, and reading of current
       literature in the field.
     * Interpreters/transliterators, by virtue of membership or
       certification by the RID, Inc., shall strive to maintain high
       professional standards in compliance with the Code of Ethics.


   Interpreting Credentials

   In the field of interpreting, as in other professions, appropriate
   credentials are an important indicator of an interpreter's
   qualifications. The Registry of Interpreters for the Deaf (RID) awards
   certification to interpreters who successfully pass national tests.
   The tests assess not only language knowledge and communication skills,
   but also knowledge and judgment on issues of ethics, culture and
   professionalism. An interpreter may hold one or more certifications.
   Information on certifications is available from RID.

   Some common sign language interpreting certifications are:

   CI-Certificate of Interpretation
   CT-Certificate of Transliteration
   CSC-Comprehensive Skills Certificate
   SC:L-Specialist Certificate: Legal
   IC-Interpretation Certificate
   TC-Transliteration Certificate
   CDI-Certified Deaf Interpreter



   _________________________________________________________________


   Appendix III


    Captioning


   FEDERAL COMMUNICATIONS COMMISSION ADOPTS RULES FOR VIDEO CLOSED
   CAPTIONING

   (MM DOCKET 95-176)


   The Commission has adopted an order (FCC 97-279) establishing rules to
   implement the closed captioning requirements of the Telecommunications
   Act of 1996. The 1996 Act required the Commission to adopt, by August
   8, 1997, rules and implementation schedules for captioning of video
   programming ensuring access to video programming by persons with
   hearing disabilities. This order implements Section 305 of the 1996
   Act which added a new Section 713, Video Programming Accessibility, to
   the Communications Act. These rules will increase the amount of closed
   captioned video programming available to the more than 22 million
   Americans with hearing disabilities.

   Congress generally required that video programming be closed
   captioned, regardless of distribution technology, to ensure access to
   persons with hearing disabilities. Congress also recognized that in
   some situations requiring that programming be closed captioned might
   prove to be an undue burden on video programming providers or owners
   and authorized the Commission to exempt classes of programs or
   services for which provision of video programming would be
   economically burdensome.

   Some of the key elements in the order adopted today include:

   Video programming distributors will be responsible for compliance with
   captioning requirements. This is the most efficient and focused way to
   ensure compliance.

   Video programming distributors include all entities who provide video
   programming directly to customers' homes, regardless of distribution
   technology used (i.e., broadcasters, cable operators, MVPDs and
   other).

   That new programming (video programming first published or exhibited
   on or after January 1, 1998) is made "fully accessible," as required
   by Section 713. The rules establish an 8 year transition period and
   define full accessibility as the closed captioning of 95% of nonexempt
   new programming. Compliance will be measured on a channel-by-channel
   basis for MVPDs and will be measured over each calendar quarter. Three
   benchmarks are established during the transition period. These
   benchmarks are based on average amounts of required captioning of
   approximately 5 hours per day after 2 years, 10 hours per day after 4
   years and 15 hours per day after 6 years. During this transition
   period if these closed captioning requirements exceed the number of
   hours of nonexempt new programming on a channel during the calendar
   quarter, 95% of the nonexempt new programming on a channel must
   contain captions. The Commission will also require video programming
   providers to continue to provide closed captioning at a level
   substantially the same as the average level of captioning that they
   provided during the first six months off 1997, even if the amount of
   captioned programming exceeds that required under the benchmarks.

   That the accessibility of pre-rule programming (video programming
   first published or exhibited before January 1, 1998) is "maximized"
   through the provision of closed captions, as required by Section 713.
   With respect to pre-rule programming that does not meet any of our
   criteria for exemption, at least 75% of such programming must contain
   closed captions at the end of a ten year transition period. Compliance
   will be measured on a per-channel, quarterly basis. The Commission
   expects that the amount of captioning of such programming will
   increase incrementally over the transition period and does not set
   specific benchmarks for pre-rule programming. During the transition
   period the Commission will monitor distributor's efforts to increase
   the amount of captioning to determine whether channels are progressing
   toward the 75% requirement. The Commission also will reevaluate its
   decision to determine whether specific benchmarks are necessary to
   increase captioning and whether the 75% threshold for maximizing the
   accessibility of pre-rule programming is the appropriate amount to
   meet the goals of the statute.

   Exemptions based on economic burden:

   The rules exempt from our closed captioning requirements several
   specific classes of programming for which such requirements would be
   economically burdensome. These include: non-English language
   programming, primarily textual programming, programming distributed
   late at night, interstitial announcements, promotional programming and
   public service announcements, certain locally-produced and distributed
   programming, non-vocal musical programming, ITFS programming and
   programming from new networks.

   The rules further exempt any video programming provider from closed
   captioning requirements where the provider has annual gross revenues
   of less than three million dollars. Advertisements of less than 5
   minutes are not included in the definition of covered programming
   here. The rules also permit some smaller video programming providers
   to caption less than the specified benchmark amounts of their
   programming by permitting them to cap their spending on closed
   captioning based on their gross revenues.

   Exemptions based on existing contracts:

   The rules will exempt any programming subject to a contract in effect
   on February 8, 1996, for which compliance with the closed captioning
   requirements would constitute a breach of contract.

   Exemptions based on undue burden:

   The Commission will consider petitions for exemption from the closed
   captioning rules if the requirements would impose an undue burden
   based on statutory criteria.


   Standards for quality and accuracy:

   Video programming distributors will be required to deliver intact the
   closed captioning they receive as part of the programming they
   distribute to viewers, where the captions do not require reformatting.
   Video programming distributors must maintain and monitor their
   equipment to ensure the technical quality of the closed captioning
   they transmit. The Commission will not adopt standards for the
   non-technical aspects of quality at this time.

   Enforcement process:

   The rules will be enforced through a complaint process. Complaints
   alleging violation of the closed captioning rules must first be
   directed in writing to the video programming distributor responsible
   for distribution of the programming. If a video programming
   distributor fails to respond to a complaint or a dispute remains
   following this initial procedure, a complaint may then be filed with
   the Commission.

   Action by the Commission August 7, 1997, by Order (FCC 97-279).
   Chairman
   Hundt, Commissioners Quello, Ness and Chong, with Chairman Hundt and
   Commissioner Chong issuing separate statements.



   Basic Captioning Terms

   If you are unfamiliar with the process of captioning, this glossary
   can help you understand the most basic terms:


   Off-line captioning:

   Captioning that is produced after a video segment has been recorded. A
   captioner watches the video recording and creates captions, paying
   attention to the timing and screen placement of each caption. The
   captions are usually then recorded on videotape with the program
   picture and sound before the program is broadcast or distributed. Most
   captioned programming is produced off-line.


   Realtime captioning:

   Captions which are simultaneously created and transmitted during a
   video program or conference. This type of captioning is most
   frequently used for live programs, including news shows and sporting
   events. A trained stenotypist, acting in much the same way as a
   courtroom reporter, enters the spoken content by typing phonetic codes
   on a special keyboard that permits high-speed transcription. A
   computer, using custom software, then very quickly translates the
   phonetic codes into proper words. In order to display the words as
   quickly as possible after they are spoken, most realtime captioning is
   shown in a scrolling style.


   Closed captions:

   Captions that appear only when special equipment called a decoder is
   used. Closed captioning is typically used for broadcast television and
   for videocassettes of movies which are widely distributed. Closed
   captioning allows caption users (people who are deaf or hard of
   hearing) to enjoy the same broadcast and pre-recorded video materials
   that other television viewers enjoy.


   Open captions:

   Captions that are visible without using a decoder. When a video is
   open captioned, the captions are permanently part of the picture. Open
   captions are advised for any situation where a decoder may be
   difficult to obtain or operate (for example, in a hotel, convention
   center, or museum). For this reason, open captioning is recommended
   for training and promotional videos.


   Closed caption decoder:

   Equipment that decodes the captioning signal and causes captions to
   appear on the screen. In the 1980s and early 1990s, closed caption
   decoders were usually separate appliances that connected to the
   television set, VCR, and/or cable converter box. Since July 1, 1993,
   all television receivers with screens 13 inches or larger manufactured
   for sale in the United States must have built-in closed caption
   decoders, and the additional appliance will not be needed for these
   sets.


   Roll-up and Pop-On captions:

   These are the two main styles in which captions may appear. Roll-up
   captions scroll onto and off the screen in a continuous motion. Pop-on
   captions do not scroll; the words display and erase entirely together.
   Pop-on captions are used for most off-line captioning. Roll-up
   captions are used for most realtime captioning.


   Captioning Service Providers

   These are links to captioning and subtitling service providers. There
   are no licensing requirements or tests a captioner must meet in order
   to call themselves a captioning service provider.

   The National Association of the Deaf in cooperation with the
   Department of Education operates a Captioned Films/Videos program; and
   the NADCFV has a list of vendors evaluated by the NAD and approved by
   the U. S. Department of Education for CFV captioning. In order to be
   listed, a captioning vendor must submit samples to the NAD for
   approval. Some of the vendors on the NAD/DOE list are represented
   here:


   Captionmax, Inc.
   530 N. 3rd St.
   Minneapolis, MN 55401
   http://www.captionmax.com/

   Caption Perfect
   P.O. Box 12454
   Research Triangle Park, NC 27709-2454
   919-942-0693 (v)
   919-942-0435 (fax)
   http://members.aol.com/captioning/index.html

   Henninger Digital Captioning
   2601-A Wilson Boulevard
   Arlington, Virginia 22201
   phone 703-243-3444
   fax 703-243-5697
   http://www.henninger.com/hcap.html


   National Captioning Institute
   NCI California Office
   303 North Glenoaks Boulevard, Suite 200
   Burbank, CA 91502
   V/TTY (818) 238-0068
   http://www.ncicap.org/


   VITAC
   4450 Lakeside Drive, Suite 250
   Burbank, California 91505
   (888) 528-4822
   (818) 295-2490
   (818) 295-2494 Fax
   http://www.vitac.com/



   _________________________________________________________________



   Appendix IV



   WAI Guidelines for Accessible Web Site Design

   (http://www.w3.org/WAI/)
   _________________________________________________________________


   Appendix V



   Microsoft's Checklist of Accessibility Design Guidelines
   (Reprinted with permission from Microsoft Corporation)

   Basic Principles

   You should follow these basic principles when designing an accessible
   application:

   Flexibility. Provide a flexible, customizable user interface for your
   application that can accommodate the user's needs and preferences. For
   example, you should allow the user to choose font sizes, reduce visual
   complexity, and customize the arrangement of menus.

   Choice of input methods. Support the user's choice of input methods by
   providing keyboard access to all features and by providing access to
   common tasks using simple mouse operations.

   Choice of output modalities. Support the user's choice of output
   methods through the use of sound and visuals and of visual text and
   graphics. You should combine these output methods redundantly or allow
   the user to choose his or her preferred output method.

   Compatibility with accessibility aids. Use programming techniques and
   user-interface elements that are compatible with accessibility aids,
   such as blind access, screen magnification, and voice input utilities.

   Consistency. Make your application's behavior consistent with other
   Windows-based applications and with system standards. For example, you
   should support Control Panel settings for colors and sizes and use
   standard keyboard behavior.


   Keyboard Access

   Providing a good keyboard user interface is key to designing an
   accessible application.
     * Provide keyboard access to all features.
     * Fully document your keyboard user interface.
     * When possible, model your keyboard interface on a familiar
       application or control.
     * Provide underlined access keys for all menu items and controls.
     * Use logical keyboard navigation order.


   If you normally hide some keyboard user interface elements, display
   them when the Keyboard Preference flag is set.
     * Allow the user to select text with the keyboard.
     * Avoid using the GetAsynchKeyState function.
     * If possible, provide customizable keyboard shortcuts.
     * Exposing the Keyboard Focus


   Many accessibility aids need to know where the user is working.
     * Expose the location of the keyboard focus within a window, either
       by moving the system caret or by using ActiveAccessibility.
     * Exposing Screen Elements


   Many accessibility aids need to identify or manipulate the objects on
   the screen.
     * Allow other software to identify and manipulate all screen
       elements that the user interacts with, using Microsoft Active
       Accessibility (which is already supported by standard window
       classes and controls).
     * Ensure that every object, window, and graphic is properly named.
       Define correct text labels for all controls, and give every window
       a user-friendly caption, even if the text is not visible on the
       screen.
     * Support the WM_GETDLGCODE message in all custom controls that have
       their own window, to identify your control type and keyboard
       interface.
     * Provide an alternative to any owner-drawn menus.
     * Display text using appropriate read-write edit, read-only edit,
       status, static, or HTML controls.
     * Make sure that dialog boxes define the correct tab order.
     * Uniquely identify every type of window.
     * Expose names or descriptions for all images and bitmapped text.
     * Give objects labels that are unique within their context and are
       unambiguous when taken out of context.


   If screen contents are not exposed in other ways, support standard
   drawing techniques that can be monitored and recorded. Provide
   alternatives to operations that directly manipulate bitmap or screen
   pixels.


   Color
     * Color should be used to enhance, emphasize, or reiterate
       information.
     * The application must respond properly when the High Contrast
       option is True.
     * Use only colors that the user can customize, ideally through
       Control Panel.
     * Use colors in their proper foreground/background combinations.
     * Omit background images drawn behind text.
     * Where possible, allow the use to customize all colors through
       Control Panel or through its own user interface.
     * When screen elements correspond with standard elements, use the
       appropriate system colors chosen in control Panel.
     * Always use colors in their proper foreground/background
       combinations.
     * If possible, be prepared to draw monochrome images that contrast
       with the background color.
     * Avoid conveying important information by color alone, or make it
       optional.
     * Draw graphic objects to contrast with the current background
       color.
     * Provide an option to omit complex or shaded backgrounds drawn
       behind text.


   Size
     * The size of text and graphics affects usability as well as
       accessibility.
     * The application must be compatible with system settings for sizes
       and fonts. (Logo Requirement).
     * Avoid hard coding any font sizes smaller than 10 points.
     * If you draw lines, determine the proper width rather than using a
       fixed value.
     * Allow the user to select font and font sizes for displayed
       information.
     * Allow the user to adjust the size of non-document elements such as
       toolbars.
     * Make sure the application is compatible with changes to the system
       font size and the number of pixels per logical inch.
     * If feasible, provide a draft mode, zoom, and wrap to window
       features.
     * Stretch, shrink, pad, or crop images appropriately when their
       space changes.
     * Avoid tuning your application too tightly to a single font.


   Sound
     * Do not convey important information by sound alone, or if you do,
       provide an option to convey this information by visual means.
     * Display important information visually when the ShowSounds option
       is True.
     * Provide closed captions for all audio content rendered through
       DirectPlay.
     * Define many custom sound events, even if they are silent in the
       default sound scheme.
     * Trigger standard sound events when carrying out equivalent
       actions.
     * If you generate sounds, provide a way to turn them off.


   Timings
     * Allow the user to customize all user interface timings.
     * Allow the user to avoid having messages time out.
     * Allow slowing down or disabling any rapid screen updates or
       flashing.


   Unexpected Side Effects
     * Moving the mouse should not trigger unexpected side effects
     * Navigating with the keyboard should not trigger unexpected side
       effects.


   Mouse Input
     * Applications must be compatible with specified system settings for
       mouse input.
     * Provide mouse shortcuts for commonly used features.
     * Make toolbars customizable.
     * Emphasize simple mouse operations that require only single clicks.


   Customizable User Interface
     * If possible, allow the user to administrator to customize the
       application to meet specific needs.


   Layout
     * Visual design and layout can make an application more usable and
       more accessible for people with cognitive or visual impairments.
     * Make it easy to recognize the label for each control or object.
     * Place a text label immediately to the left of or above its
       control.
     * Do not separate a control and its label by too great a distance.
     * Do not place unlabeled controls both to the left of and beneath a
       label.
     * All text labels should end with colons, and static text controls
       that do not label other controls should not end in colons.
     * Follow conventions for labeling icons, with text below or to the
       right of the icon, or displayed as a tooltip.
     * Try to position related objects near each other.


   Verifying Accessibility
     * Test the application against this guidelines checklist.
     * Test with the High Contrast option and high contrast appearance
       schemes.
     * Test compatibility with extra-large appearance schemes.
     * Verify that all features can be used without a mouse.
     * Verify that all keyboard user interface methods are documented.
     * Test with the Inspect Objects tool to verify that all screen
       elements are exposed and properly labeled.
     * Test with the Microsoft Magnifier to verify that the keyboard
       focus location is properly exposed during navigation and editing.
     * Test with commercial accessibility aids.
     * Test with changes to the system font size and number of pixels per
       logical inch.
     * Include people with disabilities and accessibility software
       vendors in your beta tests.
     * Include people with disabilities in your usability tests.
     * Conduct surveys of your users who have disabilities.
     * Distribute free evaluation copies of your product to individuals
       with disabilities, disability organizations, and accessibility
       software vendors.


   Documentation
     * Provide documentation in accessible format, such as ASCII text or
       HTML.
     * Accessible documentation should contain descriptions of
       illustrations and tables.
     * Do not convey important information by color or graphics alone.
       Use color and graphics redundantly to the text.
     * Maintain high contrast between the text and its background.
     * Do not use text smaller than 10 points in size.
     * If possible, bind printed documentation to lie flat.


   _________________________________________________________________


   Software Design Guidelines (TRACE Research Center)


   General Design Guidelines

   There are a few general themes that you'll notice occurring repeatedly
   in the specific guidelines in the next section. They are worth noting
   since they provide the rationale for many of the specific guidelines
   and can be used to help make decisions when options exist for a given
   design.
     * Use system tools whenever possible.
     * Maintain consistent, predictable layout & behavior and adhere to
       system standards/style guides.
     * Provide keyboard access to all dialogs, menus, and tools.
     * Design software to minimize the skills and abilities needed to
       operate it.
     * Be sure software cooperates with (or at the least, does not break)
       special access features in the OS and third party access software.
     * Use an open systems approach.



   1. Use system tools whenever possible


   Many software based access programs provide their alternate input and
   display capabilities by tapping into the system software. These access
   systems depend on the application program using the system tools
   provided for input and output. Application programs which do not use
   the system tools may not be accessible to people using special access
   software or features in the operating system.

   For example, alternate input software may take Morse code in and
   convert it into alternate or "counterfeit" keystrokes which it then
   puts into the input cue or buffer just as if they came from the
   keyboard. Application software that takes its keystrokes from the
   input buffer will find these alternate keystrokes and treat them just
   like regular keystrokes. If your application program bypasses the
   input buffer and takes its keystrokes directly from the input
   hardware, then the alternate keystrokes will not be seen and the
   person will not be able to use it.

   Similarly, screen reading software for people who are blind works by
   watching the activity of the text drawing routines in the operating
   system. By watching commands sent to the operating system telling it
   to draw text on the screen, the screen reading software can keep track
   of everything that is written to the screen. If application software
   writes text directly to the screen, then the screen reading software
   will not know that it is there.

   Alternate mouse or pointer routines would also depend on the ability
   to make system and application software think that a person was moving
   the mouse when in fact they were operating a mouse simulation program.


   2. Maintain consistent, predictable layout & behavior and adhere to
   system standards/style guides


   Wherever possible, follow system standards and style guides. For
   people with cognitive disabilities it makes it easier to predict and
   understand how things should operate and what they mean. For people
   who are blind and use screen readers to find out what is on the
   screen, predictable layouts and controls are easier to figure out.
   Also, adaptive software manufactures can build techniques into their
   software to handle the standard objects and appearances, but not
   unique or one of a kind implementations. If you do something
   different, be sure it is accessible (see "Product Testing and
   Developer Support" at the end of Guidelines-Part I.)


   3. Provide keyboard access to all dialogs, menus, and tools


   Application programs which provide the ability to access all of the
   menus by using the keyboard greatly facilitate access by individuals
   who cannot use the standard mouse. It also makes access easier (or
   possible) for people with poor eye hand coordination or those who are
   blind. This access may be provided either by use of the arrow keys to
   move around through the menu structure, or through use of keyboard
   equivalents for ALL menu items.


   4. Design software to minimize the skills and abilities needed to
   operate it


   The best way to view people who have disabilities is to think of them
   simply as individuals with reduced abilities rather than as people
   without an ability. The reduction in their abilities may vary from
   slight to severe. The more you can reduce the sensory, physical, or
   cognitive skills necessary to operate the program, the more people
   will be able to directly use the program. It also makes it easier for
   everyone else to use the program. Some examples: using a slightly
   larger or clearer type, using menus which can be scanned rather than
   commands which must be memorized, keeping menus short and dialog boxes
   uncluttered, reducing or eliminating the need for fine motor control.

   It is also helpful to provide multiple ways of accomplishing functions
   in order to adapt to different needs or weaknesses. For example,
   having pull-down menus reduces the cognitive load and makes it easier
   to operate computers. While providing hot keys reduces the motor load
   and makes it easier and faster for individuals with physical
   disabilities to use computers, providing both addresses the needs of
   both groups and gives all users more options to meet their
   preferences. A second example would be the ability to use either the
   scroll bar or the keyboard to select position within a document.

   The third general strategy is to provide layering to reduce visual and
   cognitive complexity. One example of this are programs which provide
   both short and long forms of their menus. The use of option buttons in
   dialog boxes or other techniques for nesting complexity would be a
   second example of this.


   5. Be sure software cooperates with (or at the least, does not break)
   special access features in the OS and third party access software


   Using system tools and conventions/standards

   As mentioned above, the most important and easiest mechanism for
   ensuring greater compatibility with access software is to use the
   tools and conventions which have been established for the operating
   system. Most access software works through modifications to the system
   tools, or bases its operation on assumptions that the standard
   conventions for the system will be followed. As long as application
   software programs use the system tools and conventions, there is
   generally little problem.

   Provide software access to commands

   When commands are all executed through the menus, access software has
   very little trouble in both accessing listings of the available
   commands and activating the commands. Program commands which are
   issued in other fashions-such as tool bars, special palettes,
   etc.-present problems. It is difficult to get a listing of all of the
   commands (for example, to present to somebody who is blind). It is
   also difficult to directly activate the various commands (for example,
   by an alternate access routine for someone with a severe physical
   disability). Where all of the palette and tool bar commands are
   available via the standard menus, this is not a problem. When these
   commands, however, are not otherwise available, it is important that
   access somehow be achieved.

   Access to commands in a program consists of four parts. Fortunately,
   the movement toward inter-application control is making the commands
   in a program more accessible electronically. Features like balloon
   help are also useful for providing descriptions of the commands and
   buttons on the screen. Eventually, it would be nice to be able to:
     * Obtain a listing of all of the possible commands
     * Obtain help text for each of the commands
     * Be able to execute all of the commands from an external program
     * Be able to read the status of user-settable parameters (and be
       able to set all such parameters) from an external program

   When these capabilities are all available in a standardized format, it
   will make the process of developing access programs much simpler and
   more complete. In the meantime, programs which have most of their
   commands available for inter-program control may consider making the
   rest of the program commands available as well.


   6. Use an open systems approach


   Providing access to people who have disabilities is in many ways just
   a natural extension of the open systems approach to software design.
   Support of the open systems through GOSIP, POSIX, and the applications
   portability profile facilitates compatibility with special access
   software and hardware within these environments. With the rapid
   advance of technologies and operating systems, software that is based
   upon open systems concepts and which retains a stable or similar
   interface format across platforms greatly facilitates the efforts of
   third-party accessibility developers in keeping up and adapting their
   products.


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