Norm,
I think your reading is reasonable. It has real possibility for lighting
fires under vendors, so to speak. It also opens the door a bit wider on the
accessibility of web sites for entities (read "libraries") covered under
Section 504 and ADA.
To add to the conversation, I offer the following as another indication of
movement on the federal level that may have huge impact. To see it - and
related material - go to
http://www.ncd.gov/newsroom/correspondence/powell_02-25-02.html
Audrey
......................................................
Letter to Michael Powell, Chairman, Federal Communications Commission,
February 25, 2002
February 25, 2002
Michael Powell, Chairman
Federal Communications Commission
445 12th Street SW
Washington, DC 20554
Dear Chairman Powell:
On behalf of the National Council on Disability (NCD), I am submitting the
comments below in response to the FCC Notice of Proposed Rulemaking and
Order, In the Matter of 'Schools and Libraries Universal Service Support
Mechanism' CC Docket No. 02-6. As you know, NCD has a statutory charge to
review all policies, programs and activities related to Americans with
disabilities. As you know, NCD has expressed the need for FCC to include
civil rights certifications (e.g., with ADA and related laws) with respect
to the universal service and e-rate program applications and grants.
Therefore, NCD supports the current NPRM's focus on the e-rate and the need
for civil rights certifications by universal service program fund
applicants.
III. Notice of Proposed Rulemaking , A. Application Process, Section 4.
Compliance with the Americans with Disabilities Act, Paragraphs 28 and 29
NCD acknowledges that FCC has included this issue within the current NPRM.
The universal service program has been operating for at least three years
under the auspices of a federal agency.
Civil rights certifications are typically required in federal operated
and/or federally assisted programs. NCD believes that the FCC should adopt
such a practice immediately. Further, NCD believes that an efficiently
designed monitoring system could be put into effect to verify and enforce
compliance based on the results of random monitoring probes.
VI. Procedural Matters, A. Paperwork Reduction Act Analysis, Section 1.
Need for, and Objectives of, the Proposed Rules, Paragraph 84
NCD has supported the need for an ADA certification in the FCC's Universal
Service program for several years (e.g., see, as an example, footnote 58 of
the FCC's current NPRM). To reiterate, without ensuring ADA certification
and compliance (and compliance with related statutes referenced by the ADA)
by recipients of universal service discounts, the FCC cannot ensure that a
fair and equitable distribution of benefits will accrue to millions of
Americans with disabilities. In addition, noncompliance with ADA and other
relevant civil rights statutes would run counter to the current
Administration's stated commitment to the nation's civil rights laws, as
specified in the New Freedom Initiative.
VI. Procedural Matters, A. Paperwork Reduction Act Analysis, Section 5.
Steps Taken to Minimize Significant economic Impact on Small Entities, and
Significant Alternatives Considered, Paragraph 101
NCD recognizes that according to FCC's own assessment "...the following
proposals will have no significant economic impact on small entities:
allowing, under certain circumstances, full discounts on Internet service
that includes content, the proposed modification to the appeals process,
requiring certification of compliance with the ADA, a proposed alteration
to the rules regarding application of tariff rates to consortia, the
proposed rule establishing the right of funding for all successful
appellants and the funding methodology, and possible rule changes affecting
over committed funding requests."
In closing, NCD acknowledges that the FCC is proposing these changes, and
anticipates that, once approved, the changes will make a contribution to a
better performing telecommunications system for people with disabilities
throughout America.
Sincerely yours,
Marca Bristo, Chairperson
National Council on Disability
------------------------------------------------------------------------
-----Original Message-----
From: Prof Norm Coombs [SMTP:[log in to unmask]]
Sent: Friday, February 22, 2002 11:49 PM
To: [log in to unmask]
Subject: This may be a giant break-through re access to databases etc.
Many on this list have been interested in getting vendors especially
database and other online services to make their systems fully accessible.
Note in the mail below that it appears that the Library of Congress may now
have to comply with Section 508. If this is true, can we force LOC to stop
purchasing any databases and online resources that are not accessible?
Many are not sure that college libraries will fully have to comply with 508
and others think they will. However, if the LOC has to comply, then
vendors will rush to keep LOC as a customer. Or I would think they would.
Am I reading the document below correctly or not???
Norm Coombs
>>>>
Date: Wed, 13 Feb 2002 14:55:11 -0500
From: [log in to unmask] (Martin Gould)
Subject: Re: GAO Report - Universal Service Report
Sender: [log in to unmask]
To: [log in to unmask]
Reply-to: [log in to unmask]
X-VMS-To: IN%"[log in to unmask]"
User-Agent: Mozilla/5.0 (Windows; U; Windows NT 5.0; en-US; rv:0.9.4)
Gecko/20011128 Netscape6/6.2.1
X-Accept-Language: en-us
Hello:
NCD applauds the November 19 announcement by the Congressional Office of
Compliance recommending that Section 508 of the Rehabilitation Act of 1973,
which requires access to the Federal Government's electronic and
information technology, be made applicable to all offices on Capitol Hill
covered by the Congressional Accountability Act, including the Government
Printing Office (<http://www.gpo.gov>www.gpo.gov ), the General Accounting
Office (<http://www.gao.gov> www.gao.gov ), and the Library of Congress
(<http://www.loc.gov> www.loc.gov ).
NCD commends the Office of Compliance for its progress in advancing access
to electronic and information technology to 54 million Americans with
disabilities. This critical step is consistent with advice provided to
Office of Compliance staff last summer and a recommendation in NCD's June
14 report National Disability Policy: A Progress Report
(<http://www.ncd.gov/newsroom/publications/progress.html>
http://www.ncd.gov/newsroom/publications/progress.html ), which urged
Congress to take whatever steps are necessary to amend the Congressional
Accountability Act so that GPO does not remain exempt from federal
accessibility laws and regulations, including Section 508, as they pertain
to Web sites.
NCD encourages Congress to act promptly to incorporate these important
recommendations from the Office of Compliance that will advance the civil
rights of all people with disabilities.
The electronic information systems interim report from the Office of
Compliance can be found at
<http://www.compliance.gov/>http://www.compliance.gov/ .
Therefore, between now and February 15, NCD is gathering information about
the experiences of people with disabilities in accessing Web sites at
congressional offices, the Government Printing Office, the General
Accounting Office, and the Library of Congress. Please include specific
examples of your electronic interactions with these Web sites, including
the name of the agency and its URL. Please send your comments to Section
508, National Council on Disability, 1331 F Street, NW, Suite 850,
Washington, DC, by fax to 202-272-2022, or by e-mail to
<mailto:[log in to unmask]> [log in to unmask] .
Thank you for helping.
Mark S. Quigley
Director of Communications
Rachael Zubal wrote:
I get a message that the PDF is corrupted.
Rachael Zubal
------------------------------------------------------------------------
----
Rachael A. Zubal
Information Coordinator, Center on Human Policy
Syracuse University
805 South Crouse Avenue
Syracuse, NY 13244-2280
315-443-2761
E-mail: <mailto:[log in to unmask]>[log in to unmask]
E-mail: <mailto:[log in to unmask]>[log in to unmask]
WWW: <http://soeweb.syr.edu/thechp/>http://soeweb.syr.edu/thechp/
ICQ #19650783
"The art of living is more like wrestling than dancing."
--Marcus Aurelius
"I will permit no man to narrow and degrade my soul by making me hate
him."
--Booker T. Washington
<<<<
Norman Coombs, Ph.D.
Cell (949) 922-5992
Professor Emeritus, Rochester Institute of Technology
http://www.rit.edu/~nrcgsh
CEO, EASI (Equal Access to Software and Information)
http://www.rit.edu/~easi
|
