**FEDERAL COMMUNICATIONS COMMISSION**

**OFFICE OF INSPECTOR GENERAL**

Special Review of Web Page
Accessibility![](media/image1.jpeg){width="3.998611111111111in"
height="3.811111111111111in"}

Special Review Report No. 00-AUD-10-55

January 19, 2001

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  H. Walker Feaster III                                                       Thomas D. Bennett

  Inspector General                                                           Assistant Inspector General - Audits
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Report on Special Review of Web Page Accessibility

Table of Contents

[Page]{.underline}

EXECUTIVE SUMMARY 1

REVIEW OBJECTIVE 2

REVIEW SCOPE 2

BACKGROUND 3

OBSERVATIONS 4

RECOMMENDATIONS 6

APPENDIX 1 - Web Sites with Accessibility Observations 7

APPENDIX 2 -- Management Response 11

[Executive Summary]{.underline}

The Federal Communications Commission (FCC) is increasingly using
Information Technology (IT) to conduct business and to disseminate
information. As FCC Chairman William Kennard recently stated: "We are at
the cusp of the third greatest revolution in mankind\'s history..., the
Information Revolution. This third revolution rewards those who control
and process information. It gives them a competitive advantage, and a
road to national affluence.[^1]"

The purpose of this Special Review on Web Accessibility was to determine
how effective the FCC has been in providing access by the disabled to
its Internet web sites. In effect, the objective of the review was to
determine how successful the Commission has been in building "curb
cuts[^2]" to its own web pages.

Web accessibility refers to the ability of individuals with disabilities
to have access to and use of information and data that is comparable to
the access to and use of information by those without disabilities. In
1998, Congress amended the Rehabilitation Act of 1973 to strengthen
provisions covering access to information in the Federal sector for
people with disabilities. The amendment, Section 508 of the
Rehabilitation Act, requires that all federal agencies ensure that
electronic and information technology is accessible to employees and the
public.

Web accessibility is a part of the Commission's Disability Rights Major
Initiative. A Major Initiative is an item that the Commission considers,
that stands out because of its affect on a potentially large number of
people, the politics involved, or its complicated regulatory history.
The FCC has included the Disabilities Rights Office, including web
accessibility, as a Major Initiative because the FCC has an obligation
to ensure

that telecommunications are accessible and usable to the 54 million
Americans with disabilities.

During our review, we found that thirty-one (31) pages had some
accessibility problems. Some of the accessibility problems identified
may make these pages difficult or impossible for a disabled person to
use. Therefore, we recommend that the problems we identified be
corrected and that web accessibility becomes an integral part of the
information systems' development life cycle. These recommendations will
correct present problems and minimize the risk that future web
accessibility problems will occur in the FCC's Internet web pages.

In a joint response to the draft report, the Chief, Consumer Information
Bureau (CIB), the Director, Office of Media Relations (OMR) and the
Managing Director (MD) concurred with OIG findings. They stated that
"OMR and the Information Technology Center (ITC) will ask the developers
responsible for the identified pages to review and fix the accessibility
problems within 90 days, or submit a work plan and time table by
February 1, 2001 for revising the pages." Also, they pointed out the
specific sections in the Commission's Systems Development Life Cycle
that relate to web accessibility laws and regulations. We have included
a copy of the joint response in its entirety as Appendix 2 to this
report.

[REVIEW OBJECTIVE]{.underline}

The objective of this special review was to determine whether the FCC
web sites are accessible to disabled users. We sought to determine if
the Commission would be able to implement the Section 508 standards as
related to web accessibility when they become effective next year. To
determine how the Commission responded to these laws and web
accessibility, we first reviewed its program on disability rights. Next,
to determine the Commission's compliance with these laws and initiative
as applied to web accessibility, we tested over three hundred FCC
Internet web pages using a series of automated tools.

To analyze Commission web sites, we used three commonly used
accessibility analysis tools, Bobby, Lynx, and Job Access With Speech
(JAWS). Bobby is a web-based automated tool that analyzes web pages for
their accessibility to people with disabilities.[^3] Lynx is a text
browser for the World Wide Web.[^4] The Department of Justices (DOJ) Web
Page Accessibility Checklist requires that an evaluator test a web page
for accessibility issues using a text-only browser. The DOJ guidelines
specifically mention Lynx as a text web browser that can be used for the
review.[^5] The JAWS analysis tool is a screen reader developed to
assist blind or visually impaired computer users access the Internet and
a variety of computer applications. With JAWS, blind or visually
impaired people can browse the web, read or write e-mail messages,
re-calculate spread sheets or access information in a database.[^6] With
Bobby, Lynx, and JAWS, we were able to analyze FCC web pages to
determine accessibility.

#### [REVIEW SCOPE]{.underline}

The scope of this audit was limited to web pages on the FCC's Internet
site. No Intranet sites were reviewed. This was because tools, such as
Bobby, were based on the Internet and could not access the FCC's
Intranet web pages. Sites using Secure Socket Layer (SSL) security
technology were only reviewed with Jaws. SSL is a web security
technology used to encrypt transmissions. The other tools available were
unable to analyze sites using SSL for web accessibility.

Another scope issue included the use of text only pages. If a web page
provided a link to an alternative, text only, page, we tested the text
page only. We considered the text page an acceptable alternative method
of providing access to Commission information on the Internet.

The special review was conducted at the Commission headquarters facility
located at 445 12^th^ Street, Southwest, Washington, DC. Fieldwork on
this special review was conducted from July 14, 2000 through September
19, 2000.

[BACKGROUND]{.underline}

The Commission's direction and efforts on web accessibility are based on
Federal laws that require that agency's web pages be accessible to all.
Federal web accessibility requirements originated from Section 508 of
the Rehabilitation Act of 1973 (Section 508). In 1998, Congress amended
the Rehabilitation Act and strengthened provisions covering access to
information in the Federal sector for people with disabilities. Section
508 requires that the Federal government\'s electronic and information
technology is accessible to employees and the public. The law applies to
all Federal agencies when they develop, procure, maintain, or use
electronic and information technology.

The scope of Section 508 is expansive. \"Electronic and information
technology\" potentially includes any technology that is used in the
"automatic acquisition, storage, manipulation, management, movement,
control, display, switching, interchange, transmission, or reception of
data or information." [^7] This broad definition potentially includes
all telecommunications devices (including telephones, voice-mail
systems, pagers, facsimile machines, and related technology) and any
technology used to convey, transmit, or receive any kind of information.
Section 508 also includes the web sites of federal agencies. This
amendment requires that all facets of information technology must be
made accessible to persons with disabilities. Section 508 became
effective the day it was enacted, August 7, 1998. Federal agencies are
required to ensure that their electronic and information technology is
accessible to persons with disabilities.

To clarify the regulations, the statute designated the Architectural and
Transportation Barriers Compliance Board (Access Board) to develop
standards for complying with Section 508. The Access Board was
originally required to complete its regulations by February 7, 2000.
However, final regulations have not been issued as of the date of this
report. The Access Board is expected to publish its final regulations by
January, 2001.

Section 508 imposes important duties on Federal agencies. Although the
Access Board has not published its guidelines, Federal agencies must
make their current information and electronic technologies accessible to
employees with disabilities and members of the public with disabilities.
Furthermore, Federal agencies should be incorporating the needs of
persons with disabilities when it makes any changes to its current
information and electronic technologies.

Secondly, Federal agencies had to conduct a self-evaluation and submit a
report to the Department of Justice (DOJ) regarding the accessibility of
their electronic and information technology by June 15, 1999.
Thereafter, all Federal agencies must provide information that the
Attorney General deems necessary to assess the ongoing compliance with
Section 508 and must cooperate with the Attorney General\'s efforts at
assessing this compliance.

Section 508 also includes remedies to insure compliance. This amendment
permits any individual or government employee with a disability may file
a complaint alleging that a Federal department or agency fails to comply
with Section 508. If a Federal agency obtains electronic and information
technology that does not comply with the standards developed by the
Access Board, it is subject to administrative complaints and private
lawsuits by employees and members of the public. This remedy is also
effective six months after the date of enactment final Access Board
standards.

The private lawsuits allow for both private rights of action in court
and for reasonable attorneys' fees. Although compensatory or punitive
damages will not be available to prevailing plaintiffs, equitable
remedies, such as declaratory and injunctive relief, are available.

[OBSERVATIONS]{.underline}

This special review focused on two aspects of the FCC's web
accessibility. First, the report analyzed the Commission's formal
disability rights program, especially as it relates to web
accessibility. Next, we tested over three hundred (300) FCC web pages to
determine the extent that the Commission has met accessibility
guidelines.

[The FCC's Accessibility Program]{.underline}

The FCC has an active accessibility program. It is one of the
Commission's Major Initiatives. The FCC chose disability rights as one
of its major initiatives because people with disabilities must have
equal access to data in the information age. In addition, the FCC has an
obligation to ensure that telecommunications are accessible and usable
to the 54 million Americans with disabilities. The FCC has a dedicated
office, the Disability Rights Office (DRO), which is dedicated to
accessibility issues.

The DRO is part of the FCC\'s [Consumer Information
Bureau](http://www.fcc.gov/cib/). It ensures that FCC actions and
policies promote access to telecommunications equipment and services by
individuals with disabilities. It provides technical assistance to
consumers, to business and other entities on their rights and
responsibilities to provide disability access and protect consumers with
disabilities. Although primarily responsible for telecommunications
issues, the DRO also has a key role in web accessibility. It is charged
with ensuring that the Commission's web site is as accessible as
possible to all people.

The ITC also plays a part in the determining that web sites comply with
accessibility laws. The ITC performs the required accessibility
assessments. In 1999, the ITC completed the FCC Web Site Accessibility
Report, which we reviewed. This report met the DOJ Section 508
accessibility requirement. We reviewed this self-evaluation and found it
satisfactory.

The ITC also has an accessibility Customer Service Representative (CSR).
She is the focal point for accessibility issues. We discussed ITC's
efforts in web accessibility with the accessibility CSR. She had a
number of web accessibility programs underway. For example, the CSR has
arranged for accessibility training for FCC software developers. Also,
she obtained and installed the JAWS software for the use by developers
for accessibility evaluation.

[Tests of Web Accessibility]{.underline}

The next step was to test compliance with Section 508 Federal Laws.
Using the Bobby, Lynx, and JAWS accessibility tools, we tested over
three hundred (300) FCC Internet web sites. These tools, as previously
described, are either commonly used for accessibility testing or are
part of DOJ's recommended web accessibility testing guidelines. The use
of all three tools enabled us to test for a variety of accessibility
issues.

Among the web sites we tested were the FCC's home, or start, page, the
Commissioners' home pages, the home pages from all Bureaus and Offices,
web pages from the Commission's Major Initiatives, and many of the FCC's
electronic filing (e-filing) and public access pages. We chose pages
that would provide us with a representative cross section of the FCC's
Internet activity.

The majority of web pages had no accessibility problems. These included
the Commission's home page, most of Commissioners' web pages, and the
majority of the remaining pages tested. In most cases, alternative,
text-only pages provided pages that were free of accessibility problems.

However, we identified thirty-one (31) web pages with accessibility
problems. A list of these sites is included in the Appendix. These sites
included Commissioner Furchtgott-Roth's home page, the home pages of
five Bureaus and Offices, three pages identified specifically with the
Chairman. Ten e-filing & public access systems had accessibility issues.
These sites are likely to be visited by the public and others submitting
filings related to FCC proceedings or otherwise doing business with the
Commission. Other sites with accessibility problems included the 2000
Regulatory Fees page, the Jobs page, and the Major Initiatives home
page.

All three of the tools used identified accessibility problems with
Commission web pages. Some of the problems can be easily fixed, such as
an unlabeled space bar, which would cause Bobby to fail the page. Others
were more serious. One site read its text in such a manner that made it
nearly impossible to follow. An e-filing site labeled many data entry
boxes with cryptic names such as "Graphic 979" that JAWS read. Another
e-filing web page did not identify its login button when accessed by one
of the accessibility tools. These types of problems make the pages
difficult, if not impossible, for a disabled person to use.

The causes of these accessibility problems are varied. Many of these web
pages appear to be older sites that were developed before accessibility
became a major issue. Other web sites appear not to have been tested for
accessibility issues before being put into production.

If developers tested web pages for accessibility issues during the
testing phase then these problems could be identified before a site is
placed into production. If web accessibility became an integral part of
the Testing Phase of the Systems Development Life Cycle (SDLC), then
many of these issues would be identified before the pages became part of
the Internet site.

[RECOMMENDATIONS]{.underline}

We recommend that the Commission enhance its existing information
systems and web accessibility program by:

1.  Fixing the accessibility problems in the Commission's web pages
    identified in the Appendix, major errors first.

2.  Integrating web accessibility into the Commission's Systems
    Development Life Cycle. Making this an integral part of the
    development process will minimize the risk that future web
    accessibility problems will occur in the FCC's Internet web pages.

Appendix 1

[Web Sites with Accessibility Observations]{.underline}

During our review, we found that thirty-one (31) Commission web pages
had accessibility observations. However, the number accessibility
observations on FCC web pages total more than thirty-one because some
pages had multiple problems.

For each accessibility observation, we have identified the specific web
pages on which problems were identified. The identification includes a
brief description (e.g., Bureau Home Page) and the specific URL (e.g.,
fcc.gov/bureau/). We grouped the observations according to the
accessibility analysis tool used to identify the problem.

We classified the observations as major or minor. Major observations
were those that affected key components of the web page or were
widespread. Examples of major observations are the inability to use a
button on an e-filing page or a large number of "Bobby-identified"
observations. Minor observations affect items on the periphery of the
web page. A logo problem is a good example of a minor observation. We
also classified a page with one or two "Bobby" observations as minor.

## [Web Sites with Observations Using Bobby]{.underline}

All web sites with "Bobby" observations had at least one Priority 1
accessibility error. The developers of Bobby, the Center for Applied
Special Technology, define Priority 1 accessibility errors as "problems
that seriously affect the page\'s usability by people with
disabilities.[^8] " A Bobby Approved rating can only be granted to a
site in which none of the pages have Priority 1 accessibility errors.
Even if the observation is minor, if its Bobby classification is
Priority 1, it fails this test. We only identified pages with Priority 1
errors.

1.  [International Bureau Electronic Filing System (IBFS)
    Login]{.underline}:

haifoss.fcc.gov/cgi-bin/ws.exe/prod/ib/forms/ibfsmenu.hts

Observation Classification: **Minor -- One Priority 1 error**

2\. [IBFS Account Maintenance:]{.underline}

haifoss.fcc.gov/cgi-bin/ws.exe/prod/ib/forms/ibfsmenu.hts?action=2&context=12

Observation Classification: **Minor -- One Priority 1 error**

3\. [Children's Educational Television Home Page:]{.underline}
svartifoss.fcc.gov:8080/prod/kidvid/prod/kidvid.htm

Observation Classification: **Major -- Three Priority 1 errors**

4\. [Office of Engineering and Technology (OET) Search
Form]{.underline}:
svartifoss.fcc.gov:8080/cgi-bin/ws.exe/prod/oet/els/forms/reports/Search_form.hts

Observation Classification: **Minor -- One Priority 1 error**

5.  [International Bureau (IB) Home Page]{.underline}:

fcc.gov/ib/

Observation Classification: **Major -- Eight Priority 1 errors**

6.  [Office of Legislative and Intergovernmental Affairs (OLIA) Home
    Page]{.underline}:

fcc.gov/olia/

Observation Classification: **Minor -- One Priority 1 error**

7.  [Office of General Counsel (OGC) Home Page]{.underline}:

fcc.gov/ogc/

Observation Classification: **Major --** **Five Priority 1 errors**

8.  [Commissioner Furchtgott-Roth's Home Page]{.underline}:

fcc.gov/commissioners/ furchtgott-roth/

Observation Classification: **Major -- Six Priority 1 errors**

9.  [2000 Regulatory Fees Home Page]{.underline}:

fcc/gov/fees/2000regfees.html

Observation Classification: **Minor -- One Priority 1 error**

10. [Office of Plans and Policy (OPP) Home Page]{.underline}:

fcc.gov/opp/

Observation Classification: **Minor -- One Priority 1 error**

11. [Office of the Managing Director (OMD) Home Page]{.underline}:

fcc.gov/omd/

Observation Classification: **Major -- Four Priority 1 errors**

12. [Kennard Development Initiative Home Page]{.underline}:

fcc.gov/ib/developinitiative/

Observation Classification: **Major -- Fourteen Priority 1 errors**

13. [International Visitors Program]{.underline}:

fcc.gov/ib/ivp/

Observation Classification: **Major -- Three Priority 1 errors**

14. [Index of Public Notices]{.underline}:

fcc.gov/Bureaus/Consumer_Information/Public_Notices/

Observation Classification: **Minor -- Two Priority 1 errors**

15. [Index of News Releases]{.underline}:

fcc.gov/Bureaus/Consumer_Information/News_Releases/

Observation Classification: **Minor -- Two Priority 1 errors**

16. [Index of Orders]{.underline}:

fcc.gov/Bureaus/Consumer_Information/Orders/

Observation Classification: **Minor -- Two Priority 1 errors**

17. [FCC Phonebook]{.underline}:

fcc.gov/phone.html

Observation Classification: **Major -- Five Priority 1 errors**

18. [FCC Topical Index]{.underline}:

fcc.gov/topindex/

Observation Classification[:]{.underline} **Minor -- One Priority 1
error**

19. [FCC Communications Commission Jobs Page]{.underline}:

fcc.gov/jobs/

Observation Classification: **Major -- Three Priority 1 errors**

**[Web Sites with Observations Using Lynx]{.underline}**

1\. Automated Reporting Management Information System (ARMIS) Page:
fcc.gov/ccb/armis

Observation Classification: **Major -- Unable to access the page using
Lynx**

2.  [Children's Educational Television Home Page]{.underline}:
    svartifoss.fcc.gov:8080/prod/kidvid/prod/kidvid.htm

Observation Classification: **Major -- Unable to access the page using
Lynx**

3.  [Consumer Complaint Form for Telephone Related Issues]{.underline}:

fcc.gov/cib/ccformpage.html

Observation Classification: **Minor -- Unable to read logo**

4.  [Mass Media Consolidated Database System (CDBS) Public
    Access]{.underline}:

svartifoss.fcc.gov:8080/prod/cdbs/pubacc/prod/cdbs_pa.htm

Observation Classification: **Major -- Unable to access the page using
Lynx**

5\. [Multipoint Distribution System (MDS)/Instructional Television Fixed
Service (ITFS)]{.underline}

[Data Entry Page]{.underline}:

haifoss.fcc.gov/cg-bin/ws.exe/prod/mmb/mdsmenu.hts

Observation Classification: **Major -- Unable to access the page using
Lynx**

6\. [Office of Engineering and Technology (OET) Search
Form]{.underline}:
svartifoss.fcc.gov:8080/cgi-bin/ws.exe/prod/oet/els/forms/reports/Search_form.hts

Observation Classification: **Major -- Unable to access the page using
Lynx**

7.  [IBFS Login]{.underline}:

Haifoss.fcc.gov/cgi-bin/ws.exe/prod/ib/forms/ibfsmenu.hts

Observation Classification: **Major -- Unable to use button bars to
login**

8.  [IBFS Account Maintenance]{.underline}:

Haifoss.fcc.gov/cgi-bin/ws.exe/prod/ib/forms/ibfsmenu.hts?action=2&context=12

Observation Classification: **Major -- Unable to use button bars to
create account**

9.  [Electronic Comment Filing System (ECFS) Alternative
    Link]{.underline}:

fcc.gov/e-file/nonssl.html

Observation Classification: **Major -- Unable to access the page using
Lynx**

10\. [Electronic Tariff Filing System (ETFS) Home Page]{.underline}:
svartifoss.fcc.gov:8080/prod/ccb/etfs/

Observation Classification: **Major -- Unable to access the page using
Lynx**

**[Web Sites with Observations Using Jaws]{.underline}**

1.  [FCC Major Initiatives]{.underline}:

fcc.gov/major.html

Observation Classification: **Minor -- Intermittently could not read
text**

2.  [FCC Resources]{.underline}:

fcc.gov/resources.html

Observation Classification: **Minor -- Intermittently could not read
text**

3.  [FCC Chairman Wm. Kennard Biography (text only]{.underline}):
    fcc.gov/commissioners/kennard/bio-text.html

> Observation Classification: **Minor -- Distorted text by reading
> spelling and grammatical errors literally and intermittently could not
> read text**

4.  [FCC Chairman Wm. Kennard Column (text only)]{.underline}:
    fcc.gov/commissioners/kennard/coltxt-text.html

Observation Classification: Minor -- Intermittently could not read text

5.  [IBFS Account Maintenance]{.underline}:

haifoss.fcc.gov/cgi-bin/ws.exe/prod/ib/forms/ibfsmenu.hts?action=2&context=12

> Observation Classification: **Major -- Unable to read data entry
> labels. For example Jaws called the password box "graphic 979"**

6.  [Universal Licensing System (ULS) Taxpayer Identification Number
    (TIN)/Call Sign Registration]{.underline}:

wtbww05.fcc.gov/cgi-bin/UlsTinRegistration/ UlsTinRegistration.exe

> Observation Classification: **Major -- Unable to read data entry
> labels. For example Jaws called the Middle Initial box "tab edit."**

Appendix 2

UNITED STATES GOVERNMENT

**memorandum**

DATE: December 20, 2000

TO: Inspector General

FROM: Managing Director

Chief, Consumer Information Bureau

Director, Office of Media Relations

SUBJECT: Response to Draft Special Review of Web Page Accessibility
Audit Report -- Draft

Special Report No. 00-AUD-10-55, November 29, 2000

The Managing Director, along with the Chief, Consumer Information Bureau
and the Director, Media Relations concur with the recommendations stated
in the "Special Review of Web Page Accessibility," prepared by your
office. We commend the OIG for their support in ensuring that the
Commission continues to comply with the Federal requirements for
providing accessible web sites.

[Recommendation 1 of 2]{.underline}

# Fixing the accessibility problems in the Commission's web pages identified in the Appendix, major errors first.

[Response]{.underline}

# Concur. OMR and ITC will ask the developers responsible for the identified pages to review and fix the accessibility problems within 90 days, or submit a work plan and time table by February 1, 2001 for revising the pages that they expect will require longer to fix.

In addition to fixing the pages that OIG has identified, ITC and OMR
plan to review all of the FCC's Internet pages using standards proposed
in the ITC accessibility plan.

[Recommendation 2 of 2]{.underline}

# Integrating web accessibility into the Commission's Systems Development Life Cycle. Making this an integral part of the development process that will minimize the risk that future web accessibility problems will occur in the FCC's Internet web pages. 

[Response]{.underline}

Concur. Accessibility is already integrated into the FCC's Systems
Development Life Cycle (SDLC) methodology. In the Initiation Phase of
the SDLC, the project owner must identify applicable laws, federal
statutes and regulatory standards. Section 508 of the Rehabilitation Act
0f 1993 is a federal law that directly applies to all IT development
activities.

In the Design Phase of the SDLC, the developer is required to prepare
design specifications to address any applicable Commission Rules,
federal laws and regulations (e.g. accessibility). The SDLC calls for a
Requirement Trace-ability Matrix to be used to track identified
requirements, including accessibility requirements, through each phase
of the life cycle in order to determine that requirements are actually
met in the implemented system. This quality assurance tool ensures that
accessibility is an integral part of the development process.

In addition, the FCC has a standard accessibility contract clause and an
attachment (Requirements for Accessible Software Design) specifically
addressing accessibility. This is an additional checkpoint to ensure
that accessibility is built into FCC IT systems.

OMR has contracted with a third party to evaluate the FCC web site and
to provide an assessment and recommendations on design changes that will
allow the public to more quickly and easily retrieve the information
that the FCC has to offer on our web site. Recommendations are to
include a set of templates for new page designs, along with recommended
methods and text-only templates we can use to address current
accessibility requirements.

The Internet Working Group discusses accessibility issues on a regular
basis at its monthly meetings, and has incorporated accessible web-page
design practices into its Web Site Design Standards Working Paper.

Also, as part of the FCC's Accessibility Plan, the Web Review Working
Group will incorporate the Section 508 Web accessibility standards into
the FCC Web Site Standards and develop a compliance mechanism to ensure
that all FCC Web page development meet the FCC Web Site Standards. It is
projected that the standards and the compliance mechanism will be in
place within the next six months.

If you have any questions, please contact Rosalind Singleton, Section
508 Coordinator, at 202-418-2850.

[^1]: 1 [The Great Equalizer]{.underline}, Remarks by William E.
    Kennard, Chairman, Federal Communications Commission, at The
    Supercomm 2000 International Dinner, Capital City Club, Atlanta,
    Georgia, June 5, 2000[.]{.underline}

[^2]: 2 [Building Curb Cuts on the Information Highway]{.underline},
    Address by Chairman William E. Kennard, Federal Communications
    Commission, Before the National Association of the Deaf, Norfolk,
    Virginia, July 3, 2000.

[^3]: 3 The Bobby analysis tool was obtained from the Center for Applied
    Special Technology (CAST) on their web page located at
    http://www.cast.org/bobby.

[^4]: The Lynx tool was obtained at http://lynx.browser.org.

[^5]: The DOJ guidelines are available from their web page located at
    http://www.usdoj.gov/crt/508/webpage.html.

[^6]: The JAWS analysis tool (a fully functional demo) was obtained from
    the Henter-Joyce, Inc on their web page located at http://
    www.hj.com/JAWS/JAWS37DemoOp.htm.

[^7]: 40 U.S.C. §1401(3) (definition of \"information technology\").

[^8]: http://www.cast.org/Bobby/index.cfm?i=325