Preliminary Regulatory Impact Analysis

Proposed Update of Section 508 Standards 

and Section 255 Guidelines

Contract No.: 

GS-10F-0269K

Order No.:

DTOS59-09-F-10094

Project No.:

1030-001

Submitted To:

U. S. Architectural and Transportation Barriers 

Compliance Board

1331 F Street NW, Suite 1000

Washington, DC 20004-1111

Submitted By:

Econometrica, Inc.

7475 Wisconsin Avenue, Suite 1000

Bethesda, MD 20814

February 12, 2015
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Table of Contents

EXECUTIVE SUMMARY ...............................................................................................................1

ACCESS BOARD PROPOSAL.......................................................................................................1

SUMMARY OF BENEFITS AND COSTS OF THE PROPOSED RULE....................................................2

BENEFITS OF THE PROPOSED RULE............................................................................................4

CURRENT (BASELINE) SECTION 508 AND SECTION 255 COSTS ...................................................5

COSTS OF THE PROPOSED RULE ................................................................................................6

CONCLUSION ...........................................................................................................................7

1. INTRODUCTION: PROPOSED UPDATE OF THE SECTION 508 STANDARDS AND THE SECTION 

255 GUIDELINES .........................................................................................................................1

2. FRAMEWORK TO EVALUATE THE PROPOSED STANDARDS AND GUIDELINES ..........................2

3. CURRENT STANDARDS AND GUIDELINES TO ENSURE EQUAL ACCESS TO ICT FOR PEOPLE 

WITH DISABILITIES ....................................................................................................................3

3.1. SECTION 508 STANDARDS..................................................................................................4

3.2. SECTION 255 GUIDELINES..................................................................................................4

3.3. W3C CONSENSUS STANDARDS ..........................................................................................6

3.4. SECTIONS 501 AND 504 OF THE REHABILITATION ACT OF 1973...........................................7

4. AN OVERVIEW OF THE PROPOSED 508 STANDARDS AND 255 GUIDELINES .............................8

4.1. NEED FOR REVISION OF CURRENT STANDARDS AND GUIDELINES........................................8

4.2. WCAG 2.0 AND OTHER PROPOSED ACCESSIBILITY STANDARDS: WHAT WOULD BE 

REQUIRED? ....................................................................................................................11

4.3. ICT CONTENT, APPLICATIONS, AND EQUIPMENT: WHAT WOULD BE COVERED? ...............12

4.4. MAJOR NEW REQUIREMENT AREAS IN THE PROPOSED STANDARDS AND GUIDELINES........14

4.5. SCOPE OF PROPOSED ICT STANDARDS AND GUIDELINES: WHAT ENTITIES WOULD HAVE TO 

COMPLY? .......................................................................................................................21

4.6. REQUEST FOR COMMENT ON SPECIFIC ASPECTS OF THE PROPOSED 508 STANDARDS AND 255

GUIDELINES ...................................................................................................................22

5. BENEFITS OF THE PROPOSED RULE ......................................................................................23

5.1. TYPES OF ADDRESSABLE DISABILITIES AND NUMBER OF POTENTIAL BENEFICIARIES.........23

5.2. BENEFITS FOR FEDERAL EMPLOYEES WITH DISABILITIES .................................................25

5.3. BENEFITS FOR CITIZENS AND OTHER RESIDENTS WITH DISABILITIES ................................29

5.4. BENEFITS FOR FEDERAL AGENCIES ..................................................................................37

5.5. BENEFITS FROM INCREASED AVAILABILITY OF ACCESSIBLE TELECOMMUNICATIONS 

PRODUCTS, DOCUMENTATION, AND SUPPORT SERVICES ..................................................39

5.6. BENEFITS ACCRUING TO OTHER ENTITIES ........................................................................40

5.7. SUMMARY OF BENEFITS...................................................................................................41

5.8. REQUEST FOR COMMENT ON SPECIFIC ASPECTS OF BENEFITS ESTIMATES .........................42

6. BASELINE COMPLIANCE COSTS ............................................................................................43
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6.1. FEDERAL AGENCY IN-HOUSE BASELINE COSTS ................................................................44

6.2. BASELINE COST ESTIMATES FOR PROCURED ICT..............................................................50

6.3. BASELINE COST ESTIMATES FOR COMPLYING WITH CURRENT SECTION 255 GUIDELINES..53

6.4. SUMMARY OF BASELINE SECTION 508 AND SECTION 255 COMPLIANCE COSTS..................55

6.5. REQUEST FOR COMMENT ON SPECIFIC ASPECTS OF BASELINE COST ESTIMATES................55

7. FACTORS AFFECTING FUTURE COMPLIANCE COSTS UNDER THE CURRENT ICT STANDARDS 

AND GUIDELINES ......................................................................................................................56

7.1. FACTORS AFFECTING FEDERAL AGENCY SECTION 508 COMPLIANCE COSTS .....................56

7.2. FACTORS AFFECTING TELECOMMUNICATIONS MANUFACTURER COSTS TO COMPLY WITH 

THE SECTION 255 GUIDELINES ........................................................................................57

8. CURRENT PRACTICES AND POTENTIAL INCREMENTAL COSTS ASSOCIATED WITH MAJOR 

NEW REQUIREMENTS IN THE PROPOSED RULE ........................................................................58

8.1. AREA 1: APPLYING WCAG 2.0 TO SOFTWARE AND APPLICATIONS ...................................58

8.2. AREA 2: ACCESSIBILITY FEATURES WITHIN SOFTWARE APPLICATIONS AND OPERATING 

SYSTEMS........................................................................................................................59

8.3. AREA 3: AUTHORING TOOLS ............................................................................................59

8.4. AREA 4: ASSISTIVE TECHNOLOGY....................................................................................59

8.5. AREA 5: ELECTRONIC CONTENT AND DATA......................................................................60

8.6. AREA 6: COLOR AND CONTRAST SETTINGS.......................................................................60

8.7. AREA 7: AUDIO CONTROLS ON WEB PAGES......................................................................60

8.8. AREA 8: USER CONTROLS FOR CAPTIONS AND VIDEO DESCRIPTION..................................61

8.9. AREA 9: RTT FUNCTIONALITY.........................................................................................61

8.10. SECTION 508 HARDWARE AND EQUIPMENT COSTS .........................................................62

8.11. SECTION 255 ELECTRONIC DOCUMENTATION AND SUPPORT COSTS ................................62

8.12. REQUEST FOR COMMENT ON COMPLIANCE COSTS ..........................................................64

9. PRELIMINARY COST ESTIMATES FOR THE PROPOSED RULE.................................................64

9.1. FEDERAL AGENCY COMPLIANCE COSTS FOR IN-HOUSE ICT.............................................65

9.2. ESTIMATED COST INCREASES ASSOCIATED WITH PROCURED ICT.....................................73

9.3. COMPLIANCE COSTS ASSOCIATED WITH PROPOSED SECTION 255 GUIDELINES .................74

9.4. SUMMARY OF MONETIZED AND UNQUANTIFIED COSTS OF THE PROPOSED RULE ...............76

9.5. REQUEST FOR COMMENT ON COST ESTIMATES FOR PROPOSED RULE ................................78

10. CONCLUSION.......................................................................................................................79

APPENDIX A: ICT ACCESSIBILITY STANDARDS..........................................................................1

A.1. WCAG 2.0 LEVEL A AND LEVEL AA SUCCESS CRITERIA ..................................................2

A.2. ADDITIONAL PROPOSED REQUIREMENTS FOR SOFTWARE AND APPLICATIONS ....................6

A.3. PROPOSED REQUIREMENTS FOR HARDWARE AND TELECOMMUNICATIONS EQUIPMENT.......8

A.4. PROPOSED REQUIREMENTS FOR SUPPORT DOCUMENTATION AND SERVICES .....................18

A.5. MAPPING OF PROPOSED RULE PROVISIONS TO PEOPLE WITH SPECIFIC TYPES OF 

DISABILITIES ..................................................................................................................19

APPENDIX B: DATA ON PEOPLE WITH DISABILITIES..................................................................1
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B.1. EXTENT AND SEVERITY OF DISABILITIES IN THE U.S. POPULATION.....................................1

B.2. USE OF ELECTRONIC TECHNOLOGIES BY PEOPLE WITH DISABILITIES .................................4

B.3. FEDERAL EMPLOYMENT OF PEOPLE WITH DISABILITIES.....................................................5

APPENDIX C: 2012 DOJ REPORT ON SECTION 508 COMPLIANCE RATES AND EXPENDITURES ..1

C.1. SECTION 508 POLICY DEVELOPMENT AND TRAINING .........................................................1

C.2. SECTION 508 SUPPORT SERVICES PROVIDED......................................................................2

C.3. SOFTWARE AND WEB APPLICATION DEVELOPMENT...........................................................2

C.4. VIDEO/MULTIMEDIA PRODUCTION ....................................................................................2

C.5. TRAINING PROVIDED.........................................................................................................3

C.6. PROCUREMENT .................................................................................................................3

C.7. WEB SITE COMPLIANCE ....................................................................................................4

APPENDIX D: DATA ON AFFECTED ENTITIES, PRODUCTS, SERVICES, AND EMPLOYEES.............1

D.1. FEDERAL AGENCY ICT BUDGETS......................................................................................1

D.2. FEDERAL AGENCY ICT BUDGETS AND PURCHASES............................................................2

D.3. FEDERAL EMPLOYMENT IN IT, CONTRACTING, AND OTHER SELECTED OCCUPATIONS ........4

D.4. ICT MANUFACTURING......................................................................................................5

D.5. PRIVATE-SECTOR IT EMPLOYMENT...................................................................................6

APPENDIX E: ANNUAL ESTIMATES OF MONETIZED BENEFITS AND COSTS.................................1
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List of Tables

Table ES-1: Annualized Value of Monetized Benefits and Costs, 2015–2024 (Millions of 2015 Dollars)

.......................................................................................................................................................... ES-4

Table ES-2: Unquantified Benefits of the Proposed Rule ................................................................... ES-5

Table ES-3: Unquantified Costs of the Proposed Rule........................................................................ ES-6

Table 1: Value of Increased Federal Employee Productivity, 2012......................................................... 27

Table 2: Number of Federal Employees With Addressable Disabilities .................................................. 27

Table 3: Estimated Benefits From Increased Federal Employee Productivity.......................................... 28

Table 4: Proportion of Adult Internet Users Visiting Government Web Sites ......................................... 29

Table 5: Average Amount of Time Saved Per Person With Vision Disabilities From Increased Web 

Accessibility.......................................................................................................................................... 32

Table 6: Number of People With Vision Disabilities Who Would Benefit From Improved Government 

Web Site Accessibility and Amount of Time Saved ............................................................................... 33

Table 7: Monetized Benefits of Improved Government Web Site Accessibility ...................................... 34

Table 8: Estimated Benefits to Federal Agencies From Reduced Call Volumes...................................... 38

Table 9: Annualized Value of Monetized Benefits, 2015–2024 (Millions of 2015 Dollars)..................... 41

Table 10: Unquantified Benefits of the Proposed Rule ........................................................................... 42

Table 11: Annual Baseline Cost of Section 508 Policy Development and Implementation...................... 44

Table 12: Annual Baseline Cost of Federal Employee Training.............................................................. 46

Table 13: Annual Baseline Cost of Software/Web/Audiovisual Media Accessibility Compliance........... 47

Table 14: Annual Baseline Cost of Software/Web/Audiovisual Media Evaluation.................................. 48

Table 15: Annual Baseline Cost of Section 508-Compliant Document Creation and Repair.................... 49

Table 16: Annual Baseline Federal Agency Compliance Costs for In-House ICT (Millions)................... 49

Table 17: Estimates of Federal ICT Purchase Share, 2012...................................................................... 52

Table 18: Annual Baseline Compliance Cost Estimate for Procured ICT................................................ 52

Table 19: Annual Baseline Compliance Cost Estimates (Billions).......................................................... 55

Table 20: Telecommunications Equipment Manufacturer Support Pages................................................ 63

Table 21: Projected Cost Increase for Policy Development and Implementation..................................... 66

Table 22: Projected Cost Increase for Federal Employee Training.......................................................... 67

Table 23: Projected Cost Increase for Software/Web/Multimedia Development Compliance.................. 68

Table 24: Projected Cost Increase for Software/Web/Audiovisual Media Evaluation.............................. 69

Table 25: Projected Cost Increase for Section 508-Compliant Document Creation and Repair................ 70

Table 26: Preliminary Percentage Increases in Agency Compliance Costs for In-House ICT.................. 71
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Table 27: Projected Increase in Annual Agency Compliance Costs for In-House ICT (Millions of 2015 

Dollars)................................................................................................................................................. 72

Table 28: Present Value in 2015 of Monetized 2015–2024 Agency Costs for In-House ICT (Millions of 

2015 Dollars) ........................................................................................................................................ 72

Table 29: Estimates of Increased Costs Associated With Procured ICT (Millions of 2015 Dollars)......... 73

Table 30: Present Value in 2015 of Monetized 2015–2024 Costs for Procured ICT (Millions of 2015 

Dollars)................................................................................................................................................. 74

Table 31: Estimated 2015–2024 Conformance Costs for Manufacturer Web Sites and Content .............. 76

Table 32: Annualized Compliance Costs for the Proposed Rule, 2015–2024 (Millions of 2015 Dollars). 77

Table 33: Unquantified Costs of the Proposed Rule ............................................................................... 77

Table A-1: WCAG 2.0 Level A and Level AA Success Criteria ...........................................................A-2

Table A-2: Proposed Requirements for Software .................................................................................A-6

Table A-3: Proposed Requirements for Hardware and Telecommunications Equipment .......................A-9

Table A-4: Proposed Accessibility Requirements for Support Documentation and Services ...............A-18

Table A-5: Proposed Rule Provisions Benefitting People With Specific Types of Disabilities ............A-19

Table B-1: U.S. Population With Addressable Disabilities, 2010.......................................................... B-2

Table B-2: U.S. Online Population With Addressable Disabilities, 2010 ..............................................B-5

Table B-3: Federal Employees Reporting Various Types of Disabilities, FY 2010 ............................... B-6

Table C-1: Section 508 Services Provided by Agency Components......................................................C-2

Table C-2: Software/Web Application Development by Agency Components......................................C-2

Table C-3: Video/Multimedia Development by Agency Components...................................................C-3

Table C-4: Section 508 Training Provided by Agency Components .....................................................C-3

Table C-5: Types of Training Provided by Agency Components.......................................................... C-3

Table C-6: Types of Testing Used to Assess Procurement Compliance ................................................C-4

Table C-7: Elements on Agency Web Sites.......................................................................................... C-4

Table C-8: Agency Web Site Compliance Testing ...............................................................................C-5

Table C-9: Agency Web Site Compliance With Current Section 508 Requirements ............................. C-5

Table D-1: Federal IT Spending by Federal Agency (Millions) ............................................................D-1

Table D-2: Federal Purchases From Selected ICT Sectors, Calendar Year (CY) 2011 ..........................D-3

Table D-3: Federal Employment in Selected Occupations, 2011 ..........................................................D-4

Table D-4: Number of Companies and Primary Product Shipments for Selected ICT Sectors, 2012 .....D-5

Table D-5: Private-Sector Employment in IT-Related Occupations, 2011 ............................................D-6

Table E-1: Annual Value of Monetized Benefits, 2015–2024 (Millions) .............................................. E-1

Table E-2: Annual Value of Monetized Costs, 2015–2024 (Millions)................................................... E-2
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Executive Summary

The U.S. Architectural and Transportation Barriers Compliance Board (hereafter the “Access 

Board”) is the Federal agency that promotes equality for people with disabilities through 

leadership in accessible design and the development of accessibility guidelines and standards for 

the built environment, transportation, communication, medical diagnostic equipment, and 

information technology. Section 508 of the 1973 Rehabilitation Act, as amended in 1998, is 

intended to ensure that people with various types of disabilities have equal access to information 

and communications technology (ICT). In 2000, the Access Board developed and adopted 

standards to support the implementation of Section 508. The current Section 508 standards 

contain six sections of requirements that apply to Web sites and applications, software 

applications and operating systems, telecommunications products, video and multimedia 

products, “self-contained, closed products” (such as multifunction copiers), and desktop and 

portable computers. The current standards also apply to electronic content, including documents, 

audio, video, and multimedia. Section 508 is specifically applicable to Federal Government 

agencies, but the standards are also relevant for Government contractors and vendors of ICT 

products, services, and content.

1

Section 255 of the Telecommunications Act of 1996 sets forth accessibility guidelines that apply 

to telecommunications equipment manufacturers. The Access Board published guidelines in 

1998 to implement Section 255, which requires manufacturers to ensure that a wide range of 

telecommunications equipment and customer premises equipment (CPE) be made accessible 

when provision of such access is “readily achievable.”

Access Board Proposal

The Access Board is proposing to update the existing Section 508 standards and Section 255 

guidelines. One of the key proposals in the Notice of Proposed Rulemaking (NPRM) is to use the 

most recent version of the Web Content Accessibility Guidelines (WCAG 2.0)

2

and other 

consensus standards for specific applications, content, and equipment to define the core set of 

accessibility requirements not only for Federal agency Web sites, but also for non-Web software 

applications and authoring tools, data processing and communications hardware, 

telecommunications equipment, and electronic content procured, developed, maintained, or used

by the Federal Government. The NPRM would specifically require ICT and specified forms of 

electronic content produced using these programs and systems to meet the Level A and Level 

AA Success Criteria and Conformance Requirements specified for Web pages in WCAG 2.0.

 

1 The term “information and communication technology” is used throughout the NPRM preamble and proposed rule 

to broadly encompass electronic and information technology covered by Section 508, as well as telecommunications 

products, interconnected Voice over Internet Protocol (VoIP) products, and CPE covered by Section 255. Examples 

of ICT include computers, information kiosks and transaction machines, telecommunications equipment, 

multifunction office machines, software, Web sites, and electronic documents.

2 WCAG 2.0 is a comprehensive set of consensus standards developed by the World Wide Web Consortium (W3C). 

WCAG 2.0 specifically addresses the accessibility of Web sites. However, the WCAG 2.0 standards are written to 

be technology neutral, with requirements specified in terms of access to functionality rather than programming 

languages (such as HTML or JavaScript).
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In addition, the Access Board is proposing to require telecommunications equipment and CPE to 

support real-time text (RTT) communications capabilities and protocols.3 Other consensus 

standards for digital television tuners, software user interfaces, electronic documents in Portable 

Document Format (PDF), and other aspects of ICT performance would also be incorporated by 

reference. Federally procured IT hardware and telecommunications equipment would also be 

required to comply with some elements of the current accessibility standards for automatic teller 

machines and self-service fare machines, which are set forth in Section 707 of the 2010 U.S. 

Department of Justice (DOJ) Standards for Accessible Design.4 A summary comparison of the 

proposed provisions with the current Section 508 standards and Section 255 guidelines is 

provided in Appendix A.

The Access Board proposal would also require telecommunications equipment manufacturers to 

meet the relevant WCAG 2.0 and 2010 Americans with Disabilities Act (ADA) standards when 

compliance is readily achievable. The proposed Section 255 guidelines would apply to all 

covered types of telecommunications equipment (e.g., cellular and wireline phones, fax 

machines) sold in the U.S. market.

Summary of Benefits and Costs of the Proposed Rule

The primary focus of this preliminary regulatory impact analysis (RIA) was to define and, where 

possible, quantify and monetize the potential societal benefits and costs of the proposed Section 

508 standards and Section 255 guidelines. Benefits were evaluated for Federal employees and 

other people with various types of vision, hearing, and speech disabilities and those with 

manipulation, reach, or strength limitations (collectively referred to in this evaluation as 

“addressable disabilities”). Benefits to Federal agencies and to ICT manufacturers and 

developers were also examined. We tried to identify, to the extent possible, which areas of the 

proposed requirements would result in specific categories of benefits for people with various 

types of disabilities. For a variety of reasons, however, it is not possible in most cases to quantify 

specific benefits of certain proposed requirements on people with particular types or 

combinations of disabilities. For example, quantifying the impact of the proposed requirements 

to improve the accessibility of Web site and software error notification and handling provisions 

would require information on the frequency of errors made by users over a representative set of 

software applications. It is unlikely that such information exists in usable form.

In addition, some of the most significant expected benefits from the proposed 508 standards and 

255 guidelines are not evaluated, either because they could not be quantified (due to lack of data) 

or are inherently qualitative. For persons with disabilities, for example, accessible ICT would 

increase the range of tasks that a Federal employee or person with a disability can complete 

independently, and RTT allows persons with hearing loss to communicate in an interactive 

fashion more akin to typical spoken conversations. More generally, enhanced ICT accessibility 

for persons with disabilities can be expected to improve civic engagement, decrease stigma, 

 

3 RTT is a next-generation technology that is expected to supplant the already declining usage of older technologies 

that enable people who are deaf or hard of hearing to use standard telecommunications equipment. RTT displays 

text on RTT-compatible devices as it is being typed, rather than requiring the receiving party to wait for the entire 

message to be completed and sent.

4 DOJ, 2010 Standards for Accessible Design, September 15, 2010.
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promote equality, and enhance integration into American society. For manufacturers and

developers of ICT products, harmonizing the 508 standards and 255 guidelines with consensus 

standards—particularly WCAG 2.0—would also be likely to assist U.S. ICT companies by 

helping to ensure return on investments in accessibility technology, remain competitive in the 

global marketplace, and achieve economies of scale created by wider use of nationally and 

internationally recognized technical standards. The fact that these benefits could not be formally 

assessed in this RIA does not diminish their importance or value.

Compliance costs were evaluated, and where possible quantified and monetized, for Federal 

agencies, Federal contractors and vendors, and U.S. and foreign telecommunications equipment 

manufacturers whose products are sold in the U.S. market.

5 Agencies and firms will incur costs 

to review and implement the proposed requirements; train employees; develop, produce, and test 

compliant ICT; and prepare and repair electronic documents and other types of electronic 

content. Contractors and vendors will also incur these types of costs to produce compliant ICT 

purchased by Federal agency clients. In many cases, the costs incurred will depend on the state 

of agency, contractor, or vendor compliance with both the existing and proposed Section 508 

standards. For example, our interviews with agency representatives indicated that agencies differ 

in their compliance strategies and practices and that in certain areas, the degree of accessibility 

provided exceeds what is required by the existing standards (e.g., both software development and 

document creation accessibility is already being defined using many of the WCAG 2.0 standards 

in some agencies).

Many types of costs could not be quantified and monetized, however. In many cases, we were 

not able to locate adequate information regarding the costs associated with specific changes in 

software coding, hardware components, or communications protocols. There are also several 

ongoing Federal Government ICT initiatives that could reduce compliance costs, including the 

efforts to develop performance metrics to monitor the effectiveness and efficiency of Section 508 

implementation at an agency level.

The impact on computer and telecommunications equipment manufacturers from the proposed 

rule is particularly difficult to quantify. Information on the impact of the proposed accessibility 

requirements was solicited in both the 2010 and 2011 Advance Notice of Proposed Rulemaking 

(ANPRM) and is again in the NPRM and this RIA. Absent this information, it is reasonable to 

expect that the costs incurred by U.S. and foreign ICT manufacturers to produce compliant 

products for sale in the U.S. market would be lower than the aggregate Section 508 compliance 

costs estimated for Federal agencies, contractors, and vendors.

As discussed below, some of the costs incurred by ICT manufacturers and developers could be 

embedded in the prices charged to all consumers, rather than being recovered solely through 

increased costs to Federal agencies for procured ICT. The RIA concludes that any such cost 

increase would be negligible—not more than 0.2 percent under the assumed upper bound of 

annualized compliance costs for computer and telecommunications equipment manufacturers.

 

5 The current and proposed Section 255 guidelines would not apply to equipment sold by U.S. and foreign 

telecommunications manufacturers in markets other than the United States.
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The Access Board invites the public to provide information, data, and methodologies for 

improving this assessment’s estimates of the proposed rule’s benefits and costs.

Table ES-1 summarizes the estimates of monetized benefits and costs developed for the 

proposed Section 508 standards and Section 255 guidelines. All benefits and costs were 

estimated for a 10-year time horizon and converted to annualized values using discount rates of 7 

and 3 percent. 

Table ES-1: Annualized Value of Monetized Benefits and Costs, 2015–2024 (Millions of 2015 

Dollars)

Monetized Benefits and Costs 7-Percent 

Discount Rate

3-Percent 

Discount Rate

Benefits from increased Federal employee productivity $46.6 $45.3 

Benefits from improved Federal Government Web site 

accessibility to people with vision disabilities $2.4 $2.3 

Benefits to Federal agencies from reduced call volumes $20.1 $19.8 

Annualized value of monetized benefits $69.1 $67.5*

In-house ICT costs $80.6 $76.3 

Procured ICT costs $74.4 $70.5 

Costs of telecommunications manufacturer product support 

Web site and content development $10.6 $9.8 

Annualized value of monetized costs $165.6 $156.6 

*Benefit numbers do not sum to total because of rounding.

Benefits of the Proposed Rule

This preliminary RIA includes monetized estimates for three types of benefits that can be 

expected from adopting the proposed Section 508 requirements. These benefits have an 

equivalent annualized value of $69.1 million over the 10-year analysis period using a 7-percent 

discount rate (see Table ES-1 above).

As noted above, several categories of benefits that could be expected from the proposed rule 

could not be quantified. These benefits are listed in Table ES-2.
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Table ES-2: Unquantified Benefits of the Proposed Rule

Time savings by people with hearing, cognitive, speech, or manual dexterity or motor impairments from 

more accessible Federal Government Web sites.

Improved accessibility of electronic content (especially PDFs and videos) on Federal Web sites for 

persons with addressable disabilities. 

Potential increase in employment of people with addressable disabilities.

Increased ability for people with addressable disabilities to obtain information and conduct transactions 

electronically.

Better civic engagement by persons with disabilities due to improved access to information and 

services on Federal Government Web sites.

Greater independence for persons with disabilities who can potentially access information on Federal 

Government Web sites themselves, rather than having to rely on others to access such information for 

them.

Increased ability for people without disabilities to access information and conduct businesses 

electronically even when they are limited by their situation, such as in a noisy or low-bandwidth 

environment or bright outdoors.

Agency cost savings from reduced levels of mail correspondence and in-person visits.

People who are deaf or hard of hearing to have faster and more natural conversations with RTT than is 

possible with current text-messaging functionality.

Improved ability of individuals with vision impairments and other disabilities to evaluate, purchase, and 

make full use of telecommunications products with the accessibility features they require or prefer to 

use because of increased accessibility of product documentation and support services.

Federal Government access to a larger pool of developers and content creators with required 

accessibility knowledge and skills because of harmonized standards.

Benefits to State and local governments, businesses, and nonprofit entities from harmonization of 

standards, including potential cost reductions to ICT manufacturers from being able to sell a single line 

of accessible products and services in public-sector, commercial, and international markets.

Intrinsic (existence) value that people with and without disabilities derive from the nondiscrimination 

and equity values served by Sections 508 and 255. 

Current (Baseline) Section 508 and Section 255 Costs

Limited data are available on the costs incurred by Federal agencies, contractors, and vendors to 

develop and maintain the current degree of required accessibility for various forms of ICT. 

Baseline estimates of current Section 508 compliance costs in five areas were developed for this 

evaluation. Overall baseline costs for in-house and procured ICT are estimated at $2.0 billion 

annually. This amount represents about 2 percent of annual Federal ICT spending, which is in 

the range between $80 billion and $120 billion, depending on which products and services are 

included in the total. Baseline costs for telecommunications equipment manufacturers to 

conform to the current Section 255 guidelines relating to product documentation and user

support are estimated to be $114 million annually. Better estimates or information on current 

Section 508 and Section 255 compliance costs are specifically requested from the public.
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Costs of the Proposed Rule

Econometrica developed estimates for five areas in which Federal agency, contractor, and vendor 

compliance costs are expected to increase under the proposed Section 508 standards:

 Policy development and implementation.

 Employee training.

 Software, Web, and audiovisual development.

 Software, Web sites, and audiovisual media evaluation.

 Electronic documents creation and repair.

Costs for manufacturers to comply with the proposed Section 255 guidelines relating to 

providing accessible electronic support documentation and services are also estimated.

Collectively, the proposed revisions to Section 508 and Section 255 have estimated compliance 

costs of $165.6 million on an annualized basis over the 10-year analysis period using a 7-percent 

discount rate (see Table ES-1).

There are also several categories of costs that would result from adoption of the proposed rule

but could not be quantified. These costs are listed in Table ES-3.

Table ES-3: Unquantified Costs of the Proposed Rule

Possible increase in Federal Government expenditures to provide accommodations if more people with 

addressable disabilities are hired.

Possible decrease in the amount or variety of electronic content produced to reduce Section 508 

compliance costs.

Costs to develop and produce hardware and telecommunications products that comply with proposed 

standards.

Costs associated with implementing and supporting RTT on telecommunications devices with text 

display capabilities.

Better estimates or information on the projected increase in compliance costs under the proposed 

Section 508 standards and Section 255 guidelines are specifically requested from the public.

Overall, we expect the proposed revisions to the Section 508 standards to have a significant 

aggregate impact on compliance costs initially but cause only a small percentage increase in 

recurring annual costs, relative to current baseline costs. We expect that compliance rates would

increase because the WCAG 2.0 standards provide a more detailed template for ensuring 

accessibility and because adopting these standards would facilitate the use of non-Section 508-

specific training and support resources to enable Federal employees to produce and evaluate ICT 

products, software, services, and content.

As noted above, the impact on telecommunications manufacturers and purchasers of 

telecommunications products from the proposed revisions to the Section 255 guidelines is more 

difficult to quantify. It is possible that manufacturers of computer hardware and 

telecommunications equipment may elect to spread the costs of compliance with the proposed 

ICT standards and guidelines across all of their entire product lines. The potential impact on 

consumer prices can be assessed by assuming that these manufacturers would incur compliance 
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costs equal to the entire amount estimated in this analysis for Federal agencies, contractors, and 

vendors (about $155 million on an annualized basis) with the aggregate value of annual 

shipments in this sector (about $100 billion). Under this conservative assumption, the 

incremental compliance costs incurred by computer and telecommunications equipment 

manufacturers would be still less than 0.2 percent of the value of their annual shipments.

Conclusion

This preliminary evaluation indicates that the monetized costs of the proposed rule exceed the 

monetized benefits. The annualized costs for the proposed Section 508 standards, net of the 

annualized benefits, represent about 4.5 percent of current annual Section 508 compliance costs. 

It is important to note, however, that there are potentially substantial compliance costs as well as 

significant benefits to people with disabilities, Federal agencies, contractors, and vendors for 

which adequate data were not available to develop monetized estimates. Indeed, the benefits of 

the proposed rule include important but inherently unquantifiable national values that are 

explicitly recognized in Executive Order 13563, including greater social equity, human dignity, 

and fairness. 

Considering all monetized and qualitative benefits and costs together, the Access Board and 

Econometrica have made a preliminary determination that the benefits of the proposed update of 

the Section 508 standards and Section 255 guidelines justify the costs.
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1. Introduction: Proposed Update of the Section 508 

Standards and the Section 255 Guidelines

The Access Board is an independent Federal agency devoted to accessibility for people with 

disabilities. The Access Board develops and maintains design criteria for the built environment, 

transit vehicles, telecommunications equipment, and electronic and information technologies. 

Section 508 of the Rehabilitation Act (as amended) requires that when Federal agencies develop, 

procure, maintain, or use electronic and information technologies, they must ensure that the 

electronic and information technologies allow Federal employees with disabilities to have access 

to and use of information and data that is comparable to the access to and use of information and 

data by Federal employees who do not have disabilities, unless doing so would impose an undue 

burden on the agency. Section 508 also requires that members of the public with disabilities who 

are seeking information or services from a Federal agency have access to and use of information 

and data that is comparable to that provided to the members of the public without disabilities, 

unless it would impose an undue burden on the agency.

The Access Board was required to develop and publish technical and functional performance 

criteria to implement Section 508. In 2000, the Board published standards that apply to Web sites 

and applications; software applications and operating systems; computers, peripherals, and “selfcontained, closed products”; and electronic content, including documents, audio, video, and 

multimedia. Federal agencies are required to comply with the Section 508 standards and to 

incorporate them into the procurement requirements for ICT products, professional services, and 

content procured from contractors and vendors.

6 The term “information and communication 

technology” is used throughout the NPRM preamble and proposed rule to broadly encompass 

electronic and information technology covered by Section 508, as well as telecommunications 

products, interconnected VoIP products, and CPE covered by Section 255. Examples of ICT 

include computers, information kiosks and transaction machines, telecommunications 

equipment, multifunction office machines, software, Web sites, and electronic documents.

The Access Board was also responsible for developing guidelines to implement Section 255 of 

the Communications Act of 1934, as amended, which requires telecommunications equipment 

manufacturers to ensure that a wide range of telecommunications equipment and services be 

made accessible when provision of such access is “readily achievable.”

7

In July 2010, the Access Board issued an ANPRM to solicit comment on revising, or 

“refreshing,” the current Section 508 standards and Section 255 guidelines.8 The Access Board 

 

6 The Federal Acquisition Regulatory (FAR) Council is responsible for issuing updated regulations that cover 

Federal Government purchases of ICT. DOJ periodically monitors and reports on Federal agency compliance with 

the Section 508 standards.

7 The Federal Communications Commission (FCC) establishes regulatory requirements for telecommunications 

equipment manufacturers based on the Section 255 guidelines. The FCC also has statutory obligations under Section 

255 and other enacted legislation to ensure the accessibility of various telecommunications services to people with 

disabilities.

8 The text of the 2010 ANPRM is available at http://www.access-board.gov/attachments/article/560/draftrule2010.pdf.
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indicated in the 2010 ANPRM that it proposed to harmonize the updated Section 508 standards 

with the current version of WCAG 2.0, which was developed by the W3C to improve the 

accessibility of Web sites. WCAG 2.0 covers a wide range of recommendations for making Web 

content more accessible.9 Following these guidelines will make content accessible to a wider 

range of people with disabilities, including blindness and low vision, deafness and hearing loss, 

learning disabilities, cognitive limitations, limited movement, speech disabilities, 

photosensitivity, and combinations of these disabilities and conditions.

Under the Access Board proposal, these requirements would serve as the core set of standards 

applicable not only to the Web sites of Federal agencies and other affected entities, but also to 

software applications, data processing and communications hardware, and telecommunications 

equipment. In December 2011, the Access Board issued a second ANPRM seeking review and 

comment on a revised Board proposal that would specifically require ICT (including specified 

types of electronic content produced using ICT) to meet the Level A and Level AA Success 

Criteria and Conformance Requirements specified for Web pages in WCAG 2.0.

10

The Access Board has received numerous comments on the two ANPRMs. In the NPRM, the 

Access Board is proposing to adopt the WCAG 2.0 Success Criteria and Conformance 

Requirements by reference as the core set of requirements in the proposed update of the current 

Section 508 standards and Section 255 guidelines. These standards would be applied not only to 

Web content, forms, and applications, but also to non-Web software, hardware and 

telecommunications equipment user interfaces, and electronic documents and other content.

These core requirements would be supplemented with other consensus standards and guidelines 

that address specific ICT areas, including PDF accessibility and RTT protocols.

2. Framework to Evaluate the Proposed Standards and 

Guidelines

Econometrica was tasked with developing a preliminary regulatory evaluation of the benefits and 

costs of the proposed requirements in the NPRM. The impact of the proposed Section 508 

standards was evaluated using the following framework: 

 Identify, summarize, and compare U.S. and international standards and guidelines that 

currently address ICT accessibility.

 Describe the reasons why updated standards and guidelines are necessary.

 Obtain and analyze data on the numbers of Federal employees and U.S. residents with 

various types of disabilities who could benefit from updated and improved ICT 

accessibility standards.

 

9 An explanation of how W3C approaches accessibility guidelines is available at 

http://www.w3.org/WAI/intro/components.php. An overview of the WCAG 2.0 standards begins on 

http://www.w3.org/WAI/intro/wcag.php.

10 The text of the 2011 ANPRM is available at http://www.access-board.gov/guidelines-andstandards/communications-and-it/about-the-ict-refresh/draft-rule-2011. 
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 Identify and quantify (where possible) the potential benefits to Federal employees, 

citizens, and agencies.

 Obtain and analyze data on Federal agency components (e.g., departments or offices), 

Federal and economy-wide ICT expenditures, and ICT sector employment. These metrics 

were used to define and quantify the entities, purchases, and personnel that would be 

affected by the need to comply with the updated standards.

 Develop estimates of current and projected future (“baseline”) Federal agency Section 

508 compliance rates and the estimated costs to achieve this projected baseline level of 

compliance if the Section 508 standards are not updated.

 Identify provisions in the proposed standards that may result in increased compliance 

costs for Federal agencies and vendors, as well as provisions that may reduce the amount 

of time and effort required to comply with Section 508 or improve the ability of Federal

employees to evaluate ICT to determine whether it meets the applicable standards.11

 Develop preliminary estimates of the net increase in compliance costs that would result 

from adopting the proposed Section 508 standards over a 10-year analysis period from 

2015 through 2024.

 Identify and assess the significance of unquantifiable costs and potential cost savings to 

Federal agencies and contractors that could be expected to result from adopting the 

proposed standards and guidelines.

A similar approach could be followed to characterize and evaluate the societal impact of the 

proposed Section 255 guidelines. However, we could not locate adequate data to develop 

quantitative estimates of the impact of many provisions in the proposed Section 255 guidelines.

The rapid evolution of ICT devices, platforms, applications, and consensus standards

complicates evaluation of the proposed regulatory requirements. Therefore, the benefits and 

costs of the proposed standards and guidelines ultimately depend not only on technologies that 

are currently available to achieve compliance, but also on emerging technologies that may 

provide better or more cost-effective options to ensure equal access to ICT for people with 

disabilities in the future.

3. Current Standards and Guidelines to Ensure Equal Access 

to ICT for People With Disabilities

The Access Board, DOJ, and the FCC each have defined responsibilities relating to the 

development and/or implementation of current Federal standards and guidelines designed to 

ensure equal access to ICT for people with disabilities.

12 In addition to the current Section 508 

 

11 Additional costs may be incurred by telecommunications and network equipment manufacturers to comply with 

the proposed update to the Section 255 guidelines. However, we were not able to develop quantitative estimates of 

these compliance costs.

12 In addition, the U.S. Department of Transportation (DOT) has jurisdiction over the accessibility of ICT related to 

air transportation under the Air Carrier Access Act.
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standards and Section 255 guidelines, Federal, State, and local government agencies, private forprofit and nonprofit entities, employers, and employees may be required to comply with other 

ICT-related accessibility obligations under Section 501 or 504 of the Rehabilitation Act of 1973. 

The FCC has also recently adopted or proposed requirements to implement accessibility 

regulations covering some telecommunications services and video programming mandated by 

the Twenty-First Century Communications and Video Accessibility Act (CVAA) of 2010.

Many State and local governments, public university systems, and libraries have also adopted 

(or, in some cases, have been required to adopt) policies or standards related to ICT accessibility. 

These standards typically reference or are partly based on requirements in the current Section 

508 standards. In contrast, U.S. corporations and foreign governments seeking to ensure equal 

access to Web content and applications have typically done so by either referencing or adapting 

the WCAG 2.0 conformance requirements and success criteria.

3.1. Section 508 Standards

The Access Board standards implementing the requirements of Section 508 were published in 

December 2000. The Section 508 standards apply to all electronic and information technologies

developed, procured, maintained, or used by Federal agencies and compiled in Section 508 of the 

Rehabilitation Act of 1973.13

Part 1194.22 of Section 508 covers Federal agency Web-based intranet and Internet information 

and applications. These requirements include 16 specific standards designed to ensure that 

Federal agency Web sites can be processed and interpreted by assistive technology (AT) such as 

screen readers. Other parts of Section 508 specify requirements applicable to software 

applications and operating systems, telecommunications products, video and multimedia 

products, “self-contained, closed products,” and desktop and portable computers.

DOJ has periodically conducted surveys of Federal agencies to establish the level of Federal 

Government compliance with the Section 508 standards. A September 2012 DOJ report provides 

recent information on Federal agency compliance rates, activities, staffing, and expenditures.

14

These DOJ report results are used to establish baseline levels of compliance costs for Federal 

agencies under the current standards.

3.2. Section 255 Guidelines

Section 255 of the Communications Act of 1934, as amended, requires the Access Board to issue 

guidelines for manufacturers of telecommunications equipment and CPE to ensure that

equipment is designed, developed, and fabricated to be accessible to and usable by individuals 

 

13 Section 508 accessibility standards, information on best practices, and links to training and technical support 

forums are available at www.section508.gov.

14 DOJ, “Section 508 Report to the President and Congress: Accessibility of Federal Electronic and Information 

Technology,” September 2012.
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with disabilities when such access is readily achievable.15 In 1998, the Access Board published 

the current Section 255 guidelines that cover telephone network equipment and CPE. CPE refers 

to telecommunications equipment used in the home or office (or other premises) to originate, 

route, or terminate telecommunications. Examples of CPE include telephones, fax machines, 

answering machines, and pagers. CPE that provides both telecommunications and nontelecommunications functions is covered only to the extent it provides telecommunications 

functions.16 Interconnected VoIP equipment manufacturers are also subject to the Access 

Board’s guidelines as a result of FCC rules issued in 2007.

While the Access Board’s guidelines concern telecommunications product and equipment 

manufacturers, the FCC rules implementing Section 255 govern telecommunications products as 

well as services, including telephone calls, call waiting, speed dialing, call forwarding, 

computer-provided directory assistance, call monitoring, caller identification, call tracing, and 

repeat dialing. In addition, the rules implementing Section 255 cover voicemail and interactive 

voice response systems (phone systems that provide callers with menus of choices). In addition, 

the 2007 FCC rules extended Section 255 accessibility obligations to interconnected VoIP 

service providers.

17

The more recently adopted CVAA addresses barriers to accessibility posed by advanced 

communications services. It contains an extensive list of requirements and a regulatory 

implementation schedule for the FCC. Advanced communications service coverage includes 

non-interconnected VoIP equipment and services, electronic messaging services (including 

email, instant messaging, and text messaging), and video conferencing:

 Section 716 of the CVAA requires providers of advanced communications services and 

manufacturers of equipment used for advanced communications services to ensure that 

their services and equipment are accessible to and usable by individuals with disabilities, 

unless doing so is not achievable with “reasonable effort or expense.”

18 The FCC adopted 

regulations partly implementing Section 716 in its October 7, 2011, Report and Order and 

published additional regulations on April 29, 2013.

 Section 718 of the CVAA requires mobile phone service providers and manufacturers to 

make Internet browsers built into mobile phones accessible to and usable by people who 

are blind or have a visual impairment, unless doing so is not achievable. The FCC issued 

regulations implementing Section 718 in its April 29, 2013, Report and Order.

 

15 Where accessibility is not readily achievable, Section 255 requires manufacturers to make their devices 

compatible with peripheral devices and specialized CPE that are commonly used by people with disabilities, if 

providing this compatibility is readily achievable.

16 The current Section 255 guidelines define CPE as “equipment employed on the premises of a person (other than a 

carrier) to originate, route, or terminate telecommunications,” while telecommunications equipment is defined as 

“equipment, other than customer premises equipment, used by a carrier to provide telecommunications services, and 

includes software integral to such equipment (including upgrades).”

17 See FCC, “Tentative Findings on Accessibility of Communications Technologies,” CG Docket No. 10-213, 

August 23, 2012.

18 The Section 716 requirements do not apply to equipment already covered under the Section 255 guidelines.
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3.3. W3C Consensus Standards

The W3C is an international community of Web programmers and users that develops technical 

specifications and guidelines for Web site technology. The W3C Web Accessibility Initiative

(WAI) has developed and adopted two sets of consensus Web site accessibility guidelines. 

WCAG 1.0, published in 1998, provided the foundation for a significant part of the current 

Section 508 standards relating to Web site (and other ICT) accessibility.19

WCAG 2.0, published 10 years later on December 11, 2008, represented a comprehensive update 

and revision of these standards. WCAG 2.0 covers a wide range of recommendations for making 

Web content more accessible. Following these guidelines will make content accessible to a wider 

range of people with disabilities, including blindness and low vision, deafness and hearing loss, 

learning disabilities, cognitive limitations, limited movement, speech disabilities, 

photosensitivity, and combinations of these disabilities or conditions.20

WCAG 2.0 is organized around four principles that ensure that Web sites are accessible for 

people with various types of disabilities:

1. Information and user interface components must be presentable to users in ways they can 

perceive.

2. User interface components and navigation must be operable.

3. Information and the operation of user interface must be understandable.

4. Content must be robust enough that it can be interpreted reliably by a wide variety of 

user agents, including ATs.

WCAG 2.0 applies broadly to more advanced technologies than WCAG 1.0. It is easier to use 

and understand and is more precisely testable with automated testing and human evaluation. The 

performance criteria specified in each section of WCAG 2.0 are widely regarded to be 

operationally achievable, measurable, and potentially enforceable.21 In contrast, elements of both 

WCAG 1.0 and the current Section 508 standards that address some of the same accessibility 

issues are difficult to measure and evaluate consistently.

In February 2014, the European Telecommunications Standards Institute (ETSI) published a new 

standard—EN 301 549—that uses the WCAG 2.0 Level A and Level AA Success Criteria as the 

basis to evaluate accessibility for all covered Web and non-Web electronic content.

22 Foreign 

government Web site accessibility requirements are also typically defined by reference to, or are 

 

19 The Access Board has determined that 11 of the 16 Section 508 requirements relating to Web sites are consistent 

with specific WCAG 1.0 Priority 1 checkpoints. Several of the remaining requirements address accessibility issues 

that were also covered in the WCAG 1.0 standards.

20 Both WCAG 1.0 and WCAG 2.0 have three nested levels of standards that afford increasing levels of 

accessibility. The WCAG 1.0 standards are categorized as Priority Levels 1, 2, or 3. The WCAG 2.0 standards are 

specified at the A, AA, and AAA levels. WCAG 1.0 Priority Level 1 and WCAG 2.0 Level A represent the least 

extensive set of requirements.

21 W3C provides extensive guidance, examples, best practices, and resources for complying with the WCAG 2.0 

specifications.

22 ETSI, “Accessibility requirements suitable for public procurement of ICT products and services in Europe,” EN

301 549 V1.1.1 (2014-02).
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largely based on, WCAG 2.0. Australia, Canada, Hong Kong, and New Zealand Government 

sites are or will be required to meet the WCAG 2.0 Level A and Level AA Success Criteria and 

Conformance Requirements. France and Germany have national standards that are based on but 

not identical to WCAG 2.0 (Level AA), while United Kingdom Government Web sites are 

required to comply with either WCAG 1.0 or 2.0 at the AA level.23

3.4. Sections 501 and 504 of the Rehabilitation Act of 1973

Federal agencies and recipients of funding are subject to additional obligations to accommodate 

employees and ensure access for programs and activities under other parts of the Rehabilitation 

Act of 1973. Section 501 requires affirmative action and prohibits discrimination in employment 

by Federal agencies of the Executive branch of Government. Federal agencies are required to 

provide reasonable accommodation for Federal employees with disabilities, including provision 

of accessible ICT and electronic content, unless doing so would cause undue hardship.

24

Section 504 requires that qualified individuals with disabilities must not be excluded from, 

denied access to, or subjected to discrimination under any program or activity that either receives 

Federal financial assistance or is conducted by any Executive agency or the U.S. Postal Service

(USPS). Each Federal agency has its own Section 504 regulations that apply to its own 

programs, and agencies that provide financial assistance have regulations that cover entities 

receiving Federal aid. Employees must be provided with reasonable accommodations, as well as 

access to participation in all programs, facilitated communication for people with hearing or 

vision disabilities, and accessible construction and alterations.25

It is important to note that Federal agency compliance with the Section 508 standards does not 

ensure that it has fully discharged its obligations to employees or the public under Section 501 or 

Section 504. For example, the applicable Department of Health and Human Services guidance 

notes in part:

An agency may, in some instances, be able to meet its Section 504 obligation to 

provide equal opportunity to persons with disabilities and ensure effective 

communication by making information available in a Section 508-compliant form 

on its external-facing website or intranet(s). However, in other cases, in order to 

meet its Section 504 obligation, an agency may need to provide an appropriate 

auxiliary aid to an individual with a disability, regardless of whether information 

on its website meets accessibility requirements under Section 508.26

 

23 Mark Rogers, “Government Accessibility Standards and WCAG 2.0,” Power Mapper Software Blog, posted 

November 13, 2012.

24 A reasonable accommodation is any change in the work environment or in the way a job is performed that enables 

a person with a disability to enjoy equal employment opportunities.

25 See DOJ Disability Rights Office, “A Guide to Disability Rights Laws,” last updated July 2009.

26 HHS.gov, “Clarification: Compliance with Sections 504 and 508 of the Rehabilitation Act.”
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4. An Overview of the Proposed 508 Standards and 255 

Guidelines

4.1. Need for Revision of Current Standards and Guidelines

The requirements in the current Section 508 standards and Section 255 guidelines are product or 

technology specific rather than being based on the functionality of the ICT. During the past 15 

years, previously distinct technologies have converged, and users are increasingly able to 

perform the same tasks using devices and software that are subject to different accessibility 

requirements. In addition, some newer technologies (e.g., JavaScript menus on Web sites, mobile 

phone interfaces) can pose accessibility issues that did not exist at the time the current standards 

were published. Inter-device and platform interoperability and compatibility have become more 

important as the numbers and capabilities of ICT products, applications, and content have 

proliferated. Businesses and foreign governments have adopted new or revised accessibility 

requirements that reference, or are based on, voluntary consensus standards for electronic 

applications, content, and devices to address the challenges posed by convergence and need for 

interoperability. 

In addition, Federal agencies have had to develop additional requirements and guidance for ICT 

professionals, contracting personnel, and other employees and contractors with Section 508 

compliance responsibilities because the many provisions of the current standards are not 

measureable or testable. To address the inefficiencies that resulted from each agency needing to 

develop supplemental requirements, guidance, and testing protocols, the Federal Government has 

undertaken several ICT initiatives that support uniform cross-agency ICT requirements, 

compliance guidance, and evaluations of products and services. Consequently, the standards that 

many Federal agencies now use to measure accessibility have evolved significantly from those 

specifically set forth in the published requirements.

The Access Board NPRM proposes to update and unify the current Section 508 standards and 

255 guidelines, largely by recognizing and leveraging voluntary consensus standards and current 

ICT industry practices. By doing so, the Federal Government and telecommunications 

manufacturers would be able to ensure the accessibility of ICT covered under the Section 508 

standards or Section 255 guidelines using a set of functionality-based requirements that are 

harmonized with those already established in other sectors.

The Access Board considered two alternative approaches to updating the current Section 508 

standards or Section 255 guidelines:

1. In the 2010 ANPRM, the Board proposed a set of requirements that were based on but 

not identical to the WCAG 2.0 standards and other voluntary consensus standards. 

Comments received from stakeholders and the public indicated that this approach was 

potentially confusing, as Federal agencies, contractors, and vendors would have to make 

specific compliance determinations in cases where the language used in the proposed 

Section 508 standards differed from that in the referenced standard.

2. The Board also considered requiring ICT to be compliant with the full set of Functional 

Performance Criteria, which state in general terms the features of ICT that ensure its 
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accessibility to people with one or more of eight different types of vision or hearing 

disabilities or manipulation, reach, or strength limitations (collectively referred to in this 

evaluation as “addressable disabilities”). Comments from stakeholders—including the 

Cellular Telecommunications Industry Association and the Software & Information 

Industry Association (SIIA)—indicated that this approach would make it difficult for ICT 

creators to be able to determine whether or not their products and services were 

compliant with the proposed Section 508 standards.

Based on the comments received in response to the 2010 and 2011 ANPRMs, the Board 

determined that the clearest and most efficient way to set out the proposed accessibility 

requirements was to identify and reference existing consensus standards directly wherever 

possible.

The Access Board is therefore proposing to update the Section 508 standards and Section 255 

guidelines in large part by referencing the applicable Level A and Level AA Success Criteria and 

Conformance Requirements specified for Web pages in WCAG 2.0.

27 There are several 

advantages to using this approach to update the current standards and guidelines:

 Referencing WCAG 2.0 is consistent with Office of Management and Budget (OMB) 

Circular A-119, which directs agencies to use voluntary consensus standards in lieu of 

government-unique standards, except where inconsistent with law or otherwise 

impractical. The primary benefit is economic in that this practice can reduce costs to the 

Government associated with developing its own standards and can also decrease the cost 

of goods and services procured by the Government. Fragmentation of standards is an 

economic issue for the Government, businesses, and Web developers. 

 WCAG is written to be technology neutral. The convergence of telecommunications and 

data processing equipment and services means that an increasing variety of devices are 

being used to perform a common set of functions and activities. Some significant trends 

directly affect the application of Section 508 standards to current ICT:28

o Wireless telecommunications devices are now capable of running sophisticated

software applications that do not involve voice communications. 

o Office computing functions are typically performed in a device-independent 

environment on network servers or, increasingly, in the “cloud.”

o Enterprise copiers, printers, and scanners have been replaced by multifunction 

machines that have characteristics of both computer peripherals and photocopying 

equipment.

 

27 A provision-by-provision comparison of the WCAG 2.0 and Section 508 standards is available on the Access 

Board Web site.

28 The preamble notes that “WCAG 2.0 addresses new technologies and is responsive to the fact that the 

characteristics of products, for example native browser behavior and plug-ins and applets, have converged over 

time. Today, there are fewer distinctions among product categories, and some are outdated. For example, modern 

smart phones include software applications and operating systems, Web-based intranet and Internet information and 

applications, and video and multimedia products. Additionally, smart phones are portable computers, 

telecommunications products, and self-contained closed products.”
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 Mobile Web content and applications emerged several years after the WCAG 1.0 and 

current Section 508 standards were developed. There is substantial overlap between the 

WAI-published Mobile Web Best Practices/Mobile Web Applications Best Practices 

guidelines and the WCAG 2.0 standards.29

 Adoption of new technologies and programming techniques has generated new 

accessibility obstacles that did not exist when the current Section 508 standards were 

developed.30

 The WAI provides an open and autonomous process for providing periodically improved 

supplementary guidance materials for their standards. These techniques and 

understanding documents are not requirements, but they are very useful.31

 The WAI provides an open and autonomous process for updating complementary 

standards, such as the Authoring Tools Accessibility Guidelines and User Agent 

Accessibility Guidelines (ATAG and UAAG, respectively).32

In addition to the proposed Access Board update of the current Section 508 standards and 

Section 255 guidelines, comparable accessibility requirements have been adopted or are 

currently being proposed in other current Federal agency rulemaking proceedings that would 

apply to providers of passenger air transportation and private-sector entities that operate public 

accommodations:

 A 2013 Rule published by DOT promulgated WCAG 2.0-based requirements to ensure 

that the Web sites of U.S. and foreign carriers marketing air transportation in the United 

States would be accessible to people with disabilities.33

 DOJ issued an ANPRM in 2010 indicating that the Department was considering revising 

the current ADA Title III regulations to establish requirements to ensure that goods, 

services, facilities, privileges, accommodations, or advantages offered by public 

accommodations via the Internet would be accessible to individuals with disabilities. The 

ANPRM also stated that “the Department is also considering revising the ADA Title II 

regulations to establish requirements for making the services, programs, or activities 

offered by State and local governments to the public via the Web accessible.34

 

29 Mappings of the differences between WAI Mobile Web Best Practices and the WCAG 2.0 (and 1.0) standards are 

provided in links from W3C, Web Accessibility Initiative, “Web Content Accessibility and Mobile Web: Making a 

Website Accessible Both for People with Disabilities and for Mobile Devices,” updated August 31, 2012.

30 For example, the current Section 508 standards do not contain explicit requirements for keyboard operability 

because 2000-era Web pages were always keyboard operable. As Web technologies have become more complex, 

mouse or touch-only interfaces have not always preserved keyboard operability.

31 A page that describes the different WCAG 2.0 technical documents is available at 

http://www.w3.org/WAI/intro/wcag20, updated December 17, 2008.

32 A new regulatory proceeding would be required to rule the proposed Section 508 standards and Section 255 

guidelines to reference future updates to any of these WAI-developed standards.

33 DOT, “Nondiscrimination on the Basis of Disability in Air Travel: Accessibility of Web Sites and Automated 

Kiosks at U.S. Airports,” Final Rule, DOT–OST–2011–0177-0006, November 12, 2013.

34 DOJ, “Nondiscrimination on the Basis of Disability: Accessibility of Web Information and Services of State and 

Local Government Entities and Public Accommodations,” ANPRM, DOJ–CRT–2010–0005–0001, July 26, 2010.
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As noted above, WCAG 1.0 and 2.0 are also internationally recognized standards for Web site 

accessibility, whereas Section 508 is specific to ICT procured, developed, maintained, or used by 

the U.S. Government.

4.2. WCAG 2.0 and Other Proposed Accessibility Standards: What 

Would Be Required?

WCAG 2.0 Level AA conformance includes 38 success criteria, most of which relate to issues 

that are also addressed in the current Section 508 standards for Web pages, content, forms, and 

applications. The Access Board has determined that 22 of the 38 specific WCAG 2.0 Level A 

and Level AA Success Criteria are “substantially equivalent” to provisions in the current Section 

508 standards. These provisions are identified in Table A-1 of Appendix A.

There are 16 WCAG 2.0 standards that could be considered “new” in the context of the current 

Section 508 standards. The majority of these are consistent with current industry standards or 

common ICT user expectations:

 Five requirements specify the organization and coding of Web pages and electronic 

content to ensure that the order and navigation are clear and consistent. Compliance with 

these standards is consistent with reasonable structure and presentation of electronic 

content for all audiences, rather than specifically for those with addressable disabilities.35

 Four provisions state standard or recommended Web and software programming 

requirements.36

 Two standards for handling forms and transactions would be desirable to incorporate into 

any ICT, irrespective of accessibility considerations.37

 One standard provides all Web or multimedia users with the ability to control audio 

content that would otherwise be impossible to pause or interrupt.38

The remaining 4 of the 16 “new” WCAG 2.0-based standards are specifically focused on the 

presentation of visual and audio information in ways that can be accessible to people with 

addressable disabilities. These include the requirements for minimum levels of color contrast, 

user ability to resize text, ability to understand instructions without reliance on specific sensory 

capabilities, and ability to navigate in multiple ways.39

The Access Board is also proposing to incorporate references to other voluntary international 

consensus standards that address specific ICT accessibility issues:

 

35 The referenced WCAG 2.0 standards are the requirements relating to meaningful sequence (1.3.2), focus order 

(2.4.3), link purpose (2.4.4), headings and labels (2.4.6), and consistent navigation (3.2.3).

36 The referenced WCAG 2.0 standards are the requirements relating to avoiding keyboard traps (2.1.2), specifying 

the language of pages and parts of pages (3.1.1 and 3.1.2), and parsing of code (4.1.1).

37 The referenced WCAG 2.0 standards are the requirements relating to error suggestion and prevention (3.3.3 and 

3.3.4).

38 The referenced WCAG 2.0 standards are the requirements relating to audio control (1.4.2).

39 The referenced WCAG 2.0 standards are the requirements relating to reliance on sensory characteristics (1.3.3), 

contrast (1.4.3), resizing of text (1.4.3), and providing multiple ways to find content (2.4.5).
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 Compliance with the International Standard for Accessible PDF Technology (PDF/UA-1) 

is proposed as an optional alternative for PDF files. PDF/UA-1 provides a technical, 

interoperable standard for the authoring, remediation, and validation of PDF content to 

ensure accessibility for people with disabilities who use assistive technology such as 

screen readers, screen magnifiers, joysticks, and other ATs to navigate and read 

electronic content.

 RTT functionality would be required where ICT provides real-time, two-way voice 

communication (such as telephones, webinars, and videoconferencing technology).

Features capable of text generation would have to be compatible with real-time voice 

communication used on a network. ICT would be required to interoperate either within its 

own closed system or outside a network.

Other proposed requirements include referenced standards applicable to software user interfaces, 

hearing aid compatibility with wireless communications devices, digital television processing of 

audio description, and other technical issues. A complete list of the referenced standards is 

provided in section E102 of the proposed rule text.

4.3. ICT Content, Applications, and Equipment: What Would Be 

Covered?

The current Section 508 standards cover six specific categories of ICT:

 Software applications and operating systems.

 Web-based intranet and Internet information and applications.

 Telecommunications products.

 Video and multimedia products.

 Self-contained, closed products.

 Desktop and portable computers.

The current Section 508 standards also apply to electronic documents and other electronic 

content created by Federal employees or contractors, although the types of content that must be 

made accessible are not specified in the rule text.

The current Section 255 guidelines cover the following:

 Wired and wireless telecommunication devices such as telephones (including pay phones 

and cellular phones), pagers, and fax machines.

 Other products that have a telecommunication service capability, such as modems

connected to computers and interconnected VoIP equipment.

 Equipment that carriers use to provide services, such as phone company switching 

equipment.

The proposed update of the current Section 508 standards and Section 255 guidelines would base 

accessibility requirements on ICT functionality (e.g., programs, video, audio, documents) rather 

than the specific technology through which the content or application is developed or distributed. 
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Proposed requirements dealing with video accessibility for people with vision-related disabilities 

would apply to displays on Web sites, software applications, and multifunction machines. Audio 

players on Web sites or on telecommunications products and desktop computers would need to 

provide accessible controls. Proposed AT compatibility requirements would apply to all 

electronic devices defined as ICT.

4.3.1. Covered Categories of Electronic Content

Although the proposed scoping definitions apply to most ICT equipment and services covered 

under the current Section 508 requirements, the types of electronic content that would fall under 

the purview of the proposed standards would be defined in more specific terms. The Access 

Board is proposing to provide a list of covered forms of electronic communications originated or 

disseminated by the Federal Government or its employees based on the type of content:

1. Public-facing content.

2. Official business content communicated by an agency through one or more of the 

following:

a. An emergency notification.

b. An initial or final decision adjudicating an administrative claim or proceeding.

c. An internal or external program or policy announcement.

d. A notice of benefits, program eligibility, employment opportunity, or personnel 

action.

e. A formal acknowledgement or receipt.

f. A questionnaire or survey.

g. A template or form.

h. Educational or training materials.

The Access Board considers that these categories of electronic content represent the official 

agency communications that are most likely to affect a significant number of employees and 

members of the public with disabilities.

4.3.2. Application of WCAG 2.0 to Non-Web ICT

In addition to electronic documents, hardware, software (including firmware, platforms, and 

applications), and ICT support documentation and services would continue to be covered under 

the proposed standards. Telecommunications equipment (whether sold to the Federal 

Government or other customers) would also be required to comply with the applicable WCAG 

2.0-based requirements in the proposed update to the Section 255 guidelines.

The Access Board is also proposing additional requirements that are specifically applicable to 

software, hardware, and telecommunications equipment. Additional information about individual 

WCAG 2.0 standards and the proposed additional requirements for software, hardware, and 

telecommunications equipment is provided in Appendix A.
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4.4. Major New Requirement Areas in the Proposed Standards and 

Guidelines

This assessment identifies 11 areas in which the proposed requirements represent potentially 

significant changes from current ICT standards and guidelines:

1. Applying WCAG 2.0 to software and applications.

2. Accessibility features within software applications and operating systems.

3. Authoring tools.

4. Assistive technology.

5. Electronic content and data.

6. Color and contrast settings.

7. Audio control on Web pages.

8. User control for captions and video description.

9. RTT functionality.

10. ICT hardware accessibility.

11. Online product documentation and support services.

A brief discussion of each area of the proposed revisions with potentially significant impact

follows.

4.4.1. Area 1: Applying WCAG 2.0 to Software and Applications

The proposed rule would apply the WCAG 2.0 Success Criteria Level A and Level AA not only 

to Web pages, but also to software platforms, toolkits, and applications. Software applications 

and operating systems are required to meet the accessibility requirements set forth in section 

1194.21 of Section 508. As noted in Appendix A, most of these requirements have analogues in 

the WCAG 2.0 Success Criteria.40

While WCAG 2.0 was developed specifically to address accessibility issues with Web-based 

content, forms, and applications, the NPRM explains the rationale for applying these standards to 

non-Web ICT:

Because WCAG 2.0 was written to be technology neutral, the language and 

phrasing of the Success Criteria can be applied to any technology found on the 

Web. Since most file types are found on the Web and much software is now Webenabled, it is reasonable to utilize WCAG 2.0 to evaluate off-line documents and 

software interfaces with straightforward substitution of terms to address this new 

application. This approach has the potential to significantly simplify accessibility 

conformance and assessment.

 

40 Some of the WCAG 2.0 criteria would be applied more broadly than their counterparts in the current Section 508 

standards. For example, the WCAG 2.0 requirement (3.2.4) to provide consistent identification of components with 

the same functionality within a set of Web pages in cases would supersede the current Section 1194.22(e) 

requirement that is limited to identification of components using bitmap images.
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The W3C has developed a working draft guidance document that provides support for the 

prospective application of WCAG 2.0 recommendations to non-Web ICT. More information on 

this guidance is provided in Section A.2 of Appendix A.41

4.4.2. Area 2: Accessibility Features in Software Applications and Operating 

Systems

In addition to requiring compliance with the applicable WCAG 2.0 Success Criteria, the NPRM 

includes three additional sets of proposed requirements for software applications and operating 

systems. The first set addresses the need to ensure that AT that uses standard accessibility 

services is interoperable with software platforms, toolkits, and applications. Software platforms 

would be required to provide a specified list of documented accessibility services, typically 

through the means of application programming interfaces (APIs). 42

4.4.3. Area 3: Authoring Tools

The proposed standards for software accessibility would also extend beyond the WCAG 2.0-

based requirements for applications that function as “authoring tools”—programs that are used to 

create other applications or electronic content.43 The current Section 508 standards have no 

explicit requirements specifically relating to authoring tools. The proposed standards would 

require authoring tools to provide a mode of operation that would allow users to create or edit 

WCAG 2.0-compliant content, preserve information required for accessibility, provide user 

prompts that would proactively support the creation of accessible content, and provide a range of

templates (where templates are provided) that facilitate the creation of accessible content. 

Software applications that function as authoring tools currently provide varying capabilities to 

support incorporating accessibility in the design of content and forms and to evaluate the 

accessibility of material created in other applications.44 The W3C developed and published the 

first consensus set of authoring tool accessibility guidelines (ATAG 1.0) in February 2000. 

However, we were not able to identify currently marketed software applications that are able to 

claim conformance with the ATAG criteria.

 

41 W3C, “Guidance on Applying WCAG 2.0 to Non-Web Information and Communications Technologies,”

Working Draft, September 5, 2013. Development of this guidance was prompted in part by some industry 

association comments on the two Access Board ANPRMs that indicated that there may be issues in applying the 

WCAG 2.0 standards to non-Web ICT. See Joint Comments of the Telecommunications Industry Association (TIA) 

and CTIA – the Wireless Association, Docket No. 2011-07, March 7, 2012, and SIIA, Comments to Access Board 

on Electronic Accessibility, Docket No. 2011-07, March 7, 2012. SIIA recommended that “the Access Board work 

together with the W3C, international technical experts, and industry participants to assess how the principles in 

WCAG 2.0 can be applied in various non-web contexts and develop interpretations or extensions of these principles 

that are appropriate for these different contexts.”

42 According to Wikipedia, “an application programming interface (API) specifies how some software components 

should interact with each other....In practice, many times an API comes in the form of a library that includes 

specifications for routines, data structures, object classes, and variables.”

43 Examples of authoring tools include office suites such as Microsoft Office, design suites such as Adobe Creative 

Suite, database development tools provided by companies such as Oracle, and programming applications.

44 For example, Adobe Acrobat XI advertises an expanded set of tools to detect violations of current Section 508 

requirements in content imported from a wide range of applications.
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An updated set of guidelines (ATAG 2.0) is currently being finalized.45 Some open-source 

authoring tools including Drupal, a content management system used to develop a large number 

of Federal Government Web sites, have evaluated their conformance with ATAG 2.0. These 

evaluations have indicated that many elements of conformance have not yet been realized.46

4.4.4. Area 4: Assistive Technology

Another proposed set of software-related accessibility requirements are intended to ensure the 

interoperability of software that functions as AT with software platforms that provide standard 

accessibility services.

As is the case with ICT generally, assistive technology can be provided in both physical 

(hardware) and virtual (software) forms. The National Center for Accessible Media lists the 

following forms of AT used in conjunction with Web sites and software applications:47

 Screen readers.

 Refreshable Braille displays.

 Screen magnifiers.

 Adaptive keyboards.

 Voice-recognition software.

The current Section 508 standards have no explicit requirements for assistive technology. 

Current practice is typically to have an API built into the main product to interact with AT or to

have products with built-in accessibility features so that no AT is needed.

4.4.5. Area 5: Electronic Content and Data

Electronic content, including documents, spreadsheets, presentations, photos, and audio and 

video clips, is not specifically included in the definitions of “electronic and information 

technology” or “information technology” in the current Section 508 standards. However, the 

Access Board has interpreted the standards to cover electronic documents and other forms of 

electronic content, irrespective of whether or not these materials are available through a publicfacing Web site.

The proposed standards add a definition of “electronic content,” list specific categories of 

electronic content that must be made accessible, and reference the WCAG 2.0 Level A and Level 

AA Success Criteria as the benchmark for determining whether covered electronic content is 

accessible.

Our interviews with agency representatives indicated that significant attention and resources 

have only recently been devoted to expanding the accessibility of electronic content accessible 

 

45 W3C, “Authoring Tool Accessibility Guidelines (ATAG) 2.0,” W3C Candidate Recommendation, November 7, 

2013. The W3C Web site indicates that “ATAG 2.0 is being developed to be compatible with WCAG 2.0. WAI 

anticipates ATAG 2.0 will be completed in 2014. Because of the nature of the W3C development process, WAI 

cannot be certain when the final version of ATAG 2.0 will be available. ATAG 1.0 will remain the latest approved 

version until version 2.0 is complete. Currently, ATAG 2.0 is a mature draft and we expect that it will not change 

significantly. We recommend that you use the ATAG 2.0 draft in most cases, understanding that it might change.”

46 Drupal Groups, “Drupal compliance overview of ATAG 2.0,” continuously updated. 

47 National Center for Accessible Media, “Accessible Digital Media Guidelines: Tools for Access.”
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beyond content posted on Federal Government Web sites. Agencies with different capabilities 

and resources have achieved varying degrees of success in making specific categories of nonWeb electronic documents and content accessible thus far.

Substantial resources are currently available for creators and editors who need to ensure that their 

electronic content is accessible. Several components of the Federal Government provide 

comprehensive “how to” portals and sites with best practices and guidance for the most common 

desktop software applications:48

 Department of Health and Human Services, Making Files Accessible.

 General Services Administration, GSA 508 Tutorials, Guidance, Checklists.

 Social Security Administration, Resources for Developers and Document Authors.

As noted above, software vendors also provide users with extensive assistance on producing 

accessible content.

4.4.6. Area 6: Color/Contrast Settings and Text Resizing

The current Section 508 standard includes several provisions governing color and contrast, 

including the following parts of Section 1194.21:

(i) Color coding shall not be used as the only means of conveying information, 

indicating an action, prompting a response, or distinguishing a visual element.

(j) When a product permits a user to adjust color and contrast settings, a variety of 

color selections capable of producing a range of contrast levels shall be provided.

However, these requirements arguably are vague and lack sufficient detail to be testable, whereas 

the proposed standards provide testable requirements for electronic content, software 

applications, and operating systems. In most cases, visual presentation of text and images of text 

would be required to have a contrast ratio of at least 4.5:1.

49

The current Section 508 standards do not address the ability of users to resize the display of text 

and other content. The Access Board proposal would require Web pages and non-Web user 

interfaces to be readable and retain their functionality when the text size is doubled.50

4.4.7. Area 7: Audio Controls on Web Pages

The current Section 508 standards have no explicit requirements for separate controls to adjust 

volume or to stop and start audio on Web pages or in software applications.51 The proposed 

 

48 It should be noted that many of these resource portals are more difficult to locate than the more general 

accessibility policy and compliance directive content on the same agency Web sites. This could be remedied at 

relatively minimal cost by adding a dedicated page on http://www.section508.gov. 

49 For example, meeting this standard would require that text in standard blue (color code #0000ff) be displayed on a 

background that is appreciably lighter than a medium gray (#a3a3a3).

50 Contrast and font size have interactive effects on readability—larger fonts can be read more easily, as can higher 

contrast pages. The WCAG standard allows a ratio of 3:1 for larger font sizes, for example. In addition, size and 

color are two attributes of text display that can be set in the same manner in HTML and other applications.

51 Web-embedded video and audio content often plays automatically without the user attempting to play it. The 

proposed requirements would provide users with the ability to control this “autoplay” feature, which can interfere 

with the ability of the user to hear the audio playback they are receiving from a screen reader.
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standards would incorporate by reference the applicable WCAG 2.0 Level A success criterion 

(1.4.2) that allows users of screen-reading software to control other audio (e.g., turn down the 

volume or turn it off) on a Web page in order to hear the screen reader.

4.4.8. Area 8: User Controls for Captions and Video Description

The current Section 508 standard does not require Web pages, software, telecommunications 

equipment, and other forms of hardware to make user controls for captions and audio description 

available in any particular form or location. The proposed rule would include new requirements 

for the location of these controls. In response to the 2010 ANPRM, consumer groups reported 

complaints that some modern products did not support captioning when in fact the problem was 

that the captioning selection was very difficult to find in the menus. The proposed rule would 

increase the usability of captioning features by making controls more prominent and easy to find.

Some Web-based and software media players already have captioning or audio description 

available. These applications would have to be redesigned to feature the controls more 

prominently. Media players without these capabilities would need to be redesigned to 

incorporate these capabilities, or Web and software developers could choose to embed an 

accessible media player in their content or applications.

Hardware manufacturers would need to modify the physical design and features of covered 

products that currently lack this capability and update software platforms and applications to 

support the required controls.

4.4.9. Area 9: RTT Functionality

The current Section 508 standards and Section 255 guidelines include functionality requirements 

for teletypewriters (TTYs). A TTY is often used to place a call to a Telecommunications Relay 

Service (TRS), which enables individuals who are deaf or hard of hearing to make successful 

phone calls to hearing phone users. The FCC estimates that there are about 100,000 TTY users. 

However, TTY usage is currently declining by 10 percent annually and is expected to fall to half 

the current level in 7 years.52

The Access Board is proposing requirements regarding text-based data transmission in real time. 

RTT has more features and functions than TTYs.53 In 2011, the FCC Emergency Access 

Advisory Committee (EAAC) sponsored a survey of people with disabilities to characterize their 

current and preferred means of being able to communicate with emergency services dispatchers.

While the results of the survey cannot be generalized, 46 percent of those who responded to the 

survey reported wanting to be able to use “real-time text, where the 9-1-1 center reads the 

characters a caller types as soon as the person types them and the caller sees the characters that 

the 9-1-1 dispatcher types back as soon as they type them.”54

 

52 FCC, Emergency Access Advisory Committee (EAAC) Report on TTY Transition, March 2013.

53 RTT can be used in conjunction with voice and/or video in a multimedia communication or on its own, on fixed 

or mobile accesses. RTT allows a more natural, bidirectional flow of conversation to take place, compared to the 

technology of instant messaging or mobile phone text messaging. RTT can also be used by relay services to offer 

real-time conversion between different modes of communication to enable people who are deaf or hard of hearing or 

who have a speech impairment to use the emergency services without limitations.

54 FCC EAAC, Report on Emergency Calling for Persons with Disabilities: Survey Review and Analysis, July 21, 

2011.
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In Section 5.4 of the NPRM, the Access Board states that:

RTT is sufficiently mature as a technology (and has sufficiently proliferated the 

current ICT marketplace) to warrant coverage in the proposed rule. For example, 

real-time instant messaging programs such as those currently used by Yahoo!

Messenger and AOL Instant Messaging with Real-Time IM have proprietary 

protocols that are very similar to Session Initiation Protocol (SIP).

The Telecommunications and Electronic and Information Technology Advisory Committee

(TEITAC) recommended that, where ICT supported real-time voice conversation, it should also 

support a method of RTT communication. The TEITAC report stated that its recommendations 

were intended to allow people with disabilities to communicate using standard IP methods rather 

than continuing to support TTY within IP networks and devices.

55

The benefits of RTT to users with disabilities over other text communication options are outlined 

in a proposal submitted by the Rehabilitation Engineering Research Center for 

Telecommunications Access to the TEITAC.56 Those benefits include the following:

 RTT is continuous and contemporaneous, like voice and signed communication.

 Delivery is instant and letters are viewed as they are typed.

 Both parties are online simultaneously, as during phone calls.

 In time-sensitive situations, time is saved because the receiver can see the text as it is 

typed and can interact to confirm contemporaneously, instead of having to wait until 

completion and transmission to read and react.

 Typing errors are visible during typing and can be corrected after transmission.

The TRACE Proposal further explained that RTT minimizes the occurrence of crossed messages, 

which occur when one party sends a second message before the other party finishes answering 

the first. In an emergency, a panicked caller sometimes asks a second or third question when 

there is no immediate visible response from the 911 call taker, and this can lead to confusion, 

crossed answers, and error in responses. 

One of the most attractive aspects of RTT functionality is the communication advantage it might 

provide to users with disabilities in emergency situations. In support of its efforts to develop a 

standardized method for text to 911, the FCC collected extensive input from the disability 

community and service providers through an EAAC, established by the FCC pursuant to the 

CVAA, Pub. L. No. 111-260. FCC’s multiyear effort looked at a variety of text-to-911 options, 

including RTT and short message service (SMS). In August 2014, the FCC announced an interim 

solution that relied on SMS.57

 

55 TEITAC Report, pp. 8, 9.

56 Rehabilitation Engineering Research Center for Telecommunications Access, Proposal R1 for Implementation of 

Real-Time Text Across Platforms Version 2.0, 7-8, 14-15 (Dec. 2013) (hereafter, “TRACE Proposal”).

57 In re Facilitating the Deployment of Text-to-911 and Other Next Generation 911 Applications, Framework for 

Next Generation 911 Deployment, PS Docket Nos. 11-153 and 10-255, Second Report and Order and Third Notice 
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The FCC stated in its report that enabling direct text messaging to 911 by the many people who 

are deaf, hard of hearing, or speech disabled will allow them to use mass market communication 

devices that have more advanced and increasingly evolving capabilities. The FCC found that, 

“while some commenters have been less supportive of SMS-to-911 because it does not support 

real-time text—i.e., the ability to send and receive text simultaneously with the time that it is 

typed without having to press a “send” key—they have given some support to SMS as a viable 

near-term solution because of its ease of use for people with disabilities and ubiquity in 

mainstream society.” Respondents to an EAAC survey “expressed a clear preference for calling a 

PSAP using the same technology that they use on a daily basis. Furthermore, 87.7 percent of 

EAAC respondents reported having used SMS text messaging and 46.1 percent reported having 

used SMS text messaging ‘almost every day.’”

58

The Access Board understands the FCC decision to rely on an SMS-based approach to be largely 

because SMS-based text messaging is ubiquitous—it is widely used by individuals with 

disabilities and technically feasible for all covered providers to support it—allowing for rapid 

implementation of the interim solution. However, a dissenting statement of one commissioner 

expressed serious concerns with the FCC’s reliance on an SMS-based approach, including the 

following: only a small percentage of public safety answering points (PSAPs) currently accept 

text messages, SMS-based transmission fails when a phone is in “roaming” mode, if a user‘s 

plan does not have an SMS subscription, and many popular texting apps would not be covered.

The dissent advocated strongly for moving directly to reliance on IP-based RTT.59

In its report, the FCC announced that it was seeking comment “on the delivery of real-time text 

communications to PSAPs, wherein the text is transmitted as it is typed. The EAAC 

recommended that ‘standards and functional requirements be adopted that are technically and 

economically feasible’ to achieve direct access to 911 using, among other IP-based text 

communications, real-time text communications. The Access Board notes that RTT differs from 

traditional forms of text communications such as SMS, in that it provides an instantaneous 

exchange, character by character or word by word, whereas SMS and other traditional forms of 

text communications require uses to finish their typed message before sending it. According to 

the Rehabilitation Engineering Research Center for Telecommunications Access (RERC-TA), in 

an emergency, real-time text can allow for interruption and reduce the risk of crossed messages 

because the PSAP call taker is able to read the caller’s message as it is being typed, rather than 

waiting until the caller presses the ‘send’ key.”60

The Access Board sees its proposal to require ICT that supports real-time voice communication 

to also support RTT as complementing the FCC’s work in the area of text to 911. The FCC 

strove to select an interim solution for text to 911 that was already widely used and that 

individuals with disabilities were familiar with and comfortable using. The FCC makes clear in 

its report that, “while the Commission continues to explore the feasibility of real-time text 

 

of Proposed Rulemaking, 29 FCC Rcd. 9846 (Aug. 2014) (hereafter, FCC Second Report and Order); see also 79 

Fed. Reg. 55,367 (September 16, 2014) (publication of final rule).

58 FCC Second Report and Order, ¶ 17.

59 FCC Second Report and Order, Dissenting Statement of Commissioner Ajit Pai.

60 FCC Second Report and Order ¶ 132.
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capabilities for 911, the Access Board believes that the adoption of a text-to-911 requirement 

provides an important interim step in responding to the emergency access needs of people who 

are deaf, hard of hearing, or speech disabled.”61 The FCC seeks comment on the technical 

feasibility and costs of other solutions.62 The FCC also indicates that it is not requiring providers 

to support SMS-based text to 911 indefinitely, as long as they provide customers with at least 

one text-to-911 option that works across the providers’ entire network coverage area, and that 

providers may select any reliable method, including SMS or IP-based such as RTT, for text 

routing and delivery.63 The Board believes that the RTT requirements it is proposing today will 

lay the foundation for accessible, reliable real-time IP communications for disabled and nondisabled users, in emergency as well as non-emergency situations.

4.4.10. ICT Hardware Accessibility

There are two additional areas of requirements set forth in the NPRM that could have potential 

cost implications for Federal agency ICT development and procurement.

The Access Board is proposing to require ICT hardware (e.g., computers, information kiosks, 

multifunction copy machines) to comply with several accessibility requirements established for 

ATMs and fare machines in Section 707 of the 2010 ADA Standards for Accessible Design

relating to the following:

 Speech output.

 Braille instructions for initiating the speech mode.

 Display screen characters and visibility.

 Privacy of input and output.

 Key or ticket insertion.

 Function key contrast.

4.4.11. Online Product and Service User Support 

The NPRM also includes proposed requirements for ICT support documentation and services; 

these are listed in Table A-4 of Appendix A. Federal agencies must currently ensure that the 

electronic content published or posted on Federal Government Web sites complies with the 

current Section 508 standards. However, the support sections of telecommunications 

manufacturer Web sites are not currently required to be accessible.

4.5. Scope of Proposed ICT Standards and Guidelines: What Entities 

Would Have to Comply?

Section 508 specifically applies to most Federal departments and agencies, as well as the 

USPS.

64 A limited number of exemptions (the Government Accountability Office, the Federal 

Election Commission, and Government-owned, contractor-operated facilities) from Section 508 

requirements would be retained under the Access Board proposal. The proposed standards and 

 

61 FCC Second Report and Order ¶ 17 and fn. 54.

62 FCC Second Report and Order ¶ 122.

63 FCC Second Report and Order ¶ 44.

64 29 U.S.C. §794(d)(1)(A). We were not able to assess the specific impact of the rule standards and guidelines on 

the USPS in this preliminary analysis.
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guidelines would also retain the present exemption for national security information, although it 

should be noted that this provision does not provide a blanket exemption for ICT developed or 

used by the U.S. Department of Defense (DOD), Homeland Security (DHS), and the national 

intelligence agencies.65

The rule requirements would apply to ICT procured from Federal contractors and vendors.66

Some of these entities may already be producing products and services that are fully or partly 

compliant with the requirements in WCAG 2.0.

Many State and local governments, public university systems, health care and social service 

organizations, and other entities that receive Federal funding have ICT accessibility policies that 

are either based on the Section 508 standards or reference them in their entirety. These policies 

are diverse in content and implementation, so it is difficult to assess the “downstream” impact of 

the proposed ICT standards and guidelines on these entities.67

U.S. and foreign telecommunications equipment manufacturers whose products are sold in the 

U.S. market would continue to be covered by the Section 255 guidelines under the proposed rule.

4.6. Request for Comment on Specific Aspects of the Proposed 508 

Standards and 255 Guidelines

1. To what extent would software developer guidelines such as the following comply with 

WCAG 2.0 Level A and Level AA?

i. Microsoft software accessibility guidelines.

ii. IBM software checklist.

iii. Adobe Acrobat software.

2. To what extent do electronic content creation programs comply with the current W3C 

Authoring Tool Accessibility Guidelines?

3. Would the types of content specified in the NPRM that would need to be WCAG 2.0

Level A and Level AA compliant expand or contract the scope of material that is 

currently required by Section 508 or agency directives to be made accessible?

 

65 For example, ICT that is used to support the business and administrative functions of these agencies is covered 

under the current and proposed Section 508 standards.

66 Federal contractor and vendor ICT that is incidental to a contract (e.g., a computer at the contractor’s workplace or 

the vendor’s main Web site) to be compliant with the proposed Section 508 standards.

67 While Section 508 does not directly regulate private businesses, State or local governments, or any other nonFederal organizations, many State and local governments have, by their own law, held themselves to complying with 

Section 508 or similar requirements in whole or in part (see http://www.section508.gov/state-policy for more 

information). Other entities such as public university systems and health care provider organizations have chosen to 

use the Section 508 standards for their ICT development or procurement, even though they are not statutorily 

required to do so. Some of these entities have adopted the current standard in its entirety, while other entities have 

adopted some portions of the standard. We do not know at this point whether or how these entities would decide to 

adopt the proposed Section 508 standards. Therefore, we cannot estimate any costs that nonregulated parties would 

incur by voluntarily adopting the proposed standard.
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4. To what extent would hardware such as the following comply with WCAG 2.0 Level A 

and Level AA?

i. Dell/EVAS computers.

ii. HP computers and printers.

iii. Xerox copiers.

iv. IBM peripherals.

5. Can touch-screen accessibility be provided exclusively through remote operation? 

6. To what extent is the availability of already captioned and audio-described programming 

expected to increase as the CVAA video programming requirements take effect?

7. Can compliant captioning and audio description be generated using automated captioning 

applications?

8. What current hardware and software approaches successfully address the accessibility 

barriers faced by individuals with disabilities who want to be able to locate and operate 

the caption and audio description controls?

5. Benefits of the Proposed Rule

The proposed Section 508 standards are intended to expand and improve access to ICT 

functionality for Federal employees with disabilities and members of the public with disabilities 

who are seeking information or data from a Federal agency.68 Both of these groups of people are 

afforded additional protections under other parts of the Rehabilitation Act of 1973. Section 501 

requires accommodations for disabled Federal employees. Section 504 requires any program or 

activity receiving Federal financial assistance to ensure that individuals with disabilities are able 

to participate. Section 508 requirements act in part to ensure that these guarantees of access 

extend to electronic information and ICT functionality.

The proposed Section 255 guidelines are intended to expand and improve the accessibility of 

telecommunications equipment to people with hearing, vision, and fine motor skill disabilities.

5.1. Types of Addressable Disabilities and Number of Potential 

Beneficiaries

The functional performance criteria proposed in Section 302 of the NPRM identify eight types of 

physical disabilities and limitations that can be potentially addressed by ICT accessibility 

standards and guidelines:69

 Without vision (about 2 million people had severe difficulty seeing in 2010).

 With limited vision (about 6 million people had non-severe vision difficulties).

 Without perception of color (not asked on the 2010 SIPP).

 

68 Access to “information or data” is interpreted to include the ability to use applications and forms hosted on the 

Web, network servers, client computers, and other devices.

69 Survey of Income and Program Participation (SIPP) estimates of the number of people with each type of disability 

in 2010 are shown in parentheses. 
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 Without hearing (about 1 million people had severe difficulty hearing).

 With limited hearing (about 6.5 million people had non-severe hearing difficulties).

 Without speech (about 2.8 million people had difficulty with speech).

 With limited manipulation (about 6.7 million people had difficulty grasping).

 With limited reach or strength (about 3.6 million people used a wheelchair).

Different provisions and combinations of provisions in the proposed requirements would 

improve ICT accessibility for Federal employees and other people with various disabilities and 

combinations of disabilities:

 Section 4.2 of this evaluation identifies 16 WCAG 2.0 standards that do not have close 

analogues in the current Section 508 standards. Compliance with most of these would 

improve the ability of screen readers to parse and interpret Web content, forms, and 

applications; software and hardware user interfaces; and telecommunications equipment 

displays for users without vision. The requirements relating to reliance on sensory 

characteristics (1.3.3), contrast (1.4.3), resizing of text (1.4.4), and providing multiple 

ways to find content (2.4.5) would also provide benefits to people with limited vision and 

those without perception of color.

 RTT capability is particularly important for people who are deaf, while the technical 

standards proposed as Section 410.2 through Section 410.5 (volume gain, magnetic 

coupling, interference, and ITU-T encoding) would benefit people who use AT to address 

hearing limitations. 

 The proposed Section 407 requirements relating to operable parts (e.g., the 407.4 key 

repeat and 407.9 operability requirements) would ensure the accessibility of ICT 

hardware and telecommunications equipment for people with motor skill limitations, as 

would the platform accessibility standards in proposed Section 502.4.

 Users of telecommunications equipment with vision, hearing, speech, or fine motor skill 

disabilities would benefit from increased availability of accessible telecommunications 

products and improved accessibility of product documentation and support services. 

A more extensive mapping of the provisions in the proposed rule that would benefit people with 

specific types of disabilities is provided in Table A-5 in Appendix A.

Some Federal employees and citizens who do not have addressable disabilities would also

benefit from more consistent implementation of the portions of the proposed ICT standards that 

require adherence to Web best practices, such as ensuring consistent navigation and allowing for 

user modification of display parameters. For example, the proposed Section 411 requirements for 

caption processing technologies would support the availability and display of captioning used by 

people without disabilities in noisy environments and those for whom English is not their native 

language. 

Other groups of people without disabilities (under the Census estimate definitions) who would 

potentially benefit may include people whose vision is corrected by using eyeglasses or contact

lenses, people whose hearing is corrected by wearing hearing aids, and people with cognitive 

issues or learning disabilities:
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 Implementation of the WCAG 2.0 text resizing and color contrast provisions referenced 

above may improve the ability of Federal employees and other people whose vision 

limitations are corrected with eyeglasses or contacts to see material on Web sites, 

software and hardware user interfaces, and telecommunications displays clearly. This 

could improve the level of comprehension of the instructions and content being 

displayed, which would reduce the time required to locate and understand the relevant 

material and the number of input errors and omissions on Web and non-Web forms and 

applications.70

 More universal adoption of the technical standards for ICT with two-way voice 

communication referenced above would improve the ability of Federal employees and 

other people who are able to address hearing limitations with the use of a hearing aid. 

Improvements in the volume and clarity of voice communications and speech output 

from machines would increase comprehension, reduce requests for repetition, and 

decrease the potential for mishearing and misunderstanding of voice communications and 

speech output.71

 More consistent implementation of the WCAG 2.0 standards referenced above relating to 

Web site and user interface navigation, consistency of menus and links, and multiple 

ways of providing content would increase the ability of people with cognitive issues and 

learning disabilities to locate and access Web content, forms, and applications on Federal 

Government Web sites. In addition, adoption of the WCAG 2.0 Level AA standards for 

error suggestion and prevention may increase the ability of people with these disabilities 

to complete and submit Web-based forms and applications.72

In addition, State and local governments, international organizations, and U.S. and foreign 

private-sector entities may benefit from more broad-based adoption of WCAG 2.0-based 

standards for Web-related and non-Web-related forms of ICT.

5.2. Benefits for Federal Employees With Disabilities

Federal Government employees who have addressable disabilities would benefit from updated 

ICT accessibility standards that allow them to be more productive and capable employees. As 

discussed in the previous section, the extent to which specific Federal employees could benefit 

from the proposed Section 508 standards would depend on the nature of their jobs and the type 

and severity of their disabilities, as well as on the extent to which the proposed Section 508 

standards improve the accessibility of various forms of ICT, relative to the level achieved by the 

current requirements. In general, however, Federal employees with specific types of disabilities 

could be expected to benefit from adoption of the provisions in the proposed requirements 

referenced in Section 5.1 above for people with the same types of disabilities.73

 

70 The 2010 SIPP did not collect information on the number of people with vision limitations corrected by 

eyeglasses or contact lenses.

71 There were also about 3.4 million people in 2010 with no hearing difficulty only with use of a hearing aid.

72 There were about 3.9 million people in 2010 with a learning disability; 2.4 with Alzheimer’s disease, senility, or 

dementia; and 1.2 million with an intellectual disability.

73 For example, a programmer without vision or with limited vision would benefit substantially from applying the 

WCAG 2.0 Level A and Level AA requirements to software, but this would provide no benefit to a program 
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We were not able to identify research studies that could be used to isolate the overall impact of 

ICT on Federal employee productivity or any that systematically relate specific ICT accessibility 

improvements to the productivity of Federal or private employees with various types of 

addressable disabilities. In the absence of such data, the average benefit per Federal employee 

with an addressable disability was estimated as follows:

 An hourly wage rate was estimated from the average annual Federal salary reported in 

September 2012 OPM data.

74

 The hourly wage was adjusted to take into account the cost of leave. The average FTE 

employee was assumed to spend 1,760 hours at work annually after taking into account 

holidays, annual leave, and sick leave. For this analysis, we assumed that Federal 

employees take an average of 4 weeks of paid annual leave and 2 weeks of sick leave per 

employee per year, in addition to 10 paid Federal holidays.

75

 The leave-adjusted wage rate was increased by 30 percent to account for benefits that 

include health insurance, life insurance, retirement, disability, and workers’ 

compensation, based on FY 2005 OPM data on Federal employee benefit costs.

76

 Updated ICT accessibility standards were assumed to improve the productivity of an 

average employee with addressable disabilities other than vision difficulties by 1 percent, 

or 17.6 hours per year spent at work. The productivity improvement for people with 

vision disabilities resulting from the proposed standards was assumed to be twice as 

large. The magnitude of productivity improvement experienced by a specific person will

depend on the employee’s occupation, type of disability, and adequacy of current 

accommodations provided by the agency to comply with its Section 501 obligations.77

 The assumed annual productivity improvement was multiplied by the leave-adjusted 

wage rate to determine the monetized value of the benefit from the rule increasing the 

productivity of Federal employees with an addressable disability. 

 

manager with difficulty hearing. Similarly, the proposed section 407.9 provision for operable controls would 

improve access to computers, copiers, and kiosks for people with limited strength and manual dexterity, but this 

requirement may not improve accessibility for someone in a wheelchair.

74 OPM, Common Characteristics of the Government, March 2013.

75 OPM, Work Years and Personnel Costs, FY 2005, October 2008 (last report available).

76 Ibid.

77 We were not able to locate data on the extent of productivity improvements that could be anticipated specifically 

as a result of switching from ICT that is compliant with the current Section 508 standards to ICT that complies with 

the applicable WCAG 2.0 Success Criteria and Conformance Requirements, as well as the additional requirements 

in the proposed rule, for workers with various types of disabilities. However, general support for an estimate of this 

magnitude is provided in a recent European study, which looked at three scenarios concerning the effect of 

improved Web access on LSHPD (long-standing health problem or disability) to non-LSHPD wage differentials. 

Scenario 1 had half of the wage differential eliminated, Scenario 2 had 10 percentage points of the wage differential 

eliminated, and Scenario 3 had the entire wage differential eliminated. Taking the average of the values reported on 

Table 49 gives an LSHPD to non-LSHPD wage ratio pf 84.7 percent. Subtracting that value from 1 gives a wage 

differential of 15.3 percent. Therefore, the lower range of wage increase is 9.1 percent (92.3 percent/84.7 percent –

1), the midrange is 11.8 percent (94.7 percent/84.7 percent – 1), and the upper range is 18.1 percent (100.0

percent/84.7 percent – 1). If the proposed rule improves Web access by 10 percent, the midrange estimate becomes 

1.2 percent. See Technosite, “Study on Economic Assessment for Improving eAccessibility Services and Products,”

SMART 2009-0072, 2012. 
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Table 1 presents a preliminary estimate of the potential increase in Federal employee 

productivity from improved ICT accessibility that was developed using this approach.

Table 1: Value of Increased Federal Employee Productivity, 2012

Estimate Component Value

Average Federal employee salary* $78,467

Number of hours in FTE year 2,080

Average hourly wage for Federal employee $37.72

Average number of working hours** 1,760

Leave-adjustment multiplier 1.18

Hourly wage adjusted for leave $44.58

Benefit multiplier*** 1.30

Fully loaded cost per employee hour of work $57.96

Average number of working hours 1,760

Assumed percent increase in productivity for an employee with a non-vision 

disability 1%

Hour-equivalent of increased productivity for an employee with a non-vision disability 17.6

Value of annual increased productivity per employee with a non-vision 

disability $1,020

Assumed percent increase in productivity for an employee with a vision disability 2%

Hour-equivalent of increased productivity for an employee with a vision disability 35.2

Value of annual increased productivity per employee with a vision disability $2,040

*OPM, Common Characteristics of the Government: 2012, March 2013.

**Based on an FY 2005 average of 8 weeks of leave (4 annual, 2 holiday, and 2 sick).

***OPM, Work Years and Personnel Costs, FY 2005, October 2008.

The estimated value of increased productivity averages $1,020 for a Federal employee with nonvision disability. A Federal employee with a vision disability was estimated to experience an 

average annual productivity improvement of $2,040.

Estimates of the FY 2010 numbers of Federal employees with specific types of disabilities who 

could potentially be more productive with updated ICT accessibility standards are presented and 

discussed in Section B.3 of Appendix B. Table 2 presents estimates of total numbers of Federal 

employees with vision disabilities and other addressable disabilities.78

Table 2: Number of Federal Employees With Addressable Disabilities

Estimate Component Vison 

Disabilities

Other 

Addressable 

Disabilities

All 

Addressable 

Disabilities

Civilian employees with addressable disabilities 9,486 26,795 36,281

Total Federal civilian workforce 2,108,639 2,108,639 2,108,639

Percentage of total civilian workforce 0.4% 1.3% 1.7%

Source: OPM, Federal Civilian Workforce Statistics for September 2010.

 

78 It should be noted that the OPM statistics do not include employment data for the USPS and some other Federal 

entities, so employees with addressable disabilities who work for these entities are not included in these estimates. 
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The average per-person value of productivity improvements and estimated numbers of 

employees potentially benefitting from the proposed rule were multiplied together to calculate 

the total productivity benefits from increased Federal employee productivity. However, it is 

important to note that the full extent of these potential productivity benefits would not be 

realized immediately upon the proposed standards taking effect. For this preliminary analysis, we 

have assumed that one-half of the recurring annual accessibility improvement from the rule

standards would be realized in the first year (2015) of the 10-year analysis period.79

Table 3: Estimated Benefits From Increased Federal Employee Productivity

Estimate Component 2015 2015–2024

Federal employees with vision disabilities 9,486 94,860

Value of annual increase in productivity per employee* $1,020 $1,913

Federal employees with other addressable disabilities 26,795 267,950

Value of annual increase in productivity per employee** $510 $956

Total productivity benefits $23,342,795 $443,513,100

Present value of benefits in 2015 (millions)*** $327.5

*Assumed increases of $1,020 in 2015 and $2,040 thereafter.

**Assumed increases of $510 in 2015 and $1,020 thereafter.

***Present value of 2015–2024 benefits calculated using a discount rate of 7 percent.

Table 3 indicates that the proposed rule would increase the productivity of Federal employees 

with addressable disabilities by $23.3 million in 2015 and $443.5 million over the 10-year 

analysis period from 2015 through 2024, the first 10 years after the proposed standards have 

been assumed to take effect. This estimate may understate the true extent of productivity-related 

benefits for the following reasons:

 The estimates assume that there will be no growth in the number or inflation-adjusted 

salary of Federal employees with addressable disabilities during the next 10 years.

 This evaluation does not take into account any potential long-term benefits from Federal 

Government employees with addressable disabilities being able to develop more 

capabilities and experience as a result of improved ICT accessibility.

 This assessment also does not include potential benefits accruing from increased levels of 

skills and experience in the pool of workers who could be hired by Federal agencies in 

the future.

 Productivity benefits for Federal Government contractor and vendor employees were not 

estimated and included in this analysis.

80

 

79 All 2015–2024 dollar values shown in this table and throughout the preliminary RIA are in 2015 (i.e., inflationadjusted) dollars.

80 Data on the number of contractor employees and the incidence rate of various disabilities among the contractor 

workforce could not be located for this preliminary analysis. Some Federal contractors and vendors will be required 

to begin collecting these data under new Section 503 regulations published by the Department of Labor on 

September 24, 2013.
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In addition, some State and local government employees with addressable disabilities may 

benefit indirectly from the proposed rule. For example, State and local government employees 

often need to work with Federal agency information and participate in or assist citizens with 

Federal Government-related electronic transactions. However, an estimate of these benefits was 

not developed for the preliminary regulatory evaluation.

Finally, it should be noted that some of the proposed ICT accessibility requirements could 

potentially reduce the productivity of Federal employees—both those with addressable 

disabilities and those who have no such disabilities—particularly in the first few years after the 

proposed standards would take effect. For example, applying the WCAG 2.0 standard to 

software may absorb developer time that would otherwise be used for other development and 

testing activities.

5.3. Benefits for Citizens and Other Residents With Disabilities

The Internet has become an important vehicle through which Americans who are online seek 

information or conduct transactions with Federal, State, and local government agencies. A 2010 

Pew Internet and American Life study found that 82 percent of adult Internet users looked for 

information or completed a transaction on a government Web site—including both Federal and 

non-Federal Government Web sites—in the most recent 12 months. Table 4 summarizes the Pew 

survey findings on commonly cited reasons for visiting government Web sites.81

Table 4: Proportion of Adult Internet Users Visiting Government Web Sites

Reason for Visiting Government Web Site Percentage of Adult 

Internet Users

Looked for information about a public policy or issue 48%

Looked up what services an agency provides 46%

Downloaded government forms 41%

Researched official government documents or statistics 35%

Sought recreational or tourist information agency 30%

Sought advice or information about a health or safety issue 25%

Sought information about or applied for government benefits 23%

Sought information about how to apply for a government job 19%

Source: Pew Internet and American Life Project, April 27, 2010.

Use of government Web sites allows citizens and other residents to obtain more information and 

perform transactions more efficiently with substantial time savings, relative to conducting these 

activities in person or over the phone.82 Increased Web accessibility provides several 

opportunities for time savings to a person with an addressable disability by:

 

81 Aaron Smith, “Government Online: The Internet Gives Citizens New Paths to Government Services and 

Information,” Pew Internet and American Life Project, April 27, 2010. Note that this survey did not specifically ask 

participants to distinguish between visits to Federal Government Web sites and those to State and local government 

Web sites. However, it is reasonable to expect that most people visiting government Web sites for most, if not all, of 

the reasons shown in Table 4 would make at least some visits for those reasons to Federal Government Web sites.

82 Federal Web analytic data underscore the growing importance of Federal Web sites as a public resource for 

obtaining documentary and multimedia-based information. According to data from the General Service 
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 Reducing the amount of time required to complete tasks already conducted online.

 Increasing the efficiency of obtaining information and completing transactions that would 

otherwise require in-person, mail, or telephone contacts.

 Reducing the amount of time lost to errors and omissions in completing applications, 

forms, and requests—both by reducing transcription and processing errors and by 

providing immediate feedback to the user on problems with the submission.

 Eliminating the need to store and retrieve paper copies of communications, documents, 

letters, and receipts.

The magnitude of time savings from improved accessibility of Federal Government Web sites 

for people with addressable disabilities depends on the following:

 The type and severity of disability or combination of disabilities.

 The frequency in which people with disabilities visit Federal Web sites and the duration 

and purpose of their visits.

 The extent to which bringing these sites into compliance with the proposed standards 

would reduce the amount of time to achieve their purpose for visiting a Federal Web site.

5.3.1. Benefits for People With Vision Disabilities From Use of More Accessible 

Web Sites

While persons with all types of addressable disabilities are expected to experience significant 

benefits from improved accessibility of Federal Web sites, this preliminary regulatory 

assessment formally estimates time savings and monetizes benefits from such improvements 

only for persons with vision disabilities. The methodology used to estimate time savings and 

monetize benefits for such individuals are described below. Benefits to persons with other types 

of addressable disabilities are discussed from a quantitative and qualitative perspective in the 

next subsection.

Based on third-party (commercial) and Federal data sources, Federal Web site usage may be 

estimated. While no data appear to be available on the Web habits of persons with disabilities 

specifically, it may be reasonably assumed that, when persons with disabilities go online, the 

number of Web sites visited and duration of their visits approximates that of the American public 

generally. For this preliminary assessment, an online adult with a vision disability was assumed 

to visit Federal Government Web sites an average of 15 times annually.83 The average duration 

 

Administration Data Analytics Program (GSA DAP), 346.5 million documents were downloaded from Federal Web

sites in 2014. Most of these downloaded documents (83 percent) were PDFs. (The Access Board received approval 

from OMB for citation and use of otherwise confidential GSA DAP Government-wide data in this regulatory 

assessment.) This volume of document downloads is important because many PDF-based forms and other 

documents are not currently accessible. The proposed Section 508 standards (E205.4) are designed to address this 

problem by requiring all PDFs posted on agencies’ public-facing Web sites to be compliant with the international 

consensus standard for accessibility of document management applications (PDF/UA-1). Monetized benefits in this 

analysis do not include the incremental value of accessible documents posted on or downloadable from Federal Web 

sites to persons with addressable disabilities.

83 This estimate was derived from Web analytic data maintained by GSA DAP and Census data. Specifically, the 

average number of annual visits per person to Federal Web sites was calculated by dividing the total number of 

sessions on Federal Government Web sites in calendar year 2014 (3.95 billion) as tracked by GSA DAP by the most 
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of a visit was assumed to be 4 minutes. This 4-minute visit duration figure represents a midrange 

estimate between several commercial and Federal data sources.84

A 2007 study that used a non-randomized sample of Internet users who are blind concluded that 

30 percent of the time spent online is lost to accessibility problems with current Web sites.85

However, the 2012 DOJ study indicates that most elements of the majority of Federal 

Government Web sites are compliant with the current Section 508 standards.86 This means that 

the extent of improvement in accessibility that can be expected from the proposed rule is less 

than what would be anticipated from making a previously noncompliant site fully accessible. For 

this preliminary assessment, the extent of improvement—measured in the form of the time 

savings for site visitors who use a screen reader—was assumed to be 20 percent of what would 

be realized for making a completely noncompliant Web site fully accessible.87

Table 5 shows how these data and assumptions are used to calculate the amount of time saved 

from Web site accessibility improvement for an adult Internet user with a vision disability.

 

recent Census Bureau statistics on the adult U.S. population (18 years and older) from the 2013 American 

Community Survey 1-Year Estimate (i.e., 242.5 million). It should be noted that the GSA DAP analytic data track 

visits to many—but not nearly all—Federal Web sites. Accordingly, since GSA DAP data does not reflect the total 

number of visits to all Federal Web sites (nor all actions or events by users on such sites), the estimated per-person 

annual number of visits to (and events on) Federal Web sites used in this analysis should be viewed as conservative. 

84 Three data sources were used to estimate the average time spent per visit on Federal Web sites. First, according to 

Web traffic statistics maintained by Nielsen NV, visitors to the eight most-visited Federal Web sites spent a total of 

about 34 minutes per person on these sites for the month of February 2014, and about 4.2 minutes per visit on the 

most-visited site (ww.irs.gov). See Clicks and Balances: Top Government Websites and U.S. Brands in February 

2014. Second, according to GSA DAP data, the average session length per visit to Federal Web sites in 2014 was 

3.7 minutes. Third, we calculated the weighted average (based on agency size) of the duration of visits to a sample 

of Federal Web sites for the period from July 2014 to January 2015 using Web analytic data from Alexa Internet, 

Inc. (www.alexa.com). This calculation yielded an average of 4.1 minutes per visit to Federal Web sites. 

85 Jonathan Lazar et al., “What Frustrates Screen Reader Users on the Web: A Study of 100 Blind Users,” 

International Journal of Human-Computer Interaction, 22(3), pp. 247–269, 2007. Other empirical studies have 

reached similar results. See Disability Rights Commission, “The Web: Access and Inclusion for Disabled People,” 

2004, which found that the incremental difference in task completion times on high and low accessibility Web sites 

was 3.7 times higher for blind Web users than for non-disabled Web users (hereinafter, “Web Access and 

Inclusion”). Melody Ivory et al., “Search Results Exploration: A Preliminary Study of Blind and Sighted Users’ 

Decision Making and Performance,” ACM CHI 2004 – Late Breaking Results Paper, April 2004, reports the results 

from a study of 16 sighted and blind users conducting nine “factoid” Internet search tasks in a computer lab. The 

study found that blind users took about three times as long as non-disabled participants to look for information on 

Web pages with low accessibility. Nielsen Norman Group, “Usability Guidelines for Accessible Web Design,”

2001, presents results from a study of 60 Internet users, which found that Web tasks were about three times easier 

for a control group of non-disabled users than for users who were blind or had low vision.

86 Reported compliance rates for current Section 508 standards applicable to Web site home pages, forms, and 

applications averaged about 80 percent in the DOJ survey. The assumed 20 percent improvement in accessibility is 

consistent with an average compliance rate of 96 percent under the proposed rule. In addition, the DOJ survey 

results may overstate the extent to which some elements of agency Web sites are fully compliant with the current 

Section 508 standards. More information is available in Appendix D.

87 The extent of time savings, relative to the use of Web sites that comply with the current Section 508 standards, 

will vary greatly depending on the Web sites visited, the tasks performed, and the type and severity of the site 

visitor’s disability. People with vision or fine motor skill-related disabilities using Web sites with online forms or 

applications can be expected to realize the largest per-person benefits from implementing the proposed standards.
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Table 5: Average Amount of Time Saved Per Person With Vision Disabilities From Increased Web 

Accessibility

Estimate Component Value

Average number of visits to Federal Government Web sites annually 15

Average minutes spent per Federal Government Web site visit 4

Time spent on Federal Government Web sites annually (hours) 1.0

Percent of time lost on inaccessible Web sites* 30%

Estimated percent improvement in accessibility from proposed 508 standards 20%

Percent of total time on Federal Government Web sites saved from accessibility 

improvement 6%

Hours saved per person from accessibility improvement 0.06

*Estimate from Lazar et al., IJHCI, 2007.

Estimating the numbers of people with vision disabilities who would benefit from more 

accessible Federal Government Web sites required several sets of calculations:88

 Age and disability status: The numbers of people in 2010 with vision disabilities were 

obtained from the U.S. Census SIPP. Separate estimates were used for people age 15 to 

64 and those age 65 and over.

 Population growth: According to the U.S. Census, the number of people age 15 to 64 is 

projected to increase by 0.5 percent annually from 2010 through 2024, while the 

population of people age 65 and over is expected to increase by 3.4 percent annually.89

We assumed that the numbers of people in each age group with vision disabilities would 

increase at the same rate as the general population in the same age group.

 Internet user population: The 2010 SIPP provides estimates of the numbers of adults in 

each age group with and without disabilities who use the Internet. According to the SIPP, 

about 65 percent of adults age 15 to 64 and 31 percent of people age 65 and over were 

online in 2010. The Internet access rates for people with disabilities were 20 percent 

lower for those age 15 to 64 and 30 percent lower for those age 65 and over.

 Internet user population growth rates: The proportion of people with disabilities who are 

online was assumed to increase online by 1 percentage point annually (starting from 

2010) for adults age 15 to 64 and 2 percentage points annually for people age 65 and 

over.

 Federal Government Web site visitors: Based on the 2010 Pew study, we assumed that 82 

percent of adults with disabilities who are online visit at least some Federal Government 

Web sites. This rate is assumed to be constant from 2015 to 2024.90

 

88 The data used to develop these estimates are presented and discussed in sections B.1 and B.2 of Appendix B.

89 Estimate derived from Census Bureau, 2012 National Population Projections, “Table 2: Projections of the 

Population by Selected Age Groups and Sex for the United States: 2015 to 2060.” The same rates of growth were 

applied to the 2010 estimates to obtain the 2015 populations for each of these age groups.

90 The Pew survey asked participants about visiting a “local, State, or Federal Government Web site.” The survey 

did not ask respondents to report visits to the Web sites of different levels of government. This analysis assumes that 

people who use the Internet to visit Federal, State, and local government Web sites make at least some of these visits 

to Federal Government Web sites annually. Thus, the Pew study estimate of the proportion of adult Internet users 
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 Time saved from increased accessibility: The time savings per person estimated in Table

5 were multiplied by the numbers of people in each age group with vision disabilities 

online who visit Federal Government Web sites to estimate the total hours saved from 

improved accessibility of Federal Government Web sites.

Table 6 presents estimates of the numbers of people with vision disabilities who are online and 

visit Federal Government Web sites, based on the data sources presented in Appendix B, 

Sections 1 and 2, and the aggregate amount of time saved from improved Federal Government 

Web site accessibility.

Table 6: Number of People With Vision Disabilities Who Would Benefit From Improved 

Government Web Site Accessibility and Amount of Time Saved

Estimate Component 2015 2015–2024

People with vision disabilities who visit Federal 

Government Web sites, age 15–64 2,069,500 22,812,622

People with vision disabilities who visit Federal 

Government Web sites, age 65 and over 1,150,468 17,184,722

Average annual hours saved from accessibility 

improvement* 0.03 0.06

Total hours saved by people with vision disabilities 

who visit Federal Government Web sites 96,599 2,303,242

*Assumed savings of 0.03 hours in 2015 and 0.06 hours thereafter for people with vision disabilities.

According to these estimates, there will be about 3.2 million people in 2015 with vision 

disabilities who visit Federal Government Web sites. As noted above, the number of potential 

beneficiaries is expected to grow in future years as the U.S. population of people with disabilities 

grows and a larger percentage of these individuals use the Internet. In addition, though not 

evaluated in this analysis, improved Web site accessibility may also increase the following:

 The proportion of online adults with addressable disabilities who visit government Web 

sites.

 The number of visits and amount of productive time spent on these Web sites.

 The efficiency of the current amount of time spent online, measured in terms of the 

volume of information obtained and transactions completed successfully in a given 

amount of time.

The aggregate value of benefits from improved Federal Government Web site accessibility was 

estimated by multiplying the total hours of time saved and the monetary value attributed to each 

 

who visit Federal, State, and local government Web sites somewhat overstates the percentage of adult Internet users 

who visit Federal Government Web sites. However, there are no data available to adjust these estimates to exclude 

people who only visit State or local government Web sites. Conversely, the 2010 SIPP provides estimates of online 

access rates for adults with various types of disabilities that are lower than the access rates reported in other surveys,

including the Pew survey. The estimated percentage of adults with disabilities who visit Federal Government Web 

sites is calculated as the product of these two numbers (see additional discussion in Section B.2 of Appendix B). 
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hour of time saved.91 The aggregate time savings were valued at $10 per hour, the monetary 

value used in the 2010 DOJ regulatory assessment of the revised ADA standards for accessible 

design.92

Table 7 presents the calculations of the monetized value of the time savings from improved 

government Web site accessibility.93

Table 7: Monetized Benefits of Improved Government Web Site Accessibility

Estimate Component 2015 2015–2024

Total hours saved by people with vision disabilities 96,599 2,303,242

Value of time saved per hour $10 $10

Total value of time saved $965,990 $23,032,416 

Present value of benefits in 2015 (millions)* $16.61 

*Present value of 2015–2024 benefits calculated using a discount rate of 7 percent.

Table 7 shows that the estimated value of time savings from improved accessibility of Federal 

Government Web sites is about $1.0 million in 2015 and $ 23.0 million over the 10-year analysis 

period from 2015 through 2024. 

As noted above, there are potentially larger time savings for people with vision disabilities (as 

well as other addressable disabilities) from being able to obtain information and complete 

transactions online on accessible government Web sites that would have otherwise required inperson visits or other forms of contact. However, we were not able to locate adequate data that 

could be used to quantify these savings.

 

91 It should be noted that this aggregate value of time saved by persons with disabilities does not include time 

savings from persons who formerly visited agency field or headquarter offices to transact business, but, due to 

improve accessibility of federal Web sites, would instead conduct their business online. Depending on the agency 

and type of transaction at issue, this time savings could potentially be quite substantial. For example, Social Security 

field offices averaged about 118,500 visitors per day in 2013, with average wait times of 30.5 minutes. See Office of 

the Inspector General, Social Security Administration, Audit Report: The Social Security Administration’s 

Reduction in Field Office Operating Hours, 2, 6 (August 2014).

92 This $10 value per hour assumption should be considered conservative in several respects. First, the average 

hourly “base” wage for all workers on which the DOJ assumption was based is now 5 years old. See HDR|HLB 

Decision Economics, “Final Regulatory Impact Analysis of the Final Revised Regulations Implementing Titles II 

and III of the ADA,” July 23, 2010 (2010 DOJ ADA Final RIA). Second, and perhaps more importantly, the 2010 

DOJ ADA Final RIA developed this $10 per hour time valuation figure based on an estimated 50-percent pay gap 

between workers with and without disabilities. Other sources, however, suggest this wage gap estimate may be too 

high. For example, a 2013 study by the Cornell School of Industrial Relations found a wage gap of only 9.3 percent

for full-time male workers with disabilities, and a compensation gap of 6.7 percent. See Cornell University, 

Employment and Disability Institute, Research Brief: Total Compensation Gaps are Distinct from Wage Gaps, 3-4 

(2013). Using either of these figures to monetize the value of time saved by persons with addressable disabilities

would also necessarily increase monetized benefits for improved accessibility of Federal Web sites.

93 As in the Federal employee benefits analysis, one-half of the accessibility improvements resulting from the 

proposed standards are assumed to be made in each of the first 2 years (2015 and 2016) of the 10-year analysis 

period.
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5.3.2. Benefits for People With Other (Non-Vision) Addressable Disabilities From 

More Accessible Websites 

People with other types of addressable disabilities (i.e., non-vision disabilities) would also be 

expected to accrue substantial benefits from improved accessibility of Federal Web sites brought 

about by the proposed rule. For example, expected benefits from improved Federal Web site 

accessibility would be experienced by people with hearing impairments or disabilities relating to 

manual dexterity or upper-body mobility:

 With Web sites incorporating a growing body of video, Flash, and other audio-based 

elements, sound is becoming an increasingly important aspect of Web content and 

function. For people who are deaf or have severe hearing impairments, multimedia 

(video) content is useless without captions. However, many video and audio files posted 

on Federal Web sites are uncaptioned, rendering such content inaccessible. The proposed 

Section 508 standards would more clearly require Federal agencies to caption multimedia 

files through incorporation of WCAG 2.0’s Success Criteria 1.2.3.

Federal Government-wide Web analytic data (GSA DAP) show that millions of videos on 

Federal Web sites are watched annually. Given the volume of videos currently posted on 

Federal Web sites, the benefits of captioned videos (or transcribed audio content) to 

persons with hearing disabilities would likely be profound. Collectively, in 2014, GSA 

DAP data show that there were 8.37 million unique video plays on Federal Web sites, 

with an average session duration of 9.5 minutes.94 People with hearing impairments 

would be better able to learn about Federal programs or services, get instruction on 

completion of Federal forms, engage in civic discourse by watching speeches of Federal 

officials, explore topics in American history, or become more informed on health issues.

 People with significant reach, dexterity, or mobility impairments—which may include, 

for example, persons with cerebral palsy, paralysis, muscular dystrophy, or traumatic 

brain injuries—often use alternate input devices such as head wands, trackballs, sip and 

puff switches, eye-tracking devices, or voice recognition systems. For them, some of the 

most commonly identified accessibility issues on Federal Web sites—including missing 

or poorly designed navigational links, inaccessible form fields, or menus that require 

using a mouse—can make it impossible to navigate between Web pages or to fill out 

forms.95 The proposed Section 508 standards, through incorporation of WCAG 2.0 

(including new Success Criteria 2.1.2, 2.4.3, 2.4.4, 2.4.6, 3.3.3, and 3.3.4) and PDF/UA1, would ensure greater navigability, functionality, and usability of Federal Web sites and 

 

94 Currently, GSA DAP government-wide data log only video-based “events” at the discretion of the agency 

webmaster. Additionally, even when an agency elects to track video usage, only the playing of videos through a 

YouTube channel or JW Player can be detected. The Web analysis tools cannot detect videos viewed on a player 

embedded on a Web site, nor do they track video downloads. For these reasons, the number of video “events” 

logged by the GSA DAP data does not fully capture the total number of videos plays (or downloads) by users of 

Federal Web sites.

95 For empirical studies on accessibility issues commonly found on Federal Web sites, see, for example, A. Olalere

and Jonathan Lazar (2011), “Accessibility of U.S. Federal Government Home Pages: Section 508 Compliance and 

Site Accessibility Statements,” Government Information Quarterly 28(3), 303–309; Paul T. Jaeger (2006), 

“Assessing Section 508 Compliance on Federal e-Government Websites: A Multi-Centered, User-Centered 

Evaluation of Accessibility for Persons with Disabilities,” Government Information Quarterly 23(2), 169–190; 

Eleanor T. Loiacono, Scott McCoy & William Chin (2005), “Freedom of Access: A Study of Federal Website 

Accessibility for Those with Disabilities,” IT Professional, 7(1), 27–31.
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forms for persons with dexterity and mobility disabilities. Design features targeted to 

Web site users who are blind would also likely benefit users with dexterity or motor 

impairments because making Web content accessible through keyboard input (or other 

alternative input device), as opposed to a mouse, is needed by both groups.96

The number of persons with other addressable disabilities expected to use and benefit from

improved access to Federal Web sites can be estimated from the data presented in Appendix B. 

An estimated 5.2 million people age 15 to 64 and 3.4 million people age 65 and over with nonvision addressable disabilities would be expected to benefit in 2015.97

Based on empirical research on Web site accessibility barriers, it is also possible—using this 

estimated beneficiary population—to develop a potential time-savings scenario on which to base 

an approximation of monetized benefits for persons with other addressable disabilities who 

would likely benefit from improved accessibility of Federal Web sites. In a 2004 study, the 

British Disability Rights Commission conducted a formal investigation of accessibility barriers 

faced by Web users with different types of disabilities (e.g., vision, hearing, dexterity/motor, and 

dyslexia). One part of this study involved a 50-person user panel consisting of individuals with 

each type of studied disability. Panelists were each asked to perform two tasks on 10 different 

Web sites, for a total of 913 completed tasks on 100 governmental and non-governmental Web

sites.98 Researchers then assessed the comparative task success rates between impairment groups. 

Relative to persons who are blind (average success rate = 53 percent), persons with non-visual 

impairments (average success rate = 84 percent) had about one-third as much reduction in the 

rate of successfully completing the test tasks, relative to a baseline of a 100-percent success 

rate.

99

In light of this study, an estimate of time savings could be made by assuming that relative task 

success rates between users who are blind and users with other addressable disabilities may be 

equated with time savings. Assuming that task success rates are directly proportional to time 

savings, people with other addressable disabilities would be expected to experience one-third of 

the time loss (i.e., 10 percent) from inaccessible Web sites as people with vision disabilities. 

People with other addressable disabilities would, under this approach, save an estimated 86,269 

hours in 2015 from improved accessibility of Federal Web sites, and a total of 2.08 million hours 

over the 10-year time horizon of the proposed rule. Applying the methodology used to calculate 

monetized benefits for persons with vision disabilities, the estimated value of these time savings 

from improved Federal Web site accessibility would be about $863,000 in 2015 and $20.8 

million over the 10-year analysis period.

 

96 Jonathan Lazar & Paul Jaeger (2011), “Reducing Barriers to Online Access for People with Disabilities,” Issues in 

Science and Technology 17(2), p. 75.

97 See also discussion in Appendix B-2.

98 Disability Rights Commission, Web Access and Inclusion, pp. 24–25.

99 Ibid. at p. 25 and Table 1.
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Data and other information on the following issues are specifically requested in comments from 

the public:

 The extent to which people with vision and other addressable disabilities currently use or 

can be expected to use government Web sites. 

 The magnitude of time savings and improved success rates by vision and other 

addressable disabilities in completing searches and transactions that could be expected to 

result from adopting the proposed standards.

 Estimation of benefits from improved accessibility of other forms of ICT covered under 

the Section 508 standards.

5.4. Benefits for Federal Agencies

Federal agencies may also realize some long-term cost savings associated with implementing the 

proposed standards and guidelines. Web sites could be more readily maintained and updated if 

the programming practices required to ensure Web site accessibility were consistently 

implemented and followed, although the associated benefits are more difficult to quantify. For 

example, the W3C WAI site notes that adopting WCAG 2.0 also offers many potential benefits 

to firms that provide Web-based content, forms, and applications:

100

Incorporating accessibility usually increases site development time initially. 

However, in the long term Web accessibility can reduce the time an organization 

spends on site development and maintenance, as follows:

 Reduced time and effort needed to change presentation across a site by 

defining presentation through a style sheet and using proper markup for 

structure.

 More efficient debugging with automated validation tools by conforming to 

standards and identifying a DOCTYPE. 

 Reduced redesign and translation time and skills.

W3C also anticipates cost savings from reduced bandwidth use and server load, easier enabling

of content on different configurations (e.g., mobile sites), and easier transition to the use of 

advanced Web technologies.

Federal agencies would also realize cost savings from reductions in the volumes of visits, mail 

correspondence, and phone calls from people with addressable disabilities. However, adequate 

data do not appear to be available on the current volumes of these transactions. For this 

preliminary assessment, we estimated specific benefits to Federal agencies from reduced call 

volumes as follows:

 While all adults with addressable disabilities may call government agencies, only those 

who are online could shift additional inquiries and requests to more accessible Web sites.

 

100 W3C, WAI, “Developing a Web Accessibility Business Case for Your Organization,” updated September 7, 

2012.
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 These individuals are assumed to make an average of two calls annually to Federal 

Government agencies, and 20 percent of these calls could be avoided by improvements in 

Web site accessibility.101

 Per-call cost savings to the Federal Government are estimated at $3.43, the amount 

estimated in the final regulatory analysis of the October 2013 DOT final rule relating to 

accessible airport kiosks and air carrier Web sites.102

Table 8 shows the calculation of these cost savings to Federal agencies from reduced call 

volumes.

Table 8: Estimated Benefits to Federal Agencies From Reduced Call Volumes

Estimate Component 2015 2015–2024

Adults with vision disabilities who visit Federal Government Web 

sites 3,219,968 39,997,345 

Adults with other addressable disabilities who visit Federal 

Government Web sites 8,626,937 108,416,973 

Assumed annual number of calls per person 2 2

Percentage reduction in calls from improved Web site accessibility* 10% 19%

Total reduction in calls 2,369,381 56,996,346 

Cost savings per avoided call $3.43 $3.43

Total savings from reduced call handling $8,126,977 $195,497,468

Present value of benefits in 2015 (millions)** $140.9 

*Assumed reductions of 10 percent in 2015 and 20 percent thereafter. The average percent reduction over 2015 

through 2024 is 19 percent.

Table 8 shows that reduced call volumes from improved ICT accessibility could be expected to 

save Federal agencies $8.1 million in 2015 and $195.5 million over the 10-year analysis period 

from 2015 through 2024. The estimated value of these cost savings would be 50 percent higher if 

the average person with an addressable disability who is online calls a Federal Government 

agency an average of three times annually. The estimated value of these cost savings would be 

50 percent lower if the average person with an addressable disability who is online calls a 

Federal Government agency an average of once per year. 

Additional savings would accrue from reduced staffing required to conduct in-person visits, 

review and reply to correspondence, and contact people who have submitted forms and 

applications with incomplete or incorrect information.

In addition, adopting the proposed ICT standards may result in improved agency compliance 

rates over time. OMB recently released a strategic plan for addressing current Section 508 

compliance shortfalls, which were attributed to three primary factors: understanding and 

 

101 A sensitivity analysis was conducted to estimate benefits with higher (three per year) and lower (one per year) 

average annual numbers of calls.

102 Econometrica, Inc., “Final Regulatory Analysis on the Final Rule on Accessible Kiosks and Web Sites,” October 

23, 2013.
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applying standards, defining and measuring program success, and developing the workforce.103

The proposed rule would help address all three of these identified deficiencies:

 The extensive resources available to support implementation of the WCAG 2.0 standards 

are universal—no individual agency or office policies would need to be developed to 

interpret the requirements, as is the case for the less concretely specified current Section 

508 standards.

 The WCAG 2.0 Success Criteria are measurable and testable, making them less 

burdensome for agencies that would find it easier to develop performance metrics that are

consistent across affected entities.

 Finally, employees with significant Section 508 compliance responsibilities would have 

increased access to external classroom, library, and online resources.

Data and other information about other areas of potential cost savings to Federal agencies are 

specifically requested in comments on the NPRM.

5.5. Benefits From Increased Availability of Accessible 

Telecommunications Products, Documentation, and Support Services

The current Section 255 guidelines provide benefits to telecommunications equipment users who 

have various types of disabilities. People who are deaf or hard of hearing are able to obtain and 

understand how to use equipment that supports TTY and TRS—typed text services using a 

communications assistant. These services are being increasingly supplanted by more capable or 

efficient alternatives to voice communications, including text messaging and Video Relay 

Services (VRS) for people using American Sign Language. RTT represents the next generation 

of these voice communication alternatives. People using RTT are able to have faster, more 

natural conversations than is possible using SMS. RTT allows the receiver to be able to see part 

of the message before it is completed, a capability that is particularly valuable in the context of 

some emergency calls.

According to the most recent SIPP, there are about 11 million adults who either have difficulty 

hearing or use a hearing aid. The Real Time Text Task Force expects that RTT:104

... will be adopted by mainstream users as well. In particular, it is a natural 

extension for other real-time, conversational services such as voice telephony, 

e.g., for use in noisy environments, when you want to communicate during a 

meeting when voice is not appropriate. It is also very useful for conveying 

information where exact spelling is important during a voice call, e.g., booking 

numbers, street addresses, words that are hard to perceive because of different 

dialects, etc.

 

103 OMB, “Strategic Plan for Improving Management of Section 508 of the Rehabilitation Act,” January 24, 2013.

104 Real Time Text Task Force, “What is Real Time Text?” viewed December 2013.
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Adequate data and information that can be used to quantify the potential benefits of the proposed 

standards in this area were not provided in response to the Access Board’s two ANPRMs, and 

we have not identified other sources for this information. The Access Board is seeking input 

from the public on the benefits associated with RTT in Section 5.8 below.

The proposed rule would also lead to improvements in the accessibility of electronic 

documentation and support services provided for telecommunications products. Users with 

various types of disabilities would be better able to evaluate, purchase, and make full use of 

products with the accessibility features they require or prefer to use.

Lastly, American companies that manufacture telecommunications equipment would likely 

derive significant benefits from harmonization of the Section 255 guidelines with consensus 

standards by helping to ensure return on investments in accessibility technology, remain 

competitive in the global marketplace, and achieve economies of scale created by wider use of 

nationally and internationally recognized technical standards.105 Similar benefits would likely 

accrue more generally to all ICT-related products as a result of harmonization; however, given

the relative lack of existing national and globally recognized standards for accessibility of mobile 

technologies, such benefits may be felt more keenly in the mobile technology marketplace.106

5.6. Benefits Accruing to Other Entities

State and local governments, international organizations, and private-sector entities may also 

benefit indirectly from more broad-based adoption of WCAG 2.0-based standards for Webrelated and non-Web-related forms of ICT. These entities are not generally required to apply the 

Section 508 standards to ICT and electronic content they purchase, produce, or disseminate. 

However, many of these organizations have accessibility standards that are based on the current 

Federal Government standards.

The proposed Section 508 standards would provide a foundation for these entities to update or 

supplement their own accessibility standards, should they choose to do so. Irrespective of 

whether they decide to proceed with this update, these organizations may also benefit over time 

from Federal Government adoption of WCAG 2.0-based standards. Specific benefits could 

include the following:

107

 Access to a larger pool of ICT developers and content creators who are trained and 

experienced in universal accessibility standards.

 Reference to a universal set of standards that expands the training and support resources 

available to employees and contractors.

 

105 See, for example, TEITAC Report, Section 4.3 (discussing benefits of harmonization); Hearing on Convention on 

the Rights of Persons with Disabilities Before Senate Committee on Foreign Relations, 113th Cong. (November 

2013) (statement of Frances W. West, Worldwide Director, Human Ability and Accessibility Center, IBM 

Corporation addressing benefits to domestic manufacturers, particularly related to mobile technologies).

106 Ibid.

107 These benefits are discussed in length in the W3C “Business Case” Guidance. They include expanded market 

share resulting from increased use, increased positive image, decreased personnel costs for maintaining the site, 

decreased cost of upgrading for new technologies, and decreased translation costs.
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 Increased variety and capability of authoring tools used to produce accessible content.

5.7. Summary of Benefits

The value of the monetized benefits estimated in this assessment was calculated over a 10-year 

analysis period (assumed to be from 2015 through 2024) and converted into annualized values 

using 7-percent and 3-percent discount rates. These estimates are presented in Table 9.

108

Table 9: Annualized Value of Monetized Benefits, 2015–2024 (Millions of 2015 Dollars)

Monetized Benefit Component 7-Percent 

Discount Rate

3-Percent 

Discount Rate

Benefits from increased Federal employee productivity $46.6 $45.3 

Benefits from improved Federal Government Web site 

accessibility to people with vision disabilities $2.4 $2.3 

Benefits to Federal agencies from reduced call volumes $20.1 $19.8 

Total quantified benefits $69.1 $67.5*

*Benefit numbers do not sum to total because of rounding.

The annualized value of monetized benefits expected to result from implementation of the 

proposed Section 508 standards during the 10-year analysis period is estimated at $ 69.1 million 

using a 7-percent discount rate and $ 67.5 million using a 3-percent discount rate.

 

108 A table showing the estimated benefits in each year of the 10-year analysis period is provided in Appendix E.
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Data were not available to develop monetized estimates for some categories of benefits. A list of 

some of these unquantified benefits is provided in Table 10.

Table 10: Unquantified Benefits of the Proposed Rule

Time savings by people with hearing, cognitive, speech, or manual dexterity or motor impairments from 

more accessible Federal Government Web sites.

Improved accessibility of electronic content (especially PDFs and videos) on Federal Web sites for 

persons with addressable disabilities. 

Potential increase in employment of people with addressable disabilities.

Increased ability for people with addressable disabilities to obtain information and conduct transactions 

electronically. 

Better civic engagement by persons with disabilities due to improved access to information and 

services on Federal Government Web sites.

Greater independence for persons with disabilities who can potentially access information on Federal 

Government Web sites themselves, rather than having to rely on others to access such information for 

them.

Increased ability for people without disabilities to access information and conduct businesses 

electronically even when they are limited by their situation, such as in a noisy or low-bandwidth 

environment or bright outdoors.

Agency cost savings from reduced levels of mail correspondence and in-person visits.

People who are deaf or hard of hearing to have faster and more natural conversations with RTT than is 

possible with current text-messaging functionality.

Improved ability of individuals with vision impairments and other disabilities to evaluate, purchase, and 

make full use of telecommunications products with the accessibility features they require or prefer to 

use because of increased accessibility of product documentation and support services.

Federal Government access to a larger pool of developers and content creators with required 

accessibility knowledge and skills because of harmonized standards.

Benefits to State and local governments, businesses, and nonprofit entities from harmonization of 

standards, including potential cost reductions to ICT manufacturers from being able to sell a single line 

of accessible products and services in public-sector, commercial, and international markets.

Intrinsic (existence) value that people with and without disabilities derive from the nondiscrimination 

and equity values served by Sections 508 and 255. 

The estimates and analysis presented in this section indicate that the proposed rule would provide 

substantial benefits to Federal employees, other people with disabilities that are addressable by 

ICT accessibility standards, Federal Government agencies, and other entities that have adopted 

ICT accessibility requirements based on the current Section 508 standards.

5.8. Request for Comment on Specific Aspects of Benefits Estimates

1. Is any information available on the numbers or proportion of Federal contractor and 

vendor employees who have various types of addressable disabilities?

2. Is there any information or data available on the time savings or productivity increases 

accruing to people with vision and other addressable disabilities from using WCAG 2.0-

compliant Web sites or non-Web ICT instead of Web sites and other ICT that is 

compliant with the current Section 508 standards?
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3. Would any of the proposed requirements limit the productivity of Federal Government, 

contractor, or vendor employees who develop or evaluate software or create electronic 

documents or other electronic content?

4. How frequently and for what duration and purposes do people with vision and other 

addressable disabilities use Federal Government Web sites?

5. Do Federal agencies have any information or data on the cost savings that can be 

achieved by substituting electronic information requests and transactions for those 

handled by means of phone calls, mail, or office visits?

6. Are there any studies or research available that could be used to develop estimates of the 

benefits of RTT capability to people who are deaf or hard of hearing?

7. Would reliance on an SMS-based approach would leave certain needs unmet that would 

be addressed by RTT, and if so, what are the scope and nature of the additional benefits 

that would be gained by requiring ICT that supports real-time voice communication to 

also support RTT. In addition, are the benefits from RTT that have are particularly 

applicable in the context of emergency calls as significant in non-emergency situations?

6. Baseline Compliance Costs

Federal agencies incur costs to comply with the current Section 508 standards—both in the form 

of personnel costs for employees to develop, maintain, and use compliant ICT and to purchase 

compliant products and services from Federal contractors and vendors. Consequently, a major 

component of the work done for this preliminary assessment was to develop estimates of current 

levels of Section 508-related expenditures for various accessibility-related activities and 

compliance requirements.

Our starting point for estimating the “baseline costs” for Federal agencies is a compilation of 

data on Section 508 compliance activities and achievements collected in a recent DOJ survey.109

The survey requested data in four areas: general processes for implementing Section 508, 

procurement, administrative complaints and civil actions, and Web site compliance. Selected 

results from the survey are presented in Appendix C.

Using the data from the DOJ survey and other data sources, we developed estimates for five 

specific categories of costs that Federal agencies currently incur to comply with the existing 

Section 508 standards:

 Developing and implementing Section 508 policy.

 Training Federal employees, including IT and procurement staff.

 Incorporating accessibility into software, Web sites, and audiovisual media.

 Creating and repairing electronic documents.

 Evaluating electronic content, products, and services for compliance.

 

109 DOJ, “Section 508 Report to the President and Congress: Accessibility of Federal Electronic and Information 

Technology,” September 2012.
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These estimates are derived in Sections 6.1 through 6.3 and summarized in Section 6.4. The 

aggregate estimate was used in conjunction with data on Federal ICT budgets and procurement 

to develop an estimate of the current costs incurred by Federal contractors and vendors to make 

and sell Section 508-compliant ICT products, services, and content to the Federal Government 

(see Section 6.2). Finally, we reviewed available data to develop an estimate of the current 

annual costs for telecommunications manufacturers to produce accessible product documentation 

and support materials (see Section 6.3).

6.1. Federal Agency In-House Baseline Costs 

6.1.1. Section 508 Policy Development and Implementation for Federal Agencies

All but the smallest agencies have Section 508 offices. Section 508 offices most frequently 

evaluate Web site accessibility, provide training, create or repair electronic documents, and assist 

acquisition officials to prepare Section 508 language in ICT contracts. However, these offices 

typically have relatively modest staffing and budget resources, as indicated in the 2012 DOJ 

report. Baseline cost estimates based on the DOJ survey data (see Appendix C) are presented in 

Table 11.

110

Table 11: Annual Baseline Cost of Section 508 Policy Development and Implementation

Agency Size Number of 

Employees

Number of 

Components*

Average Section 508 

Office Budget

Very large >25,000 178 $557,584

Large 10,000–25,000 68 $208,305

Medium 1,000–10,000 18 $76,000

Small 100–1,000 28 $13,698

Very small <100 26 $0

All agencies 318 $362,158

Baseline policy cost $115,166,236

*Agency components are typically separate administrations but can be branches, divisions, or offices.

Source: Econometrica calculations from 2012 DOJ Section 508 report.

Current costs for Section 508 offices are estimated at $115.2 million annually.

 

110 Note that the average cost for all agencies ($362,158) is lower than the figure ($413,497) reported in the DOJ 

report. The DOJ estimate does not adjust for differences in the response rates for components in different agency 

size classes.
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6.1.2. Training of Federal Employees

Various categories of Federal employees require training to be able to ensure that the Web pages 

and applications, software, electronic documents, and other electronic content they produce or 

disseminate comply with the current Section 508 requirements. A preliminary estimate of 

baseline Section 508 compliance training costs was developed using the following assumptions:

 According to the Federal employment data presented in Table D-3 of Appendix D, there 

were 81,639 Federal employees in information technology occupations in 2011. These 

employees were assumed to receive an average of 2 hours of training annually related to 

Section 508 compliance.111

 There were 41,874 Federal employees in contracting-related occupations in 2011. These 

employees were assumed to receive an average of 1 hour of training annually.

 There were 76,013 Federal employees in selected other occupations that are likely to 

have responsibilities for Section 508 compliance. These occupations include audiovisual 

production employees, writers and editors, visual information specialists, program 

managers, human resources managers, and EEO staff. These employees were assumed to 

receive an average of 1 hour of training annually.

 The direct expenses (or “out-of-pocket costs”) of providing training vary significantly 

depending on whether employees receive in-person or online training. Classroom training 

provided by third-party instructors typically costs several hundred dollars per attendee.112

On the other hand, the incremental direct cost of having an additional employee complete 

an online training course available on www.section508.gov is effectively zero. For the 

baseline cost estimate, direct training costs were assumed to average $100 per employee

receiving training.

 In addition to the direct expenses incurred for in-person and online training, the costs of 

training include the value of the time employees spend in training. For the baseline cost 

estimate, the time employees spend in training was valued at the average hourly Federal 

wage rate for employees in that occupational category.

 Wage costs for employees receiving training were multiplied by a factor of 1.54 to 

account for benefits and other non-wage compensation.

Baseline cost estimates for Section 508 compliance training based on these data and assumptions 

are presented in Table 12.

 

111 The average amounts of annual training are based on the results from the 2012 DOJ report. It should be noted that 

while some IT-related employees probably receive several hours of training annually, some employees in these 

occupational categories may not receive any training at all.

112 This cost could be incurred either as a direct expense (in the case of contractor training) or as the value of trainer 

time (if a Federal employee provides the training).
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Table 12: Annual Baseline Cost of Federal Employee Training

Estimate Component Number

Number of employees requiring training

IT 81,639

Contracting 41,874

Other selected occupations 76,013

Total number of employees 199,526

Direct expense per employee $100

Direct expense of training (1) $19,952,600

Average hourly wage

IT $44.69

Contracting $38.95

Other selected occupations $41.07

Value of trainee time

IT (2 hours each) $7,308,260

Contracting (1 hour each) $1,631,165

Other selected occupations (1 hour each) $3,120,422

Indirect cost of trainee time $12,059,847

Multiplier to account for benefits 1.54

Loaded cost of trainee time (2) $18,625,315

Baseline training cost (1) + (2) $38,577,915

Direct training costs for Federal employees are estimated at $20.0 million annually, and the value 

of employee time spent receiving training is estimated at $18.6 million annually. Total baseline 

costs for Section 508 compliance training of Federal employees are estimated to be $38.6 million 

annually.

6.1.3. Development of Accessible Software, Web Sites, and Audiovisual Media

A preliminary estimate of recurring annual baseline costs associated with Federal agencies 

incorporating accessibility into software (including firmware, platforms, and applications) and 

Web sites, forms, and applications was developed using the following assumptions:

 Federal IT employees who develop applications or system software were assumed to 

devote time to ensuring that the software they develop is Section 508 compliant.113

 Of the Federal IT employees included in the “information security analysts, Web 

developers, and computer network architects” occupational group, half were assumed to 

devote time to developing Section 508-compliant Web sites, forms, and applications.114

 

113 A detailed breakout of the number of Federal employees in specific IT occupations could not be located. The 

percentage of Federal IT employees who are software developers was assumed to be equal to the percentage in the 

private sector calculated using the Bureau of Labor Statistics (BLS) data in Table D-4.

114 The percentage of Federal IT employees who are classified in this category was assumed to be equal to the 

percentage in the private sector calculated using the BLS data in Table D-4.
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 All Federal audiovisual production employees were assumed to devote time to 

developing Section 508-compliant audiovisual media.

 The average Federal employee works 1,760 hours annually, net of holiday, annual, and 

sick leave.115

 An average of 5 percent of these employees’ working time was assumed to be devoted to 

ensuring that the software, Web, and multimedia products they develop are Section 508 

compliant.116

 Direct wage costs were multiplied by a factor of 1.54 to account for benefits and other 

non-wage compensation.

Baseline cost estimates based on these data and assumptions are presented in Table 13.

Table 13: Annual Baseline Cost of Software/Web/Audiovisual Media Accessibility Compliance

Estimate Component Software 

Development

Web 

Development

Audiovisual 

Production

All 

Applications

Number of employees 22,980 3,380 1,184 27,544

FTE work hours per year* 40,444,821 5,948,717 2,083,840 48,477,378

Compliance hours per year** 2,022,241 297,436 104,192 2,423,869

Average annual salary $92,080 $81,670 $82,890 $90,408

Direct cost per hour $44.27 $39.26 $39.85 $43.47

Loaded cost per hour $68.37 $60.64 $61.55 $67.13

Baseline development cost $138,260,058 $18,036,589 $6,412,613 $162,709,260

*Based on average work hours of 1,760 annually.

**Assumed to be 5 percent of total employee work time.

Compliance costs for accessible software, Web, and multimedia developed by Federal 

employees are estimated at $162.7 million annually.

6.1.4. Evaluation of Software, Web, and Multimedia for Section 508 Compliance

Federal agency IT developers must spend a certain percentage of their time evaluating and 

testing the software, Web programming, and multimedia they design and produce. It is 

reasonable to assume that evaluation time can be estimated as a percentage of the time spent 

developing these forms of ICT. 

Accordingly, baseline evaluation and testing costs were estimated using the following data and 

assumptions:

 

115 OPM, “Federal Civilian Workforce Statistics: Work Years and Personnel Costs, FY 2005,” October 2008 (most 

recent report available).

116 This estimate is consistent with the estimated percentage of time that is reportedly required to build accessibility 

into newly developed Web sites. See, for example, “The Response to United States Department of Justice Advance 

Notice of Proposed Rulemaking (RIN 1190-AA61, Docket No. 110) Nondiscrimination on the Basis of Disability; 

Accessibility of Web Information and Services of State and Local Government Entities and Public 

Accommodations,” comments submitted by Marco Maertens on behalf of Accessibility Associates, LLC, January 

24, 2011. Mr. Maertens estimated that incorporating accessibility in the early stages of a Web site design project can 

be expected to add 3 to 6 percent to development time.
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 Incorporating Section 508 compliance into these forms of ICT developed by Federal 

agencies was assumed to account for 5 percent of the total development hours estimated 

in Table 13.

 For this analysis, we assumed that the time required to determine whether applications 

and systems software; Web sites, forms, and applications; and audiovisual media meet 

applicable accessibility standards is equal to 25 percent of the development time devoted 

to Section 508 compliance for each of these types of ICT developed by Federal 

agencies.

117

Baseline cost estimates developed using these data and assumptions are presented in Table 14.

Table 14: Annual Baseline Cost of Software/Web/Audiovisual Media Evaluation

Estimate Component Software 

Evaluation

Web 

Evaluation

Audiovisual 

Evaluation

All 

Applications

Development hours per year for 

compliance activities 2,022,241 297,436 104,192 2,423,869

Additional hours for compliance testing 

and evaluation 25% 25% 25% 25%

Testing and evaluation hours per year 505,560 74,359 26,048 605,967

Loaded hourly wage rate $68.37 $60.64 $61.55 $67.13

Baseline testing/evaluation cost $34,565,015 $4,509,147 $1,603,153 $40,677,315

Compliance costs for evaluating and testing software, Web, and multimedia ICT developed by 

Federal employees are estimated at $40.7 million annually.

6.1.5. Creation and Repair of Electronic Documents and Other Electronic Content

This cost element is the most difficult to estimate, but it is also likely to account for the largest 

share of the total baseline cost for Federal agencies because achieving compliance requires the 

time of a much larger number of Federal employees on a continuous basis.118

A preliminary estimate of recurring annual baseline costs associated with creating and repairing 

electronic documents was developed using the following assumptions:

 The 199,526 Federal employees in the occupational categories included in Table D-3 

spend at least some time creating or repairing Section 508-compliant electronic 

documents.

 The average Federal employee works 1,760 years annually, net of holiday, annual, and 

sick leave.

 

117 Estimates of the proportion of development time required for testing and evaluation vary from 10 percent to 50 

percent, depending on the type of project and what specific activities are included in testing and evaluation. This 

preliminary analysis uses the midpoint of the 20- to 30-percent range cited as a common rule of thumb in Alan 

Forand, “The Top Seven: Review Current Software Testing Misconceptions,” Hewlett-Packard Viewpoint Paper, 

July 2013.

118 Developing and disseminating compliant document templates reduces per-document recurring compliance costs 

but involves additional one-time and ongoing maintenance, updating, and training costs. We were not able to 

identify suitable data that could be used to estimate these specific cost elements.
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 An average of 3 percent of these employees’ time is required to ensure that the electronic 

content they produce or review is Section 508 compliant.119

 The value of time spent was calculated using the average hourly wage rate ($42.13) for 

the occupational category included in this analysis, multiplied by a factor of 1.54 to 

account for benefits and other non-wage compensation.

The baseline cost estimate calculations are presented in Table 15.

Table 15: Annual Baseline Cost of Section 508-Compliant Document Creation and Repair

Estimate Component Value

Number of Federal employees 199,526

Average work hours per year 1,760

Percent of time spent on compliance 3%

Hours spent on document compliance 10,534,973

Direct cost per hour $42.13

Multiplier to account for benefits 1.54

Loaded cost per hour $65.06

Baseline document compliance cost $685,441,683

Compliance costs for creating and repairing electronic documents prepared by Federal 

employees are estimated at $685.4 million annually.

6.1.6. Summary of Baseline Federal Agency Cost Estimates for In-House ICT

Combining the cost estimates for each component discussed above yields an estimate of total 

baseline compliance costs for Federal agencies. The component cost estimates are summarized in 

Table 16.

Table 16: Annual Baseline Federal Agency Compliance Costs for In-House ICT (Millions)

Cost Component Annual Cost

Policy development and implementation $115.2

Employee training $38.6

Software, Web, and audiovisual development $162.7

Software, Web sites, and audiovisual media evaluation $40.7

Electronic documents creation and repair $685.4

Baseline agency compliance costs for in-house ICT $1,042.6

On a preliminary basis, we estimate that Federal agencies incur costs of approximately $1.0

billion annually to ensure that ICT developed, maintained, or used in house complies with the 

current Section 508 standards. However, this estimate does not include the costs associated with 

 

119 Three percent is the low end of the range cited as the increase in development time required to build accessibility 

into newly developed Web sites. No estimates are available for the percentage of time required to create and repair 

other types of electronic content. However, building accessibility into documents typically involves less time and 

effort than ensuring compliance with a much larger set of standards applicable to Web sites.
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procurement of compliant ICT products, services, and content from Federal contractors and 

vendors. The costs associated with purchasing compliant ICT are estimated in Section 6.2 below.

6.2. Baseline Cost Estimates for Procured ICT

Federal agencies must also procure Section 508-compliant ICT hardware, software, services, and 

content from Federal contractors and vendors.120 In contrast to the costs that Federal agencies 

incur to produce compliant ICT, the costs associated with compliant ICT produced by Federal 

contractors and vendors cannot be directly calculated:

 Adequate data on the size and characteristics of the Federal contractor workforce are not 

available.

 Contractors and vendors may not be able to recoup all of the costs of producing 

compliant ICT through existing or future contracts.

 Agencies sometimes procure partially compliant or noncompliant ICT when compliant 

products are not available or only available at a much higher cost.

The magnitude of these costs can be estimated indirectly, however, using data on the total size of 

the Federal ICT budget and ICT purchases from contractors and vendors. For the preliminary 

analysis, we have identified two estimates of the Federal ICT budget and calculated the estimate 

of annual ICT purchases using two alternative assumptions. This set of four estimates (two 

Federal budget estimates matched to two Federal purchase estimates) was used to develop an 

estimate of baseline compliance costs associated with procured ICT under the assumption that 

Section 508 compliance-attributable costs account for the same share of total costs for ICT 

developed in house and ICT procured from contractors and vendors.

6.2.1. Estimates of the Federal ICT Budget

As noted above, Federal agencies are required to provide data annually on IT project spending to 

OMB. Federal agencies’ IT budgets have been flat for the past few years at a level of 

approximately $80 billion annually (see Table D-1 in Appendix D). This total includes spending 

by most, but not all, Federal agencies. It also may not include expenditures on certain types of 

ICT products and services (including multimedia production and telecommunications services) 

that may be covered under certain provisions in the current Section 508 standards. The Federal 

budget estimate of IT spending is appropriately regarded as a lower bound estimate of all 

spending covered by ICT accessibility requirements.

A more inclusive estimate of total Federal ICT spending is available from Deltek, a government 

accounting and business intelligence firm that provides projections of future contracting 

opportunities. Deltek estimates that Federal ICT spending totaled approximately $120 billion in 

2012.121 However, the Deltek budget figure includes spending on weapons systems and other 

forms of IT that may not be materially affected by the Section 508 requirements.

 

120 These services include provision of contract employees performing work on site and off site for Federal agencies. 

However, ICT that is incidental to a contract is not covered under the current Section 508 standards, nor would it be 

under the proposed section E202.3.

121 Deltek’s Bjorklund said that “the difference is because the Deltek forecast tries to capture the whole Federal 

‘addressable’ market, including the legislative and judicial branches and a host of independent and quasi-
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In the absence of more precise estimates of the Federal ICT budget, we have used a consensus

estimate of $100 billion annually (the average of the OMB and Deltek estimates) to calculate the 

potential share of Federal ICT spending that is accounted for by purchases from Federal 

contractors and vendors.

6.2.2. Federal Purchases of ICT Products and Services

The Federal Procurement Data System (FPDS Next Generation, or FPDS-NG, in its most recent 

form) provides source data on Federal ICT hardware, software, content, and service purchases. 

The 2011 FPDS-NG records for purchases in all potentially applicable NAICS sectors were 

reviewed, edited, and tabulated. Econometrica tabulations of the FPDS-NG data for 2011 are 

presented in Table D-2 in Appendix D.122

Based on the definition of IT provided in the OMB guidance to Federal agencies, it is likely that 

the amounts shown in Table D-2 for telecommunications services and multimedia production 

services are not included in the Federal IT budget estimates. However, these services clearly 

have to meet various accessibility requirements under the current and proposed Section 508 

standards. If telecommunications and multimedia production services are included in the 

estimates of Federal IT spending, 2011 purchases of ICT products and services were $52.8 

billion. If these services are excluded, 2011 purchases of ICT products and services totaled 

approximately $43.9 billion. The average of these two estimates is $48.3 billion.

6.2.3. Estimating the Share of Federal ICT Procured From Contractors and 

Vendors

The high and low estimates of total Federal ICT spending ($120 and $80 billion) and Federal 

ICT purchases ($52.8 and $43.9 billion) can be used to estimate the share of all Federal ICT that 

is procured from contractors and vendors. A range of estimates can be developed using the high 

and low estimates for each of these two variables as follows:

 Each of the two estimates of Federal ICT purchases can be divided into the OMB 

estimate of Federal IT spending (which is known to be somewhat understated) to get 

high-end estimates of the share of procured ICT.

 Each of the two estimates of Federal ICT purchases can be divided into the Deltek 

estimate of Federal IT spending (which is likely to be overstated with respect to the 

forms of ICT covered by Section 508) to get low-end estimates of the share of procured

ICT.

 

governmental agencies, such as the U.S. Postal Service, Fannie Mae, Freddie Mac, and the Tennessee Valley 

Authority. The company also includes spending on IT systems contained within other programs, such as aircraft and 

weapons systems, and estimates on IT spending within the U.S. intelligence community.” Quoted in Information 

Week, “Federal IT Spending Likely to Decline,” June 20, 2012.

122 While the ICT sector estimates presented in Appendix D do not include electronic documents and other 

electronic content created by non-ICT contractors and vendors, the compliance costs associated with creating 

compliant documents and content in this analysis are taken into account because the cost estimates for management, 

training, and document creation and repair are scaled from Federal expenditure and employment data that are not 

limited to the ICT sector.
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Estimates of the share of Federal ICT procured from contractors and vendors are presented in 

Table 17.

Table 17: Estimates of Federal ICT Purchase Share, 2012

Calculation Element OMB Deltek

Federal ICT spending (millions) $80.0 $120.0

High estimate of Federal ICT purchases (millions) $52.8 $52.8

Low estimate of Federal ICT purchases (millions) $43.9 $43.9

High estimate of Federal ICT purchase share 66% 44%

Low estimate of Federal ICT purchase share 55% 37%

The average of the four estimates of Federal ICT purchase share shown in Table 17 (48 percent) 

was used as a baseline estimate of the share of all Federal ICT that is procured from contractors 

and vendors.

6.2.4. Estimating Baseline Compliance Costs for Procured Federal ICT

Baseline compliance costs associated with procured ICT products and services can be estimated 

as follows:

 The ratio of procured ICT to in-house ICT spending is 0.923, estimated from the shares 

of total ICT spending estimated from the data in Table 17. Procured ICT accounts for 48

percent of total ICT spending, while in-house ICT accounts for 52 percent of total ICT 

spending.

 Applying the 0.923 ratio to baseline agency compliance costs for in-house ICT ($1.0426 

billion from Table 16) yields an estimate of baseline compliance costs for procured ICT.

The calculation of baseline compliance costs for procured ICT is presented in Table 18.

Table 18: Annual Baseline Compliance Cost Estimate for Procured ICT

Calculation Element Value

Share of total spending on procured ICT 48%

Share of total spending on in-house ICT 52%

Ratio of procured to in-house ICT spending 0.923

Baseline compliance cost estimate for procured ICT (millions) $962.3

Baseline compliance costs for procured ICT were estimated at $962.3 million in 2011. It is 

important to note that this aggregate estimate of compliance costs for procured ICT does not 

depend on the extent to which contractors or vendors are able to pass on some or all of these 

costs in the form of higher prices charged to Federal agencies for compliant ICT products and 

services, because higher purchase costs and lower contractor profits both represent social costs of 

the current Section 508 standards.

123

 

123 It is also possible that some Federal contractors and vendors may spread the incremental compliance costs across 

all of the products and services they sell that incorporate these accessibility features. This would be most likely to 

occur in the markets for products such as general office software and end user hardware, because incremental costs 

of incorporating the required accessibility features into all units of the products sold would not be much greater than 
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Total baseline Section 508 compliance costs for agency-developed and -procured ICT are 

estimated at about $2.0 billion annually. This amount represents about 2 percent of annual 

Federal ICT spending, which is in the range between $80 billion and $120 billion, depending on 

what products and services are included in the total.

6.3. Baseline Cost Estimates for Complying With Current Section 255 

Guidelines

Telecommunications equipment manufacturers incur costs to comply with the current Section 

255 guidelines. Engineering, management, and marketing employee time is required to evaluate 

the accessibility and usability of manufacturers’ products from the earliest stages of design 

through the entire lifecycle of production and subsequent improvements, modifications, and 

updates. Manufacturers also incur costs to develop and provide user guides, installation guides, 

and product support in alternative formats.

The most recent Census data available indicate that there were 1,384 U.S. communications 

equipment manufacturers (NAICS code 33411, 33421, and 33422) with 120,265 employees in 

2011.124 However, there are three reasons why these estimates may not adequately represent the 

numbers of firms and employees with Section 255 compliance responsibilities:

 Some of these manufacturers have product lines focused on areas (e.g., radio and 

television broadcasting, other communications equipment) that do not fall under the 

scope of the guidelines.

 A substantial portion of telecommunications equipment is imported.

 Documentation and support services may be developed or provided by third parties. 

In any event, it is unlikely that the costs telecommunications manufacturers incur to comply with 

the equipment accessibility provisions in the current Section 255 guidelines can be estimated. 

For large manufacturers, compliance with these requirements appears to have been embedded in 

the overall product design and development process. For example, the AT&T universal design 

policy includes the following components:125

 Product development processes consider the universal design implications in the design 

of new products and services.

 Alternative means of access are incorporated where feasible and consistent with Section 

255 and Section 508.

 Products and services adhere to existing industry accessibility standards and guidelines, 

including WCAG and hearing aid compatibility.

 

if the manufacturers were to produce and sell separate versions of these products specifically to Federal Government 

customers. However, the aggregate amount of compliance costs incurred in this scenario would be unchanged, 

although the incidence of which parties bear the costs would be different.

124 Census Bureau, “Number of Firms, Number of Establishments, Employment, and Annual Payroll by Enterprise 

Employment Size for the United States, All Industries: 2011,” Statistics of U.S. Businesses.

125 AT&T, “Solutions for Customers with Disabilities,” last viewed January 30, 2014.
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 Suppliers and vendors are encouraged to develop accessible products and services and 

include contract language about accessibility and compatibility, as appropriate.

 The needs of people with disabilities and older individuals are considered in market 

research, product conceptualization, human factors research, field trials, and product 

marketing.

However, it is possible to develop estimates of the annual costs incurred to conform with the 

current Section 255 guidelines relating to product documentation and support services using 

Access Board estimates of burden hours in the Paperwork Reduction Act (PRA) analysis section 

of the NPRM. The PRA identifies four categories of proposed information collection 

requirements for telecommunications equipment and CPE manufacturers:

 Support documentation must be offered that lists and explains how to use the 

accessibility and compatibility features of ICT.

 Electronic support documentation (Web site support, PDF versions of user’s manuals) 

must meet the applicable accessibility standards (WCAG 2.0 or PDF/UA-1).

 Non-electronic support documentation must be provided in alternate formats (e.g., braille, 

large print) that are usable by users with vision impairments upon request.

 Support services (e.g., help desks) must offer accessibility and compatibility information, 

include a contact method (e.g., point of contact), and accommodate the communication 

needs of individuals with disabilities.

The PRA estimates that telecommunications equipment manufacturer employees or contractors 

would spend about 2.4 million hours annually to ensure that product documentation meets these 

requirements, which are generally similar to those under the current Section 255 guidelines. The 

monetized value of this employee time was calculated as follows:

 Data on communications equipment manufacturer employee occupations and hourly 

compensation are available from BLS. The employees preparing accessible product 

documentation were assumed to be technical writers and editors who had an average 

wage of $36.64 in May 2012.126

 Fringe benefits represented 30 percent of total compensation in the communications 

equipment manufacturing sector in 2012.

127

 The fully loaded wage rate of $47.63/hour ($36.64 times the benefit multiplier of 1.3) 

was used to value employee time.

 

126 BLS, “May 2012 National Industry-Specific Occupational Employment and Wage Estimates: NAICS 334200 –

Communications Equipment Manufacturing.” NAICS 334200 includes three subsectors: telephone apparatus 

manufacturing (334210), radio and television broadcasting and wireless communications equipment manufacturing 

(334220), and other communications equipment manufacturing (334290). However, the OES data do not provide 

data on employment and wages at the subsector level.

127 Census Bureau, “Economic Census, Detailed Statistics by Industry for the United States: 2012,” Table 

EC0731I1, 2012, released August 29, 2014.
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Baseline costs for telecommunications equipment manufacturers to conform to the current 

Section 255 guidelines relating to product documentation and user support are estimated to be 

$114 million annually.

6.4. Summary of Baseline Section 508 and Section 255 Compliance 

Costs

Collectively, quantifiable costs to comply with the current Section 508 standards and Section 

255 guidelines are estimated at $2.1 billion annually (see Table 19).

Table 19: Annual Baseline Compliance Cost Estimates (Billions)

Monetized Cost Component Value

Baseline compliance cost for in-house ICT $1.042

Baseline compliance cost for procured ICT $0.963

Baseline compliance costs to conform with Section 255 product documentation 

and user support guidelines $0.114

Total baseline compliance costs $2.119

6.5. Request for Comment on Specific Aspects of Baseline Cost

Estimates

1. Are the estimates of the numbers of Federal employees receiving Section 508 training, 

the direct costs per person of this training, and the average number of hours of training 

received annually presented in Section 6.1.2 reasonable?

2. Is it reasonable to attribute 5 percent of the time spent by Federal software and Web 

developers to Section 508-related activities, as this assessment does in Section 6.1.3?

3. Is it reasonable to expect that software and Web testing and evaluation requires about 1 

hour for every 4 hours spent on development, as assumed in Section 6.1.4?

4. In Section 6.1.5, writers, editors, and other content creators are estimated to spend about 

3 percent of their time ensuring that electronic documents and other electronic content are

accessible. Is this a reasonable estimate?

5. Is any information available on the extent to which Section 508 requirements increase the 

costs of producing software, hardware, and telecommunications equipment sold to 

Federal agencies? Are these costs typically recouped in higher prices charged to Federal 

clients, or are they incorporated into the prices charged to all customers?

6. Is any information or data available on the costs incurred by telecommunications 

manufacturers to develop and produce equipment that complies with the current Section 

255 guidelines?
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7. Factors Affecting Future Compliance Costs Under the 

Current ICT Standards and Guidelines

7.1. Factors Affecting Federal Agency Section 508 Compliance Costs

There are several factors that will collectively lead to changes in Federal agency compliance 

rates and costs in the next few years, even if the proposed updates to the current Section 508 

standards are not adopted. Recent Federal Government initiatives are focusing attention and 

resources on measuring and improving agency Section 508 compliance rates, while IT budget 

constraints have both limited available resources and prompted efforts to use them more 

efficiently:

 In 2013, OMB released a strategic plan for addressing current Section 508 compliance 

shortfalls.128 Agencies are now required to provide annual reports on progress made in 

achieving these goals. At a minimum, this initiative is likely to increase the short-term 

costs associated with policy development, implementation, and employee training. Some 

agencies will also come under pressure to improve compliance rates for various forms of 

covered ICT.

 As noted above, increased focus in the past few years has been directed toward creating 

accessible electronic documents that are widely circulated or available to the public, even 

if they are not posted on public-facing Web sites.

129 This emphasis will increase the 

numbers of employees who have to be trained in how to create accessible documents, as 

well as agency technical support capabilities and staff resources. Increased agency efforts 

to produce and distribute compliant electronic content can be expected to increase 

baseline compliance costs in the short term.

 Federal IT budgets have been sharply constrained in the past 4 fiscal years, with 

essentially no growth projected for the next few years as well.130 These budgetary 

limitations could mean that the proposed Section 508 standards could:

o Divert resources from already planned or implemented compliance activities to 

fund new policy development and training requirements.

o Leverage the availability of existing external resources to support improved 

compliance with both the current and proposed Section 508 standards.

 Several cross-agency technical support and ICT evaluation initiatives have been launched 

to reduce the duplication of effort and reduce the costs associated with policy 

development and testing of ICT products and services procured by multiple agencies:

o Enterprise architecture review is being used to ensure that agency components 

adopt common Section 508-compliant hardware and systems software 

solutions.131

 

128 OMB, “Strategic Plan for Improving Management of Section 508 of the Rehabilitation Act,” January 24, 2013.

129 See, for example, Department of Veterans Affairs (VA), “Section 508 Conformance Requirement for Electronic 

Documents,” June 20, 2012.

130 Steven VanRoekel, U.S. Chief Information Officer, “Federal Information Technology, FY 2014 Budget 

Priorities,” undated presentation.

131 Executive Office of the President, “The Common Approach to Federal Enterprise Architecture,” May 2, 2012.
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o The trusted tester program now permits agencies to purchase ICT that has already 

been certified as Section 508 compliant by other agency evaluations.132

o Staff members from 22 Federal agencies are collaborating on a Government-wide 

effort (the Accessible Electronic Document Community of Practice) to provide 

additional resources and support for efforts to increase the share of electronic 

documents that are accessible.

Some of these initiatives have incorporated the adoption and use of WCAG 2.0-based standards, 

particularly in the areas of Web/software testing and electronic document creation and repair. 

However, it is reasonable to expect that there would still be substantial transition costs associated 

with switching to the proposed ICT standards, even for agencies that have had adequate 

capabilities and resources available to achieve and maintain substantial compliance with the 

current Section 508 requirements.

7.2. Factors Affecting Telecommunications Manufacturer Costs to 

Comply With the Section 255 Guidelines

Since the current Section 255 guidelines were adopted, the telecommunications equipment sector 

(especially smartphones and other wireless communications devices) has been characterized by 

rapid evolution of devices, platforms, applications, and consensus standards. We assume that this 

pace of innovation will continue whether or not the proposed ICT standards and guidelines are 

finalized.

This consideration is particularly relevant when assessing the potential impact of the proposed 

requirement that telecommunications devices with display screens support RTT. Recent 

developments suggest that device support for RTT may be much more widely implemented by 

the time any proposed updates to the ICT standards and guidelines would take effect:

 In response to the FCC’s 2011 NPRM regarding the next generation of emergency calling 

services (NG 9-1-1), Verizon and Verizon Wireless supported the adoption of RTT 

capabilities into the NG 9-1-1 system, noting that “Verizon’s product development and 

network teams also are engaged in text-to-911 and NG911-related standards development 

efforts, including the incorporation of RTT capability into future device requirements.”133

 A consortium of European companies appears to be offering support for RTT services. 

The RTT Service promoted by the RTT Alliance is a carrier-class implementation of the 

RTT standard, offering mobile and Web-based user interfaces.134

Similarly, the international adoption of increasingly harmonized standards for document 

accessibility can be expected to increase the availability of software features and templates that 

 

132 Access Board, “Trusted Tester Program,” Section 508 Webinar, April 03, 2014.

133 FCC, “In the Matter of Facilitating the Deployment of Text-to-911 and Other Next Generation 911 Applications, 

PS Docket No. 11-153, and Framework for Next Generation 911 Deployment, PS Docket No. 10-255,” September 

22, 2011; Comments of Verizon and Verizon Wireless submitted to the docket, March 11, 2013.

134 HTK Horizon, “HTK Horizon Hosted Telecom Services Supporting the Real-Time Text Alliance,” viewed 

December 2013.
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could reduce the amount of time required for telecommunications equipment manufacturers to 

prepare accessible electronic documentation and Web support materials.

8. Current Practices and Potential Incremental Costs

Associated With Major New Requirements in the Proposed 

Rule

Many aspects of the proposed Section 508 requirements are not likely to entail measurable 

increases in compliance costs.135 In some areas, the proposed references to WCAG 2.0 would 

provide more specific objective checkpoints that could be used to test and evaluate compliance 

with requirements that already exist in the current standards. For example, the current Section 

508 requirement “A text equivalent for every non-text element shall be provided” would be 

augmented by specific WCAG 2.0 provisions applicable to controls, input, and time-based 

media. This increase in specificity is likely to increase the extent of testing and evaluation 

required to establish that covered ICT is compliant, but it is also likely to reduce long-term costs 

for agencies and vendors that already attempt to produce compliant content and products. The 

proposed standards may also make it easier for developers to identify and remediate 

noncompliant content and products. 

However, some of the proposed standards represent expansions of or additions to current Section 

508 requirements. Proposed revisions to the current Section 508 standards and Section 255 

guidelines were identified and discussed in Section 4.4. In this section, we present information 

on current agency and industry practices and assess the extent to which these practices largely 

conform to the proposed standards or, alternatively, indicate that significant work will be 

required to achieve compliance.

8.1. Area 1: Applying WCAG 2.0 to Software and Applications

Several major software vendors currently provide users with extensive online assistance on 

producing accessible content. These accessibility resources are typically oriented to providing 

generalized accessibility support rather than assisting developers and content creators to comply 

with a specific set of accessibility standards such as the current Section 508 standards. We also 

anticipate that these resources would be updated to support the proposed Section 508 standards. 

However, additional resources for software development, coding, and evaluation would be 

required to ensure that software platforms, toolkits, and applications comply with the entire set of 

WCAG 2.0-based requirements, particularly those that do not have analogues or predecessors in 

the current Section 508 standards. Some of the associated costs can be expected to decrease over 

 

135 We have used the term “measurable increases in compliance costs” in this analysis because compliance with 

some provisions may take no time at all (i.e., for Web developers already using correct programming techniques, the 

parsing and page language provisions would simply require them to do what they do already). For other situations, 

these provisions may require a one-time change in technique or approach to a method that may make it easier to 

update or modify the ICT in the future. Consequently, there would not be measurable increases in cost in these 

situations.
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time as developers become more familiar with the updated standards, but the proposed standards 

would increase the number and specificity of software accessibility requirements that would need 

to be addressed on a continuing basis. 

In addition, software developers (both Federal and contractor employees) would require 

additional training, and government evaluation, testing, and acquisition protocols would need to 

be revised. We expect that most of the costs associated with these activities would be incurred on 

a one-time basis. These costs are estimated in Sections 9.1.2, 9.1.3, and 9.1.4.

8.2. Area 2: Accessibility Features Within Software Applications and 

Operating Systems

Federal agencies could comply with this requirement by developing or purchasing applications 

and operating systems that provide the APIs that would be required. It is not clear that this would 

increase software development or acquisition costs because these applications, platforms, and

systems appear to be readily available in the current marketplace.136

8.3. Area 3: Authoring Tools

Vendors who develop and market authoring tools will incur significant costs to design and 

implement the capabilities required by the proposed standards. However, the significant 

limitations in current software are already being widely addressed by voluntary or de facto 

standards developed by leading ICT companies, trade associations, or third-party standards 

organizations. In addition, Web site authoring tools, user agents, applications, and content are 

increasingly required to support creation and maintenance of WCAG 2.0-compliant (or 

equivalent) Web sites for for-profit and nonprofit entities, as well as for most foreign 

governments in developed countries. 

We expect that authoring tools will increasingly incorporate features to produce and maintain 

accessible content even if the current Section 508 standards are not updated. The proposed 

requirements do not appear to extend past the boundaries of other existing or emerging standards 

and therefore may not result in identifiable incremental costs.137

8.4. Area 4: Assistive Technology

The proposed standards include a provision that would require software that functions as 

assistive technology to use standard platform accessibility services. Our preliminary research 

indicates that most current-generation AT software already makes use of standard APIs, so the 

impact of these requirements may be limited to accelerating the phase-out or replacement of 

 

136 See, for example, Adobe Accessibility, “Accessing PDF Documents with Assistive Technology: A Screen 

Reader User’s Guide.” 

137 This does not imply that the authoring tools currently used by Federal agencies all comply with the proposed 

standards. Rather, it is the case that the tools developed or purchased by Federal agencies can be expected to comply 

with them over time, even if the current Section 508 standards are left in place. This is especially true for authoring 

tools that appear to have expanded capabilities to produce accessible content in recent releases.
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legacy AT equipment and applications.138 Consequently, no identifiable costs were estimated for 

Federal agencies to comply with this proposed requirement.

8.5. Area 5: Electronic Content and Data

The amount of time required for individual authors and editors to produce WCAG 2.0-compliant 

documents and other forms of electronic content will depend in large part on the availability, 

cost, and usability of agency, vendor, and third-party compliance guidance (particularly in the 

form of “how to” materials, product templates, and other support). It will also depend on the 

extent to which employees producing or editing covered content receive sufficient training and 

have access to adequate support resources.139 These costs are estimated in Section 9.1.5.

8.6. Area 6: Color and Contrast Settings

The adoption of testable requirements would increase the time required to evaluate software, 

Web sites, and audiovisual media, but it would also simplify the evaluation and reduce the need 

to make subjective judgments about compliance.

140 For example, the proposed requirement for a 

specific minimum contrast ratio requirement could increase the number of instances in which 

selected images, graphics, and backgrounds in applications and content must be altered to 

achieve compliance. However, the time required to change color contrast is typically minimal, 

and developers would be able to accommodate these requirements in newly developed content 

and applications without additional time and effort.

Consequently, no specific estimates of Federal agency costs associated with complying with the 

proposed requirements in this area were developed. Instead, the impact of these proposed 

requirements is embedded in the overall cost estimates developed for software, Web, and 

multimedia development and evaluation (Sections 9.1.3 and 9.1.4) and electronic content 

(Section 9.1.5).

8.7. Area 7: Audio Controls on Web Pages

Web developers and site administrators would have to evaluate current and newly developed 

audiovisual content and applications to ensure that they comply with the proposed requirement. 

However, many Web sites and software applications currently comply with this standard, and the 

changes required to make noncomplying ICT meet this standard can be accomplished with 

relatively little developer time and effort. In many cases, the following advice will be 

sufficient:141

 

138 For example, the Microsoft Active Accessibility API for accessibility was introduced as a platform add-on to 

Microsoft Windows 95 in 1997. Similar API capabilities have been developed, maintained, and documented for 

Apple, Google, Linux, and Oracle-based systems.

139 In our cost estimates, we assume that Federal employees receive sufficient training and access to adequate 

resources that enable them to produce content that complies with the proposed standards without incurring more 

time than is necessary to ensure that content meets the current standards.

140 Several free color-checking tools, such as Firefox Colorzilla, are available for Web developers and content 

creators.

141 HowTo.gov, “Making Multimedia Section 508 Compliant and Accessible,” updated July 26, 2013.
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Rather than setting videos and other multimedia with sound to start playing when 

your web page loads, allow your users to start the media. Otherwise, the sound 

will interfere with content read by screen readers and refreshable Braille displays.

In Web and software applications, compliance is achieved by specifying one option on the 

default settings rather than another. Both are currently in use, and switching from one to the 

other does not require a measurable amount of programming time or effort. Consequently, no 

specific estimates of Federal agency costs associated with complying with this proposed 

requirement were developed.

8.8. Area 8: User Controls for Captions and Video Description

We have not been able to identify adequate data and information that can be used to quantify the 

potential impact of the proposed standards in this area. Data and other information on market 

trends and costs relating to these proposed requirements are specifically requested in Section 

8.12 below.

8.9. Area 9: RTT Functionality

In discussing the costs of RTT to industry, the TRACE RA Proposal states that it “does not 

require any additional hardware (displays, keyboards, etc.) beyond what a phone/device already 

has for other functions. Open source versions of the software (stacks and Codecs), as well as 

some commercial versions (including reference designs) needed to receive and send real-time 

text, are available. As a result, the costs associated with this proposal are primarily in the initial 

implementation for a company or transport technology. But even these costs will be kept down if 

real-time text design is incorporated in the beginning of the design process. At that stage, these 

costs should be merely a small fraction of the overall design costs, which can be amortized 

across all of the products sold—and carried forward to future designs. Indeed, given the 

capabilities of modern VoIP devices (the only type of devices to which this proposal applies), the 

small software (including firmware) changes needed should not add any significant cost to the 

manufacture of the products.”142

We have not been able to identify adequate data and information that can be used to quantify the 

potential impact of the proposed standards in this area. Data and other information on market 

trends and costs relating to the proposed requirement for telecommunications devices with 

display screens to support RTT are specifically requested in Section 8.12 below.

As discussed in Section 5.5 above, the Access Board is seeking input from the public on whether 

to retain the RTT provisions in the proposed Section 508 standards and Section 255 guidelines in 

light of the FCC’s report. The Board is interested in hearing from manufacturers and service 

providers on whether complying with the proposed RTT requirements would impose costs in 

addition to those identified by the FCC for implementing SMS-based text to 911, and if so, to 

 

142 TRACE Proposal, p. 17.
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identify the scope and nature of those costs and quantify wherever possible. Questions have been 

included in Section 8.12 below.

8.10. Section 508 Hardware and Equipment Costs

We have not been able to locate adequate data to characterize the extent to which Federal 

agencies are currently able to purchase specific categories of accessible telecommunications 

equipment, video and multimedia products, “self-contained closed products,” and computers (the 

four categories of hardware specifically covered by the current standards).143 Consequently, we 

are not able to estimate the baseline level of purchases of Section 508-compliant hardware and 

the incremental costs associated with purchasing hardware that incorporates the required 

accessibility features. Data and other information on potential costs relating to making hardware 

and equipment compliant with the proposed requirements are specifically requested in Section 

8.12 below.

8.11. Section 255 Electronic Documentation and Support Costs

To ascertain the extent to which product documentation and support content on 

telecommunications manufacturer Web sites are currently accessible to people with disabilities, 

Econometrica identified and briefly reviewed the product support pages of 25 leading 

telecommunications equipment manufacturer Web sites.144 Each manufacturer Web site was 

reviewed to determine if product support information could be readily accessed from the home 

page by means of a direct link or a Javascript menu. Where a landing page for the product 

support section could be identified, that page was evaluated for the subset of accessibility issues 

that can be identified using the WebAIM.org WAVE checker.145

It is explicitly noted that the number of accessibility errors detected by the WAVE checker may 

not be indicative of the actual degree to which the structure and content of the support home 

page is accessible, and different types of errors can require widely varying degrees of effort to 

repair. With this disclaimer, the results of this review are presented in Table 20.

 

143 For example, we were not able to identify any GSA materials that provided any information on the availability or 

cost of equipment offered in compliant and noncompliant versions (relative to the current Section 508 standards).

144 This review included the Web sites of 25 of the 50 manufacturers with contact information listed on FCC, 

“Section 255 Manufacturers,” last viewed January 30, 2014.

145 The Web Accessibility Evaluation Tool (WAVE) is developed and made available as a free community service. 

WebAIM.org provides more information on this tool on the WAVE help page, which also includes important 

information about the limitations of automated Web page accessibility evaluation.
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Table 20: Telecommunications Equipment Manufacturer Support Pages

Telecommunications Equipment 

Manufacturer Site*

Support Page Link on 

Home Page?

Support Page 

Errors**

Alcatel Yes 15

Apple Inc. Yes 0

Canon USA Yes 1

Cisco Systems, Inc. Yes 24

Ericsson, Inc. No N/A

Hewlett-Packard Company Yes 0

HTC Corporation Yes 17

Kyocera Wireless Corporation Yes 19

LG Electronics MobileComm U.S.A., Inc. Yes 34

Lucent Yes 4

Microsoft Corporation Yes 3

Mitel Networks, Inc. No N/A

Motorola Mobility No N/A

NEC Corporation of America Yes 6

Nokia Yes 2

Panasonic Corporation of North America Yes 74

RadioShack Corporation No N/A

Research in Motion Limited/RIM Yes 6

Samsung Telecommunications America No N/A

Sharp Electronics Yes 28

Skype Communications Sarl Yes 1

Sony Mobile Communications (USA), Inc. Yes 1

Toshiba America Information Systems, Inc. Yes 5

Uniden America Corporation Menu*** 3

VTech Telecommunications, Ltd. Menu*** 5

*Companies listed on FCC, “Section 255 Manufacturers,” January 29, 2014.

**Identified using WebAIM.org WAVE checker, January 29, 2014.

***Support FAQ page reviewed.

Source: Econometrica, Inc., review of Web pages in table hyperlinks.

This review indicated that about half of the support pages reviewed (13 of 25) had fewer than 10 

errors identified by the WAVE checker. This group includes the support home pages of several 

leading mobile phone manufacturers, including Apple, Nokia, and Research in Motion, as well 

as those of cordless handset manufacturers such as Uniden and VTech. These pages generally 

appear to require relatively modest revisions to improve accessibility. 

Another seven pages had more extensive accessibility issues, some of which could potentially 

limit the ability of users with vision disabilities to be able to locate and review material on 

specific products or issues of concern. The Web sites of the remaining five manufacturers do not 

provide a clear link to the support services section on the home page, which may further 

complicate users’ ability to locate and review product documentation and other support content.
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8.12. Request for Comment on Compliance Costs

1. Relatively few, if any, authoring tools available are compliant with the current W3C 

ATAG 1.0 guidelines. Is this mostly due to feasibility, cost, or lack of customer demand?

2. Would the requirement to provide captioning and audio description controls impose 

additional costs on manufacturers? Would that burden be mitigated if the requirement for 

caption and audio description controls be limited only to certain types of hardware, such 

as remote controls?

3. Which proposed Section 508 requirements, if any, will increase compliance costs for 

manufacturers and sellers of ICT hardware and equipment? Specifically:

a. Are there any data available on the difference in the cost of ICT that meets the 

508 accessibility requirements and ICT that does not meet them?

b. Are there some product types where the cost differences are de minimis and 

others where the cost differences are more pronounced?

c. Are there certain accessibility features that are more costly to incorporate into 

products and result in higher prices reflected in procurements?

4. Do any other specific provisions of the WCAG 2.0 standards impose additional 

compliance costs compared to the current Section 508 regulations? If so, which 

provisions? What is the estimated difference in cost between complying with the current 

requirement(s) and the proposed requirement(s)?

a. Web site standards.

b. Operating systems and applications software.

c. Hardware and telecommunications equipment.

d. Self-contained, closed products.

e. Documents and other non-multimedia content.

f. Multimedia content/image-based software.

5. Are there substantial technical or cost issues associated with implementing support for 

the proposed RTT standard on the following?

a. Customer devices.

b. Telephone network equipment.

c. Online video communication software and displays.

d. Other components of wireline and wireless telephone networks.

6. Is any information or data available on the share of the U.S. telecommunications market 

that is expected to have the capability to support RTT functionality in the next 3 to 5 

years?

9. Preliminary Cost Estimates for the Proposed Rule

Ideally, this preliminary assessment would include estimates of the incremental costs associated 

with meeting each of the proposed accessibility standards. However, the increase in compliance 
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costs attributable to specific provisions depends on the extent of current compliance with the 

proposed requirement across affected entities and various types of ICT products, software, 

services, and content.

Our interviews with agency representatives indicated that there is substantial diversity in current 

compliance rates—whether measured against the current Section 508 standards or those in the 

proposed rule—within and among agencies, agency components, and types of ICT. In addition, 

the amount of effort and cost that would be incurred to ensure that some form of ICT complies 

with a specific provision in the proposed standards depends on the extent to which it already 

complies with other provisions in the proposed requirements. Consequently, it is not possible to 

develop estimates of the potential increases in costs that would result from separately 

implementing each of the individual provisions included in the proposed rule.

The approach used instead in this analysis was to evaluate the potential impact of the proposed 

requirements (particularly those discussed in Section 8 above) on each of the five compliance 

cost components (e.g., policy development, training) included in the baseline cost estimates

developed and presented in Section 6. The sum of these component estimates were used to 

develop overall estimates of the projected increases in costs for in-house procured ICT.

We were also unable to develop quantitative estimates of the costs that telecommunications 

manufacturers would incur to comply with the proposed rule of the current Section 255 

guidelines, including the requirement to support RTT and to provide accessible support 

documentation and services.

9.1. Federal Agency Compliance Costs for In-House ICT

9.1.1. Section 508 Policy Development and Implementation

The proposed rule would require revisions to current agency Section 508 policies, guidelines, 

information dissemination, and compliance monitoring practices. We expect that agencies will 

incur a substantial one-time fixed cost associated with adoption of revised standards:

 Section 508 offices and coordinators would need to review and revise all existing policy 

directives and guidance for agency employees. 

 These revised materials would need to be disseminated and discussed with personnel in 

each agency component who have significant Section 508 compliance responsibilities.

 Current compliance measurement and tracking programs and reports would also need to 

be revised.

For this preliminary analysis, we have assumed that agencies would incur a one-time cost to 

support the transition to the proposed Section 508 standards equal to as much as 100 percent or 

as little as 25 percent of the current baseline cost for policy development and implementation 

activities. A point estimate of 50 percent was used to develop an estimate of the projected onetime impact of the proposed rule on policy development and implementation costs. 

Recurring annual costs would likely increase by a small percentage as well, because the 

proposed standards and guidelines are more extensive and specific than the current Section 508 
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standards. However, Section 508 offices and coordinators would be able to draw on an expanded 

set of interagency and external resources to support their activities because the proposed 

standards would require less ongoing interpretation and less agency-specific directives and 

guidance than is the case with the current Section 508 standards. It is possible that these 

recurring costs would not ultimately be higher than they would be under the current standards. 

However, we assumed that recurring annual costs for policy development and implementation 

would increase by an average of 5 percent in this preliminary analysis.

A preliminary estimate of the impact of the proposed Section 508 standards on this component of 

compliance costs for Federal agencies is presented in Table 21.

Table 21: Projected Cost Increase for Policy Development and Implementation

Estimate Component Value

Baseline costs (millions) $115.2

Projected increase (initial) 50%

Initial cost increase (millions) $57.6

Projected increase (recurring) 5%

Recurring cost increase (millions) $5.8

Federal agency budget constraints are likely to limit the extent of any increase in the resources 

available to Section 508 offices and coordinators for the next few years. Therefore, we have 

assumed that the initial cost increase of $57.6 million would be spread over a 2-year period, with 

recurring costs of $5.8 million incurred annually during each of the remaining 8 years in the 10-

year analysis period.

9.1.2. Training of Federal Employees

The proposed rule would require extensive additional training for Federal agency IT employees, 

as well as employees involved in contracting, writing, editing, audiovisual production, and the 

other occupations included in Table D-3. Agencies would be likely to incur a substantial onetime increase in training costs associated with adoption of revised standards:

 Software developers would need to be trained on the techniques that can be used to 

satisfy the WCAG 2.0 Level A and Level AA Success Criteria and Conformance 

Requirements for non-Web ICT (see Section 8.1). They would also need information on 

the proposed requirements for support of accessibility services and authoring tools (see 

the discussion in Sections 8.2 and 8.3).

 Web and other content developers would need to be informed about the more detailed 

requirements in the proposed rule relating to issues such as color contrast, text resizing, 

audio controls, and captioning (see the discussion in Sections 8.6 through 8.8).

 Employees evaluating in-house ICT would need to understand the more specific and 

extensive benchmarks that must be satisfied to ensure that procured or developed ICT 

complies with the proposed standards.

For this preliminary analysis, we have assumed that agencies would incur additional one-time 

training costs in an amount equal to the current annual baseline cost for Federal employee 
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training.

146 Recurring annual costs would also be likely to increase by a small percentage 

because the proposed standards and guidelines are more extensive and specific than the current 

Section 508 standards. For this preliminary analysis, we have assumed that this recurring 

increase in policy development and implementation costs would average about 10 percent after 

the first year.

A preliminary estimate of the cost of the proposed Section 508 standards attributed to training 

Federal employees is presented in Table 22.

Table 22: Projected Cost Increase for Federal Employee Training

Estimate Component Value

Baseline costs (millions) $38.6

Projected increase (initial) 100%

Initial cost increase (millions) $38.6

Projected increase (recurring) 10%

Recurring cost increase (millions) $3.9

Federal agencies currently have very restricted budgets for training. The preliminary analysis 

estimates assume that the initial cost increase of $38.6 million would be spread over a 2-year 

period, with recurring costs of $3.9 million incurred annually during each of the remaining 8 

years in the 10-year analysis period.

9.1.3. Developing Accessible Software, Web Sites, and Audiovisual Media

Software and Web developers would require additional time to ensure that the platforms and 

applications they create and modify comply with the proposed application of WCAG 2.0 

standards to software:

147

 Design time would be required to ensure that software would comply with the proposed 

Section 502 requirements for interoperability with AT accessibility services (see Section 

8.2).

 Developers of authoring tools would need additional time to ensure that this software 

complies with the proposed Section 504 requirements (see Section 8.3).

 Developers of software that functions as AT would need additional time to ensure that 

these applications comply with the proposed Section 503 requirements for AT (see 

Section 8.4).

 Multimedia developers would need to spend time to comply with the proposed 

requirements for captioning and user controls (see Sections 8.7 and 8.8).

 Additional time would be required for these employees to develop compliant program 

documentation and support materials.

 

146 The size of this projected increase is attributable in part to the relatively small reported number of hours of 

Section 508 training currently provided to Federal IT staff and other employees with compliance responsibilities.

147 See discussion in Sections 4.4.1 and 8.1.
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The costs associated with this additional time would be incurred on a continuing basis. However, 

there are several reasons why the amount of time required for these activities would decline after 

an initial adjustment period:

 Developers would become increasingly familiar with the proposed requirements and 

would learn better techniques for designing in compliance in early stages of ICT projects.

 Successful approaches would be incorporated into templates that could be reused on new 

projects.

 Newly hired developers would be more likely to have been trained on the proposed 

accessibility requirements.

For this preliminary analysis, we have assumed that it would initially take developers of 

software, Web, and multimedia ICT 20 percent longer to develop compliant platforms, 

applications, and content than is currently required, but only half as long to do so after the initial 

phase-in period.

A preliminary estimate of the impact of the proposed Section 508 standards on ICT development 

costs for Federal agencies is presented in Table 23.

Table 23: Projected Cost Increase for Software/Web/Multimedia Development Compliance

Estimate Component Software 

Development

Web 

Development

Audiovisual 

Production

All 

Applications

Baseline costs (millions) $138.3 $18.0 $6.4 $162.7

Projected increase (initial) 20% 20% 20% 20%

Initial cost increase (millions) $27.7 $3.6 $1.3 $32.5

Projected increase (recurring) 10% 10% 10% 10%

Recurring increase (millions) $13.8 $1.8 $0.6 $16.3

Software development typically takes place over an extended period of time. The preliminary 

analysis estimates assume that the initial cost increase of $32.5 million would be spread over a 2-

year period, with recurring costs of $16.3 million incurred annually during each of the remaining 

8 years in the 10-year analysis period.

9.1.4. Evaluation of Software, Web Sites, and Audiovisual Media for Compliance

In our analysis of baseline costs, we assumed that evaluation of software applications, Web 

sites/forms/applications, and audiovisual media currently accounts for 25 percent of the total 

time spent developing these products. The increase in the number and specificity of the standards 

under the proposed approach for software and Web sites means that more evaluation time will be 

required in the design, implementation, and testing stages for these products. The preliminary 

analysis assumes that the proposed rule would initially require a 20-percent increase in 

evaluation and testing time.

148

 

148 This is an estimate of the time that would be required to evaluate compliance with the full set of proposed 

standards. Different provisions in the proposed standards will be applicable for varying types of software, Web sites, 

and audiovisual media. The addition or deletion of single provisions from the proposed requirements would not be 

likely to materially affect the total time required.
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It is possible that the amount of time required for evaluation and testing could decline after an 

initial adjustment period. However, current initiatives such as the trusted tester program have 

already begun to reduce the recurring costs of ICT accessibility evaluation and testing, and it is 

not clear the proposed standards would provide future opportunities for additional cost savings 

from interagency evaluation and testing, relative to the current standards. Consequently, the 

preliminary analysis assumes that the incremental increase in evaluation and testing effort (20 

percent over current baseline hours) would be required on a continuing basis.

A preliminary estimate of the impact of the proposed Section 508 standards on compliance 

evaluation and testing costs for Federal agencies is presented in Table 24.

Table 24: Projected Cost Increase for Software/Web/Audiovisual Media Evaluation

Estimate Component Software 

Evaluation

Web 

Evaluation

Audiovisual 

Evaluation

All 

Applications

Baseline costs (millions) $34.6 $4.5 $1.6 $40.7

Projected increase (initial) 20% 20% 20% 20%

Initial cost increase (millions) $6.9 $0.9 $0.3 $8.1

Projected increase (recurring) 20% 20% 20% 20%

Recurring increase (millions) $6.9 $0.9 $0.3 $8.1

The preliminary analysis estimates that the Federal Government would incur increased costs of 

$8.1 million annually to evaluate and test agency-developed ICT.

9.1.5. Creation and Repair of Electronic Documents

The proposed rule would provide specific categories of electronic documents and other content 

that would have to comply with the Section 508 standards. Based on our interviews with agency 

representatives, agencies have not yet been able to ensure that most of the electronic content 

produced in some of these categories is compliant with the current accessibility requirements.

However, current Federal Government initiatives may mean that increased agency attention and 

effort will need to be devoted to electronic document and content accessibility in the next few 

years, irrespective of whether or not the proposed standards are adopted (see the discussion in 

Section 7). Thus, the potential impact of incorporating specific categories of covered documents 

and content in the proposed Section 508 standards on volume of these materials that must be 

made accessible is not clear.149

It is also not clear that complying with the proposed standards and guidelines for electronic 

content would require additional time and effort for authors and editors of conventional 

documents, spreadsheets, and PDFs relative to ensuring that these types of content comply with 

the current Section 508 standards. However, the proposed standards are more specific and 

testable, so these forms of ICT may be prepared more thoroughly and attentively.

In addition, there are other forms of electronic content (presentations, project management 

software output, accounting and financial software reports) that may require more effort to make 

 

149 Also see the previous discussion in Sections 4.4.5 and 8.5.
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compliant under the proposed standards because current authoring tools and templates may 

provide lower or less consistent support for incorporating accessibility.

Based on these considerations, the preliminary analysis assumes that creators and editors of 

electronic content would initially require 10 percent more time on average to ensure that covered 

materials comply with the proposed standards.150 As Section 508-compliant authoring tools and 

templates become more widely available and employee training is completed, it would be 

reasonable to assume that the additional time that would be required to create or repair electronic 

content would be reduced in future years. The preliminary analysis assumes that the incremental 

time required after a 2-year phase-in period would be half of the amount assumed for the first 2 

years after the proposed standards are adopted.

Because incremental costs are calculated based on a proportion of baseline costs, it is thereby 

assumed that the types of Federal employees (i.e., job categories) needed to create or repair 

accessible electronic documents under the proposed Section 508 standards would be the same as 

those employees needed under the current standards (See Table D-3). It is possible that, under 

the proposed 508 Standards, other types of Federal employees might spend time creating or 

repairing electronic content who do not currently engage in these tasks. However, no suitable 

information or data is available at this time on which to base incremental estimates of time spent 

by new categories of Federal employees. Accordingly, in Section 9.5, we request comment on 

other categories of Federal employees (i.e., job categories not included in the baseline cost 

assumptions in Table D-3) who potentially may need to spend time creating or remediating 

electronic documents under the proposed Section 508 standards.

A preliminary estimate of the impact of the proposed Section 508 standards on electronic 

document creation and repair costs for Federal agencies is presented in Table 25.

Table 25: Projected Cost Increase for Section 508-Compliant Document Creation and Repair

Estimate Component Value

Baseline costs (millions) $685.4

Projected increase (initial) 10%

Initial cost increase (millions) $68.5

Projected increase (recurring) 5%

Recurring cost increase (millions) $34.3

The preliminary analysis estimates that the Federal Government would incur increased costs of 

$68.5 million in each of the first 2 years of the 10-year analysis period to create and repair 

electronic documents. The recurring cost is estimated to be half as much ($34.3 million annually) 

in each of the remaining years in the analysis period.

9.1.6. Overall Increase in Agency Compliance Costs for In-House ICT

As noted above, there is a substantial degree of uncertainty associated with the impact of 

adopting specific provisions included in the proposed rule on Federal agency compliance costs. 

 

150 Different provisions will be applicable for varying types of electronic documents and other electronic content. 

The addition or deletion of single requirements would not materially affect the total time required.
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The discussion provided in Sections 9.1 through 9.4 makes clear that the extent of this 

uncertainty can be potentially reduced by assessing the potential impact of the proposed rule at 

an aggregated level of analysis. However, the potential percentage increases in specific 

categories of costs could plausibly be much higher or lower than those used to develop the 

preliminary estimates of incremental compliance costs in this preliminary analysis. 

Table 26 presents the ranges of percentage increases for each cost component that were 

examined before selecting a point estimate to develop the preliminary estimates of compliance 

costs that would be incurred by Federal agencies from the proposed rule. Comments on the range 

of potential increases in costs and the point estimates used to estimate these costs are specifically 

requested.

Table 26: Preliminary Percentage Increases in Agency Compliance Costs for In-House ICT

One-Time Costs Recurring Annual Costs

Cost Component High Low Point 

Estimate*

High Low Point 

Estimate*

Policy development and 

implementation 100% 25% 50% 10% 0% 5%

Employee training 200% 50% 100% 20% 5% 10%

Software, Web, and audiovisual 

development 40% 10% 20% 20% 5% 10%

Software, Web sites, and 

audiovisual media evaluation 40% 10% 20% 40% 10% 20%

Electronic documents creation and 

repair 20% 5% 10% 10% 0% 5%

*Estimate used in the compliance cost calculations.

In the absence of better data or more available information on the potential impact of the 

proposed standards, the point estimates of the projected increases in one-time and recurring costs 

shown in Table 26 were used to develop the component cost estimates presented in Sections 9.1 

through 9.4. 

The projected increases in costs for these five components were aggregated to develop 

preliminary estimates of the overall increase in compliance costs for Federal agencies 

attributable to the proposed standards and guidelines. Preliminary estimates of the impact of the 

proposed Section 508 standards for overall compliance costs for Federal agencies are presented 

in Table 27.
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Table 27: Projected Increase in Annual Agency Compliance Costs for In-House ICT (Millions of 

2015 Dollars)

Cost Component Initial Cost Recurring Cost

Policy development/implementation $57.6 $5.8

Employee training $38.6 $3.9

Software/Web/audiovisual development $32.5 $13.8

Software/Web/audiovisual evaluation/testing $8.1 $8.1

Electronic document creation/remediation $68.5 $34.3

Overall increase in agency costs for in-house ICT $205.4* $65.8*

Percentage of annual baseline costs for in-house ICT 20% 6%

*Cost numbers do not sum to total because of rounding.

During the first 2 years after the proposed standards and guidelines take effect, Federal agencies 

are projected to incur additional one-time costs to transition to the rule Section 508 standards. 

These one-time costs are projected to be about $205 million, or 20 percent of the annual baseline 

costs of $1.0 billion estimated for agencies to comply with the current Section 508 standards.

Based on our preliminary assumptions about the impact of specific areas included in the 

proposed standards and guidelines on baseline compliance costs, the increase in recurring overall 

Federal agency compliance costs is projected to be approximately $65 million annually. This 

represents an increase of about 6 percent of annual baseline compliance costs estimated for 

agencies to comply with the current Section 508 standards. 

In accordance with OMB regulatory review guidelines, the annual values of total monetized 

costs were calculated over a 10-year analysis period (assumed to be from 2015 through 2024) 

and converted into base-year (2015) present values using 7-percent and 3-percent discount rates. 

A summary of these estimates is provided in Table 28.

151

Table 28: Present Value in 2015 of Monetized 2015–2024 Agency Costs for In-House ICT (Millions

of 2015 Dollars)

Monetized Cost Component 7-Percent 

Discount Rate

3-Percent 

Discount Rate

Policy development/implementation $80.1 $92.2

Employee training $53.7 $61.8

Software/Web/audiovisual development $110.7 $127.3

Software/Web/audiovisual evaluation/testing $56.6 $65.1

Electronic document creation/remediation $265.0 $304.8

Total 2015–2014 agency costs for in-house ICT $566.1 $651.2

The present value of monetized costs expected to result from implementation of the proposed 

rule of the Section 508 standards during the 10-year analysis period is estimated at $566 million 

using a 7-percent discount rate and $651 million using a 3-percent discount rate.

 

151 A table showing the estimated costs in each year of the 10-year analysis period is provided in Appendix E.
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The estimates in Table 28 and the analysis presented in this section indicate that Federal agencies 

would incur substantial costs to implement and comply with the proposed ICT accessibility 

standards.

As noted above, data were not available to quantify some categories of the costs discussed in this 

section. This is especially true for the costs that may be incurred to ensure that ICT procured by 

the Federal Government meets the proposed accessibility standards.

9.2. Estimated Cost Increases Associated With Procured ICT

As noted in Section 6.2, the costs agencies incur to purchase compliant ICT were not directly 

calculated. Similarly, adequate data are not available to estimate the increase in costs to purchase 

ICT products, services, and content that would comply with the proposed Section 508 standards 

from Federal contractors and vendors.

However, an estimate of incremental compliance costs associated with procured ICT can be 

developed as follows:

 The share of total Federal agency ICT procured from contractors and vendors is 48 

percent (see Section 6.2.4).

 Federal contractors and vendors were assumed to incur the same percentage increases in 

the time required for compliance program development and implementation, employee 

training, development, evaluation, and document creation and repair as Federal agency 

employees who produce and maintain ICT developed in house.

 The ratio of costs associated with procured and in-house ICT is therefore 0.923 (.48/.52). 

This ratio was applied to each of the cost estimates shown in Table 27 to obtain estimates 

of costs for the same category that are associated with procured ICT.

Estimates of the initial and recurring increases in compliance costs for procured ICT developed 

using this approach are presented in Table 29.

Table 29: Estimates of Increased Costs Associated With Procured ICT (Millions of 2015 Dollars)

Component Initial Cost Recurring Cost

Policy development/implementation $53.2 $5.3

Employee training $35.6 $3.6

Software/Web/audiovisual development $30.0 $12.8

Software/Web/audiovisual evaluation/testing $7.5 $7.5

Electronic document creation/remediation $63.3 $31.6

Increase in costs for procured ICT $189.6 $60.8

The initial increase in compliance costs associated with procured ICT is estimated at $190

million. Recurring annual compliance costs for procured ICT are estimated to be $61 million 

higher under the proposed Section 508 standards.
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Estimates of the 2015 present value of the increase in compliance costs associated with procured

ICT during the 10-year analysis period from 2015 through 2024 are presented in Table 30.

Table 30: Present Value in 2015 of Monetized 2015–2024 Costs for Procured ICT (Millions of 2015 

Dollars)

Monetized Cost Component 7-Percent 

Discount Rate

3-Percent 

Discount Rate

Policy development/implementation $74.0 $85.1

Employee training $49.6 $57.0

Software/Web/audiovisual development $102.2 $117.5

Software/Web/audiovisual evaluation/testing $52.3 $60.1

Electronic document creation/remediation $244.6 $281.4

Total 2015–2024 costs for procured ICT $522.6 $601.1

The present value of the increased costs during the 10-year analysis period associated with 

procured ICT is estimated at $523 million using a 7-percent discount rate and $601 million using 

a 3-percent discount rate.

As noted in Section 6.2, this estimate of projected cost increases does not depend on the extent to 

which contractors or vendors would be able to pass on some or all of these costs in the form of 

higher prices charged to Federal agencies for compliant ICT products and services, as both 

higher purchase costs and lower contractor profits would represent social costs of the proposed 

Section 508 standards.

9.3. Compliance Costs Associated With Proposed Section 255 

Guidelines

As noted in Section 7.2, it is not clear that telecommunications equipment manufacturers would 

incur costs for supporting RTT on devices with display screens, because these capabilities may 

be developed and, in some cases, implemented prior to the adoption of a final rule to update the 

current ICT standards and guidelines.

In addition, significant costs could be incurred to make product support Web site content and the 

electronic documentation furnished on these sites and through other channels comply with the 

WCAG 2.0 Level A and Level AA and PDF/UA-1 standards. Based on the review discussed in 

Section 8.11, several of the largest telecommunications manufacturers appear to have relatively 

accessible support sections of their public-facing Web sites. However, many others would need 

to undertake a substantial effort to make the product support sections of their Web sites and the 

content made available therein accessible. Costs for manufacturers with Section 255 obligations 

to ensure that their product documentation and support services conform to the proposed 

guidelines were estimated as follows:

 According to the 2011 Statistics of U.S Business, there were 263 telephone apparatus 

manufacturers (NAICS 33421), 730 radio and television broadcasting and wireless 

communications equipment manufacturers (NAICS 33422), and 391 electronic computer 

manufacturers (NAICS 334111). For this assessment, we assumed that firms with 20 or 
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more employees have Section 255 obligations under the current FCC regulations. About 

16 percent of the firms (217) in this sector had 100 or more employees, and another 20 

percent (278) had between 20 and 99 employees.

152 Firms with fewer than 20 employees 

are less likely than larger firms to provide electronic customer support on their Web 

sites—in many case because they serve as partners or suppliers to larger firms that offer 

this support.

 The 25 firms included in our review of telecommunications equipment manufacturer 

Web support pages (see Section 8.11) were assumed to be representative of the 217 firms 

with 100 or more employees in this sector. Firms with between 20 and 99 employees 

were assumed to have substantially less extensive Web support and electronic product 

documentation that would need to be made accessible under the proposed guidelines.

 Per-firm costs for Web site and electronic content repairs to meet the proposed 

accessibility guidelines were developed based on estimates presented in the Econometrica 

regulatory evaluation of the 2013 DOT rule that will require public-facing airline Web 

sites to be WCAG 2.0 compliant. Estimated one-time costs for airline Web sites ranged 

from $500,000 for the largest carriers to $50,000 for smaller carriers without online 

booking capabilities.153

 These per-firm estimates were modified to take into account the following

considerations:

o The airline sites reviewed as part of the DOT regulatory evaluation were 

substantially less accessible than most of the product support sections of the 

telecommunications equipment manufacturer Web sites reviewed as part of this 

assessment. 

o Restructuring or repairing the product support section of a Web site (and in some 

instances, improving the navigation to that section from the home page) should 

typically require less effort than overhauling an entire Web site. The 

telecommunications product support sections also do not have the complex 

interactive functionality that characterizes online air travel booking engines.

 For this preliminary assessment, we assumed that one-time remediation costs for firms 

with 100 or more employees would average $125,000, or 25 percent of the costs incurred 

to overhaul a large airline’s (largely inaccessible) Web site. Firms with between 20 and 

99 employees were assumed to incur an average of $25,000 in one-time costs, or 50 

percent of the average for smaller firms without online booking capabilities estimated in 

the DOT regulatory evaluation.154

 

152 Census Bureau, “Number of Firms, Number of Establishments, Employment, and Annual Payroll by Enterprise 

Employment Size for the United States, All Industries: 2011,” Statistics of U.S. Businesses. 

153 Econometrica, Inc., “Final Regulatory Analysis on the Final Rule on Accessible Kiosks and Web Sites,” October 

23, 2013.

154 The higher percentage of airline Web site accessibility costs assumed for smaller manufacturers takes into 

account the fact that smaller telecommunications equipment manufacturers would need to provide a full inventory of 

accessible product support materials even if the product support sections of most of their public-facing Web sites are 

less extensive and have less functionality than those of the largest manufacturers.
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 Providing accessible product documentation and support also entails continuing costs as 

Web support pages are modified or expanded and as new or updated electronic content is 

created. The DOT regulatory evaluation estimated that these annual operating and 

maintenance costs would be equal to 10 percent of the one-time costs for making airline 

Web sites accessible. Telecommunications and CPE manufacturers typically make large 

volumes of product documentation and support materials available in electronic form. It 

would therefore be reasonable to assume that recurring annual costs would represent a 

larger percentage of the initial one-time costs for firms with Section 255 conformance 

obligations. For this preliminary analysis, we have assumed that these annually recurring 

costs average 20 percent of the one-time costs estimated for firms of the same size class.

These data and assumptions were used to develop the preliminary estimates of the costs that 

would be incurred by telecommunications equipment manufacturers to provide accessible 

electronic product documentation and Web-based support. These conformance costs were 

calculated as shown in Table 31.

Table 31: Estimated 2015–2024 Conformance Costs for Manufacturer Web Sites and Content

Cost Calculation Element 100 or More 

Employees*

20 to 99 

Employees* Total

Total number of firms 217 278 495

Average one-time repair cost per firm $125,000 $25,000 $68,838

Total one-time costs $27,125,000 $6,950,000 $34,075,000

Average annual per-firm maintenance cost** $25,000 $5,000 $13,768

Total annual maintenance costs $5,425,000 $1,390,000 $6,815,000

Total Web site accessibility costs, 2015–2024 $92,002,500

Present value of costs in 2015 (millions)*** $74.18

*Based on the number of NAICS 33421, 33422, and 334111 firms in these size classes, assuming that the largest 

firms in this sector are those with Section 255 obligations.

**Assumed to be 20 percent of one-time repair costs per firm annually.

***Assumes that half of firms in each size class incur one-time repair costs in 2015 and the remaining firms incur 

these costs in 2016. Annual maintenance costs begin in 2016 for Web sites made accessible in 2015 and in 2017 for 

Web sites made accessible in 2016. Present value of costs calculated using a discount rate of 7 percent.

The costs for manufacturers to comply with the proposed Section 255 guidelines relating to 

electronic product documentation and support are estimated at $17 million in 2015 and $92

million over the 10-year analysis period.

Telecommunications equipment manufacturers may incur additional costs to provide accessible 

support services, but the extent of these potential cost increases could not be quantified.

Information on the nature and extent of these costs is specifically requested in the comments.

9.4. Summary of Monetized and Unquantified Costs of the Proposed 

Rule

Finally, the costs estimated for in-house ICT (Section 9.1.6), procured ICT (Section 9.2), and 

telecommunications manufacturers (Section 9.3) were converted to an annualized basis using 
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discount rates of 7 percent and 3 percent. The annualized costs estimated for the proposed rule 

are summarized in Table 32.

Table 32: Annualized Compliance Costs for the Proposed Rule, 2015–2024 (Millions of 2015 

Dollars)

Monetized Cost Component 7-Percent 

Discount Rate

3-Percent 

Discount Rate

Annualized in-house ICT cost $80.6 $76.3 

Annualized cost for procured ICT $74.4 $70.5 

Annualized costs of telecommunications manufacturer 

product support Web site and content development $10.6 $9.8 

Annualized value of monetized costs $165.6 $156.6 

Collectively, the proposed revisions to the Section 508 standards and Section 255 guidelines 

have estimated compliance costs of $165.6 on an annualized basis over the 10-year analysis 

period using a 7-percent discount rate.

There are also several categories of costs that would result from adoption of the proposed rule 

that could not be quantified. These costs are listed in Table 33.

Table 33: Unquantified Costs of the Proposed Rule

Possible increase in Federal Government expenditures to provide accommodations if more people with 

addressable disabilities are hired.

Possible decrease in the amount or variety of electronic content produced to reduce Section 508 

compliance obligations.

Costs to develop and produce hardware and telecommunications products that comply with proposed 

standards.

Costs associated with implementing and supporting RTT on telecommunications devices with text 

display capabilities.

The impact on computer and telecommunications equipment manufacturers from the proposed 

rule is particularly difficult to quantify. Information on the impact of the proposed accessibility 

requirements was solicited in both the 2010 and 2011 ANPRMs and is again in the NPRM and 

this RIA. Absent this information, it is reasonable to expect that the costs incurred by U.S. and

foreign ICT manufacturers to product compliant products for sale in the U.S. market would be 

lower than the aggregate Section 508 compliance costs estimated for Federal agencies, 

contractors, and vendors.

It is possible that manufacturers of computer hardware and telecommunications equipment may 

elect to spread the costs of compliance with the proposed ICT standards and guidelines across all 

of their entire product lines. The potential impact on consumer prices can be assessed by 

assuming that these manufacturers would incur compliance costs equal to the entire amount 

estimated in this analysis for Federal agencies, contractors, and vendors (about $160 million on 

an annualized basis) with the aggregate value of annual shipments in this sector (about $100 

billion). Under this conservative assumption, the incremental compliance costs incurred by 
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computer and telecommunications equipment would be still less than 0.2 percent of the value of 

shipments.

9.5. Request for Comment on Cost Estimates for Proposed Rule

1. Would a large number of agency component offices need to revise policies, online 

resources, and training materials?

a. Does the current DOJ survey data on Section 508 offices and coordinators provide 

an adequate basis for projecting additional time required?

b. Would possibilities for policy/resource consolidation be created because of 

reference to external standards?

2. Would additional resources be required, or could the expenditures be funded from current 

Section 508 office/coordinator budgets?

a. Could the reference to external standards reduce the need to develop customized 

compliance advice and resources?

b. Would it be necessary to develop guidance to explain the differences between 

Section 508 and WCAG 2.0 to a large pool of employees (i.e., not just developers, 

programmers, and evaluators)?

3. Is the amount of Section 508 training currently provided to Government employees in 

different occupations adequate for them to comply?

a. DOJ report: Only Section 508 office/coordinator personnel receive more than 1 

hour of training per year.

b. Other sources recommend higher levels of training for programmers and graphic 

designers. With adequate training and online resources, can incremental costs of 

creating, editing, and maintaining various types of compliant electronic content 

(Web sites, documents, multimedia) be reduced or eliminated?

4. WCAG 2.0 standards are more measurable and testable than those of Section 508. Does 

this make evaluating compliance:

a. Take less time, because there is less subjective evaluation and review?

c. Take more time, because there are more provisions that need evaluation?

d. Less likely to be undertaken, because it would be easier for third parties to detect 

and report noncompliance?

e. More likely to be undertaken, because of the increased likelihood of the 

evaluation producing usable results?

5. Would the proposed requirements for electronic content result in agencies or contractors 

providing less electronic content than they would in the absence of the proposed 

requirements?

a. If so, please describe what types of electronic content agencies or contractors may 

choose to not provide due to this rule, and identify which requirement(s) have the 

greatest effect in terms of reducing electronic content.
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b. If this rule would result in less electronic content, are there any changes that could 

be made to the rule that would minimize the amount of lost content while not 

substantially reducing the amount of added accessibility?

6. Would telecommunications equipment manufacturers or other entities incur substantial 

costs to implement support for the proposed RTT standard on the following types of ICT?

a. End user devices.

b. Telephone network equipment.

c. Online video communication software and displays.

d. End user devices.

e. Telephone network equipment.

f. Online video communication software and displays.

7. Would manufacturers and service providers incur fixed or variable costs in addition to 

those identified by the FCC for implementing SMS-based text to 911 to comply with the 

proposed RTT requirements? If so, please indicate the scope and nature of these costs and 

quantify if possible.

8. Are there other categories of Federal employees likely to have responsibility for creating 

or repairing accessible electronic documents other than the occupational categories listed 

in Appendix D-3?

a. If so, what are these additional job categories?

b. What proportion of employees serving in these new categories would likely have 

responsibility for creation or remediation of accessible electronic documents?

c. What proportion of time would persons in each of these new job categories likely 

spend on creation or remediation of accessible electronic documents?

d. Are other data available to estimate the costs to create or repair accessible 

electronic documents by these Federal employees?

10. Conclusion

The preliminary regulatory evaluation indicates that there are substantial benefits and costs 

associated with the proposed update to the current ICT standards and guidelines. The benefits of 

this proposed rule that we were able to monetize are estimated at $69.1 million annually over the 

10-year analysis period using a 7-percent discount rate and $67.5 million annually using a 3-

percent discount rate. The costs of this proposed rule that we were able to monetize are estimated 

at $165.6 million annually over 10 years using a 7-percent discount rate and $156.6 million using 

a 3-percent discount rate.

It is important to note, however, that there are important benefits to people with disabilities, 

Federal agencies, contractors, and vendors for which adequate data were not available to develop 

monetized estimates. In addition, the benefits of the proposed rule include important, but 

inherently unquantifiable, national values that are explicitly recognized in Executive Order 

13563, including greater social equity, human dignity, and fairness. There are also potentially 

significant costs that could not be quantified with the available information.
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The Access Board and Econometrica have made a preliminary determination that the costs of the 

proposed update of the Section 508 standards and Section 255 guidelines are justified by the

benefits.
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Appendix A: ICT Accessibility Standards

W3C finalized the WCAG 1.0 recommendations in May 1999. Shortly thereafter, the Access 

Board published the current Section 508 standards, which include accessibility requirements for 

Web sites and other forms of ICT. The W3C standards were updated when the WCAG 2.0 

recommendations were published in December 2008. This appendix provides additional 

information on the evolution of these standards and the areas in which they differ from one 

another. Additional information is provided on the proposed requirements for software, 

hardware, and telecommunications equipment, including references to applicable current Federal 

and consensus standards.

WCAG 1.0 Recommendations

WCAG 1.0 has three priority levels (1 through 3) that correspond to the A, AA, and AAA levels 

in WCAG 2.0. A substantial portion of the current Section 508 standards for Web sites, and in 

many instances other forms of ICT, was adopted from the WCAG 1.0 recommendations. A 

Section 508-compliant Web site could require additional remediation in a few areas (including 

audio description, dynamic updating of text equivalents, and use of clear language) to meet the 

WCAG 1.0 Priority 1 recommendations. 

Evolution of Current Section 508 Part 22 Standards From WCAG 1.0 Standards

Five provisions in Part 22 of the Section 508 standards do not have close analogs to WCAG 1.0 

Priority 1 checkpoints, but they were incorporated in the development of WCAG 2.0. Some 

Section 508 requirements are similar but not identical to the analogous provisions in WCAG 1.0 

(scripting, applets/plug-ins, forms), and others (flicker, navigation bypass) are more specific than 

their WCAG 1.0 counterparts. Only one Section 508 requirement (the need to provide users with 

adequate time to respond when a timed response is required) was not addressed at all in the 

WCAG 1.0 Priority 1 recommendations.155

Evolution of WCAG 2.0 Success Criteria From Current Section 508 Part 22 Standards

New technologies, techniques, and accessibility issues have emerged since the current Section 

508 standards were published. The NPRM explains the evolution of WCAG 2.0 from the current 

Section 508 standards:

WCAG 2.0 standardizes best practices that were developed in response to 

requirements of the current 508 Standards.... Where a WCAG 2.0 success 

criterion is new and does not correspond to a current 508 provision, it addresses 

what has come to be regarded by the WCAG developers as a deficiency in the 

current 508 Standards. In most cases, agencies with 508 testing processes have 

adapted their procedures to address these accessibility concerns.

The NPRM identifies new requirements in WCAG 2.0 that address specific gaps in the current 

Section 508 standards, including a requirement for a logical reading order, the ability to resize 

text, the ability to turn off background audio that might interfere with comprehension, and 

compatibility with screen reading software.

 

155 JimThatcher.com provides a provision-by-provision comparison and discussion of the Section 508 and WCAG 

1.0 Priority 1 provisions in “Side by Side WCAG vs. 508.”
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One important aspect of the WCAG 2.0 standards is that they are generally more testable than 

those in Section 508 or WCAG 1.0 because WCAG 2.0 establishes a set of success criteria for 

defining conformance to the WCAG 2.0 standards. WCAG 2.0 success criteria are written as 

testable statements that are not technology specific. Consequently, Federal employees, 

contractors, and vendors would be able to conduct more specific testing and evaluation of the 

products, services, and content they create or modify than is the case under the current standards.

A.1. WCAG 2.0 Level A and Level AA Success Criteria

WCAG 2.0 Level A success criteria provide a minimal level of accessibility without necessarily 

requiring any changes in the underlying design of the ICT. Implementing the Level AA success 

criteria may require changes in design or programming but will afford more complete 

accessibility to users with various types of disabilities. Table A-1 lists WCAG 2.0 Level A and 

Level AA success criteria and describes what is required to ensure that each criterion is satisfied 

in the context of an HTML-coded Web site.

Table A-1: WCAG 2.0 Level A and Level AA Success Criteria 

Guideline Heading Level 508 

Reference Description

1.1.1 Non-Text 

Content

A 1194.22(a) All images, form image buttons, and image map 

hot spots have appropriate, equivalent 

alternative text. Embedded multimedia is 

identified via accessible text.

1.2.1 Prerecorded 

Audio-Only and 

Video-Only

A 1194.22(a) A descriptive text transcript is provided for nonlive, Web-based audio. A text or audio 

description is provided for non-live, Web-based 

video-only.

1.2.2 Captions 

(Prerecorded)

A 1194.22(b) 

and .24(c)

Synchronized captions are provided for non-live, 

Web-based video (YouTube videos, etc.).

1.2.3 Audio 

Description or 

Media 

Alternative 

(Prerecorded)

A 1194.22(b) 

and .24(d)

A descriptive text transcript OR audio description 

audio track is provided for non-live, Web-based 

video.

1.2.4 Captions (Live) AA 1194.22(b) 

and .24(c)

Synchronized captions are provided for all live 

multimedia that contains audio (audio-only 

broadcasts, webcasts, video conferences, Flash 

animations, etc.).

1.2.5 Audio 

Description 

(Prerecorded)

AA 1194.22(b) 

and .24(d)

Audio descriptions are provided for all video 

content. NOTE: Only required if the video 

conveys content visually that is not available in 

the default audio track.

1.3.1 Information and 

Relationships

A 1194.22(e) 

through (h)

Semantic markup is used to designate headings, 

lists, and emphasized or special text. Tables are 

used for tabular data. Where necessary, data 

cells are associated with their headers. Table 

captions and summaries are used where 

appropriate.

1.3.2 Meaningful 

Sequence

A New The reading and navigation order (determined by 

code order) is logical and intuitive.
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Guideline Heading Level 508 

Reference Description

1.3.3 Sensory 

Characteristics

A New Instructions do not rely on shape, size, or visual 

location (e.g., “Click the square icon to continue”

or “Instructions are in the right-hand column”).

1.4.1 Use of Color A 1194.22(c) 

and .21(i)

Color is not used as the sole method of 

conveying content or distinguishing visual 

elements.

1.4.2 Audio Control A New A mechanism is provided to stop, pause, mute, 

or adjust volume for audio that automatically 

plays on a page for more than 3 seconds.

1.4.3 Contrast 

(Minimum)

AA New Text and images of text have a contrast ratio of 

at least 4.5:1. Large text (over 18 point or 14 

point bold) has a contrast ratio of at least 3:1.

1.4.4 Resize Text AA New The page is readable and functional when the 

text size is doubled.

1.4.5 Images of Text AA 1194.21(f) If the same visual presentation can be made 

using text alone, an image is not used to present 

that text.

2.1.1 Keyboard A 1194.21(a) All page functionality is available using the 

keyboard, unless the functionality cannot be 

accomplished in any known way using a 

keyboard.

2.1.2 No Keyboard 

Trap

A New Keyboard focus is never locked or trapped at one 

particular page element. The user can navigate 

to and from all navigable page elements using 

only a keyboard. Page-specified shortcut keys do 

not conflict with existing browser and screen 

reader shortcuts.

2.2.1 Timing 

Adjustable

A 1194.22(p) If a page or application has a time limit, the user 

is given options to turn off, adjust, or extend that 

time limit. This is not a requirement for real-time 

events (e.g., an auction), where the time limit is 

absolutely required, or if the time limit is longer 

than 20 hours.

2.2.2 Pause, Stop, 

Hide

A 1194.21(h) Automatically moving, blinking, or scrolling 

content that lasts longer than 5 seconds can be 

paused, stopped, or hidden by the user. 

Automatically updating content can be paused, 

stopped, or hidden by the user, or the user can 

manually control the timing of the updates.

2.3.1 Three Flashes 

or Below 

Threshold

A 1194.21(k)

and .22(j)

No page content flashes more than three times 

per second unless that flashing content is 

sufficiently small and the flashes are of low 

contrast and do not contain too much red. (See 

general flash and red flash thresholds.)

2.4.1 Bypass Blocks A 1194.22(o) A link is provided to skip navigation and other 

page elements that are repeated across Web 

pages.

2.4.2 Page Title A 1194.22(i) The Web page has a descriptive and informative 

page title.

2.4.3 Focus Order A New The navigation order of links, form elements, 

etc., is logical and intuitive.
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Guideline Heading Level 508 

Reference Description

2.4.4 Link Purpose 

(In Context)

A New The purpose of each link (or form image button 

or image map hot spot) can be determined from 

the link text alone or from the link text and its 

context (e.g., surrounding paragraph, list item, 

table cell, or table headers).

2.4.5 Multiple Ways AA New Multiple ways are available to find other Web 

pages on the site—at least two of a list of related 

pages, table of contents, site map, site search, or 

list of all available Web pages.

2.4.6 Headings and 

Labels

AA New Page headings and labels for form and 

interactive controls are informative. Avoid 

duplicating heading (e.g., “More Details”) or label 

text (e.g., “First Name”) unless the structure 

provides adequate differentiation between them.

2.4.7 Focus Visible AA 1194.21(c) It is visually apparent which page element has 

the current keyboard focus (i.e., as you tab 

through the page, you can see where you are).

3.1.1 Language of 

Page

A New The language of the page is identified using the 

HTML lang attribute.

3.1.2 Language of 

Parts

AA New The language of page content that is in a 

different language is identified.

3.2.1 On Focus A 1194.21(l) 

and .22(n)

When a page element receives focus, it does not 

result in a substantial change to the page, the 

spawning of a pop-up window, an additional 

change of keyboard focus, or any other change 

that could confuse or disorient the user.

3.2.2 On Input A 1194.21(l) 

and .22(n)

When a user inputs information or interacts with 

a control, it does not result in a substantial 

change to the page, the spawning of a pop-up 

window, an additional change of keyboard focus, 

or any other change that could confuse or 

disorient the user unless the user is informed of 

the change ahead of time.

3.2.3 Consistent 

Navigation

AA New Navigation links that are repeated on Web pages 

do not change order when navigating through the 

site.

3.2.4 Consistent

Identification

AA 1194.22(e) Elements that have the same functionality across 

multiple Web pages are consistently identified. 

For example, a search box at the top of the site 

should always be labeled the same way.

3.3.1 Error 

Identification

A 1194.21(l) 

and .22(n)

Required form elements or form elements that 

require a specific format, value, or length provide 

this information within the element’s label or 

within the element’s title attribute. If utilized, form 

validation errors are presented in an efficient, 

intuitive, and accessible manner.

3.3.2 Labels or 

Instructions

A 1194.21(l) 

and .22(n)

Sufficient labels, cues, and instructions for 

required interactive elements are provided via 

instructions, examples, properly positioned form 

labels, and/or fieldsets/legends.
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Guideline Heading Level 508 

Reference Description

3.3.3 Error 

Suggestion

AA New If an input error is detected (via client-side or 

server-side validation), provide suggestions for 

fixing the input in a timely and accessible 

manner.

3.3.4 Error 

Prevention 

(Legal, 

Financial, 

Data)

AA New If the user can change or delete legal, financial, 

or test data, the changes/deletions can be 

reversed, verified, or confirmed.

4.1.1 Parsing A New Significant HTML/XHTML validation/parsing 

errors are avoided.

4.1.2 Name, Role, 

Value

A 1194.21(d) Markup is used in a way that facilitates 

accessibility. This includes following the 

HTML/XHTML specifications and using forms, 

form labels, frame titles, etc., appropriately.

Source: Adapted from WebAIM.org WCAG 2.0 checklist for HTML documents. Section 508 references are from 

Access Board staff standards comparison table referenced in the NPRM.

A.1.2. Application of WCAG 2.0 Success Criteria to Non-Web ICT

The WCAG2ICT Task Force evaluated how each WCAG 2.0 success criterion would apply in 

the context of certain types of non-Web ICT and developed guidance to assist developers in 

applying the WCAG 2.0 recommendations to ensure the accessibility of non-Web documents 

and software. The task force found that the majority of success criteria from WCAG 2.0 can 

apply to non-Web documents and software with no or only minimal changes: 156

 Of the 38 Level A and Level AA success criteria, 26 did not include any Web-related 

terms and apply directly as written and as described in the “Intent” sections from the 

updated “Understanding WCAG 2.0.”

 Of the remaining 12 success criteria, the task force found that 8 of them apply as written 

when replacing certain Web-specific terms or phrases such as “Web page(s)” with nonWeb terms or phrases such as “non-Web document(s) and software” or “for non-Web 

documents and software that use markup languages, in such a way that...,” etc. 

 The remaining four success criteria apply in situations when “a set of Web pages” or 

“multiple Web pages” share some characteristic or behavior. For these, the task force 

found that (with substitutions) the success criteria apply to non-Web documents fairly 

straightforwardly. However, no guidance has been developed to assist in applying these 

four standards to non-Web software.

The proposed requirements for one specific type of electronic documents—those stored in

PDF—would be established by referencing the applicable ISO standard. PDF/UA-1 provides a 

 

156 W3C, “Guidance on Applying WCAG 2.0 to Non-Web Information and Communications Technologies,”

Working Draft, December 13, 2012. The task force noted that this guidance was required because, “while WCAG 

2.0 was designed to be technology neutral, it assumes the presence of a ‘user agent’ such as a browser, media player, 

or assistive technology as a means to access Web content. Therefore, the application of WCAG 2.0 to documents 

and software in non-Web contexts required some interpretation in order to determine how the intent of each WCAG 

2.0 success criterion could be met in these different contexts of use.”
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technical, interoperable standard for the authoring, remediation, and validation of PDF 

content.157

A.2. Additional Proposed Requirements for Software and Applications

The proposed rule includes three sets of additional specific requirements for certain types of 

software and applications: interoperability with assistive technology, non-Web software 

applications, and authoring tools.158 As Table A-2 shows, many of these requirements are based 

on WCAG 2.0 success criteria.

Table A-2: Proposed Requirements for Software

Proposed 

Reference Heading 508 Reference

WCAG 2.0 

Reference Requirement Stated in Reference

CHAPTER 5: SOFTWARE

502 Interoperability with Assistive Technology

502.2 Documented 

Accessibility 

Features

1194.21(b) None Applications shall not disrupt or disable activated 

features of other products or operating systems 

that are identified as accessibility features, where 

those features are developed and documented 

according to industry standards.

502.3 Accessibility 

Services 

New

(current 

practice)

None Platforms (such as operating systems) would be 

required to provide a documented set of 

accessibility services, usually referred to as 

Application Programming Interfaces (APIs).

502.3.1 Object 

Information

Expanded 

from 

1194.21(d) 

(current 

practice)

4.1.2 For all user interface components, the name and 

role can be programmatically determined; states, 

properties, and values that can be set by the user 

can be programmatically set; and notification of 

changes to these items is available to user 

agents, including assistive technologies.

502.3.2 Row, Column, 

and Headers

1194.22(g) 

and (h)

1.3.1 Row and column headers shall be identified for 

data tables. Markup shall be used to associate 

data cells and header cells for data tables that 

have two or more logical levels of row or column 

headers.

502.3.3 Values 1194.21(d) 

(current 

practice)

4.1.2 For all user interface components, the name and 

role can be programmatically determined; states, 

properties, and values that can be set by the user 

can be programmatically set; and notification of 

changes to these items is available to user 

agents, including assistive technologies.

502.3.4 Label 

Relationships

1194.21(l) 

and .22(n)

1.3.1 Row and column headers shall be identified for 

data tables. Markup shall be used to associate 

data cells and header cells for data tables that 

have two or more logical levels of row or column 

headers.

 

157 ISO 14289-1 (2012), Document Management Applications—Electronic Document File Format Enhancement for 

Accessibility—Part 1: Use of ISO 32000-1 (PDF/UA-1).

158 Web applications that conform to all Level A and Level AA Success Criteria and all Conformance Requirements 

in WCAG 2.0 would not be required to conform to the provisions that address interoperability with AT and 

requirements for applications.
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Proposed 

Reference Heading 508 Reference

WCAG 2.0 

Reference Requirement Stated in Reference

502.3.5 Hierarchical 

Relationships

1194.21(l) 

and .22(n)

1.3.1, 3.3.1, 

3.3.2

When electronic forms are used, the form shall 

allow people using assistive technology to access 

the information, field elements, and functionality 

required for completion and submission of the 

form, including all directions and cues.

502.3.6 Text 1194.21(f) 1.4.5 Textual information shall be provided through 

operating system functions for displaying text. 

The minimum information that shall be made 

available is text content, text input caret location, 

and text attributes.

502.3.7 Actions New

(current 

practice)

None A list of all actions that can be executed on a 

programmatic object would have to be 

programmatically determinable and that software 

allows assistive technology to programmatically 

execute available actions on objects.

502.3.8 Focus Cursor 1194.21(c) 2.4.7 A well-defined onscreen indication of the current 

focus shall be provided that moves among 

interactive interface elements as the input focus 

changes. The focus shall be programmatically 

exposed so that assistive technology can track 

focus and focus changes.

502.3.9 Event 

Notification

1194.21(d)

(current 

practice)

None Programmatic notification of events relevant to 

user interactions, including but not limited to 

changes in the component’s state, value, name, 

description, or boundary, would need to be 

available to assistive technologies.

502.4 Platform 

Accessibility 

Features

ANSI/ HFES 

200

None Specifies requirements for core accessibility 

features available in platforms (harmonized with 

accepted industry practices).

503 Applications

503.2 User 

Preferences

1194.21(g) New Applications shall not override user-selected 

contrast and color selections and other individual 

display attributes.

503.3 Alternative 

User Interfaces

New New Software that functions as assistive technology 

would be required to use platform accessibility 

services. 

503.4 User Controls 

for Captions 

and Audio 

Description

New New Controls for captions and audio description would 

be required and would have to be provided at the 

same menu level as those used for volume 

control or channel selection. 

504 Authoring Tools

504.2 Content 

Creation or 

Editing

New ATAG 2.0 

(expected)*

Authoring tools would be required to include at 

least one mode of operation to create or edit 

content that would conform to WCAG 2.0 

Success Criteria for features and formats 

supported by the authoring tool. 

504.2.1 Preservation of 

Information 

Provided for 

Accessibility in 

Format 

Conversion

1194.23(j) ATAG 2.0 

(expected)*

When converting one format to another, authoring 

tools would be required to preserve the 

information required for accessibility to the extent 

that it is supported by the destination format.
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Proposed 

Reference Heading 508 Reference

WCAG 2.0 

Reference Requirement Stated in Reference

504.3 Prompts New ATAG 2.0 

(expected)*

Authoring tools would be required to include a 

feature to provide prompts that proactively 

support the creation of accessible content.

504.4 Templates New ATAG 2.0 

(expected)*

Where templates are provided, authoring tools 

would be required to provide a range of templates 

that facilitate accessible content creation.

*W3C, ATAG, version 2.0, currently in draft form.159

Source: Econometrica, Inc., compilation from NPRM section-by-section analysis.

A.3. Proposed Requirements for Hardware and Telecommunications 

Equipment

The application of WCAG 2.0 to computers, copiers, scanners, telecommunications equipment,

and other types of ICT hardware is not as straightforward. The proposed standards for hardware 

and telecommunications equipment includes several requirements from the ADA and 

Architectural Barriers Act Accessibility Guidelines (36 CFR Part 1191, Appendix D, Section 

707), as well as requirements recommended by the TEITAC for ICT that provides two-way

voice communication. A summary of the proposed requirements for hardware and 

telecommunication equipment is provided in Table A-3.

 

159 W3C ATAG version 1.0 was approved in February 2000. ATAG 2.0 is being developed to be compatible with 

WCAG 2.0. The W3C WAI anticipates ATAG 2.0 will be completed in 2014.
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Table A-3: Proposed Requirements for Hardware and Telecommunications Equipment 

Proposed 

Reference Heading 508 Reference

255 

Reference

707 

Reference

Requirement 

Stated in Reference

CHAPTER 4: HARDWARE

402 Closed Functionality

402.1 General 1194.25(a) *Excepted Products with closed 

functionality shall be 

usable by people 

with disabilities 

without requiring an 

end user to attach 

assistive technology 

to the product. 

Personal headsets 

for private listening 

are not assistive 

technology.

402.2 Speech Output

Enabled

New *Excepted 707.5 Machines shall be 

speech enabled. 

Operating 

instructions and 

orientation, visible 

transaction prompts, 

user input 

verification, error 

messages, and all 

displayed 

information for full 

use shall be 

accessible to and 

independently 

usable by individuals 

with vision 

impairments. 

Speech shall be 

delivered through a 

mechanism that is 

readily available to 

all users. Speech 

shall be recorded or 

digitized human or 

synthesized.

402.2.1 User Control 1194.25(e) *Excepted 707.5.1 Speech shall be 

capable of being 

repeated or 

interrupted. 

402.2.2 Braille 

Instructions

New *Excepted 707.8 Braille instructions 

for initiating the 

speech mode shall 

be provided. 
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Proposed 

Reference Heading 508 Reference

255 

Reference

707 

Reference

Requirement 

Stated in Reference

402.3.1 Private 

Listening

1194.25(e) *Excepted When products 

provide auditory 

output, the audio 

signal shall be 

provided at a 

standard signal level 

through an industry 

standard connector 

that will allow for 

private listening. The 

product must provide 

the ability to 

interrupt, pause, and 

restart the audio at 

any time.

402.3.2 Non-Private 

Listening

1194.25(f) 

and .23(g)

*Excepted When products 

provide non-private 

listening, 

incremental volume 

control shall be 

provided with output 

amplification up to a 

level of at least 65 

dB. Where the 

ambient noise level 

of the environment is 

above 45 dB, a 

volume gain of at 

least 20 dB above 

the ambient level 

shall be user 

selectable. A 

function shall be 

provided to 

automatically reset 

the volume to the 

default level after 

every use.
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Proposed 

Reference Heading 508 Reference

255 

Reference

707 

Reference

Requirement 

Stated in Reference

402.4 Characters New *Excepted 707.7.2 Characters 

displayed on the 

screen shall be in a 

sans serif font. 

Characters shall be 

3/16-inch (4.8 mm) 

high minimum based 

on the uppercase 

letter “I.” Characters 

shall contrast with 

their background 

with either light 

characters on a dark 

background or dark 

characters on a light 

background.

403 Biometrics

403.1 General 1194.25(d) 

and .26(c)

New When biometric 

forms of user 

identification or 

control are used, an 

alternative form of 

identification or 

activation, which 

does not require the 

user to possess 

particular biological 

characteristics, shall 

also be provided.
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Proposed 

Reference Heading 508 Reference

255 

Reference

707 

Reference

Requirement 

Stated in Reference

404 Preservation of Information Provided for Accessibility

404.1 General 1194.23(j) 1193.37 Products that 

transmit or conduct 

information or 

communication shall 

pass through crossmanufacturer, nonproprietary, industrystandard codes, 

translation protocols, 

formats, or other 

information 

necessary to provide 

the information or 

communication in a 

usable format. 

Technologies that

use encoding, signal 

compression, format 

transformation, or 

similar techniques 

shall not remove 

information needed 

for access or shall 

restore it upon 

delivery.

405 Flashing

405.1 General 1194.25(i) 1193.43(f) Products shall be 

designed to avoid 

causing the screen 

to flicker with a 

frequency greater 

than 2 Hz and lower 

than 55 Hz.

406 Standard Connections

406.1 General 1194.26(d) 1193.51(a) Where provided, at 

least one of each 

type of expansion 

slots, ports, and 

connectors shall 

comply with publicly 

available industry 

standards.

407 Operable Parts

407.1 General Not stated 1193.41(a), 

(f)

707.3 Unless a clear or 

correct key is 

provided, each 

operable part shall 

be able to be 

differentiated by 

sound or touch, 

without activation.
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Proposed 

Reference Heading 508 Reference

255 

Reference

707 

Reference

Requirement 

Stated in Reference

407.2 Contrast New New 707.6.3.1 Function keys shall 

contrast visually 

from background 

surfaces. Characters 

and symbols on key 

surfaces shall 

contrast visually 

from key surfaces. 

Visual contrast shall 

be either light on

dark or dark on light.

407.3.1 Tactilely 

Discernible and

Identification

1194.23(k)(1) New 707.6.1 At least one tactilely 

discernible input 

control shall be 

provided for each 

function. Input 

controls shall be 

tactilely discernible 

without activation 

and operable by 

touch. Where 

provided, key 

surfaces outside 

active areas of 

display screens shall 

be raised above 

surrounding 

surfaces.

407.3.2 Alphabetic 

Keys

New (industry 

standard)

New (industry 

standard)

Alphabetic keys shall 

be arranged in a 

QWERTY keyboard 

layout. The “F” and 

“J” keys shall be 

tactilely distinct from 

the other keys.

407.3.3 Numeric Keys New (industry 

standard)

New (industry 

standard)

707.6.2 Numeric keys shall 

be arranged in a 12-

key ascending or 

descending 

telephone keypad 

layout. The number 

five key shall be 

tactilely distinct from 

the other keys.

407.4 Key Repeat 1194.23(k)(3) New If key repeat is 

supported, the delay 

before repeat shall 

be adjustable to at 

least 2 seconds. Key 

repeat rate shall be 

adjustable to 2 

seconds per 

character.
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Proposed 

Reference Heading 508 Reference

255 

Reference

707 

Reference

Requirement 

Stated in Reference

407.5 Timed 

Response

1194.25(b) 

and .23(d)

1193.41(g) When a timed 

response is required, 

the user shall be 

alerted and given 

sufficient time to 

indicate more time is 

required.

407.6 Status 

Indicators

1194.23(k)(4) New The status of all 

locking or toggle 

controls or keys shall 

be visually 

discernible and 

discernible either 

through touch or 

sound.

407.7 Color 1194.25(g) 1193.41(c) Color coding shall 

not be used as the 

only means of 

conveying 

information, 

indicating an action, 

prompting a 

response, or 

distinguishing a 

visual element.

407.8 Audio Signaling New New Audio signaling 

cannot be the only 

means of conveying 

information, 

indicating an action, 

or prompting a 

response.

407.9 Operation 1194.23(k)(2) 1193.41(e) 

and .41(f)

707.3 Controls and keys 

shall be operable 

with one hand and 

shall not require tight 

grasping, pinching, 

or twisting of the 

wrist. The force 

required to activate 

controls and keys 

shall be 5 lbs. (22.2 

N) maximum.

407.10 Privacy New New 707.4 Machines shall 

provide the 

opportunity for the 

same degree of 

privacy of input and 

output available to 

all individuals.
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Proposed 

Reference Heading 508 Reference

255 

Reference

707 

Reference

Requirement 

Stated in Reference

407.11 Keys, Tickets, 

and Fare Cards

New *Excepted 707.1-A If fare cards have 

one tactually 

distinctive corner,

they can be inserted 

with greater 

accuracy. Token 

collection devices 

that are designed to 

accommodate 

tokens that are 

perforated can allow 

a person to 

distinguish more 

readily between 

tokens and coins.

407.12 Reach Height 1194.25(j)(1)–

(j)(4) (partial)

*Excepted At least one of each 

type of operable part 

of stationary ICT 

must be accessible 

by side or forward 

reaches, relative to a 

specified vertical 

reference plane.

408 Display Screens

408 General New *Excepted 707.7.1 The display screen 

shall be visible from 

a point located 40 

inches (1015 mm) 

above the center of 

the clear floor space 

in front of the 

machine.

409 Transactional Outputs

409 General New *Excepted 707.5.2 Where transactional 

outputs are provided

by ICT with speech 

output, speech 

output shall audibly 

provide information 

necessary to 

complete or verify 

the transaction.
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Proposed 

Reference Heading 508 Reference

255 

Reference

707 

Reference

Requirement 

Stated in Reference

410 ICT With Two-Way Voice Communication

410.2 Volume Gain 1194.23(f) 1193.43(e) Volume gain shall be 

provided and would 

also require the 

volume control to 

conform to the 

requirements of 47 

CFR 68.317,

“Hearing Aid 

Compatibility 

Volume Control: 

Technical 

Standards.”

410.3 Magnetic 

Coupling

1194.23(h) 1193.43(i) Where ICT delivers 

output by an audio 

transducer that is 

typically held up to 

the ear, ICT shall 

provide a means for 

effective magnetic 

wireless coupling to 

hearing 

technologies.

410.4 Minimize 

Interference

1194.23(i) 1193.43(h) Interference with 

hearing technologies 

(including hearing 

aids, cochlear 

implants, and 

assistive listening 

devices) shall be 

reduced to the 

lowest possible 

level. 

410.5 Digitally 

Encoded 

Speech

New (industry 

standard)

New (industry 

standard)

ICT shall transmit 

and receive speech 

that is digitally 

encoded in the 

manner specified by 

ITU-T 

Recommendation 

G.722 for encoding 

and storing audio 

information.

410.6 Real-Time Text

Functionality

New New Wherever ICT 

provides real-time 

voice 

communication, ICT 

shall also support 

real-time text 

functionality. 
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Proposed 

Reference Heading 508 Reference

255 

Reference

707 

Reference

Requirement 

Stated in Reference

410.7 Caller ID 1194.23(e) New Where provided, 

caller identification 

and similar 

telecommunications 

functions shall be 

available in text or 

audio form. 

410.8 Video 

Communication

New New Where ICT provides 

two-way voice 

communication that 

includes real-time 

video functionality, 

the quality of the 

video shall be 

sufficient to support 

communication 

using sign language. 

411 Closed Caption Processing Technologies

411 General 1194.24(a) 1193.37 Where players and 

displays process 

video with 

synchronized audio, 

they must decode 

closed-caption data 

and display captions. 

Where players and 

ancillary equipment 

process video with 

synchronized audio, 

cabling would be 

required to passthrough caption 

data.

412 Audio Description Processing Technology

412 General 1194.24(b) New Where ICT displays 

or processes video 

with synchronized 

audio, ICT shall 

provide a mode of 

operation that plays 

associated audio 

description. 

413 User Controls for Captions and Audio Description

413.1.1 Caption 

Controls

New *Excepted User controls for 

captioning shall be 

comparable in 

prominence to the 

location of user 

controls for volume 

where ICT displays 

video with 

synchronized audio.
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Proposed 

Reference Heading 508 Reference

255 

Reference

707 

Reference

Requirement 

Stated in Reference

413.1.2 Audio 

Description 

Controls

New *Excepted User controls for the 

selection of audio 

description shall be 

comparable in 

prominence to the 

location of user 

controls for program 

selection.

*ICT components covered under Sec. C201.1 would not have to comply with this proposed requirement.

Source: Econometrica, Inc., compilation from NPRM section-by-section analysis.

A.4. Proposed Requirements for Support Documentation and Services

Finally, the Access Board is proposing to revise and expand the current accessibility 

requirements for ICT support documentation and services. These provisions are listed in Table 

A-4.

Table A-4: Proposed Accessibility Requirements for Support Documentation and Services

Proposed 

Reference Heading 508 Reference

255 

Reference Requirement Stated in Reference

CHAPTER 6: SUPPORT DOCUMENTATION AND SERVICES

602 Support Documentation

602.2 Accessibility and 

Compatibility 

Features

1194.41(b) 1193.33 Documentation would be required to 

list and explain how to use the 

compatibility features of ICT that 

support the technical requirements of 

this document. Documentation would 

be required to include information on 

accessibility features that are built in to 

ICT and ICT accessibility features that 

provide compatibility with assistive 

technology. 

602.3 Electronic Support 

Documentation

New New Documentation in electronic format, 

including Web-based self-service 

support, would be required to conform 

to all Level A and Level AA Success 

Criteria and all Conformance 

Requirements in WCAG 2.0 or to ISO 

14289-1 (PDF/UA-1). 

602.4 Alternative 

Formats for NonElectronic Support 

Documentation

1194.41(a) 1193.33(a)(2) Documentation that is not in electronic 

format would have to be provided in 

alternate formats usable by individuals 

who are blind or have low vision, upon 

request. 

603 Support Services

603.2 Information on 

Accessibility and 

Communication 

Features

New 1193.33(a)(3) ICT support services would be 

required to include information on ICT 

accessibility and compatibility features 

of ICT.
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Proposed 

Reference Heading 508 Reference

255 

Reference Requirement Stated in Reference

603.3 Accommodation of 

Communication 

Needs

1194.41(c) 1193.33 ICT support services would be 

required to accommodate the 

communication needs of individuals 

with disabilities. When support 

services provide documentation, the 

documentation provided is required to 

be accessible.

Source: Econometrica, Inc., compilation from NPRM section-by-section analysis.

A.5. Mapping of Proposed Rule Provisions to People With Specific 

Types of Disabilities

Table A-5 identifies the specific provisions in the proposed Rule that would benefit people with 

the following specific types of disabilities:

 Blind: Person with significant vision impairment who prefers to use a non-visual 

interface.

 LV (low vision): Person with significant vision impairment, but who prefers to use a 

visual interface when available.

 Deaf: Person who prefers to use a non-auditory interface.

 HoH (Hard of Hearing): Person with a significant hearing impairment, but who prefers to 

use an auditory interface when available.

 Motor: Person with limited manual dexterity, reach range (including someone using a 

wheelchair), or strength.

 Speech: Person limited on their ability to speak clearly.

 CLL (Cognitive, Language, and learning): Person with limited ability to process, 

understand, or comprehend information.

 Photo (Photosensitivity): Person who is susceptible to visually induced seizures.

Table A-5: Proposed Rule Provisions Benefitting People With Specific Types of Disabilities

Provision Number and Title Blind LV Deaf HoH Motor Speech CLL Photo

301 General, 302 Functional 

Performance Criteria X X X X X X

302.1 Without Vision X

302.2 With Limited Vision X

302.3 Without Perception of Color X

302.4 Without Hearing X

302.5 With Limited Hearing X

302.6 Without Speech X

302.7 With Limited Manipulation X

302.8 With Limited Reach and 

Strength X
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Provision Number and Title Blind LV Deaf HoH Motor Speech CLL Photo

402 Closed Functionality, 402.1 

General, 402.2 Speech-Output 

Enabled

X X X

402.2.1 User Control X X X

402.2.2 Braille Instructions X

402.3 Volume X

402.3.1 Private Listening X X

402.3.2 Non-Private Listening X X

402.4 Characters X

403 Biometrics, 403.1 General X X X

404 Preservation of Information 

Provided for Accessibility, 404.1 

General

X X X X X

405 Flashing, 405.1 General X

406 Standard Connections, 406.1 

General X X X

407 Operable Parts, 407.1 General X X X X X X

407.2 Contrast X

407.3 Tactilely Discernible (and subprovisions) X

407.4 Key Repeat X

407.5 Timed Response X X X X

407.6 Status Indicators X

407.7 Color X X

407.8 Audio Signaling X X

407.9 Operation X

407.10 Privacy X X

407.11 Keys, Tickets, and Fare Cards X

407.12 Reach Height (and subprovisions) X

408 Display Screens, 408.1 General X

409 Transactional Outputs, 409.1 

General X

410 ICT With Two-Way Voice 

Communication, 410.1 General X X X X

410.2 Volume Gain X

410.3 Magnetic Coupling X

410.4 Minimize Interference (includes 

sub-provisions) X

410.5 Digitally Encoded Speech X

410.6 Real-Time Text Functionality 

(includes sub-provisions) X X X

410.7 Caller ID X X X X

410.8 Video Communication X
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Provision Number and Title Blind LV Deaf HoH Motor Speech CLL Photo

411 Caption Processing 

Technologies, 411.1 General 

(includes sub-provisions)

X X

412 Audio Description Processing 

Technology, 412.1 General (includes 

sub-provisions)

X

413 User Controls for Captions and 

Audio Description, 413.1 General 

(includes sub-provisions)

X X X

502 Interoperability With Assistive 

Technology, 502.1 General X X X X X X

502.2 Documented Accessibility 

Features (includes sub-provisions) X X X X

502.3 Accessibility Services (includes 

sub-provisions) X X

502.4 Platform Accessibility Features X X X X X X

Section 9.3.3 Enable sequential entry 

of multiple (chorded) keystrokes X

Section 9.3.4 Provide adjustment of 

delay before key acceptance X

Section 9.3.5 Provide adjustment of 

same-key double-strike acceptance X

Section 10.6.7 Allow users to choose 

visual alternative for audio output X X

Section 10.6.8 Synchronize audio 

equivalents for visual events X X X

Section 10.6.9 Provide speech output 

services X X X X

Section 10.7.1 Display any captions 

provided X X

503 Applications, 503.1 General X X X X X

503.2 User Preferences X

503.3 Alternative User Interfaces X X

503.4 User Controls for Captions and 

Audio Description (includes subprovisions)X X X

504 Authoring Tools, 504.1 General X X X X

504.2 Content Creation or Editing X X X X

504.2.1 Preservation of Information 

Provided for Accessibility in Format 

Conversion

X X X

504.3 Prompts X X X X

504.4 Templates X X X X

Source: U.S. Access Board.
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Appendix B: Data on People With Disabilities

This section provides information on people with disabilities who could potentially benefit from 

the proposed update of the current Section 508 standards and Section 255 guidelines.

B.1. Extent and Severity of Disabilities in the U.S. Population

Information on the extent and severity of disabilities in the U.S. population is available from a 

variety of Government data sources. The most recent SIPP provides estimates of the proportion 

of the U.S. civilian noninstitutional population in selected age groups who have hearing, vision, 

or ambulatory disabilities. Additional questions provide data on use of hearing aids and 

wheelchairs.

160 These data can be used to develop estimates of the numbers of people with 

disabilities that could be addressed by ICT accessibility standards. These data were used to 

develop estimates of the population of people with disabilities who would potentially benefit 

from various updated ICT standards (people with “addressable disabilities”). Selected results 

from the 2010 SIPP data are presented in Table B-1.161

 

160 The SIPP is a household-based survey designed as a continuous series of national panels. Each panel features a 

nationally representative sample interviewed over a multiyear period lasting approximately 4 years. Functional 

disability questions were administered from May through August 2010 in Wave 6 of the 2008 SIPP panel. Severe 

difficulty seeing is defined as “not able to see the words and letters in ordinary newspaper print at all.”

161 The estimate of people with “difficulty hearing” includes severe difficulty hearing (1.1 million), non-severe 

hearing (6.5 million), and used a hearing aid–no hearing difficulty (3.4 million). This is because the SIPP report 

cited above does include people who provide responses of “yes” to the question “Do you use a hearing aid?” and 

“no” to the question “Do you have difficulty hearing what is said in a normal conversation ... when wearing your 

hearing aid?” in the disability totals on Table A-1; they are only listed under the category “used a hearing aid–no 

difficulty hearing.” We have included them in the estimate of people with difficulty hearing because many of the 

proposed requirements—in Section 255 in particular—are directed at assisting persons who use hearing aids using 

ICT equipment, which often pose accessibility problems that are different than hearing normal conversation in 

person.
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Table B-1: U.S. Population With Addressable Disabilities, 2010

Age 15–64 Age 65 and over Age 15 and over

Nature of Disability Number Percent Number Percent Number Percent

Difficulty seeing 4,295,000 2.1% 3,782,000 9.8% 8,077,000 3.3%

Severe 960,000 0.5% 1,050,000 2.7% 2,010,000 0.8%

Not severe 3,336,000 1.6% 2,731,000 7.1% 6,067,000 2.5%

Difficulty hearing 4,308,000 2.1% 6,642,000 17.2% 10,950,000 4.5%

Severe 430,000 0.2% 666,000 1.7% 1,096,000 0.5%

Not severe 2,990,000 1.5% 3,485,000 9.0% 6,475,000 2.7%

Corrected with 

hearing aid* 888,000 0.4% 2,491,000 6.5% 3,379,000 1.4%

Difficulty with 

speech 1,975,000 1.0% 843,000 2.2% 2,818,000 1.2%

Severe 365,000 0.2% 158,000 0.4% 523,000 0.2%

Not severe 1,610,000 0.8% 685,000 1.8% 2,295,000 0.9%

Adjustment for 

people with multiple 

seeing, hearing, and 

speech difficulties**

-1,675,000 -0.8% -1,867,000 -4.8% -3,542,000 -1.5%

Severe -172,000 -0.1% -169,000 -0.4% -341,000 -0.1%

Not severe -1,503,000 -0.7% -1,698,000 -4.4% -3,201,000 -1.3%

Mobility impairmentused a wheelchair 1,623,000 0.8% 2,014,000 5.2% 3,637,000 1.5%

Difficulty grasping 3,837,000 1.9% 2,875,000 7.4% 6,712,000 2.8%

Severe 559,000 0.3% 334,000 0.9% 893,000 0.4%

Not severe 3,278,000 1.6% 2,541,000 6.6% 5,819,000 2.4%

People with ICTaddressable 

disabilities***

14,363,000 7.1% 14,289,000 37.0% 28,652,000 11.9%

Total U.S. population 203,083,000 38,599,000 241,682,000

Percent of total U.S. 

population 7.1% 37.0% 11.9%

*Net of people also included in estimates of people with severe or not severe difficulty hearing estimates.

**Required to avoid double counting of people with multiple seeing, hearing, and speech disabilities.

***Difficulty seeing, difficulty hearing, difficulty with speech, used a wheelchair, or difficulty grasping.

Source: Census Bureau, Americans With Disabilities: 2010, P70-131, Table A-1.

Based on the 2010 SIPP data, about 8.1 million people age 15 or older have difficulty seeing 

even when using glasses or contact lenses, and 11.0 million people age 15 or older have 

difficulty hearing normal conversations or use a hearing aid to be able to hear normal 

conversations. Overall, about 14.4 million people age 15 to 64 and 14.3 million people age 65 

and over in 2010 had disabilities that can potentially be addressed by ICT accessibility 

requirements. In addition, the numbers of people with addressable disabilities can be expected to 

increase in the next decade as the U.S. population ages.
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It is important to note that these SIPP-based estimates of persons with addressable disabilities do 

not include some other individuals who might benefit from improved ICT accessibility 

standards. Some of the types of individuals with disabilities or population groups who might also 

benefit from improved ICT accessibility but are not included as persons with addressable 

disabilities include the following:

 Persons with disabilities living in institutional group settings: The population living in 

institutional group quarters—including nursing homes, mental (psychiatric) hospitals, 

correctional facilities, and residential treatment centers—is not captured in SIPP data.162

 Persons with photosensitivity-based seizure disorders: SIPP data does not separately 

categorize persons with seizure disorders. There are two requirements in the proposed 

rule (i.e., section 405 Flashing and WCAG Success Criteria 2.3.1 Three Flashes or Below 

Threshold) that are expressly aimed at curbing photosensitive seizures.163 While the total 

population of persons with photosensitivity-based seizure disorders is unknown, it is 

estimated, for example, that there are about 2.3 million adults in the United States with 

epilepsy.164

 Persons with cognitive disabilities: As noted in Table A-5 (Appendix A), several 

requirements in the proposed rule are likely to benefit persons with cognitive disabilities 

to a greater or lesser extent depending on the nature and severity of any individual’s 

particular impairment. The requirements include 402.2 Speech-Output Enabled, 402.2.1 

User Control, 407 Operable Parts, 407.5 Timed Response, 407.7 Color, and 502 

Interoperability With Assistive Technology. The SIPP data is not sufficiently refined to 

permit “mapping” of these proposed requirements to the likely beneficiary population 

and, for this reason, persons with cognitive disabilities are not included in the population 

of persons with addressable disabilities for purposes of this assessment. SIPP data does 

estimate that about 15.2 million persons have one or more “mental” disabilities, with 

statistics provided for a few disability sub-types.165 This figure is undoubtedly larger than 

likely beneficiaries of the proposed rule with cognitive disabilities, but it nonetheless 

provides an upper-bound estimate. Moreover, as the TEITAC noted, cognitive disabilities 

cover a wide spectrum of impairments and capabilities, which makes it challenging to 

assess the benefits from particular requirements. Accordingly, benefits for persons with 

cognitive disabilities were not formally calculated in this assessment. Nevertheless, it is 

clear that many people with cognitive disabilities would benefit to an indeterminate 

extent from the proposed rule.

 

162 See Census Bureau, Americans With Disabilities: 2010 at 2, 4; Peiyun She & David C. Stapleton, Cornell Univ. 

Inst. for Policy Research, Research Brief: A Review of Disability Data for the Institutional Population (May 2006). 

According to the Census data, as of 2009, there were about 8.2 million people living in group quarters, with the vast 

majority of such persons living in adult correctional facilities (2.2 million) and nursing facilities (1.8 million). U.S. 

Census Bureau, Statistical Abstract of the United States: 2012, Table 73. 

163 See Appendix A, Table A-5 (section 405); World Wide Web Consortium, Understanding WCAG 2.0, Three 

Flashes or Below Threshold: Understanding SC 2.3.1 (September 2014).

164 Centers for Disease Control and Prevention, “Epilepsy Fast Facts” (2012).

165 See Census Bureau, Americans With Disabilities: 2010, Table A-1.
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B.2. Use of Electronic Technologies by People With Disabilities

Federal Government agencies increasingly rely on Web sites, applications, and forms to provide 

information and facilitate transactions with individuals, businesses, and organizations. The 2010 

SIPP data provide estimates of the number of people with severe and non-severe disabilities who 

use the Internet. These estimates were used to estimate the U.S. online population with ICTaddressable disabilities as follows:

 The estimated numbers of people with and without disabilities using the Internet in 2010 

were added to estimate the U.S. online population. According to the SIPP estimates, 

about 60 percent of the U.S. population, but only 38 percent of adults with disabilities, 

used the Internet in 2010.

166

 Data from Table D-12 on the SIPP Web site were used to calculate the ratio of Internet 

access rates for people with and without disabilities in the age 15 to 64 and age 65 and 

over groups.167

 People with vision disabilities and other addressable disabilities were assumed to have 

the same Internet access rates as people with disabilities that are not addressable by ICT 

accessibility standards.168

Calculations of the numbers of people with vision and other addressable disabilities who were 

online in 2010 are presented in Table B-2.

 

166 Census Bureau, “Computer and Internet Use in the United States: 2010,” Table 5, Internet release of June 2012. 

The Internet access rate estimated from the SIPP data is lower than that reported in other studies of the U.S. adult 

online population. For example, a Pew Internet and American Life Project survey found that 54 percent of adults 

living with a disability use the Internet, compared with the 38-percent rate estimated from the SIPP data. See

Susanna Fox, “Americans Living With Disability and Their Technology Profile,” Pew Internet and American Life 

Project, January 21, 2011.

167 Consistent with other studies, the SIPP estimates indicate that people with disabilities had somewhat lower 2010 

Internet access rates in both age groups: people with disabilities age 15 to 64 had an online rate of 52 percent, 

compared with 65 percent for the overall population in this age group. Similarly, 22 percent of people with 

disabilities age 65 and over were online in 2010, compared with 31 percent of all people 65 and over.

168 People with vision disabilities have lower Internet access rates than people with other types of disabilities, but 

most of this difference is attributable to age, rather than the type of disability.
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Table B-2: U.S. Online Population With Addressable Disabilities, 2010

Estimate Component Age 15 to 64 Age 65 and over Age 15 and over

U.S. population 203,083,000 38,599,000 241,682,000

U.S. population online 133,037,850 12,248,050 145,285,900

Percent of U.S. population online 65.5% 31.7% 60.1%

People with addressable disabilities 14,363,000 14,289,000 28,652,000

Estimated percentage of people with 

addressable disabilities online 52.4% 22.2% 37.3%

People with addressable disabilities 

online 7,527,258 3,173,882 10,701,140

People with vision disabilities online 2,250,893 840,060 3,090,953

People with other addressable 

disabilities online 5,276,365 2,333,822 7,610,187

Source: Census Bureau, Americans With Disabilities: 2010, P70-131, Tables A-1 and D-12; and Computer and 

Internet Use in the United States: 2010, Table 5.

The percentage of U.S. adults who are online has been increasing steadily, with the largest 

growth in recent years occurring among those who are age 65 and over. For this analysis, the 

online percentage of people with addressable disabilities age 15 to 64 is assumed to grow by 1 

percentage point annually; the online rate for people with addressable disabilities age 65 and 

over is assumed to grow by 2 percentage points annually.

B.3. Federal Employment of People With Disabilities

OPM has defined several categories of “reportable disabilities,” including hearing impairments, 

vision impairments, missing extremities, and other disabilities that may be potentially 

addressable by ICT accessibility standards. Table B-3 presents Fiscal Year 2010 OPM Federal 

workforce statistics on the numbers of employees who have various types of reportable 

disabilities, along with Econometrica estimates of the number of employees with disabilities that 

are most likely to be addressed by ICT accessibility standards (“addressable disabilities”).

169

 

169 OPM, Federal Civilian Workforce Statistics: Demographic Profile of the Federal Workforce as of September 

2010, “Table 5: Federal Civilian Employment Distribution by Type of Disability,” April 2011. Employees who 

reported being hard of hearing, having no side vision, being blind in one eye, or having one missing, paralyzed, or 

orthopedically impaired hand were included in the category of people with other addressable disabilities. The 

statistics in the OPM profile do not include military personnel.
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Table B-3: Federal Employees Reporting Various Types of Disabilities, FY 2010

Type of Disability Reportable Addressable*

Speech impediments* 1,097 1,097

Hearing* 15,686 15,686

Vision* 9,486 9,486

Missing extremities** 1,445 1,267

Non-paralytic orthopedic impairments** 34,627 3,683

Partial paralysis** 4,871 3,919

Complete paralysis* 1,143 1,143

Convulsive disorders 2,541 0

Mental retardation 1,019 0

Mental illness 5,399 0

Other disabilities*** 50,048 0

Disability not listed 17,673 0

Federal employees with disabilities 145,035 36,281

Total Federal civilian workforce**** 2,108,639 2,108,639

Source: OPM, Federal Civilian Workforce Statistics for September 2010.

*Potentially addressed by ICT accessibility requirements.

**Includes disabilities involving hands or arms that are potentially addressed by ICT accessibility requirements.

***Includes heart disease, diabetes, cancer, mental illness, and other conditions.

****Does not include USPS employees or those from some other Federal entities.

About 36,000 Federal civilian employees in 2010 reported having speech, hearing, vision, 

paralysis, or fine motor skill limitations that are potentially addressed by the current and 

proposed ICT accessibility requirements. In addition, some Federal employees who did not 

report having a disability may have single or multiple disabilities that make it difficult to use 

inaccessible ICT.

Employees of Federal Government contractors perform a substantial and increasing share of 

Federal agency work. However, data are not available on the number of these employees or the 

prevalence of various types of disabilities in the Federal contractor workforce.170

 

170 As noted in the text, some Federal contractors and vendors will be required to begin collecting these data under 

new Section 503 regulations published by the Department of Labor on September 24, 2013.
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Appendix C: 2012 DOJ Report on Section 508 Compliance 

Rates and Expenditures

DOJ published a comprehensive report on Federal Government Section 508 compliance 

activities and achievements in 2012.171 The report provides data that can be used to develop 

overall estimates of current compliance rates and costs based on survey data collected from 

Federal agencies. Important results from the survey are presented and discussed in this appendix.

The DOJ survey requested data in four areas:

 General processes for implementing Section 508.

 Procurement.

 Administrative complaints and civil actions.

 Web site, forms, and applications. 

The DOJ report indicated that the extent of compliance varies among agencies (and their 

component branches, divisions, and offices) and activities. Selected results from this survey are 

presented and discussed in this section.

C.1. Section 508 Policy Development and Training

The DOJ report found that slightly more than 50 percent of agency components had established a 

general policy to implement and comply with Section 508.172 Nearly 70 percent of agency 

components appointed a Section 508 coordinator, and 35 percent of agency components 

established a Section 508 office or program. However:

 About 40 percent of agency components that developed software had included a process 

to ensure the accessibility of software.

 About 30 percent of agency components that developed videos or multimedia 

productions had included a process to ensure the accessibility of training or informational

videos or multimedia productions.

 About 40 percent of agency components provided Section 508 training.

 Components provided only a small number of hours of training to their ICT developers 

(just over 1 hour annually on average) and the acquisition workforce (less than 1 hour).

 

171 DOJ, “Section 508 Report to the President and Congress: Accessibility of Federal Electronic and Information 

Technology,” September 2012, available at http://www.ada.gov/508/508_Report.htm.

172 The survey requested data from individual agency “components”—branches, divisions, and offices. To obtain the 

most comprehensive and reliable data possible, the survey asked the Federal agencies to identify components within 

each agency that were responsible for each category of duties referenced in each section of the survey. These agency 

components completed the survey and submitted the survey responses to their parent agency. The parent agency 

collected and provided the combined survey responses from all of their components to DOJ. The 89 Federal 

agencies, including cabinet-level agencies, independent agencies, and boards, commissions, and committees that 

participated in the survey identified 318 components that provided the responses to the survey.
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These results suggest that substantial portions of compliance support activities, particularly 

training, are provided through channels other than the Section 508 coordinator or program office.

C.2. Section 508 Support Services Provided

The DOJ report indicates that Section 508 offices and programs provide a wide range of 

compliance support services, notwithstanding generally small budgets (an average of about 

$400,000 annually) and limited staffing (an average of 2.5 FTE employees). The most common 

service provided by agency components, regardless of whether they had established a Section 

508 office or program, was to evaluate the accessibility of Web sites, and the least common 

service provided was to evaluate the accessibility of hardware (Table C-1).

Table C-1: Section 508 Services Provided by Agency Components

Q. II.C.6. Section 508 Services Provided Percentage of 

Respondents

(a) Assist acquisition officials to prepare Section 508 language in IT contracts 65%

(b) Assist developers to design software that complies with Section 508 66%

(c) Create or repair electronic documents to comply with Section 508 70%

(d) Evaluate Web sites 81%

(e) Evaluate software 65%

(f) Evaluate hardware 41%

(g) Provide training 52%

(h) Provide alternate formats 50%

C.3. Software and Web Application Development

The DOJ report indicated that 75 percent of agency components reported developing software or 

Web applications. About 40 percent of these agency components reported establishing a policy 

to ensure the accessibility of software, including testing developed software for compliance

(Table C-2).

Table C-2: Software/Web Application Development by Agency Components

Q. II.D.1. Software/Application Development Percentage of Respondents

(a) Yes, software was developed in house 52%

(b) Yes, but development was limited to contractors 23%

(c) No 25%

C.4. Video/Multimedia Production

The DOJ report indicated that 71 percent of agency components reported developing training or 

informational videos or multimedia productions. About 30 percent of these agency components 

reported establishing a policy to ensure the accessibility of videos or multimedia productions, 

including testing developed videos or multimedia production for compliance (Table C-3).
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Table C-3: Video/Multimedia Development by Agency Components

Q. II.D.1. Section 508 Services Provided Percentage of Respondents

(a) Yes, video or multimedia production was developed in house 52%

(b) Yes, but the production was limited to contractors 18%

(c) No, all productions were procured, or we do not create any video 

or multimedia productions 29%

C.5. Training Provided

The DOJ report indicated that 41 percent of agency components reported providing Section 508 

training. Agency components reported providing the most average hours of training to Section 

508 coordinators and the fewest average hours of training to IT help desk staff (Table C-4).

Table C-4: Section 508 Training Provided by Agency Components

Q. II.H.3–10. Section 508 Training Provided Average Hours Per 

Employee

(3) Section 508 coordinators 4.2

(4) “Requiring officials” (program managers, contracting officer’s 

representatives, etc.) 0.8

(5) Acquisition workforce (contracting officers, contract specialists, etc.) 0.9

(6) Purchase cardholders 0.8

(7) Web site developers 1.6

(8) Video and multimedia developers 1.0

(9) IT help desk staff 0.6

(10) Other employees 0.7

A majority of agency components that offered training reported online training as the most 

common method for providing Section 508 training (Table C-5).

Table C-5: Types of Training Provided by Agency Components

Q. II.H.11. Section 508 Training Methods Percentage

(a) Section 508 universe (www.section508.gov) 52%

(b) Other online training 67%

(c) Classroom instruction 54%

(d) Conferences and seminars 55%

(e) Other 41%

C.6. Procurement

The DOJ report indicated that Federal agencies use multiple ways to specify Section 508 

requirements in procurement solicitations. Most agency components incorporated general 

language about compliance requirements, and about half (48 percent) added language identifying 

specific requirements applicable to the solicitation.
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About half (46 percent) of Federal agency components reported conducting in-house testing of 

procured ICT to assess compliance with the applicable Section 508 requirements. One-quarter of 

agency components used third-party testing for at least some procurement (Table C-6).

Table C-6: Types of Testing Used to Assess Procurement Compliance

Q. III.A.3. Acceptance Compliance Testing Percentage

(a) Testing done in house 46%

(b) Testing done by a third party 25%

(c) Review of material submitted 60%

(d) Special acceptance provisions 12%

(e) No evaluation 18%

(f) Other 13%

C.7. Web Site Compliance

The DOJ report indicated that Federal agency Web sites typically contain multiple elements and 

types of electronic content. Nearly all (96 percent) of the Web sites included in agency survey 

responses have PDFs, and three quarters (77 percent) have embedded multimedia content. The 

majority also contain JavaScript menus, data tables, Flash content, or other elements that require 

specific attention to make them accessible (Table C-7).

Table C-7: Elements on Agency Web Sites

Q. V.A.3. Web Site Elements Percentage

Portable document files 96%

Multimedia content 77%

JavaScript or other scripts 75%

Word processing files 74%

Microsoft PowerPoint 67%

Data tables 67%

Spreadsheet files 65%

Flash content 58%

A majority of agencies that have Web sites evaluate them for Section 508 compliance. However, 

22 percent reported doing so only when notified about an accessibility issue; 21 percent reported 

not having conducted an evaluation at all (Table C-8).
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Table C-8: Agency Web Site Compliance Testing

Q. V.A.7. Web Policy on Testing Percentage

Routine automated and manual evaluations 28%

Routine automated evaluations 6%

Routine manual evaluations 24%

Evaluate only when notified 22%

No, but a timetable has been established to do so 9%

No, and there were no plans to do so 12%

Agency Web Site Accessibility

Finally, a majority of agencies indicated that their external Web home pages, forms, and 

applications complied with each specific Section 508 requirement included in the survey. 

Reported compliance rates for most specific requirements were in the range between 95 and 76 

percent, but lower percentages of agency Web sites reportedly meet the standards for captioning 

and audio description (Table C-9). 

Table C-9: Agency Web Site Compliance With Current Section 508 Requirements

Q.V.B 

Number Requirement Web Site Home Page

Web 

Forms

Web 

Applications

3 Text Equivalents 87% 83% 80%

4

Multimedia Content Accessibility 

Synchronization 76% 65% 65%

5 Appropriate Use of Color 82% 88% 88%

6 Style Sheet Accessibility 92% 92% 87%

7 Server-Side Image Map Accessibility 80% 82% 82%

8 Use of Client-Side Image Map 86% 83% 86%

9 Row and Column Header Identification 88% 83% 82%

10 Data and Header Cell Association 83% 86% 76%

11 Frame Accessibility 86% 90% 82%

12 Designed to Avoid Screen Flicker 95% 96% 94%

14 Java/Flash Accessibility 83% 83% 77%

15 Plug-In or Other Programmatic Object 

Accessibility 85% 80% 73%

16 Electronic Form Accessibility 87% 86% 80%

17 Navigational Link Skipping 80% 81% 76%

18 Time Limits 76% 77% 75%

19 Keyboard Accessibility 87% 89% 87%

20 Screen Focus 77% 87% 81%

21 Availability of User Interface Information 84% 83% 82%

22 Captioning 69% 69% 64%

Note: Compliance rates exclude agency components that indicated that a particular requirement was not applicable 

to the contents of their Web site home pages, forms, or applications.
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Appendix D: Data on Affected Entities, Products, Services, 

and Employees

This section provides a description and statistical profile of Federal Government ICT 

expenditures, purchases, and employment, as well as data on the overall sales of private firms in 

ICT-related sectors. These statistics provide baseline data for assessing the numbers and types of 

entities, employees, and expenditures that may be affected by adoption of the rule standards and 

guidelines. 

D.1. Federal Agency ICT Budgets

Federal purchases of hardware, software, services, and content must be made in conformance 

with the current Section 508 standards. These purchases account for a substantial share of overall 

agency IT budgets, which must be compiled and reported annually to OMB. Table D-1 shows 

that the overall Federal Government IT budget has remained essentially flat since 2011. Little, if 

any, spending growth is anticipated during the next few years.173

Table D-1: Federal IT Spending by Federal Agency (Millions)

Federal Agency FY 2011 

Actual

FY 2012 

Actual

FY 2013 

Budget

Major Civilian Agencies $41,094 $40,690 $41,766

DOD $39,090 $39,588 $38,810

Total for Federal Government $80,184 $80,278 $80,576

Source: U.S. CIO, “Federal Information Technology, FY 2014 Budget Priorities.”

DOD and its constituent service branches accounted for nearly half of the total Federal IT budget 

in FY 2012. DHS and the Department of Health and Human Services were the only agencies that 

accounted for more than 10 percent of civilian agency IT spending.174

It should be noted that the IT budget numbers reported to OMB include spending by most, but 

not all, Federal agencies. In addition, these estimates may not include expenditures on certain 

types of ICT products and services (including multimedia production and telecommunications 

services) that may be covered under certain provisions in the current Section 508 standards. The 

 

173 Steven VanRoekel, U.S. Chief Information Officer, “Federal Information Technology, FY 2014 Budget 

Priorities,” and “Federal Information Technology, FY 2013 Budget Priorities: Doing More With Less,” undated 

presentations. IT is defined as “any equipment or interconnected system or subsystem of equipment that is used in 

the automatic acquisition, storage, manipulation, management, movement, control, display, switching, interchange, 

transmission, or reception of data or information by an executive agency.” Budget data are compiled and reported 

according to OMB guidance for Form 53. 

174 Federal IT spending for major civilian agencies includes cabinet-level departments (Agriculture, Commerce, 

Education, Energy, Health and Human Services, DHS, Housing and Urban Development, Interior, Justice, Labor, 

State, Transportation, and the Treasury), the Agency for International Development, the Army Corps of Engineers, 

the Environmental Protection Agency, the General Services Administration, the National Aeronautics and Space 

Administration, the National Archives and Records Administration, the National Science Foundation, the Nuclear 

Regulatory Commission, the Office of Personnel Administration, the Small Business Administration, the 

Smithsonian Institution, and the Social Security Administration.
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Federal budget estimate of IT spending can therefore be regarded as a lower-bound estimate of 

all spending covered by ICT accessibility requirements.

A more inclusive estimate of total Federal ICT spending is available from Deltek, a Government 

accounting and business intelligence firm that provides projections of future contracting 

opportunities. Deltek estimates that Federal ICT spending totaled approximately $120 billion in 

2012.175 However, the Deltek budget figure includes spending on weapons systems and other 

forms of IT that may not be materially affected by the Section 508 requirements.

D.2. Federal Agency ICT Budgets and Purchases

The Federal Procurement Data System (FPDS Next Generation, or FPDS-NG, in its most recent 

form) provides data on Federal ICT hardware, software, content, and service purchases. 

Econometrica tabulations of the FPDS-NG data for 2011 are presented in Table D-2.

 

175 Deltek’s Bjorklund said that “the difference is because the Deltek forecast tries to capture the whole federal 

‘addressable’ market, including the legislative and judicial branches and a host of independent and quasigovernmental agencies, such as the U.S. Postal Service, Fannie Mae, Freddie Mac, and the Tennessee Valley 

Authority. The company also includes spending on IT systems contained within other programs, such as aircraft and 

weapons systems, and estimates on IT spending within the U.S. intelligence community.” Quoted in Information 

Week, “Federal IT Spending Likely to Decline,” June 20, 2012.
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Table D-2: Federal Purchases From Selected ICT Sectors, Calendar Year (CY) 2011

NAICS Code and Description Number of 

Purchases Millions of Dollars

Computer and electronic product manufacturing

334111 Electronic computers 37,078 $3,581.5

334112 Computer storage devices 3,994 $321.2

334113 Computer terminals 421 $42.0

334119 Other computer peripheral equipment 7,631 $794.3

334210 Telephone apparatus 4,240 $742.8

334220 Radio and television broadcasting and wireless 

communications equipment 14,979 $5,470.8

334290 Other communications equipment manufacturing 12,580 $2,103.3

334310 Audio and video equipment 3,729 $135.7

Manufacturing subtotal 84,652 $13,191.6

Information services

511210 Software publishers 15,950 $1,377.5

514210 Data processing services 279 $201.7

516110 Internet publishing and broadcasting 50 $15.0

518111 Internet service providers 692 $89.0

518112 Web search portals 17 $0.7

518210 Data processing, hosting, and related services 7,479 $1,229.9

519130 Internet publishing, broadcasting, and Web search 

portals 1,989 $82.6

5121 Motion picture and video industries 1,955 $70.8

5122 Sound recording industries 268 $5.8

5141 Information services 4,035 $474.4

513/517 Telecommunications services 87,623 $8,283.7

515 Broadcasting/cable services 4,332 $71.6

Information services subtotal 124,669 $11,902.7

Office equipment rental and leasing

532420 Office equipment rental and leasing 5,459 $307.6

Rental and leasing subtotal 5,459 $307.6

Computer systems design and related services

541511 Custom computer programming services 21,380 $5,887.4

541512 Computer systems design services 21,268 $9,885.1

541519 Other computer-related services 75,659 $11,918.2

Computer services subtotal 118,307 $27,690.7

Total IT purchases 333,807 $53,092.7

Source: Econometrica tabulations of downloaded CY 2011 Federal Procurement Data System data.

Table D-2 shows that computer systems design and related services accounted for $27.7 billion 

of the $53.0 billion of total Federal IT purchases in 2011. Hardware purchases totaled $13.2 

billion in 2011, and information services accounted for $11.9 billion in Federal ICT purchases. 

Telecommunications services accounted for the majority of Federal information services 

purchases ($8.3 billion of the $11.9 billion total).
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D.3. Federal Employment in IT, Contracting, and Other Selected 

Occupations

Significant numbers of Federal employees work in IT, contracting, and other occupations that 

can be expected to have specific responsibilities for ensuring that agencies comply with their 

current and future Section 508 obligations. FY 2011 OPM employment and salary data for 

selected occupations are presented in Table D-3.

Table D-3: Federal Employment in Selected Occupations, 2011

Occupation (Code) Number of 

Employees Average Salary

IT-related occupations

Information technology (2200) 81,639 $93,100

IT subtotal 81,639 $93,100

Contracting-related occupations

Contracting (1102) 36,890 $85,541

Purchasing (1105) 3,329 $48,663

Procurement technician (1106) 1,655 $45,448

Contracting subtotal 41,874 $81,025

Other occupations likely to have Section 508 compliance obligations

Audiovisual production (1071) 1,184 $82,890

Writing and editing (1082) 1,397 $86,349

Technical writing and editing (1083) 1,206 $77,306

Visual information (1084) 1,820 $77,914

Editorial assistance (1085) 204 $45,972

Program management (0340) 14,571 $130,872

Administrative officer (0341) 9,336 $80,180

EEO compliance (0360) 1,633 $89,959

EEO assistance (0361) 347 $47,730

Human resource management (0201) 28,034 $83,356

Human resource assistance (0203) 12,883 $42,174

Mediation (0241) 188 $120,213

Training (0243) 89 $91,551

Labor management relations (0244) 315 $106,882

EEO (0260) 2,673 $93,206

Employee benefits lawyer (0958) 133 $110,117

Other selected occupation subtotal 76,013 $85,386

Total employees in selected occupations 199,526

IT percentage of total 41%

Contracting percentage of total 21%

Source: Tabulations of December 2011 OPM FedScope Employment Data “cube.”
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Of the approximately 200,000 Federal employees in these selected occupations, 41 percent

(81,639) work in IT and another 21 percent (41,874) work in contracting-related jobs. It should 

be noted that in addition to the remaining categories of Federal employees shown in Table D-3, 

other Federal employees may be required to prepare or participate in the creation of Section 508-

compliant materials in the course of the regular performance of their duties. Federal agencies 

may increase, decrease, or change the categories and numbers of Federal employees who would 

be required to create or repair electronic documents if the proposed standards are adopted.

Some Federal contractor and vendor employees are also required to design, create, maintain, or 

repair accessible ICT. There are no data available on the number of such employees or the 

average level of compensation for various occupations.

D.4. ICT Manufacturing

The Census Bureau recently released 2012 Economic Census data for the computer, 

telecommunications, and audio/video equipment manufacturing sectors. Selected data are 

presented Table D-4.176

Table D-4: Number of Companies and Primary Product Shipments for Selected ICT Sectors, 2012

6-Digit NAICS Code and Description Number of 

Companies

Number of 

Employees

Primary 

Product 

Shipments 

(Millions)

334111 Electronic computer manufacturing 360 18,785 $9,665

334112 Computer storage device manufacturing 105 15,641 $11,069

334118 Computer terminal and other computer peripheral 

equipment manufacturing 611 24,238 $11,412

334210 Telephone apparatus manufacturing 251 17,989 $8,142

334220 Radio and television broadcasting and wireless 

communications equipment manufacturing 753 67,868 $27,412

334290 Other communications equipment manufacturing 363 14,910 $5,020

334310 Audio and video equipment manufacturing 457 9,559 $2,925

Total ICT 2,900 168,990 $75,646

Source: Economic Census, Detailed Statistics by Industry for the United States: 2012

U.S. electronic computer (334111), computer terminal/peripheral (334118), telephone apparatus 

(334210), wireless communications equipment (included in 334220), and audio/video equipment 

(334310) manufacturers produce types of equipment that are most likely to be covered under the 

current Section 508 standards or Section 255 guidelines. However, some types of equipment 

produced by manufacturers in these sectors would not be required to be accessible.

A substantial amount of computer and telecommunications equipment is imported. Data are not 

available on the numbers of foreign manufacturers and the level of employment. Moreover, 

 

176 Estimates of the numbers of ICT firms from the 2011 Census Statistics of U.S. Business are used in the estimates 

of telecommunication manufacturer product support costs presented in Sections 6.3 and 9.3 to be consistent with the 

estimates presented in the NPRM Paperwork Reduction Analysis. The numbers of firms and employees are very 

similar in the two Census data sources.
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sector-specific estimates of the value of imports are only available through the second quarter of 

2011, when the Census Bureau suspended issuing detailed Current Industrial Reports data. The 

value of imports shipments was estimated at $79.4 billion and $68.5 billion, respectively, for 

computer and telecommunications equipment manufacturing.177

Based on a review of more detailed shipments data, about two-thirds of the aggregate value of 

ICT products in these sectors (i.e., about $50 billion annually each for U.S. manufacturers and 

imports from foreign manufacturers) would potentially be covered by the proposed Section 508 

standards or Section 255 guidelines.

D.5. Private-Sector IT Employment

BLS estimates provide a more detailed breakout of IT employment and salaries for the specific 

occupational classifications in the private sector than is available for Federal employees.178

Private-sector IT employment and salary data for 2011 are summarized in Table D-5.

Table D-5: Private-Sector Employment in IT-Related Occupations, 2011

SOC 

Code* Occupation Number of Employees Average Salary

151111 Computer and information research scientists 25,160 $103,160

151121 Computer systems analysts 487,740 $82,320

151131 Computer programmers 320,100 $76,010

151132 Software developers applications 539,880 $92,080

151133 Software developers systems software 387,050 $100,420

151141 Database administrators 108,500 $77,350

151142 Network and computer systems administrators 341,800 $74,270

151150 Computer support specialists 632,490 $51,820

151179 Information security analysts, Web developers, and 

computer network architects 272,670 $81,670

151199 Computer occupations (all other) 177,630 $80,500

Total 3,293,020 $78,584

Software developers (151132/151133) 926,930 $95,562

Web developers (151179)** 136,335 $81,670

*BLS Standard Occupational Classification code.

**Assumed to be 50 percent of SOC 151179 employees.

Source: BLS Occupational Employment Statistics for May 2012.

The OPM Federal employee data do not provide average salaries for specific IT occupations. 

The BLS data for private-sector employment indicate that annual salaries for software developers 

and Web developers averaged $95,600 and $81,700, respectively, in 2011.

 

177 Census Bureau, Current Industrial Reports, MQ334R - Computers and Peripheral Equipment, June 2011, and 

MQ334P - Telecommunications, July 2011.

178 BLS, “May 2012 National Occupational Employment and Wage Estimates.” The Occupational Employment 

Statistics (OES) survey covers all full-time and part-time wage and salary workers in nonfarm industries. Surveys 

collect data for the payroll period, including the 12th day of May. The survey does not cover the self-employed, 

owners and partners in unincorporated firms, household workers, or unpaid family workers. 
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Appendix E: Annual Estimates of Monetized Benefits and Costs

The annual values of the benefits estimated in Sections 5.1 through 5.3 are shown in Table E-1.

Table E-1: Annual Value of Monetized Benefits, 2015–2024 (Millions)

2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2015–

2024

Benefits from increased 

Federal employee productivity $23.3 $46.7 $46.7 $46.7 $46.7 $46.7 $46.7 $46.7 $46.7 $46.7 $443.5

Benefits from improved 

Federal Government Web site 

accessibility to people with 

vision disabilities

$1.0 $2.0 $2.1 $2.2 $2.3 $2.4 $2.6 $2.7 $2.8 $2.9 $23.0

Benefits to Federal Agencies 

from reduced call volumes $8.1 $17.1 $17.9 $18.8 $19.7 $20.7 $21.7 $22.7 $23.8 $25.0 $195.5

Total monetized benefits $32.4 $65.8 $66.7 $67.7 $68.7 $69.8 $70.9* $72.1 $73.3 $74.6 $662.0

Present value in 2015 

(7% discount rate) $32.4 $61.5 $58.3 $55.3 $52.4 $49.8 $47.3 $44.9 $42.7 $40.6 $485.0

Present value in 2015 

(3% discount rate) $32.4 $63.9 $62.9 $62.0 $61.1 $60.2 $59.4 $58.6 $57.9 $57.2 $575.4

Annualized value 

(7% discount rate) $69.1 $69.1 $69.1 $69.1 $69.1 $69.1 $69.1 $69.1 $69.1 $69.1 $69.1

Annualized value 

(3% discount rate) $67.5 $67.5 $67.5 $67.5 $67.5 $67.5 $67.5 $67.5 $67.5 $67.5 $67.5

*Benefit numbers do not sum to total because of rounding.
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The annual values of the costs estimated in Sections 9.1 through 9.5 are shown in Table E-2.

Table E-2: Annual Value of Monetized Costs, 2015–2024 (Millions)

2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2015–2024

Total in-house ICT cost $102.7 $102.7 $65.8 $65.8 $65.8 $65.8 $65.8 $65.8 $65.8 $65.8 $732.2

Procured ICT cost $94.8 $94.8 $60.8 $60.8 $60.8 $60.8 $60.8 $60.8 $60.8 $60.8 $675.9

Manufacturers Web site and 

content development $17.0 $20.4 $6.8 $6.8 $6.8 $6.8 $6.8 $6.8 $6.8 $6.8 $92.0

Total monetized cost $214.5 $217.9 $133.4 $133.4 $133.4 $133.4 $133.4 $133.4 $133.4 $133.4 $1,500.0*

Present value in 2015 

(7% discount rate) $214.5 $203.7 $116.6 $108.9 $101.8 $95.1 $88.9 $83.1 $77.7 $72.6 $1,162.9

Present value in 2015 

(3% discount rate) $214.5 $211.6 $125.8 $122.1 $118.6 $115.1 $111.8 $108.5 $105.3 $102.3 $1,335.6

Annualized cost 

(7% discount rate) $165.6 $165.6 $165.6 $165.6 $165.6 $165.6 $165.6 $165.6 $165.6 $165.6 $165.6

Annualized cost 

(3% discount rate) $156.6 $156.6 $156.6 $156.6 $156.6 $156.6 $156.6 $156.6 $156.6 $156.6 $156.6

*Cost numbers do not sum to total because of rounding.