# Preliminary Regulatory Impact Analysis

Proposed Update of Section 508 Standards

and Section 255 Guidelines

Contract No.:

GS

- 10F

- 0269K

Order No.:

DTOS59

- 09

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- 100 94

Project No.:

10 30

- 00 1

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 Ave nue, Suite 1000 Bethesda, MD 20814



## February 12, 2015Evaluation of Proposed Update of Section 508 Standards and Section 255 Guidelines 1030

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# Table of Contents

E XECUTIVE 

### S UMMARY



### ................................ ................................ ................................ ............... 1

A CCESS 

### B OARD 

### P ROPOSAL



### ................................ ................................ ................................ ....... 1

S UMMARY OF 

### B ENEFITS AND 

### C OSTS OF THE 

### P ROPOSED 

### R ULE



### ................................ .................... 2

B ENEFITS OF THE 

### P ROPOSED 

### R ULE



### ................................ ................................ ............................ 4

C URRENT 

### (B ASELINE 

### ) S ECTION 

### 508 AND 

### S ECTION 

### 255 C OSTS



### ................................ ................... 5

C OSTS OF THE 

### P ROPOSED 

### R ULE



### ................................ ................................ ................................ 6

C ONCLUSION



### ................................ ................................ ................................ ........................... 7

1. I NTRODUCTION 

### : P ROPOSED 

### U PDATE OF THE 

### S ECTION 

### 508 S TANDARDS AND THE 

### S ECTION


### 255 G UIDELINES



### ................................ ................................ ................................ ......................... 1

2. F RAMEWORK TO 

### E VALUATE THE 

### P ROPOSED 

### S TANDARDS AND 

### G UIDELINES



### .......................... 2

3. C URRENT 

### S TANDARDS AND 

### G UIDELINES TO 

### E NSURE 

### E QUAL 

### A CCESS TO 

### ICT FOR 

### P EOPLE


### W ITH 

### D ISABILITIES



### ................................ ................................ ................................ .................... 3

3.1. S ECTION 

### 508 S TANDARDS



### ................................ ................................ ................................ .. 4

3.2. S ECTION 

### 255 G UIDELINES



### ................................ ................................ ................................ .. 4

3.3. W3C C ONSENSUS 

### S TANDARDS



### ................................ ................................ .......................... 6

3.4. S ECTIONS 

### 501 AND 

### 504 OF THE 

### R EHABILITATION 

### A CT OF 

### 1973

................................ ........... 7

4. A N 

### O VERVIEW OF THE 

### P ROPOSED 

### 508 S TANDARDS AND 

### 255 G UIDELINES



### ............................. 8

4.1. N EED FOR 

### R EVISION OF 

### C URRENT 

### S TANDARDS AND 

### G UIDELINES



### ................................ ........ 8

4.2. WCAG 2.0 AND 

### O THER 

### P ROPOSED 

### A CCESSIBILITY 

### S TANDARDS 

### : W HAT 

### W OULD 

### B E


### R EQUIRED 

### ?

................................ ................................ ................................ .................... 11

4.3. ICT C ONTENT



### , A PPLICATIONS



### , AND 

### E QUIPMENT 

### : W HAT 

### W OULD 

### B E 

### C OVERED 

### ?

............... 12

4.4. M AJOR 

### N EW 

### R EQUIREMENT 

### A REAS IN THE 

### P ROPOSED 

### S TANDARDS AND 

### G UIDELINES



### ........ 14

4.5. S COPE OF 

### P ROPOSED 

### ICT S TANDARDS AND 

### G UIDELINES 

### : W HAT 

### E NTITIES 

### W OULD 

### H AVE TO


### C OMPLY 

### ?

................................ ................................ ................................ ....................... 21

4.6. R E QUEST FOR 

### C OMMENT ON 

### S PECIFIC 

### A SPECTS OF THE 

### P ROPOSED 

### 508 S TANDARDS AND 

### 255

G UIDELINES



### ................................ ................................ ................................ ................... 22

5. B ENEFITS OF THE 

### P ROPOSED 

### R ULE



### ................................ ................................ ...................... 23

5.1. T YPES OF 

### A DDRESSABLE 

### D ISABILITIES AND 

### N UMBER OF 

### P OTENTIA L 

### B ENEFICIARIES



### ......... 23

5.2. B ENEFITS FOR 

### F EDERAL 

### E MPLOYEES 

### W ITH 

### D ISABILITIES



### ................................ ................. 25

5.3. B ENEFITS FOR 

### C ITIZENS AND 

### O THER 

### R ESIDENTS 

### W ITH 

### D ISABILITIES



### ................................ 29

5.4. B ENEFITS FOR 

### F EDERAL 

### A GENCIES



### ................................ ................................ .................. 37

5.5. B ENEFITS 

### F ROM 

### I NCREASED 

### A VAILABILITY OF 

### A CCESSIBLE 

### T ELECOMMUNICATIONS


### P RODUCTS



### , D OCUMENTATION



### , AND 

### S UPPORT 

### S ERVICES



### ................................ .................. 39

5.6. B ENEFITS 

### A CCRUING TO 

### O THER 

### E NTITIES



### ................................ ................................ ........ 40

5.7. S UMMARY OF 

### B ENEFITS



### ................................ ................................ ................................ ... 41

5.8. R EQUEST FOR 

### C OMMENT ON 

### S PECIFIC 

### A SPECTS OF 

### B ENEFITS 

### E STIMATES



### ......................... 42

6. B ASELINE 

### C OMPLIANCE 

### C OSTS



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### 6.1. F EDERAL 

### A GENCY 

### I N



### - H OUSE 

### B ASELI NE 

### C OSTS



### ................................ ................................ 44

6.2. B ASELINE 

### C OST 

### E STIMATES FOR 

### P ROCURED 

### ICT

................................ .............................. 50

6.3. B ASELINE 

### C OST 

### E STIMATES FOR 

### C OMPLYING 

### W ITH 

### C URRENT 

### S ECTION 

### 255 G UIDELINES



### .. 53

6.4. S UMMARY OF 

### B ASELINE 

### S ECTION 

### 508 AND 

### S ECTION 

### 255 C OMPLIANCE 

### C OSTS



### .................. 55

6.5. R EQUEST FOR 

### C OMMENT ON 

### S PECIFIC 

### A SPECTS OF 

### B ASELINE 

### C OST 

### E STIMATES



### ................ 55

7. F ACT ORS 

### A FFECTING 

### F UTURE 

### C OMPLIANCE 

### C OSTS 

### U NDER THE 

### C URRENT 

### ICT S TANDARDS

AND 

### G UIDELINES



### ................................ ................................ ................................ ...................... 56

7.1. F ACTORS 

### A FFECTING 

### F EDERAL 

### A GENCY 

### S ECTION 

### 508 C OMPLIANCE 

### C OSTS



### ..................... 56

7.2. F ACTORS 

### A FFECTING 

### T ELECOMMUNICATIONS 

### M ANUFACTURER 

### C OSTS TO 

### C OMPLY 

### W ITH

THE 

### S ECTION 

### 255 G UIDELINES



### ................................ ................................ ........................ 57

8. C URRENT 

### P RACTICES AND 

### P OTENTIAL 

### I NCREMENTAL 

### C OSTS 

### A SSOCIATED 

### W ITH 

### M AJOR


### N EW 

### R EQUIREMENTS IN THE 

### P ROPOSED 

### R ULE



### ................................ ................................ ........ 58

8.1. A REA 

### 1: A PPLYING 

### WCAG 2.0 TO 

### S OFTWARE AND 

### A PPLICATIONS



### ................................ ... 58

8.2. A REA 

### 2: A CCESSIBILITY 

### F EATURES 

### W ITHIN 

### S OFTWARE 

### A PPLICATIONS AND 

### O PERATING


### S YSTEMS



### ................................ ................................ ................................ ........................ 59

8.3. A REA 

### 3: A UTHORING 

### T OOLS



### ................................ ................................ ............................ 59

8.4. A REA 

### 4: A SSISTIVE 

### T ECHNOLOGY



### ................................ ................................ .................... 59

8.5. A REA 

### 5: E LECTRONIC 

### C ONTENT AND 

### D ATA



### ................................ ................................ ...... 60

8.6. A REA 

### 6: C OLOR AND 

### C ONTRAST 

### S ETTINGS



### ................................ ................................ ....... 60

8.7. A REA 

### 7: A UDIO 

### C ONTROLS ON 

### W EB 

### P AGES



### ................................ ................................ ...... 60

8.8. A REA 

### 8: U SER 

### C ONTROLS FOR 

### C APTIONS AND 

### V IDEO 

### D ESCRIPTION



### ................................ .. 61

8.9. A REA 

### 9: RTT F UNCTIONALITY



### ................................ ................................ ......................... 61

8.10. S ECTION 

### 508 H ARDWARE AND 

### E QUIPMENT 

### C OSTS



### ................................ ......................... 62

8.11. S ECTION 

### 255 E LECTRONIC 

### D OCUMENTATION AND 

### S UPPORT 

### C OSTS



### ................................ 62

8. 12

. R EQUEST FOR 

### C OMMENT ON 

### C OMPLIANCE 

### C OSTS



### ................................ .......................... 64

9. P RELIMINARY 

### C OST 

### E STIMATES FOR THE 

### P ROPOSED 

### R ULE



### ................................ ................. 64

9.1. F EDERAL 

### A GENCY 

### C OMPLIANCE 

### C OSTS FOR 

### I N



### - H OUSE 

### ICT

................................ ............. 65

9.2. E STIMATED 

### C OST 

### I NCREASES 

### A SSOCIATED 

### W ITH 

### P ROCURED 

### ICT

................................ ..... 73

9.3. C OMPLIANCE 

### C OSTS 

### A SSOCIATED 

### W I TH 

### P ROPOSED 

### S ECTION 

### 255 G UIDELINES



### ................. 74

9.4. S UMMARY OF 

### M ONETIZED AND 

### U NQUANTIFIED 

### C OSTS OF THE 

### P ROPOSED 

### R ULE



### ............... 76

9.5. R EQUEST FOR 

### C OMMENT ON 

### C OST 

### E STIMATES FOR 

### P ROPOSED 

### R ULE



### ................................ 78

10. C ONCLUSION



### ................................ ................................ ................................ ....................... 79

A PPENDIX 

### A: ICT A CCESSIBILITY 

### S TANDARDS



### ................................ ................................ .......... 1

A.1. WCAG 2.0 L EVEL 

### A AND 

### L EVEL 

### AA S UCCESS 

### C RITERIA



### ................................ .................. 2

A.2. A DDITIONAL 

### P ROPOSED 

### R EQUIREMENTS FOR 

### S OFTWARE AND 

### A PPLICATIONS



### .................... 6

A.3. P ROPOSED 

### R EQUIREMENTS FOR 

### H ARDWARE AND 

### T ELECOMMUNICATIONS 

### E QUIPMENT



### ....... 8

A.4. P ROPOSED 

### R EQUIREMENTS FOR 

### S UPPORT 

### D OCUMENTATION AND 

### S ERVICES



### ..................... 18

A.5. M APPING OF 

### P ROPOSED 

### R ULE 

### P ROVISIONS TO 

### P EOPLE 

### W ITH 

### S PECI FIC 

### T YPES OF


### D ISABILITIES



### ................................ ................................ ................................ .................. 19

A PPENDIX 

### B: D ATA ON 

### P EOPLE 

### W ITH 

### D ISABILITIES



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### B.1. E XTENT AND 

### S EVERITY OF 

### D ISABILITIES IN THE 

### U.S. P OPULATION



### ................................ ..... 1

B.2. U SE OF 

### E LECTRONIC 

### T ECHNOLO GIES BY 

### P EOPLE 

### W ITH 

### D ISABILITIES



### ................................ . 4

B.3. F EDERAL 

### E MPLOYMENT OF 

### P EOPLE 

### W ITH 

### D ISABILITIES



### ................................ ..................... 5

A PPENDIX 

### C: 2012 DOJ R EPORT ON 

### S ECTION 

### 508 C OMPLIANCE 

### R ATES AND 

### E XPENDITURES



### .. 1

C.1. S ECTION 

### 508 P OLICY 

### D EVELOPMENT AND 

### T RAINING



### ................................ ......................... 1

C.2. S ECTION 

### 508 S UPPORT 

### S ERVICES 

### P ROVIDED



### ................................ ................................ ...... 2

C.3. S OFTWARE AND 

### W EB 

### A PPLICATION 

### D EVELOPMENT



### ................................ ........................... 2

C.4. V IDEO 

### /M ULTIMEDIA 

### P RODUCTION



### ................................ ................................ .................... 2

C.5. T RAINING 

### P ROVIDED



### ................................ ................................ ................................ ......... 3

C.6. P ROCUREMENT



### ................................ ................................ ................................ ................. 3

C.7. W EB 

### S ITE 

### C OMPLIANCE



### ................................ ................................ ................................ .... 4

A PPENDIX 

### D: D ATA ON 

### A FFECTED 

### E NTITIES 

### , P RODUCTS 

### , S ERVICES 

### , AND 

### E MPLOYEES



### ............. 1

D.1. F EDERAL 

### A GENCY 

### ICT B UDGETS



### ................................ ................................ ...................... 1

D.2. F EDERAL 

### A GENCY 

### ICT B UDGETS AND 

### P URCHASES



### ................................ ............................ 2

D.3. F EDERAL 

### E MPLOYMENT IN 

### IT, C ONTRACTING



### , AND 

### O THER 

### S ELECTED 

### O CCUPATIONS



### ........ 4

D.4. ICT M ANUFACTURING



### ................................ ................................ ................................ ...... 5

D.5. P RIVATE



### - S ECT OR 

### IT E MPLOYMENT



### ................................ ................................ ................... 6

A PPENDIX 

### E: A NNUAL 

### E STIMATES OF 

### M ONETIZED 

### B ENEFITS AND 

### C OSTS



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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 Empl oyees 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 P er 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: Annualiz ed 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 S oftware/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 Ba seline 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 Increa se 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

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### Table 27: Projected Increase in Annual Agency Compliance Costs for In

- H ouse 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: Prop osed 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

Tab le B

- 2: U.S. Online Population W ith Addressable Disabilities, 2010

................................ .............. B

- 5

Table B

- 3: Federal Employees Reporting Various Types of Disabilities, FY 2010

............................... B

- 6

Table C

- 1: Sect ion 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 Pr ovided 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 Curr ent 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 an d 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

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# Executive Summary

The U.S. Architectural and Transportation Barriers Compliance Board (hereafter the “Access Board”) is the F ederal agency that promotes equality for people with disabilities through leadership in accessible design and the development of accessibility guidel ines 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 d isabilities 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 G overnment 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 guideline s 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 Propo sal

The Access Board is proposing to update the existing Section 508 standards and Section 255 guidelines. O ne of the key proposals i n the Notice of Proposed Rulemaking (NPRM) is to use the most recent version of the Web Content Accessibility Guidelines ( W CAG 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 proce ssing 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 the se programs and systems to meet the Level A and Level AA Success Criteria and Conformance Requirements speci fied 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 ove r 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, W eb 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 requireme nts specified in terms of access to functionality rather than programming languages (such as HTML or JavaScript).Evaluation of Proposed Update of Section 508 Standards and Section 255 Guidelines 1030

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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 incorporate d 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 propo sal 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 t ypes of telecommunications equipment (e.g., cell ular and wirel ine 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, w here 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

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

spe cific 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 h andling 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 benef its 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 o f 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 IC T 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 ar e 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.Evaluation of Proposed Update of Section 508 Standards and Section 255 Guidelines 1030

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### promote equality, and enhance integration into American society

. For manufacturers and developers of ICT products

, h armonizing 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 quantifie d 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 re quirements; 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 Fed eral 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 ag encies 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 be ing 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.

T he impact on computer and telecommunications equipment manufacturers from the proposed

ru le 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 informat ion, it is reasonable to expect that the costs incurred by U.S. and foreign ICT manufacturers to produc e compliant products for sale in the U.S. market would be lower than the aggregate Section 508 compliance costs estimated for Federal agencies, contracto rs, 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

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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 Sect ion 255 guidelines. All benefits and costs were

estimated for a 10

- year time horizon and converted to annualized value s using discount rate s of 7

and 3 percent.

Table ES

- 1 : Annualized Value of Monetized Benefits and Costs, 2015

– 2024 ( M illions of 2015

D ol lars )

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 a gencies from reduced call volumes $20.1 $19.8

Annualized value of monetized benefits $69.1 $67.5 *

I n

- house ICT costs $80.6 $76.3

P rocured ICT costs $74.4 $70.5

C osts 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. T hese benefits are listed in Table ES

- 2.Evaluation of Proposed Update of Section 508 Standards and Section 255 Guidelines 1030

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- 2 : Unquantified Benefits of the Proposed Rule Time saving s by people with hearing, cognitive, speech, or manual dexterity or motor impairments from
more accessible Federal Government W eb 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
electroni c ally

. Better civic engagement by persons with disabilities due to improved access to information and
services on F ederal Government W eb sites. Greater independence for persons with disabilities who can potentially access information on Federal
Government W eb 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 si tuation

, 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.

P eople 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 i ncreased accessibility of product documentation and support service s

. Federal Government access to a larger pool of developers and content creators with required accessibility knowledge and skills because of harmo nized standards

. Benefits to S tate 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 service s 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 S ections 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 bet ween $80 billion and $120 billion

, depending on wh ich 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.Evaluation of Proposed Update of Section 508 Standards and Section 255 Guidelines 1030

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## Costs of the Proposed Rule

Econometrica developed e stimates 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

.

 S oftware, Web sites, and audiovisual media evaluation

.

 E lectronic documents creation and repair

.

C osts for manufacturers to comply with the proposed Section 255 guidelines relating to providing accessible electronic support documentation and services ar e 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 als o several categories of costs that would result from adoption of the proposed rule

but could not be quantified. These costs are listed in Table E S

- 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 stan dards to have a significant

aggregate impact on compliance costs init i ally but cause only a small percentage increase in recurring annual costs

, relative to current baseline costs. We expect that c ompliance 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 pro duce and evaluate ICT products, software, services, and content.

As noted above, t he impact on telecommunications manufacturers and purchasers of telecommunications products from the proposed revisions to the Section 255 guidelines is more difficult to qu antify. 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

con sumer prices can be assessed by assuming that these manufacturers would incur complianceEvaluation of Proposed Update of Section 508 Standards and Section 255 Guidelines 1030

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### costs equal to the entire amount estimated in this analysis for Federal agencies, contractors, and

vendors (about $1 5 5 million on an annualized basis) with the aggrega te value of annual shipments in this sector (about $100 billion). Under this conservative assumption, the incremental compliance c osts 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 s tandards, net of the annualized benefits, represent about 4 .5 percent of current annual Section 508 compliance costs

. It is important to note, h owever, that there are potentially substantial compliance costs as well as significant benefits to people with disabilities, F ederal agencies, contractors, and vend ors 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 grea ter social equity, human dignity,

and fairness.

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

Econometrica ha ve made a preliminary determin ation that the benefits of the proposed update of

the Section 508 sta ndards 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 F ederal 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 electro nic and information technolog ies

.

Section 5 08 of the Rehabilitation Act ( as amended ) requires that when Federal agencies develop, procure, maintain, or use electronic and information technolog ies , they must ensure that the electronic and information technolog ies 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 impos e 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 pu blic with out disabilities

, unless it would impose an undue burden on the agency.

T he 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 “self

contained, closed products”; and electronic content, including documents, audio, video, and

multimedia. Federal agencies are required to comply w ith 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, info rmation kiosks and transaction machines, telecommunications equipment, multifunction office machines, software, W eb sites, and electronic documents.

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

the Communicat ions 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 Se ction 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/draft

rule2010.pdf

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### indicated in the 2010 ANPRM that it proposed to harmoniz e the updated Section 50 8 standards

with the current version of WCAG 2.0 , which was developed by t he 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 conten t 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 disab ilities 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 F ederal 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 cont ent produced using ICT) to meet the Level A and Level AA Success Criteria and Conformance Requirements specified for W eb pages in WCAG 2.0

. 10



### The Access Board has received numerous comments on the two ANPRM s . In the NPRM, t he

Access Board is proposing to a dopt the WCAG 2.0 S uccess C riteria and C onformance

R equirements 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, f

orms, 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 ad dress 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. T he impact of th e 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 th e 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/compo nents.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

- and

standards/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 F ederal agency components (e.g., departments or offices),

Federal and economy

- wide ICT expenditures

, and ICT sector emplo yment. 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 th is 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 a nd 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 est imates 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.

T he rapid evolution of ICT devices, platforms, applications , and consensus standards complicates evaluat ion of the proposed regulatory requirements

. Therefore, the benefits and

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

are currently available to achiev e compliance

, but also on emerging technologies that ma y 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 Pe ople W ith Disabilities

The Access Board, DOJ, and the FCC each have defined responsibilit ies relating to the development and/or implementation of current Federal standards and guidelines designed to

ensure equal access to ICT for pe ople 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 additi on, the U.S. Department of Transportation (DOT) has jurisdiction over the accessibility of ICT related to air transportation under the Air Carrier Access Act.Evaluation of Proposed Update of Section 508 Standards and Section 255 Guidelines 1030

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### standards and Sect ion 255 guidelines, F ederal, S tate, and local government agencies, private for

profit 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 S tate 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 pa rtly 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 technolog i es 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 agenc y Web

- based i ntranet and Internet information and applications. These requirements include 16 specific standards designed to ensure that Federal agenc y Web sites can be processed and interpreted by assistive technology (AT) such as

screen readers. Other parts of Section 508 specify requirements applicable to s oftware applications and operating systems , t elecommunications products , v ideo and multimedia products , “s elf

- contained, closed products ,” and d esktop and portable computers.

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

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



### The se DOJ report results are used to establish baseline levels o f 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 t echnical support

forums are available at www.section508.gov

. 14 DOJ, “ Section 508 Report to the President and Congress: Accessibility of Federal Electronic and I nformation Technology ,” September 2012.Evaluation of Proposed Update of Section 508 Standards and Section 255 Guidelines 1030

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### with disabilities when such access is readily achievable. 15 

### In 1998

, t he Access Board published

the current Se ction 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 mac hines, answering machines

, and pagers. CPE that provides both telecommunications and non

telecommunications functions is covered only to the extent it provide s telecommunications

functions. 16 

### I nterconnected VoIP equipment manufacturers are also subject to t he 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, t he 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 voice mail and interactive voice response systems (phone systems that provide callers with menus of choices). In addition,

the 2007 FCC rules extend ed Section 255 accessibility obligations to interconnected VoIP

service providers

. 17



### The more recently adopted CVAA addresse s 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 VoI P equipment and services, electronic messaging services (including email, instant messaging, and text mes saging), 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 implemen ting Section 716 in its October 7, 2011

, Report and Order and published a dditional 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 accessibl e to and usable by people who are blind or have a visual impairment, unless doing so is not achievable. The FCC issued

r egulations 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 a chievable.

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 t

han 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.Evaluation of Proposed Update of Section 508 Standards and Section 255 Guidelines 1030

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## 3

. 3

. W 3 C 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 accessibil ity 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 y ears later on December 11, 2008, represented a c omprehensive 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 bli ndness 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 th at 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 AT s.

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 enforcea ble. 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 201 4 , the European Telecommunications Standards Institut e (ETSI) published a new standard

— E N 301 549

— that uses the WCAG 2.0 Level A and Level AA S uccess C riteria as the basis to evaluate accessibility for all covered W eb and non

- W eb electronic content

. 22 

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

19 The Access Boar d 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 standa rds.

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

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### largely based on, WCAG 2. 0

. Australia, Canada, Hong Kong, and New Zealand G overnment sites are or will be required to meet the WCAG 2.0 Level A and Level AA Success Criteria and Conformance Requirements . Fran ce 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 program s and activities under other parts of the Rehabilitation

Act of 1973 . Section 501 requires aff irmative 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 accessi b le 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 e ither receives Federal financial assistance or is conducted by any Executive agency or the U.S. Postal Service (USPS)

. Each Federal agency has its own S ection 504 regulations that apply to its own programs, and agencies that provide financial assistance ha ve regulations that cover entities receiving Federal aid. E mployees 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 accessibl e construction and alterations. 25



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

e nsure that it has fully discharged its obligations to employees or the public under Section 501 or Section 504. For example, t he applicable Department of Health and Human Service s 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 wi th 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 .”Evaluation of Proposed Update of Section 508 Standards and Section 255 Guidelines 1030

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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 requirem ents 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 increa singly 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 tha t 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. B usiness es 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

i nteroperability

.

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 provis ions 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 ini tiatives 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 specif ically 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 we re 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

Pe rformance Criteria, which state in general terms the features of ICT that ensure itsEvaluation of Proposed Update of Section 508 Standards and Section 255 Guidelines 1030

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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

C ellular Tel e communications Industry Association and the S oftware & 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 ANPRM s, 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 th e 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 W eb pages in WCAG 2.0

. 27 

### There are several advantages to using this approach to u pdate 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 incon sistent 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 W eb developers.

 WCAG is w ritten to be technology neutral. The convergence of telecommunications and data processing equipment and services means that an increasing varie ty 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 be en 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 Sectio n 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

, W eb

- based intranet and I nternet information and applications

, a nd video and multimedia products. Additionally, smart phones are portable computers, telecommunications products, and self

- contained closed products .”Evaluation of Proposed Update of Section 508 Standards and Section 255 Guidelines 1030

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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 d id 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 A uthoring T ools Accessibility Guidelines and U ser A gent
A ccessibility G uidelines (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 proceeding s that would apply to provide r s 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 m arketing 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 “ t he 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 ,” update d 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 W eb technologies have become more complex,

mouse or touch

- only in terfaces 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.Evaluation of Proposed Update of Section 508 Standards and Section 255 Guidelines 1030

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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: Wh at Would Be Required?

WCAG 2.0 Level AA conformance include s 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 t hat 22 of the 38 specific WCAG 2.0 Level A

and Level AA S uccess C riteria 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 elec tronic

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 addre ssable 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 o f 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 requir ements 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).Evaluation of Proposed Update of Section 508 Standards and Section 255 Guidelines 1030

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###  Compliance with the International Standard for A ccessible 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 accessibili ty for people with disabilities who use assistive technology such as screen readers, screen magnifiers, joysticks

, and other AT s to navigate and read

electronic content.

 RTT functionality would be required where ICT provides real

- time

, two

- way voice

communication (such as telephones, w ebinars, and videoconferencing technology)

. F eatures capable of text generation would have to be compatible with real

- time voice communication used on a network. ICT would be required to interoperate eithe r 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 de scription, 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 spe cific categories of ICT :

 Software applications and operating systems.

 Web

- based intranet and I nternet 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 Sec tion 255 guidelines cover the following :

 W ired and wireless telecommunication devices such as telephones (including pay phones and cellular phones), pagers, and fax machines

.

 O ther products that have a telecommunication service capability, such as modems connected to computers and interconnected VoIP equipment

.

 E quipment 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

accessibi lity 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

.Evaluation of Proposed Update of Section 508 Standards and Section 255 Guidelines 1030

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### Proposed r equirements dealing with video accessibility for people wit h 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 requ irements, the types of electronic content that would fall under the purview of the proposed standards would be defined in more specific terms. T he Access Board is proposing to provide a list of covered forms of electronic communications originated or

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

1. P ublic

- facing content

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

a. An emergency n otification.

b. An initial or final decision adjudicating an adm inistrative 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 fo rmal acknowledgement or receipt.

f. A questionnaire or surv ey.

g. A template or form

. h. Ed ucational 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, h ardware, software (including firmware, platforms, and applications), and ICT support documentation and services would continue to be covere d under

the proposed standards. T elecommunications equipment (whether sold to the Federal

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

2.0

- based requirements in the proposed updat e 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 so ftware, hardware, and telecommunications equipment is provided in Appendix A.Evaluation of Proposed Update of Section 508 Standards and Section 255 Guidelines 1030

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## 4.4. Major New Requirement Areas in the Proposed Standards and
Guidelines

This assessment identifie s 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. A ssistive 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 service s

.

A brief discussion of each area of the proposed r ev isions with p otentially s ignificant i mpact
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, toolk its, 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 S uccess C r iteria. 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 S uccess C riteria can be applied to any technology found on the Web. Since most file types are found on the Web and much software is now Web

enabled, it is reasonabl e 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.Evaluation of Proposed Update of Section 508 Standards and Section 255 Guidelines 1030

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### The W 3C 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 S uccess C riteria, 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 ser vices, 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 an d 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 curr ently marketed software applications that are able to

claim conformance with the ATAG criteria.

41 W3C, “ Guidance on Applying WCAG 2.0 to N on

- 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 ANPR Ms 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 Associa tion (TIA)

and CT I A

– 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.Evaluation of Proposed Update of Section 508 Standards and Section 255 Guidelines 1030

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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 d evelop 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: A ssistive T echnology

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 r eaders

.

 Refreshable Braille d isplays

.

 Screen m agnifiers

.

 Adaptive k eyboards

.

 Voice

- r ecognition s oftware

.

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 i n 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, irre spective of whether or not these materials are available through a public

facing 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 S uccess C riteria as the benchmark for determining whether covered electronic content is

accessible.

Our interviews with agency representatives indicated that significant attention and resources

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

45 W3C, “ Authoring Tool Acce ssibility 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 com pleted 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 .”Evaluation of Proposed Update of Section 508 Standards and Section 255 Guidelines 1030

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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 non

Web electro nic 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 A dministration, 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 use r 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 standa rds 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 s tandards 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 s ites. 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 ) b e 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 with out the user attem pting 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.Evaluation of Proposed Update of Section 508 Standards and Section 255 Guidelines 1030

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### standards would incorporate by r eference the applicable WCAG 2.0 Level A success criterion (1.4.2) that allow s 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 Contro ls 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

, 

### c onsumer groups reported complaints that some modern products did not s upport captioning when in fact the problem was that the captioning selection was very difficult to find in the menus. The proposed rule would

increas e 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. M edia 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 curr ently 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 teletypewriter s (TTY s ). 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 estimat es that there are about 100,000 TTY u sers

. H owever, 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 an d 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 see s 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 communicat ion 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

rea l

- 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.Evaluation of Proposed Update of Section 508 Standards and Section 255 Guidelines 1030

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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 market place ) 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 S ession Initiation Pro tocol (SI P ).

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 th at 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 communica tion 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

.

 D elivery is instant and letters are viewed as they are typed

.

 B oth parties are online simultaneously, as during phone calls

.

 I n 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

.

 T yping 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 multi year 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

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### The FCC stated in its report that enabling direct text messaging to 911 by t he 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 o f 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 messagi ng is ubiquitous

— i t is widely used by individuals with disabilities and technically feasible for all covered providers to support it

— a llowing for rapid implementation of the interim solution. However, a dissenting statement of one commissioner expressed se rious 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 relia nce 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, rea l

- 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

individua ls 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 Sec ond Report and Order ¶ 132

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### capabilities for 911, the Access Board believe s 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 non

disabled users, in emergency as well as non

- emergency situations.

4. 4

. 10. ICT H ardware A ccessibility 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.

 Privac y 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 cur rently 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 f n. 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.Evaluation of Proposed Update of Section 508 Standards and Section 255 Guidelines 1030

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### guidelines would also reta in 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 t elecommunications 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 deve loper 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

A uthoring 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 i s 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 50 8 standards.

67 While Section 508 does not directly regulate private businesses, State or local governments, or any other non

Federal organizations, many State and local governments have, by their own law, held themselves to complying with

Section 508 or si milar 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 ch osen 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 portion s 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 stand ard.Evaluation of Proposed Update of Section 508 Standards and Section 255 Guidelines 1030

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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

Th e 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 gr oups 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 t o 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 prop osed 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 t he 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 o f 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 m illion 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 applicati ons ; 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

way s 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 Sec tion 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 operabilit y 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 vis ion, 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 provision s 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 implementatio n 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 pr ocessing 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 Censu s estimate definitions) who would potentially benefit may include people whose vision is corrected by using eyeglasses or contact

lense s
, people whose hearing is corrected by wearing hearing aids

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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

limitation s are corrected with eyeglasses or contacts to see material on Web sites,

softw are 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 an d 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 peo ple 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 pot ential 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 multipl e 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 stand ards 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 priva te

- sector entities may benefit from more broad

- based adoption of WCAG 2.0

- b ased

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, t he extent to which specific Federal em ployee s could benefit

from the proposed Section 508 standards would depend on the nature of their job s 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 variou s 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 2 010 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 programEvaluation of Proposed Update of Section 508 Standards and Section 255 Guidelines 1030

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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 acc essibility 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 a n addressable disability was estimated as follows:

 An h o urly wage rate was estimate d from the average annual F ederal 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

includ e 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 disabilit ies other than vision difficulties by 1 percent,

or 1 7

. 6 hours per year spent at work. The productivity improvement for people with

vision dis abilities 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

accommodation s 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 Fe deral employee s with a n addressable disability.

manager with difficulty hearing. Similarly, the proposed s ection 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 product ivity 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

i mproved W eb access on LSHPD (long

- standing health problem or disability) to non

- LSHPD wage differentials. Scenario 1 had half of the wage differential eliminated , S cenario 2 ha d 10 percentage points of the wage differential

eliminated

, and S cenario 3 had t he entire wage differential eliminated. Taking the average of the values reported on

T able 49 gives a n 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 wag e 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 W eb 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 F ederal 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 increase d 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 increase d productivity per employee with a vision disability $ 2 ,0 4 0

*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.



### T he estimated value of increased productivity averages $1,0 20 for a Federal employee with non

vision disability. A Federal e mployee with a vision disabilit y was estimated to experience an

average annual productivity improvement of $2,040

.

Estimates of the FY 2010 number s 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 number s of Federal employees with vision disabilities and other addressable disabilities. 78

Table 2 : Number of Federal Employees W ith 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 statis tics 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.Evaluation of Proposed Update of Section 508 Standards and Section 255 Guidelines 1030

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### T he 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 t hese 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 b e realized in the first year (2015) of the 10

- year an alysis period. 79

Table 3 : Estimated Benefits F rom 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 perio d 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 di sabilities being able to develop more capabilities and experience as a result of improved ICT accessibility

.

 T his assessment also does not include potential benefits accruing from increased levels of skills and experience in the pool of workers who could b e hired by Federal agencies in

the future

.

 P roductivity benefits for Federal G overnment contract or and vendor employee s we re not
estimated and included in th is analysis

. 80

79 All 2015

– 2024 dollar values shown in this table and throughout the preliminary RIA are in 2015 (i.e., inflation

adjusted) 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.Evaluation of Proposed Update of Section 508 Standards and Section 255 Guidelines 1030

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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 G overnment

- 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 pro ductivity of Federal employees

— b oth th ose with addressable

disabilities and those who have no such disabilities

— par ticularly in the first few year s after the proposed standards would take effect. For example, applying the WCAG 2.0 standard to software may absorb developer time that would other wise 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 Inte rnet 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 I nternet G ives C itizens N ew P aths to G overnment S ervices and

I nformation ,” 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 analyt ic data underscore the growing importance of F ederal W eb sites as a public resource for obtaining documentary and multimedia

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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 a nd 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 W ith 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 e stimates 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 type s 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 o n 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 th is 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 F ederal W eb

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 t his regulatory assessment.) This volume of document downloads is important because many PDF

- based forms and other documents are not currently accessible. The p roposed Section 508 standards ( E205.4) are designed to address this problem by requiring all PDFs posted on agencies’ public

- facing W eb 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 F ederal 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 mostEvaluation of Proposed Update of Section 508 Standards and Section 255 Guidelines 1030

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### of a visit was assumed to be 4 minutes. This 4

- minute visit duration figure represe nts 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 re ader

— 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 assumpti ons 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 fo r the month of February 2014, and about 4.2 minutes per visit on the

most

- visited site (ww.irs.gov). See Cli cks 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 siz e) 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 foun d 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 Expl oration: 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 user s, which found that Web tasks were about three times easier

for a control group of non

- disabled users than for users who we re blind or ha d 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 ty pe 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

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Page 32 of 80 Pages Econometrica, Inc. February 12, 2015 Table 5 : Average Amount of Time Saved Per Person W ith Vision Disabilities From Increased Web Accessibility

Estimate Component Value

Average number of visits to Federal G overnment Web sites annually 15

Average minutes spent per Federal Government Web site visit 4

Time spent on Federal G overnment 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 o f 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 vis ion 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. Acco rding 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 pe ople 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 t o 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 N ational Pop ulation 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 we re 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, S tate, or F ederal G overnment W eb site.” The survey did not ask respondents to report visits to the We b 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 estim ate of the proportion of adult Internet usersEvaluation of Proposed Update of Section 508 Standards and Section 255 Guidelines 1030

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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 W ith Vision Disabilities Who Would Bene fit 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 ab ove, 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, impro ved 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 cur rent 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

estima ted 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 e stimates 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).Evaluation of Proposed Update of Section 508 Standards and Section 255 Guidelines 1030

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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 fr om 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 governmen t Web sites that would have otherwise required in

person 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 th is 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 co nduct 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 t imes 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 estimat e 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 addr essable 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 as sumed to be made in each of the first 2 year s (2015 and 2016 ) of the 10

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### 5.3.2. Benefits for People W ith Other (Non

- V ision) Addressable Disab ilities F rom 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 vi deo, 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 vi deo and audio files posted on Federal Web sites are uncaptioned, rendering such content inaccessible. The proposed

Section 508 s tandards would more clearly require Federal agencies to caption multimedia files through incorporation of WCAG 2.0’s Success Cri teria 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 audi o 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 i mpairments would be better able to learn about Federal programs or services, get instruction on completion of F ederal 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 field s, 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/UA

1, 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 tra ck video usage, only the playing of videos through a YouTube channel or JW Player can be detected. The W eb analysis tools cannot detect videos viewed on a player

embedded on a W eb 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. Olaler e and Jonathan Lazar (2011), “ Accessibility of U.S. Federal Government Home Pages: Section 508 Compliance an d Site Accessibility Statements,” Government Information Quarterly 28 (3), 303

– 309 ; Paul T. Jaeger (2006)

,

“ Assessing Section 508 Compliance on Feder al 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 Fe deral Website Accessibility for Those with Disabilities, ” IT Professional , 7(1), 27

– 31.Evaluation of Proposed Update of Section 508 Standards and Section 255 Guidelines 1030

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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 use rs 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 t o 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 non

vision addressable disabilities would be expect ed 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 fo r 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

fac ed 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 ta sks on 10 different

W eb sites, for a total of 913 completed tasks on 100 governmental and non

- governmental W eb

sites. 98 

### Researchers then assessed the comparative task success rates between impairment groups. Relative to persons who are blind (average succes s 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 calcula te 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 Acce ss 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.Evaluation of Proposed Update of Section 508 Standards and Section 255 Guidelines 1030

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### Data and other informati on 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 im proved success rates by vision and other addressable disabilities in completing searches and transaction s that could be expected to result from adopting the proposed standards.

 Estimation of benefits from improved accessibility of other forms of ICT covere d 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

.

W 3C 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 fr om people with addressable disabilities. However, a dequate 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 inquiri es and request s to more accessible Web sites.

100 W3C

, WAI , “ Developing a Web Accessibility Business Case for Your Organization ,” updated September 7,

2012.Evaluation of Proposed Update of Section 508 Standards and Section 255 Guidelines 1030

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###  T hese 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 s a vings 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 F rom 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 accessib il ity* 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 1 9 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 $ 1 95.5 million over the 10

- year analysis period

from 2015 t hrough 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 sav ings 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,

r eview 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 recent ly released a strategic plan for addressing current Section 508 compliance shortfalls, which were attributed to three primary factors: u nder standing 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.Evaluation of Proposed Update of Section 508 Standards and Section 255 Guidelines 1030

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### applying standards

, d efinin g and measuring program success

, and d eveloping 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 req uirements, as is the case for the less concretely specified current Section

508 standards.

 The WCAG 2.0 S uccess C riteria 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 F rom Increased Availability of Accessible Telecommunications Products, Documentation, and Support Services

The current Section 255 guidelines provide benefi ts 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 Sig n 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

me eting 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.Evaluation of Proposed Update of Section 508 Standards and Section 255 Guidelines 1030

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### A deq uate data and information that can be used to quantify the potential benefits of the proposed

standards in this area w ere not provided in response to the Access Board’s two ANPRMs , and

we have not identified other sources for this information. The Access B oard is seeking input

from the public on the benefits associated with RTT in Section 5. 8 below.

T he 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 technolo gy, 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 re sult of harmonization; however, give n 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 A ccruing 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 Web

related and non

- Web

- related forms of ICT. T hese entities ar e 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 m ay 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 accessibilit y standards.

 Reference to a universal set of standards that expand s 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, 113 th 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.Evaluation of Proposed Update of Section 508 Standards and Section 255 Guidelines 1030

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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 throu gh 2024) and converted into annualized values using 7

- percent and 3

- percent discount rates. These estimates are pr esented in Table 9

. 108

Table 9 : Annualized Value of Monetized Benefits , 2015

– 2024 ( M illions 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 a gencies 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.Evaluation of Proposed Update of Section 508 Standards and Section 255 Guidelines 1030

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### Data were not available to develop monetized estimates for some categories of benefits

. A l ist 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 acces sible 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
electronic ally.

Better civic engagement by persons with disabilities due to improved access to information and
services on F ederal Government W eb sites. Greater independence for persons with disabilities who can potentially access information on Federal
Government W eb sites themselves, rather than having to rely on others to access such information for
them. Increased ability for people without di sabilities 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.

P eople 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 i ncreased accessibility of product documentation and support service s

. Federal Government access to a larger pool of developers and content creators with required accessibility knowledge and skills because of harmonized standards

. Benefits to S tate and local governments, businesses, and nonprofit entities from harmonization of
standards , including potential cost red uctions 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 nondiscri mination and equity values served by S ections 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 t ime savings or productivity increases accruing to people wi th vision and other addressable disabilities from using WCAG 2.0

- compl i a nt W eb sites or non

- Web ICT instead of Web sites and other ICT that is compliant with the current Section 508 standards?Evaluation of Proposed Update of Section 508 Standards and Section 255 Guidelines 1030

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### 3. Would any of the proposed requirements limit the productivity o f 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 us e 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. Ar e 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 a n SMS

- based approach would leave certain needs unmet that would

be addressed b y 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 i n the context of emergency calls as significant in non

- emergency situations?



# 6 . Baseline Compliance Cost s

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 coll ected 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. S elected

results from the survey are presented in App endix 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 5 08 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 c ompliance.

109 DOJ, “ Section 508 Report to the President and Congress: Accessibility of Federal Electron ic and Information Technology ,” September 2012.Evaluation of Proposed Update of Section 508 Standards and Section 255 Guidelines 1030

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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 Feder al 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

- H ouse Baseline Costs

6.1.1. Section 508 Policy Development and Implementation for Federal Agencies All but the smallest agencies ha ve Section 508 offices. Section 508 offices most frequently

evaluate W eb 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. B aseline 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 l arge >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 s mall <100 26 $0

All agencies 318 $362,158

B aseline policy c ost $115,166,236

* Agency c omponents 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 i n different agency

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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 compl y 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 8 1

, 639 Federal employees in information technolo gy occupations in 2011. These employees were assumed to receive an average of 2 hours of training annually related to Section 508 compliance. 111



###  T here were 41,874 Federal employees in contracting

- related occupations in 2011. These employees were assumed to r eceive an average of 1 hour of training annually.

 T here were 7 6

, 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 d irect expenses (or “out

- of

- pocket costs”) of providing training var y 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 a dditional employee complete an online training course available on www. s ection508.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 expense s 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 emplo yees in that occupation al category

.

 W age costs for employees receiving train ing were multiplied by a factor of 1.5 4 to
account for benefits and other non

- wage compensation.

B aseline 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 thes e 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).Evaluation of Proposed Update of Section 508 Standards and Section 255 Guidelines 1030

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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 trai ning c ost (1) + (2) $38,577,915



### D irect 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. Develop ment of Accessible Software, Web Sites, and Audiovisual Medi a 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 followin g 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 “i nformation s ecurity a nalysts, We b

d evelopers, and c omputer n etwork a rchitects ” occupational group , half were assumed to devote time to developing Section 508

- compliant Web sites, forms, and applications. 114

113 A detailed breakou t 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 St atistics (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

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###  All Federal audiovisual production employees were assumed to devote time to develop ing Section 508

- compliant audiovisual media.

 The average Federal employee work s 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

ensur ing that the software, Web, and multimedia products they develop are Section 508 compliant. 116



###  Direct wage costs were multiplied by a factor of 1.5 4 to account for benefits and other

non

- wage compensation.

B aseline 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 d evelopment 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.



### C ompliance 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 d evelopers must spend a certain percentage of their time evaluating and testing the software, Web programming, and multimedia they design and produce

. I t is

reasonable to assume that evaluation time can be estimated as a percentage of the time spen t developing these forms of ICT.

Accordingly, b aseline 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 Entitie s 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.Evaluation of Proposed Update of Section 508 Standards and Section 255 Guidelines 1030

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###  Incorporating Section 508 compliance into these forms of ICT dev eloped 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 accessi bility standards is equal to 2 5 percent of the development time devoted to Section 508 compliance for each of these type s of ICT developed by Federal agencies

. 117



### B aseline 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 t esting /

evaluation cost $34,565,015 $4,509,147 $1,603,153 $40,677,315



### C ompliance costs for evaluating and testing software, Web, and multimedia ICT de veloped by Federal employees are estimated at $ 40.7 million annually.

6

. 1. 5

. Creation and Repair of Electronic Documents and O ther Electronic Content This cost element is the most difficult to estimate, but it is also likely to account for the largest

sha re 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 r epairing electronic documents was developed using the following assumptions:

 The 199,526 Federal employees in the occupational categories included in Table D

- 3

s pend at least some time creating or repairing Section 508

- compliant electronic

documents.

 The average Federal emplo yee work s 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 evaluat ion. 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: R eview C urrent S oftware T esting M isconceptions ,” 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.Evaluation of Proposed Update of Section 508 Standards and Section 255 Guidelines 1030

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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 a verage hourly wage rate ($42.13) for

the occupational category included in this analysis

, multiplied by a factor of 1.5 4 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



### C ompliance 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 ( M illions)
Cost Component Annual Cost

Policy development and implementation $115.2

Employee training $38.6

Software, Web, and audiovisual development $162.7

S oftware, Web sites, and audiovisual media evaluation $40.7

E lectronic 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 compl ies 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, b uilding accessibility into documents typically involves less time and effort than ensuring compliance with a much larger set of s tandards applicable to Web sites.Evaluation of Proposed Update of Section 508 Standards and Section 255 Guidelines 1030

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### procurement of compliant ICT products, services, and content from F ederal 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 I CT 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, howeve r, 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 co mpliance

- 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, F ederal 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 estim ate of IT spending is appropriate ly 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 intell igence 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 F ederal

‘ 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 appl icable 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

t he 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 prop osed Section 508

standards. I f 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 F rom Contractors and

Vendors The high and low estimates of total Federal ICT spending ($12 0 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 th ese two variables as follows:

 Each of the two estimates of F ederal 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 F ederal 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 Sect i on 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 esti mates on IT spending within the U.S. intelligence community .” Quoted in Information Week, “ Federal IT Spending Likely to Decline ,” June 20, 201 2.

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 a nalysis are taken into account because the cost estimate s 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 I C T Purchase Share , 2012

Calculation Element OMB Deltek

Federal ICT spending (millions) $80.0 $120.0

High estimate of Federal I C T purchases (millions) $52.8 $52.8

Low estimate of Federal I C T purchases (millions) $43.9 $43.9

High estimate of Federal I C T purchase share 66% 44%

Low estimate of Federal I C T purchase share 55% 37%



### The average of the four estimates of Federal I C T 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

B aseline 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 . P rocured ICT accounts for 48

percent of total ICT spending, while in

- house ICT accounts for 52 percent of total ICT spending.

 Apply ing 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 proc ured 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 ( m illions) $ 962.3



### Baseline compliance costs for procured ICT we re estimated at $ 962.3 m illion in 2011

. It is important to note that th is 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 hi gher 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 con tractors 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 thanEvaluation of Proposed Update of Section 508 Standards and Section 255 Guidelines 1030

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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 W ith 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 t o develop and provide user guides, installation guides, and product suppo rt in alternative formats.

The most recent Census data available indicate that there were 1,3 84 U.S. communications equipment manufacturers (NAICS code 334 11, 33421, and 3342 2) with 120,265 employees in

2011. 124 

### However, there are t hree 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.

I n any event, i t is unlikely that the costs telecommunications manufacturers incur to comply with

the equipment accessibility provisions in the current Section 255 guidelin es can be estimated. For large manufacturers, c ompliance 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 existi ng industry accessibility standards and guidelines, including WCAG and hearing aid compatibility.

if the manufacturers were to produce and sell separate versions of these products spec ifically 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 o f 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.Evaluation of Proposed Update of Section 508 Standards and Section 255 Guidelines 1030

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###  Suppliers and vendors are encouraged to develop accessible products and services and include contract language about accessibility and compatibility, as appro priate.

 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 f our cate gories of proposed information collection requirements for telecommunications equipment and CPE manufacturers :

 S upport documentation must be offered that list s and explains how to use the accessibility and compatibility features of ICT

.

 E lectronic support documentation (Web site support, PDF versions of user’s manuals) must meet the applicable accessibility standards (WCAG 2.0 or PDF/UA

- 1).

 N on

- electronic support documentation must be provided in alternate formats (e.g., braille, large print) that are usab le by users with vision impair ments upon request

.

 S upport services (e.g., help desks) must offer accessibilit y and compatibility information, include a contact method (e.g., point of contact), and accommodate the communication

needs of individuals with dis abilities

.

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 p roduct 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 20 12

. 127



###  The fully load ed 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

E C0731I1 , 2012, released August 29, 2014.Evaluation of Proposed Update of Section 508 Standards and Section 255 Guidelines 1030

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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 : Annu a l Baseline Compliance Cost Estimates ( B illions)
Monetized Cost Component Value

Baseline compliance cost for in

- house ICT $1.0 42

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 co ntent 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 equipm ent that complies with the current Section 255 guidelines?Evaluation of Proposed Update of Section 508 Standards and Section 255 Guidelines 1030

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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 Sectio n 508 standards are not adopted. Recent Federal Government initiatives ar e 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 f or 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, i ncreased 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 con strained 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 a nd 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 use d 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 Conforma nce Requirement for Electronic

Documents ,” June 20, 2012.

130 Steven VanRoekel, U.S. Chief Information Officer, “ Federal Information Techno logy, FY 201 4 Budget

Priorities

, ” undated presentation.

131 Executive Office of the President, “ The Common Approach to Federal Enterprise Architecture ,” May 2, 2012.Evaluation of Proposed Update of Section 508 Standards and Section 255 Guidelines 1030

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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 evaluat ions. 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 tha t 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 w ould 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 re quirements.



## 7.2. Factors Affecting Telecommunications Manufacturer Costs to Comply W ith the Section 255 Guidelines

Since the current Section 255 guidelines were adopted, the telecommunications equipment sector (especially smartphones and other wireless co mmunications 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 implem ented 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 requir ements.” 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 W eb

- based user interfaces. 134



### Similarly, th e 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 O ther 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 W ireless submitted to the docket, March 11, 2013.

134 HTK Horizon, “ HTK Horizon Hosted Telecom Services Supporting the Real

- Time Text Alliance ,” viewed

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### could reduce the amount of time required for telecommunications equipment manufact urers to prepare accessible electronic documentation and Web support materials.



# 8

. Current Practices and Potential Incremental Cost s Associated W ith Major New Requirements in the Proposed
Rule

Many aspects of the proposed Section 508 r equir e ments 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 increa se 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 reduc e 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. Propos ed r evisions 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 large ly 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 m ajor software vendor s currently provide users with extensiv e 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 st andards 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 hav e 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 wou ld 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, t here would not b e measurable increases in cost in these

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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, s oftware developers (both Federal and contractor employees) would require

additional train ing, and government evaluation, testing, and acquisition protocols would need to

be revised. We expect that most o f 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 coul d 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, platf orms , and systems appear to be readily available in the current marketplace. 136



## 8. 3. Area 3: Authoring Tools

V endors who develop and market authoring tools will incur significant costs to design and implement the capabilities required by the proposed standa rds. 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 author ing 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

governm ents in developed coun tries.

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. T he proposed requirements do not appear to extend past the boundaries of ot her 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 Scree n 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

wi th 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.Evaluation of Proposed Update of Section 508 Standards and Section 255 Guidelines 1030

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### leg acy 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 evaluat e software, Web sites, and audiovisual media , but it would also simplify the evaluation and reduce the need to make subjective judgments about comp liance

. 140 

### For example, t he 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. H owever, 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 Acce ssibility 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 as sume 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 st andards.

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.Evaluation of Proposed Update of Section 508 Standards and Section 255 Guidelines 1030

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### Rather than setting videos and other multim edia 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 achie ved 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 agen cy costs associated with complying with this proposed requirement were developed.



## 8. 8. Area 8: User Control s for Captions and Video Description

We have not been able to identify adequate data and information that can be used to quantify the potential impa ct 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

8.1 2 below.



## 8. 9. Area 9: RTT Functionality

In discussing the costs of RTT to ind ustry, 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 the se 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

manufactu re 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 8.1 2 below.

As discussed in Section 5. 5 above, t he Access Board is seeking input from the public on whether to retain the RTT provisions in the proposed Section 508 s tandards and Section 255 g uidelines 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 . Q uestions 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 ha rdware 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.



## 8.1 1

. 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 sub set 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 typ es of errors can require widely varying degrees of effort to repair. With this disclaimer, t he results of this review are presented in Table 20

.

143 For example, we were not able to identify any GS A materials that provide d 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 conta ct 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 comm unity 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.Evaluation of Proposed Update of Section 508 Standards and Section 255 Guidelines 1030

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Page 63 of 80 Pages Econometrica, Inc. February 12, 2015 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 usi ng 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 ) ha d fewer th an 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 rev isions 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 c oncern. 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.Evaluation of Proposed Update of Section 508 Standards and Section 255 Guidelines 1030

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## 8. 1 2

. Request for Comment on Compliance Costs

1. R elatively 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 pr oposed 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 requiremen ts 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 co mmunication 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 functio nality in the next 3 to 5 years?



# 9

. Preliminary Cost Estimates for the Proposed Rule

Ideally, this preliminary assessment would include e stimates of the incremental costs associated

with meeting each of the proposed accessibility standards. However, t he increase in complianceEvaluation of Proposed Update of Section 508 Standards and Section 255 Guidelines 1030

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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 add ition, 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 r ule

.

The approach used instead in this analysis was to eva luate 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 increase s in costs for in

- house procured ICT.

W e 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

- H ouse ICT

9.1.1. Section 508 Policy Development and Implementation The proposed rule would require revision s 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 re vised 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 disseminate d 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 as sumed 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 one

time impact of the proposed r ule on policy development and implementation costs.

R ecurring annual costs would likely increase by a small percentage as well , because the

pro posed standards and guidelines are more extensive and specific than the current Section 508Evaluation of Proposed Update of Section 508 Standards and Section 255 Guidelines 1030

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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 a gency

- specific directives and guidance than is the case with the current Section 508 standards. I t 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 propo sed 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 Em ployees The proposed rule would require extensive additional training for Federal agency IT employees, as well as employees involved in contract ing

, writing, editing, audiovisual production , and the

other occupations included in Table D

- 3

. A gencies would b e likely to incur a substantial one

time increase in training cost s 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 S uccess C riteria and C onformance

R equirements for non

- Web ICT ( s ee 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 employeeEvaluation of Proposed Update of Section 508 Standards and Section 255 Guidelines 1030

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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 ye ar.

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 t he platforms and applications they create and modify compl y 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 ( s ee Section 8.2).

 Developers of authoring tools would need additional time to ensure that this software complies with the proposed Section 504 requirements ( s ee Section 8.3).

 Developers of software that functions as AT woul d need additional time to ensure that these applications comply with the proposed Section 503 requirements for AT ( s ee Section 8. 4 ).

 Multimedia developers would need to spend time to comply with the proposed requirements for captioning and user controls ( s ee Sections 8.7 and 8.8).

 A dditional time would be required for these employees to develop compliant program documentation and support materials.

146 The size o f 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.Evaluation of Proposed Update of Section 508 Standards and Section 255 Guidelines 1030

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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 complianc e 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 preli minary 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 i nitial 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. T he 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 tes ting 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 t ime 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.Evaluation of Proposed Update of Section 508 Standards and Section 255 Guidelines 1030

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### It is possible that the amount of time required for evalu ation 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 propos ed 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 e ffort (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 electro nic 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 p roposed 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, t here 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.Evaluation of Proposed Update of Section 508 Standards and Section 255 Guidelines 1030

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### compliant under the proposed standards because current authoring tools and templa tes 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 en sure 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 propos ed 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 t he 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 electr onic 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 S ection 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

- H ouse 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 varyi ng types of electronic documents and other electronic content. The addition or deletion of single requirements would not materially affect the total time required.Evaluation of Proposed Update of Section 508 Standards and Section 255 Guidelines 1030

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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 co uld plausibly be much higher or lower than those used to develop the preliminary estimates of incremental compliance costs in this preliminary analysis.

Table 26 pre sents 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 th e 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

- H ouse 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%

S oftware, Web sites, and
audiovisual media evaluation 40% 10% 20% 40% 10% 20%

E lectronic 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 component s were aggregated to develop preliminary estimate s of the overall i ncrease 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

.Evaluation of Proposed Update of Section 508 Standards and Section 255 Guidelines 1030

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Page 72 of 80 Pages Econometrica, Inc. February 12, 2015 Table 27 : Projected Increase in Annual Agency Compliance Costs for In

- H ouse ICT ( M illions 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 i ncrease in a gency c osts for in

- house ICT $205.4 * $65.8 *

Percentage of a nnual b aseline c osts 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 $20 5 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 compli ance costs, the increase in recurring overall Federal agency compliance costs is projected to be approximately $ 6 5 million annually. This represents an increase of about 6 percent of annual baseline compliance costs estimated for agencies to comply with th e 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) pre sent 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

- H ouse ICT ( M illions
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.Evaluation of Proposed Update of Section 508 Standards and Section 255 Guidelines 1030

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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 meet s 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 IC T were not directly calculated. Similarly, adequate data are not available to esti mate 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 ca n be developed as follows:

 T he share of total Federal agency ICT procured from contractors and vendors is 48 percent ( s ee 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 increase s in compliance costs for procured ICT developed using this approach are presented in Table 29

.

Table 29 : Estimates of Increased Costs Associated W ith Procured I C T ( M illions 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 $6 1 million higher under the proposed Section 508 standards

.Evaluation of Proposed Update of Section 508 Standards and Section 255 Guidelines 1030

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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 20 2 4 are presented in Table 30

.

Table 30 : Present Value in 2015 of Monetized 2015

– 2024 Costs for Procured ICT ( M illions 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 $52 3 million using a 7

- percent discount rate and $6 01 million using

a 3

- percent discount rate.

As noted in Section 6. 2

, this estimate of projected cost increase s 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 ag encies for compliant ICT products and services, as both higher purchase costs and lower contractor profits would represent social costs of the proposed

S ection 508 standards.



## 9. 3 . Compliance Costs Associated W ith 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 c ould 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 8.1 1 , s everal of the largest telecommunications manufacturers appear to have relatively accessible support sections of their public

- facing Web sites. Howeve r, 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. C osts for manufacturers with Section 255 obligations to ensure that their product documen tation and support services conform to the proposed guidelines were estimated as follows:

 According to t he 20 11 Statistics of U.S Business , there were 2 63 t elephone apparatus

manufactur ers (NAICS 33421), 73 0 r adio and television broadcasting and wireless communications equipment manufacturers (NAICS 33422), and 391 electronic computer manufacturers (NAICS 3341 1 1 ). For this assessment, we assumed that firms with 20 orEvaluation of Proposed Update of Section 508 Standards and Section 255 Guidelines 1030

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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 8.1 1 ) were assumed to be representative of the 217 firms

with 100 or more employees in this sector. F irms with between 20 and 99 employees were assumed to have substantially less extensive Web support and electronic product

documentation that would need t o 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 D OT 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 pe r

- 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 R estructuring or r epairing the product support section of a Web site (and in some instances, improving the navigation to that section from the home page) sh ould typically require less effort than overhauling an entire Web site. The telecommunications product support sec tions 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 2 5 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 onli ne 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 airlin e 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

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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. T elecommunications and CPE manufacturers typically make large volumes of prod uct documentation and support materials available in electronic form . I t
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 obligation s. 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 cos ts that would be incurred by telecommunications equipment manufacturers to provide accessible electronic product documentation and Web

- based support. The se 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 1 00 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 $9 2

, 002

, 5 00

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 S ection 255 guidelines relating to electronic product documentation and support are estimated at $ 17 million in 2015 and $ 9 2

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 specifi cally requested in the comments.



## 9. 4

. Summary of Monetized and Unquantified Costs of the P roposed
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 usingEvaluation of Proposed Update of Section 508 Standards and Section 255 Guidelines 1030

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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

Annuali z ed 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 $ 1 65.6 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 cost s 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 manufac turers 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

ass uming 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 thi s sector (about $100 billion). Under this conservative assumption, the incremental compliance c osts incurred byEvaluation of Proposed Update of Section 508 Standards and Section 255 Guidelines 1030

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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 pro

jecting 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/coord inator 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 employ ees (i.e., not just developers, programmers, and evaluators)?

3. Is the amount of Section 508 training currently provided to G overnment 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 testa ble 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 wo uld 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 c ontractors 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.Evaluation of Proposed Update of Section 508 Standards and Section 255 Guidelines 1030

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### b. I f 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

substantial ly 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 ident ified by the FCC for implementing SMS

- based text to 911 to comply with the proposed RTT requirements ? I f so, please indicate the scope and nature of th e se costs and quantify if possible.

8. Are there other categories of Federal employees likely to have respon sibility 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 hav e 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 dis count 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, h owever, that there are important benefits to people with disabilities,

F ederal 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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### T he 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 evo lution 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

WCA G 1.0 Priority 1 recommendations.

Evolution of Current Section 508 Part 22 Standards F rom WCAG 1.0 Standards

F ive provisions in Part 22 of the Section 508 standards do not have close analogs to WCAG 1.0 Priority 1 checkpoints

, but they w ere 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 counterp arts. 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 F rom Current Se ction 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 n ew requirements in WCAG 2.0 that address specific gaps in the current

Section 508 s tandards , 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 .”Evaluation of Proposed Update of Section 508 Standards and Section 255 Guidelines 1030

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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 a re 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. Implementi ng 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 requ ired 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

- T ext

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

- O nly and
Video

- O nly A 1194.22(a) A descriptive text transcript is provided for non

live, W eb

- based audio. A text or audio description is provided for non

- live, W eb

- based
video

- only.

1.2.2 Captions

(Prerecorded) A 1194.22(b)

and .24 (c) Synchronized captions are provided for non

- live,

W eb

- 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, W eb

- 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, w ebcasts, 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

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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 T ext 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 f lash 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 W eb

pages.
2.4.2 Page Title A 1194.22(i) The W eb page has a descriptive and informative page title.

2.4.3 Focus Order A New The navigation order of links, form elements,

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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 W eb 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 W eb 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 1194.2 1 (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 chan ge 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 W eb 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 W eb 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

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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 acce ssibility 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 cr iteria, 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 non

Web 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 su ccess 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 N on

- 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 te chnology 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 diffe rent contexts of use.”Evaluation of Proposed Update of Section 508 Standards and Section 255 Guidelines 1030

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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, m any of these requirements are based

on WCAG 2.0 success criteri a.

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 M anagement A pplications

— Electronic D ocument F ile F ormat E nhancement for

A ccessibility

— 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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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
allow s 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 destin ation format.Evaluation of Proposed Update of Section 508 Standards and Section 255 Guidelines 1030

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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

T he 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 A TAG 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.Evaluation of Proposed Update of Section 508 Standards and Section 255 Guidelines 1030

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- 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 P roducts 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 O utput

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 a vailable to all users. Speech

shall be recorded or digitized human or synthesized.

402.2.1 User C ontrol 1194.2 5 ( e ) *Excepted 707.5.1 Speech shall be capable of being repeated or interrupted.

402.2.2 Braille

I nstructions New *Excepted 707.8 Braille instructions for initiating the speech mode shall be provided.Evaluation of Proposed Update of Section 508 Standards and Section 255 Guidelines 1030

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Reference Heading 508
Reference 255

Reference 707

Reference Requirement

Stated in Reference

402.3.1 Private

L istening 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

- P rivate

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
fun ction shall be provided to automatically reset
the volume to the
default level after

every use.Evaluation of Proposed Update of Section 508 Standards and Section 255 Guidelines 1030

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Reference Heading 508
Reference 255

Reference 707

Reference Requirement

Stated in Reference

402.4 C haracters 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.

40 3 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.Evaluation of Proposed Update of Section 508 Standards and Section 255 Guidelines 1030

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Reference Heading 508
Reference 255

Reference 707

Reference Requirement

Stated in Reference

40 4 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 cross

manufacturer, non

proprietary, industry

standard 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.Evaluation of Proposed Update of Section 508 Standards and Section 255 Guidelines 1030

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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 ra ised above surrounding
surfaces

. 407.3.2 Alphabetic

K eys 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 K eys 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 R epeat 1194.23(k)(3) New If key repeat is supported, the delay before repeat shall be adjustable to at

l east 2 seconds. Key repeat rate shall be adjustable to 2 seconds per
character.Evaluation of Proposed Update of Section 508 Standards and Section 255 Guidelines 1030

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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

I ndicators 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 S ignaling 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 M achines shall provide the opportunity for the same degree of privacy of input and output available to
all individuals.Evaluation of Proposed Update of Section 508 Standards and Section 255 Guidelines 1030

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Reference Heading 508
Reference 255

Reference 707

Reference Requirement

Stated in Reference

407.11 Keys, T ickets,

and F are C ards 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 R each 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

spe cified 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.Evaluation of Proposed Update of Section 508 Standards and Section 255 Guidelines 1030

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Reference Heading 508
Reference 255

Reference 707

Reference Requirement

Stated in Reference

410 ICT W ith Two

- Way Voice Communication

410.2 Volume G ain 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

C oupling 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

- T ime T ext

Functionality New New Wherever ICT provides real

- time
voice communication, ICT shall also support
real

- time text functionality

.Evaluation of Proposed Update of Section 508 Standards and Section 255 Guidelines 1030

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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 pass

through 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

C ontrols 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.Evaluation of Proposed Update of Section 508 Standards and Section 255 Guidelines 1030

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Reference Heading 508
Reference 255

Reference 707

Reference Requirement

Stated in Reference

413.1.2 Audio

D escription
C ontrols 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 Se c. C201.1 would not have to comply with this proposed requirement.
Source: Econo metrica, 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 s upport d ocumentation and s ervices . 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

Documentat i on 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 Alternat i ve

Formats for Non

E lectronic 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.Evaluation of Proposed Update of Section 508 Standards and Section 255 Guidelines 1030

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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 W ith 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 W ith 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 XEvaluation of Proposed Update of Section 508 Standards and Section 255 Guidelines 1030

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- 20 Econometrica, Inc. February 12, 2015 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

- P rivate 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 sub

provisions) 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 sub

provisions) X

408 Display Screens

, 408.1 General X 409 Transactional Outputs , 409.1
General X

410 ICT W ith 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 XEvaluation of Proposed Update of Section 508 Standards and Section 255 Guidelines 1030

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- 21 Econometrica, Inc. February 12, 2015 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 W ith 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 sub

provisions) 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.Evaluation of Proposed Update of Section 508 Standards and Section 255 Guidelines 1030

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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 ext ent and severity of disabilities in the U.S. population is available from a variety of Government data sources . The most recent SIPP provide s 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 c ould 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 re sults

from the 2010 SIPP data are presented in Table B

- 1. 161

160 The SIPP is a household

- based survey designe d 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 heari ng (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 d ifficulty 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.Evaluation of Proposed Update of Section 508 Standards and Section 255 Guidelines 1030

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- 2 Econometrica, Inc. February 12, 2015 Table B

- 1 : U.S. Population W ith 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 impairment

used 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 ICT

addressable
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 1 4

. 4 million people age 15 to 64 and 1 4

. 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.Evaluation of Proposed Update of Section 508 Standards and Section 255 Guidelines 1030

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- 3 Econometrica, Inc. February 12, 2015 

### 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 d isabilities 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



###  Per sons 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 Sta tes 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 sever ity 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 W ith Assistive Technology. The SIPP data is not suffi ciently 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 th is 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 c ognitive 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 requi rements. 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 gr oup 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 Thr eshold: 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

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## B .2

. Use of Electronic Technologies by People W ith Disabilities

Federal Government agencies increasingly rely on Web sites, applications, and forms to provide information and facilitate transactions with individuals, businesses, and organizations. The 201 0

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 ICT

addressable disabilities as follows:

 The estimated numbers of peop le 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 T able 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



### C alculations of the numbe rs 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 W ith 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 disabi lities, but most of this difference is attributable to age, rather than the type of disability.Evaluation of Proposed Update of Section 508 Standards and Section 255 Guidelines 1030

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- 2 : U.S. Online Population W ith Addressable Disabilities, 2010

Estimate C omponent Age 1 5 to 64 Age 65 and over Age 1 5 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 occu rring 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 W ith 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

disabilit ies , along with Econometrica es timates of the number of employees with disabilities that are most likely to be addressed by ICT accessibility standards (“addressable disabilities”)

. 169

169 OPM, Fe deral 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 visi on, 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.Evaluation of Proposed Update of Section 508 Standards and Section 255 Guidelines 1030

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- 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 emplo yees or those from some other Federal entities.



### A bout 3 6 ,0 00 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, s ome Federal employees who did not report having a disability may have single or multiple disabilities that make it dif ficult to use

inaccessible ICT.

Employees of Federal Government contractors perform a substanti al 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.Evaluation of Proposed Update of Section 508 Standards and Section 255 Guidelines 1030

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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 fou r areas:

 G eneral processes for implementing Section 508

.

 P rocurement

.

 A dministrative complaints and civil actions

.

 Web site , forms, and applications

.

The DOJ report indicated that the extent of compliance varies among agencies (and their component branch es, 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 trainin g or informational videos or multimedia productions.

 About 40 percent of agency components provided Section 508 training

.

 C omponents provided only a small number of hours of training to their I C T developers ( just over 1 hour annually on average ) and the a cquisition workforce (less than 1 hour).

171 DOJ, “Section 508 Report to the President and Congre ss: 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”

— b ranches, divisions, and offices. T o obtain the most comprehensive and reliable data possible, the survey asked the F ederal agencies to identify components within each agency that were responsible for each category of duties referenced in each section of th e 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.Evaluation of Proposed Update of Section 508 Standards and Section 255 Guidelines 1030

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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 Sup port 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 W eb 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 W eb 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

W eb 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,

includi ng testing developed videos or multimedia production for compliance ( Table C

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- 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 P er 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 p roviding 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 solicitati on.Evaluation of Proposed Update of Section 508 Standards and Section 255 Guidelines 1030

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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 procure ment (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 embedde d 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

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- 8 : Agency Web Site Compliance Testing

Q. V .A. 7

. Web Policy on Testing Percentage

R outine automated and manual evaluations 28%

R outine automated evaluations 6%

R outine manual evaluations 24%

E valuate 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 c aptioning and audio description (Table C

- 9)

.

Table C

- 9 : Agency Web Site Compliance W ith 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.Evaluation of Proposed Rule of Federal ICT Standards and Guidelines 1030

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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 assessin g 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 conform ance 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 essen tially 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 ( M illions)

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 201 4 Budget

Priorities ,” and “ Federal Information Technology

, FY 2013 Budget Priorities: Doing More W ith Less ,” undated presentations. IT is defined as “any equipment or interconnected system or subsystem of equipment that is used in the automatic acquis ition, 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 a nd 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 Admi nistration, 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.Evaluation of Proposed Rule of Federal ICT Standards and Guidelines 1030

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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 G overnment accounting and business intelligence firm that provides projections of future contracting opportunities. Deltek estimates that Federal ICT spendin g 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 quasi

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

weap ons systems, and estimates on IT spending within the U.S. intelligence community .” Quoted in Information Week, “ Federal IT Spending Likely to D ecline ,” June 20, 2012.Evaluation of Proposed Rule of Federal ICT Standards and Guidelines 1030

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- 2 : Federal Purchases F rom Selected ICT Sectors, Calendar Year (CY) 2011

NAICS Code and Description Number of
Purchases Millions of Dollars

Computer and electronic product manufacturing

334111 E lectronic computers 37,078 $3,581.5

334112 C omputer storage devices 3,994 $321.2

334113 C omputer terminals 421 $42.0

334119 O ther computer peripheral equipment 7,631 $794.3

334210 T elephone apparatus 4,240 $742.8

334220 R adio and television broadcasting and wireless communications equipment 14,979 $5,470.8

334290 O ther communications equipment manufacturing 12,580 $2,103.3

334310 A udio and video equipment 3,729 $135.7
Manufacturing subtotal 84,652 $13,191.6

Information services

511210 S oftware publishers 15,950 $1,377.5

514210 D ata 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 D ata processing, hosting, and related services 7,479 $1,229.9

519130 Internet publishing, broadcasting, and Web search portals 1,989 $82.6

5121 M otion picture and video industries 1,955 $70.8

5122 S ound recording industries 268 $5.8

5141 I nformation services 4,035 $474.4

513/517 T elecommunications services 87,623 $8,283.7

515 B roadcasting/cable services 4,332 $71.6

Information services subtotal 124,669 $11,902.7
Office equipment rental and leasing

532420 O ffice equipment rental and leasing 5,459 $307.6
Rental and leasing subtotal 5,459 $307.6
Computer systems design and related services

541511 C ustom computer programming services 21,380 $5,887.4

541512 C omputer systems design services 21,268 $9,885.1

541519 O ther computer

- related services 75,659 $11,918.2
Computer services subtotal 118,307 $27,69 0.7

Total IT purchases 333,807 $5 3 ,0 92.7

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 $5 3 .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).Evaluation of Proposed Rule of Federal ICT Standards and Guidelines 1030

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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

- r elated o ccupations

Information t echnology (2200) 81,639 $93,100

IT subtotal 81,639 $93,100

Contracting

- r elated o ccupations

Contracting (1102) 36,890 $85,541

Purchasing (1105) 3,329 $48,663

Procurement t echnician (1106) 1,655 $45,448

Contracting subtotal 41,874 $81,025

Other o ccupations l ikely to h ave Section 508 c ompliance o bligations

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.”Evaluation of Proposed Rule of Federal ICT Standards and Guidelines 1030

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### Of the approximately 200,000 Federal employees in these selected occupations, 4 1 percent ( 8 1

, 639 ) work in IT and another 21 percent (41,874) work in contracting

- related jobs

. It should

be n oted 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 regul ar performance of thei r 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 ( M illions)
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 (33 4 118 ), 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 2 55 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 fore ign 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.Evaluation of Proposed Rule of Federal ICT Standards and Guidelines 1030

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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 o f 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 T able 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 5 0 percent of SOC 151179 employees. Source: BLS Occupational Employment Statistics for May 201 2.



### 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

- C omputers 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. T he survey does not cover the self

- employed, owners and partners in unincorporated firms, household workers, or unpaid family workers.Evaluation of Proposed Rule of Federal ICT Standards and Guidelines 1030

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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 ( M illions)

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.Evaluation of Proposed Rule of Federal ICT Standards and Guidelines 1030

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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 ( M illions)

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 W eb 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.