December 8, 2000

U.S. National Commission on Libraries
and Information Services
1110 Vermont Ave., NW, Suite 820
Washington DC 20005?3552

Background:

The American Council of the Blind (ACB) is the leading national organization of and for blind adults in United States with tens of thousands of members, and more than seventy affiliates across the United States. ACB strives to increase the independence, security, equality of opportunity and to improve the quality of life for all blind and visually impaired people. The American Council of the Blind is pleased to provide comment on this document.

ACB would like to thank the U.S. National Commission on Libraries and Information Science (NCLIS) for their thoughtful and diligent efforts to address the informational needs of people with disabilities. The American Council of the Blind is confident that with input from disabled consumers, this document will provide the valuable information to the Congress and the Administration that is necessary to empower and enable federal government to implement effective policy and practices that ensure all public, government information is available, usable and accessible to people with disabilities including those with visual impairments.

Section By Section Analysis:

1.B. Individual users of government information are extremely diverse in terms of computer and information literacy skill levels, specific kinds of information needs, economic status, geography, and other demographic variables.

Comments:
ACB believes that it is imperative that the federal government make information available to all American citizens regardless of whether citizens have access to a computer and/or are computer literate. Having information available only on websites does not qualify as "available and accessible." This is especially true for people who are blind and visually impaired. The unemployment rate for blind people in the United States is approximately 76 percent. Often, people with disabilities cannot afford computers nor do many have access to an available accessible computer. Most blind and visually impaired people need specialized software and adaptations in order for a computer to be usable. An example is screen-reading software that reads information which is displayed on a computer monitor aloud, for someone who can't see the screen.

ACB recommends that government information be made available through a variety of avenues. In many instances government publications are available through government sponsored toll?free technical assistance lines, and often federal government documents can be ordered be though toll?free lines as well. These types of services benefit a range of populations, including people with disabilities who may not own a personal computer or have adequate access to facilities where a computer is available.

ACB strongly urges that federal government entities comply with Section 504 of the Rehabilitation Act as amended. Section 504 requires that entities receiving federal money make their programs and services accessible to people with disabilities. This means that all federal government information that is available and targeted to the public, has to also be accessible to people who are blind or visually impaired. Having information available in a variety of formats is the only way to comply with this requirement and hence provide accessible information to people who are blind or visually impaired. Accessible formats include large print (i.e. 14?16 point font), audio?cassette, braille, accessible electronic documents.

ACB suggests that NCLIS examine the policies and practices that are currently being successfully used by federal agencies that are accomplishing the goals of making information accessible to disabled populations. An example of one such agency is the U.S. Access Board.

1.D: FirstGov is a step in the right direction but has a long way to go before becoming fully effective.

Comments:
ACB understands the value of websites such as FirstGov. Having electronic information centralized on a website such as Firstgov makes information gathering easier for everyone. Information available through an accessible website is extremely valuable for people with disabilities. Blind and visually impaired computer users can use these internet sites effectively if websites are created with accessibility features (see comments on section 2.E..) ACB strongly urges that NCLIS consult with consumer organizations of people with disabilities (such as ACB), as well as technology groups charged with implementation of policies which make information accessible to disabled people, to make all government websites accessible to blind and visually impaired individuals. This approach will enhance compliance with sections 504 and 508 of the Rehabilitation Act.

2.B: People with disabilities stand to gain the most from the new technologies, which give them tools to gain greater independence and social integration.

Comments:
ACB would once again like to thank NCLIS for addressing the needs of people with disabilities in this section. We strongly support the findings of the survey results concerning the information needs of persons with disabilities (listed on page 44 of the report). However, aside from this list, essentially all government information that is available to the public should be available and accessible to persons with disabilities both electronically on accessible websites and through a variety of other avenues in alternate formats (see comments on section 1.B.)

2.E. The visually impaired are a disadvantaged population.

Comments:
This section has addressed the Government's use of PDF files on websites. ACB strongly views the government's use of PDF files on websites as a major barrier towards information access for blind or visually impaired individuals. PDF files cannot generally be read with screen reader software used by people who are blind. PDF files cannot be converted easily into other formats which are accessible to a screen reader. The report claims that "it is hoped that the next release of the Adobe Acrobat Reader will contain this (accessibility) feature (pg 45)." However, several versions have been released to date, and none have ever been consistently accessible to blind and visually impaired individuals. ACB urges federal government entities to offer accessible, downloadable files on their websites in formats other than PDF. The following file types are accessible by screen readers: text, HTML, Microsoft Word, and Word Perfect. It is clear that there are many other format options besides PDF that the federal government can utilize. Many government websites already offer access to documents in varying file types, this is ideal. Continued use of PDF files without alternative options will only contribute to this population's disadvantage.

2.F. The hearing impaired are a disadvantaged population.

Comments:
This section discusses the importance of the rules for section 508 of the Rehabilitation Act's electronic and information technology provisions. The report claims "Several of the associations serving the hearing impaired (as well as other disadvantaged populations) strongly recommend that these populations go to the Access Board's website to read about the rules for Section 508 of the Rehabilitation Act Electronic and Information Technology provisions." ACB feels that it is imperative that federal agencies learn about this rule and ways to ensure proper compliance with these regulations.

11.A & 11.B.

Comments:
ACB concurs with the findings in this section relating to the non?profit sector. ACB is pleased that NCLIS recognizes the connection with government information that serves as a cornerstone for many non?profit organizations. This includes value?added republishing. The non?profit sector and federal government entities should create partnerships which foster accessible information dissemination practices and policies

2. Conclusions Relating to Disadvantaged and Special Populations

Comments
ACB also believes that the federal government should monitor Section 508 of the Rehabilitation Act very closely. Compliance with Section 508 is vital to achieving the goal of full accessibility of federal government information. ACB strongly urges that federal government agencies adhere to their responsibilities under section 504 of rehabilitation act to ensure that all of their services are accessible to people with disabilities including individuals who are blind and visually impaired.

Distributing accessible information (electronic, braille, large print and audio-cassette) through various avenues is the only way to ensure that Federal Government information is available to all citizens regardless disability. ACB supports any and all efforts that aim to achieve the goal of full information access.

ACB appreciates this opportunity to make the needs of the consumers who we represent known to NCLIS in an effort to facilitate mutual understanding and foster continued and enhanced access of information for all Americans.