California Public Utilities Commission and Local Phone connections to the InternetIn May, 1999, we learned that the California PUC was to decide on a case that might cause an increase in Internet rates in CaliforniaThere's been some news coverage this week of an important case pending before the California Public Utilities Commission that's likely to impact the cost of Internet connectivity for all Californians. The case stems from deregulation of the phone industry, which put in place a set of complex rules that establish a system for phone companies to charge one another for completion of each other's calls. Currently, when someone logs on to the Internet via their local Internet service provider (ISP), that call is considered a local call. Now the PUC is looking at whether to reclassify Internet calls as long distance calls. If they decide to do this, ISPs will no longer receive income for completing those calls. This loss of revenue, which will be substantial, is likely to force ISPs to raise their prices. SF BAND RESPONDS:Subj: COMMENT ON: Reclassification of Internet calls as Long Disance Date: 99-06-01 20:38:23 EDT From: JEANNANDI To: public.advisor@cpuc.ca.gov, commissionerduque@cpuc.ca.gov To the Public Advisor and Commissioner Henry M. Duque Pacific Utilities Commission COMMENT ON: Reclassification of Internet calls as Long Disance Dear Members of the PUC: We are a large group of active users of the internet located in the San Francisco Bay region. Our membership consists of persons with disabilities and their friends and families. We have found the internet to be a really important means by which we can communicate with each other and with the outside world. Through these communications we have been able to educate ourselves about resources available to us for developing skills, finding work, advocating for ourselves and others not so fortunate to be so interconnected through the world wide web. We have also been able to educate others about our skills and capabilities, as well as needs that must be met to enable us to lead productive, dignified lives. Because of the importance of the internet to us, as a means to better our conditions and to find productive and satisfying activities, we resist all attempts by government to regulate away our full access to this new medium. Because we are disabled, many among us are of very limited means or downright poverty stricken, and potential increases in internet costs are a serious threat to our well being and even livelihoods in some cases. For these several reasons, we urge you NOT to take a step which will potentially add new costs to our acquisition of internet services. This is not a trivial matter in the lives of many persons with disabilities here and elsewhere across the country. We are convinced that reclassification of our local internet calls will result in revenue losses to our Internet Service Providers, and as a consequence they will be forced to raise their user rates. Sincerely Yours, Jean Nandi, Chairperson San Francisco Bay Area Network on Disability (SF BAND) http://disweb.org/sfband/ jeannandi@aol.com 1529 Josephine St. Berkeley, CA 94703-1168 phone: (510) 845-8236 BILLING DECISION POSTPONED, THEN TEMPORARILY SET ASIDEFrom: jeannandi@aol.comDate: 6/4/99 11:53 AM Subj: Puc puts off billing decision Source: Oakland Tribune Friday June 04, 1999 By Eve Mitchell Business Writer SAN FRANCSICO -- The state Public Utilities Commission delayed voting Thursday on a billing dispute between Pacific Bell and a competing phone company that could lead to higher calling charges for all Internet users. Despite the delay, the key vote deciding the issue is expected to be taken Thursday, June 10. The dispute involves whether PacBell should have to pay Stockton-based Pac-West Telecomm $50 million in so-called reciprocal billing fees involving calls made by PacBell customers to 85 Internet service providers served by Pac-West. If the fees were eliminated, as Pacific Bell proposes, Pac-West Telecomm could pass the charges along to Internet service providers, who in turn could raise monthly fees to Web users. Legislators favoring a delay in eliminating the fees have warned that access to the Internet could be restricted, especially in rural areas if fees were canceled. Under reciprocal billing contracts, when local calls originating from one carrier are made to a competing carrier's network, the first company has to pay the second one to terminate the call. Such contracts are required under the Telecommunications Act of 1996. Pac-West contends that local calls placed by PacBell customers to ISPs served by Pac-West should qualify for the same kind of reciprocal billing that applies to local voice calls. PacBell disagrees, arguing that only local voice calls should qualify and that Internet calls should be treated as long distance calls, given that they could end up anywhere in the world. If the PUC ends up siding with PacBell, PacBell could argue that it doesn't have to pay reciprocal billing fees to other competing phone companies that serve ISPs, said David Simpson, outside counsel for California Internet Service Providers Association. If that happens, then local phone companies would have to charge higher rates to ISPs that in turn might pass on those costs to Internet users. The two proposals before the commissioners could possibly prompt the board to review a PUC position made last October that determined Internet calls are local, not long-distance. PacBell is appealing that decision. In one proposal, an administrative law judge ruled that PacBell should be required to pay the disputed reciprocal billing fees to Pac-West. But an alternative proposal made by PUC Commissioner Josiah Neeper calls for delaying a decision on the fees until a full-scale hearing involving the telecommunications industry as a whole can be held. "The best venue for this resolution of this issue is not in an arbitration proceeding but rather in (a public forum)," Neeper said. Bill Mashek, spokesman for PacBell, said the company is confident that its position that Internet calls should be treated as long distance calls will ultimately prevail if Neeper's proposal is accepted. "(Neeper's alternative) would offer a more thorough discussion of this issue. We think the more discussion there is, the stronger our case will be," he said. Further complicating the issue are the feds. In February, the Federal Communications Commission classified Internet calls as long-distance. But the federal agency is reconsidering that decision, which means for now that the matter is left up to individual states. (c) 1999 by MediaNews Group, Inc. and ANG Newspapers AND NOW, IN Y2K, THE ISSUE AGAIN RAISES ITS UGLY HEADSF BAND RESPONDS AGAIN--February 7, 2000 Richard A. Bilas, President California Public Utilities Commission 505 Van Ness Avenue San Francisco, CA 94102 by FAX 415/703-1758 Re: Issue 98-11-024, treating Internet calls as local Dear President Bilas: In reference to your unanimous vote of February 3, 2000, to review the policy that treats Internet calls as local when it comes to reciprocal fees competing phone companies pay each other for handling each other's calls, I would like to reiterate testimony which I sent you in June, 1999 when this policy was last reviewed. We feel that the Commission should let its previous rulings stand. In no circumstances should telephone-based Internet access be charged differently than any other local telephone call. We are a large group of active users of the internet located in the San Francisco Bay region. Our membership consists of persons with disabilities and their friends and families. We have found the internet to be a really important means by which we can communicate with each other and with the outside world. Through these communications we have been able to educate ourselves about resources available to us for developing skills, finding work, advocating for ourselves and others not so fortunate to be so interconnected through the world wide web. We have also been able to educate others about our skills and capabilities, as well as needs that must be met to enable us to lead productive, dignified lives. Aside from the importance of the internet to us, many among us are of very limited means or downright poverty stricken, and potential increases in internet costs are a serious threat to our well being and even livelihoods in some cases. For these reasons, we urge you NOT to take a step which will potentially add new costs to our acquisition of internet services. This is not a trivial matter in the lives of many persons with disabilities here and elsewhere across the country. We are convinced that reclassification of our local internet calls will result in revenue losses to our Internet Service Providers, and as a consequence they will be forced to raise their user rates. Sincerely Yours, Jean Nandi, Chair, San Francisco Bay Area Network on Disability (SF BAND) 1529 Josephine St. Berkeley, CA 94703-1168 phone: (510) 845-8236; email: jeannandi@aol.com or jeannandi@able-net.net http://disweb.org/sfband/ |
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CONGRESSIONAL SUBCOMMITTEE HOLDS HEARING ON THE APPLICABILITY OF THE ADA TO THE INTERNET
[See Statement by the American Federation of the Blind on the Applicability of the ADA to the Internet WEBWATCH Digest2 for Wednesday, February 09, 2000. Subject: Press Release on Constitution Subcommittee Hearing From: Kelly Ford kford@teleport.com Date: Wed, 09 Feb 2000 08:04:20 -0800 Hi All, Below is a press release issued by the Constitution Subcommittee on today's hearing. I haven't found a live feed as of yet but will let folks know if I do. U.S. House of Representatives Committee on the Judiciary Henry J. Hyde, Chairman http://www.house.gov/judiciary/na020800.htm News Advisory For immediate release February 8, 2000 Contact: Sam Stratman/Terry Shawn (202) 225-2492 Subcommittee Schedules Oversight Hearing on Americans with Disabilities Act and the Internet What: Oversight Hearing on "The Applicability of the Americans with Disabilities Act (ADA) to Private Internet Sites." Subcommittee on the Constitution. When: 1 p.m. Wednesday, February 9, 2000 Where: 2237 Rayburn House Office Building The impact of the Internet on the American economy and the availability of new sources of information to the American people, including the disabled community and the blind, has been remarkable and liberating. There are concerns however, from the disabled community, that new advancements in Internet communication may limit access, especially to the blind, to commercial web sites. Currently... *** The Department of Justice has said the accessibility requirements in the Americans with Disabilities Act apply to private Internet web sites and services, and, in November, 1999, the National Federation for the Blind filed a class action law suit against America Online claiming that the matter in which AOL services are provided, violates the accessibility requirements in the ADA. These hearings will... *** Address the potential opportunities and pitfalls, both economic and constitutional, of extending ADA coverage to the Internet, that, without the burden of accessibility regulations and threatened ADA litigation, already provides the disabled community with vast new opportunities to retrieve information amidst a dynamic and innovative technological environment. WEBWATCH Digest2 for Wednesday, February 09, 2000. Subject: Re: Press Release on Constitution Subcommittee Hearing From: love26@gorge.net (William Loughborough) Date: Wed, 09 Feb 2000 08:55:47 -0800 The Judiciary hearings will be broadcast on the Web today. http://www.house.gov/judiciary has details. Although the guy I spoke to said they'd be in RealAudio, the site says Windows Media Player (with link for download). [NOTE: This broadcast did not happen, due to technical difficulties--JN] Subj: Re: Internet Hearings Date: 00-02-06 11:07:41 EST From: JEANNANDI Appended is the letter I will be faxing to the committee members tomorrow, Monday, Feb. 7. Please check the websites in the letter and my hompage for information on our California activities. Yours, Jean Nandi http://members.aol.com/jeannandi/HOMEPAGE/JEANHOME.HTML February 7, 2000 The Honorable Charles T. Canady, Chairman House Judiciary Committee Subcommittee on the Constitution 2432 Rayburn House Office Building Washington, DC 20515 By FAX: 202-225-2279 Subject: 02/09/00 Hearing, applying Title III of the ADA to the Internet Dear Chairman Canady: I represent several hundred persons with disabilities who have successfully networked via the Internet, educating each other in the skills of living with our disabilities and in advocating for our civil rights. Our skills include using the internet itself to acquire an education, to shop for goods and services, and otherwise conduct business or even obtain employment. We have been heard across the country, and our causes in promoting better health care and the right to live as independently as possible within our own homes have resonated with many other similarly linked people with similar problems and issues. Equally resonant are the **means** by which we achieve these goals, through research and discussions carried on via the Internet. A letter that reached me this weekend illustrates eloquently the importance of the internet to us all: [Can] "...a C3-C4 Quadriplegic that has been stuck in bed for the past year and stayed productive advocating for seniors and disabled citizens help show how important email access is to us? If I wasn't able to do the work I've done during the past year online while stuck in bed I would have become seriously depressed. Probably wouldn't have recovered as soon as this if I wasn't able to be online! Being online has helped me help others with access problems and it also gives me the opportunity to research everything someone might ask about. Being online has made my life onehundred percent better than before I was online." --Corey Nelson, Upton, Massachusetts I am in a similar situation, lying in bed, but through the internet leading a productive life. As Chair of the San Francisco Bay Area Network on Disability, I actively participate in the work of the Congressional Internet Caucus Advisory Committee. As a member of the Executive Committee of the California Disability Alliance, I have led a statewide group in health care advocacy with the California legislature and government agencies. Unfortunately there are groups of disabled persons who are shut out of much of this empowering activity because little thought to **universal** access is given by commercial and government web developers. The World Wide Web is still young, and it makes a great deal of sense to ensure that its future development includes **everybody**. Under the ADA and other federal and state laws it is no longer acceptable or legal to create programs or operate business enterprises which shut out persons by reason of disability. Yet many programs and facilities now available to the public through the internet are just as **in**-accessible as a store with no ramp at the entrance, or an educational institution which does not provide interpreters, or a public elevator without brailled buttons, just to give a few examples. Achieving universal access is not difficult or costly. It simply requires forethought and understanding of the special tools that many of us use to access web pages, email programs and other computerized facilities. There are excellent guidelines available which should be used by all web programmers. There is no good excuse for allowing businesses which normally fall under Title III of the ADA to conduct business online which does not meet the same standards of accessibility required elsewhere. I urge you to recommend that Congress pursue a plan to enable all of us to participate in this flowering of the online world. It will continue to bring more persons with disabilities into the working world and into the community. Very Sincerely, Jean Nandi Chair, San Francisco Bay Area Network on Disability (SF BAND) http://disweb.org/sfband/ and Member, Executive Committee, California Disability Alliance (CDA) http://www.dredf.org/cda/cdahome.html 1529 Josephine St., Berkeley, CA 94703-1168 Phone: (510) 845-8236 email: jeannandi@able-net.net or jeannandi@aol.com cc: Committee members, Representatives Henry Hyde, Mel Watt, Asa Hutchinson, Maxine Waters, Spencer Bachus Barney Frank, Bob Goodlatte, John Conyers, Bob Barr, Jerrold Nadler William L. Jenkins, Lindsey Graham WEBWATCH Digest2 for Wednesday, February 09, 2000. Subject: URLs for Witness Statements from the Subcommittee Hearing From: Kelly Ford kford@teleport.com Date: Wed, 09 Feb 2000 13:39:22 -0800 Hi All, Witness statements are now posted from the Constitution Subcommittee hearing held earlier today. Below are direct URLs to each statement Dennis Hayes http://www.house.gov/judiciary/hay30209.htm Gary Wunder http://www.house.gov/judiciary/hay30209.htm Dr. Steven Lucas http://www.house.gov/judiciary/hay30209.htm Judy Brewer http://www.house.gov/judiciary/hay30209.htm Susyn Conway http://www.house.gov/judiciary/hay30209.htm Elizabeth K. Dorminey http://www.house.gov/judiciary/hay30209.htm Peter D. Blanck http://www.house.gov/judiciary/hay30209.htm Walter Olson http://www.house.gov/judiciary/hay30209.htm Charles J. Cooper http://www.house.gov/judiciary/hay30209.htm |
WORK BY SF BAND AND OTHERS ON BRINGING THE STATES UP TO FEDERAL STANDARDS[Coalition of State Web Access Initiatives][State of California] [State of Minnesota] [More on Web Accessibility from SF BAND] [TOP] Coalition of State Web Access InitiativesThis letter is a follow-up from a telephone conference on the Digital Divide.--JNSee Digital Divide Subj: [DD] trying again to get that web address Date: 00-05-04 14:05:32 EDT From: JEANNANDI To: cboyer@resna.org (Carol J. Boyer) Carol, I apologize for muddleheadedness or whatever. I know you keep trying to give me information about this coalition of state agencies etc. working with the Tech Act to leverage 508 web standards from states receiving Tech Act $$. On the last call with Jonathan Young you mentioned a website, but whatever I heard was not correct and I have been unable to find it. Since our organizations work primarily at the state level, it is very important for us to get this information. Please indugle me with the URL! I got your email address from Jonathan. Thanks very much for your help. Yours, Jean Nandi, San Francisco Bay Area Network on Disability (SF BAND) http://disweb.org/sfband/ and California Disability Alliance http://www.dredf.org/cda/cdahome.html Subj: RE: [DD] trying again to get that web address Date: 00-05-04 15:10:45 EDT From: cboyer@resna.org (Carol Boyer) To: JEANNANDI@aol.com Jean, The easiest way to find this information is to go to the RESNA Technical Assistance Project website area on Section 508: http://www.resna.org/taproject/policy/initiatives/508.html Scroll down and find the "Summary of Information Technology Access Laws and Policies." There, you will have the link to: The Association of Tech Act Projects (ATAP) which provides a chart that shows what legislative initiatives several of the Assistive Technology Act grantees have accomplished regarding Section 508 implementation/compliance in their states. The name of the coalition that ATAP has formed is called SITAC (State Information Technology Access Coalition) made of up ATAP, the National Association of State Information Resource Executives, and the National Association of State Procurement Officers. Carol Boyer Project Associate RESNA Technical Assistance Project cboyer@resna.org Subj: Fed/State Section 508 Alert Date: 00-04-30 17:09:32 EDT From: cynthia.waddell@ci.sj.ca.us (Waddell, Cynthia) To: JEANNANDI@aol.com ('JEANNANDI@aol.com') Hi- You might also want to look at the Fed/State alert at: http://policyworks.gov/org/main/mg/intergov/Alert-Newresp.htm From this website: The purpose of this Federal/State Issues Alert on accessibility is to direct attention to recent legislation that may affect a small but significant part of the workforce who needs are often ignored (people with disabilities). The series of Federal/State Issue Alerts are intended to assist busy managers who need to know about emerging and hot topics in the dynamic field of intergovernmental management. New Responsibilities for Managers Providing Information Technology Services September 1999 Background: Accessibility is defined as electronic and information technology that provides people with disabilities comparable or equivalent access to computers and information as people without disabilities. On August 7, 1998, Public Law 105-220 amended Section 508 of the Rehabilitation Act of 1973. It requires Federal agencies and States that receive federal funds to acquire only accessible electronic and information technology (IT) unless it would create an undue burden. Enforcement begins August 7, 2000. Accessible equipment refers to IT that allows people with disabilities to have access to and use of information that is comparable to what is available to people without disabilities.Key Issues concerning Product Testing for Accessibility Development of adequate criteria for product testing for accessibility.What Will Drive This Issue in the Next Year? Current Federal legislation requires Federal government and States that receive federal funds to acquire accessible electronic and IT products. Many Federal agencies and state agencies continue to acquire IT products that are not accessible and may result in congressional oversight.Additional Information Center for IT Accommodation, the General Services Administration; nationally recognized model demonstration facility influencing accessible information environments, services, and management practices. (http://www.itpolicy.gsa.gov/cita/index.htm) Department of Justice Section 508 Home Page: http://www.usdoj.gov/crt/508/508home.html Center for Applied Special Technology (CAST), not for profit organization, whose mission is to expand opportunities for people with disabilities through innovative use of computer technology. (http://www.cast.org/bobby/) The Growing Digital Divide in Access for People with Disabilities; ADA Coordinator, City of San Jose, CA, Cynthia Waddell. (http://www.digitaleconomy.gov) President's Information Technology Advisory Committee (PITAC) Report to the President: (http://www.hpcc.gov/ac/report/) Re-Charting the Course: The First Report of the Presidential Task Force on Employment of Adults with Disabilities: (http://www.dol.gov/dol/_sec/public/programs/ptfead/rechart/index.htm) More Than Screen Deep: Toward Every-Citizen Interfaces to the NLItion's Information Infrastructure (NII): (http://www.nap.edu/readingroom/books/screen/) Petition for the Accessibility of the Portuguese Internet: (http://www.acessibilidade.net/petition/parliament.report.html) State of Washington: (http://www.aasa.dshs.wa.gov/access/) [BACK TO STATE INITIATIVES] State of CaliforniaDirect link to Cynthia Waddell's pages on Web Accessibility ]Waddell, ADA Coordinator for the City of San Jose, is our greatest California Advocate for making the web accessible to all persons with disabilities and others. Subj: Correspondence with state contractors for the CCR Date: 00-05-01 09:41:40 EDT From: JEANNANDI To: cynthia.waddell@ci.sj.ca.us Thanks for your references! Wish you luck this week, and look forward to learning of your results. The CCR is the California Code of Regulations, produced by the Office of Administrative Law (OAL). The OAL regulations/Internet are under contract with the West Group out of Minneapolis, MN through their subsidiary in S.F., Barclays (1-800-537-2707). The attorney with OAL who specifically handles the OAL/CA contract with Barclays is Barbara Steinhardt-Carter, 916-323-6805 (E-mail: bstcarter@oal.ca.gov). The Governor recently appointed David Judson, to head OAL; his telephone numbers is 916-323-6790 Here is our correspondence: :Subj: Re: CCR Contract, Office of Administrative Law Date: 00-02-22 12:11:57 EST From: JEANNANDI To: bstcarter@oal.ca.gov CC: djudson@oal.ca.gov To: Ms Barbara Stinhardt-Carter, California Office of Administrative Law CC: David Judson, Director, California Office of Administrative Law Dear Ms. Stinhardt-Carter, I am writing on behalf of two California groups serving persons with disabilities who actively use the internet for advocacy and information regarding California Rules and Regulations which affect our lives. The California Disability Alliance (CDA) is a state-wide organization working primarily on health care issues (http://www.dredf.org/cda/cdahome.html), and the San Francisco Bay Area Network on Disability (SFBAND) is a Bay Area group working on greater access to the internet for persons with disabilities (http://disweb.org/sfband/). Our members have complained bitterly that the pages containing California regulations on the OAL website are poorly designed and utterly inaccessible to persons with low-end computers and browsers, and for persons who are blind or visually impaired and use screenreaders or other special software to access the internet. It is not that hard to create highly accessible web pages, and we must protest that the web developers have not been instructed to do so on a government site that serves the public. As of August, 2000, all Federal websites will be required to be fully accessible, and it is difficult to understand that the great state of California sees fit to lag behind the rest of the country in making its laws and regulations available to the public. Furthermore, persons with disabilities who are particularly affected by poor web design are just the ones making maximum use of the web to acquire information of this type: for example, visually impaired or many mobility impaired persons such as myself are quite unable to read printed text. I cannot read braille either, but can quite readily use the internet to access complex materials. We have repeatedly requested that we be allowed to speak directly with your web developers. It is our understanding that the OAL regulations/Internet are under contract with the West Group out of Minneapolis, MN through their subsidiary in S.F., Barclays, and that you handle this OAL/CA contract with Barclays. This contract should be a public document, and on behalf of my constituents I would like to request a copy. An electronic copy, naturally, would be preferable, but I would appreciate it in any form whatever and would make arrangements to hire a reader if you were to send it to my address below. If a document is available that could be sent as a text attachment or copied into an email, that would be great! We would be happy to work with your office as well as the web developers to assist you in creating an accessible website for OAL/CA. Please go to the SF BAND pages (http://disweb.org/sfband/) for more information regarding web accessibility. Thank you for your prompt attention to this matter. Very Sincerely, Jean Nandi, Member, Executive Committee California Disability Alliance (CDA) 1529 Josephine St. Berkeley, CA 94703-1168 (510) 845-8236 email: jeannandi@able-net.net or jeannandi@aol.com Web: http://www.dredf.org/cda/cdahome ----- The work of the California Disability Alliance is supported in part by a grant from the Disability Rights Advocates Fund of the San Francisco Foundation ------------------ Subj: RE: CCR Contract, Office of Administrative Law Date: 00-02-23 17:34:01 EST From: BSTCARTER@oal.ca.gov (Barbara Steinhardt-Carter) To: JEANNANDI@aol.com ('JEANNANDI@aol.com') CC: DJUDSON@oal.ca.gov (David Judson) Dear Ms. Nandi, This note is to acknowledge receipt of your letter detailing your concerns about the CCR. Today or tomorrow we will be sending you the contract OAL has with West Group for publication of the CCR online and in hard copy. Unfortunately, we do not have any of the contract documents in electronic format. The contract documents include the original OAL Request for Proposal, West Group's Response to the RFP, and finally, an excerpt of the primary contract provisions from these other documents attached to the required state contract form. We share your concern for making the online CCR more accessible to all users, and are in the process of gathering resources, talking to the contractor, the California Home Page folks, and others to see what we can accomplish. I appreciate the web resources you have steered us to, and hope to remain in touch with you as we progress in this area. We will be sending you a more formal response, but I did want to let you know right away that we got your letter and that the contract is on its way. Sincerely, Barbara Steinhardt-Carter Staff Counsel ------------------ Subj: RE: CCR Contract, Office of Administrative Law Date: 00-03-07 20:50:11 EST From: JEANNANDI To: BSTCARTER@oal.ca.gov (Barbara Steinhardt-Carter) CC: DJUDSON@oal.ca.gov (David Judson) CC: magdisbl@ccnet.com (Maggie Dee) Dear Ms. Steinhardt-Carter: As per this message, I received a week or so ago the OAL RFP (OAL 8008) and the West Group response re the contract for publishing the CCR, including the online (internet) version. It took me some time to go through the materials owing to my visual and physical disabilities. However, I copied certain relevant materials and make some comments on them. I do hope, as per your message appended at the end, that we will be able to work with you to make the internet CCR a useful document for all of us who use the internet, irrespective of physical, visual, or other disability. This includes those whose computers are not state-of-the-art. As you know, many folks who are most affected by the CCR are in fact not well-to-do and are using equipment that may be substandard. Disallowing them access to your government pages is equivalent to insisting that only automobiles built after 1999 be permitted in the City of Sacramento. I look forward to your response to these comments. Very Sincerely, Jean Nandi, Member, Executive Committee California Disability Alliance (CDA) 1529 Josephine St. Berkeley, CA 94703-1168 (510) 845-8236 email: jeannandi@able-net.net or jeannandi@aol.com Web: http://www.dredf.org/cda/cdahome ----- The work of the California Disability Alliance is supported in part by a grant from the Disability Rights Advocates Fund of the San Francisco Foundation ========= RFP OAL 8008 p. I-7: K. AMERICANS WITH DISABILITIES ACT NOTICE AMERICANS WITH DISABILITIES ACT (ADA) COMPLIANCE POLICY OF NONDISCRIMINATION ON THE BASIS OF DISABILITY To meet and carry out compliance with the nondiscrimination requirements of Title II of the Americans With Disabilities Act (ADA), it is the policy of the Procurement Division (within the State Department of General Services) to make every effort to ensure that its programs, activities, employment opportunities and services are available to all persons, including persons with disabilities. [JN Note: this policy appears only to apply to the contractors, not to their products, even though Title II requires programs and services to be available to all persons including persons with disabilities.] ========= RFP OAL 8008 p IV-10: 8. Internet Duties The bidder must propose a solution that receives data from the Master CCR database and converts it into an Internet viewable text (html, etc.). The Contractor will create a website for the CCR that is linked transparently to the OAL's home page. OAL requires the Internet database provide an universal research capability, be accessible by section and title subject matter, key words and related terms, and also capable of progressively narrowing or broadening research requests with re-keying. Solutions must include ways to ensure that the electronic database has search capacity to accommodate a large number of simultaneous users and that it is **capable of modification to future needs. ** [JN Note: emphasis indicated by ** **. This requirement implies that a future need might be a determination by OAL and the State of California that its websites should meet FEDERAL standards. These standards are currently being developed by the Access Board, the standards are currently open to comment, but will become effective in August, 2000.] ========= RFP OAL 8008 p V-2: D. RIGHT OF STATE AGENCIES OAL reserves for the State of California the right on the part of the Office of State Publishing to print any of the regulations of the State of California in any form it chooses. Pursuant to Government Code Sections 11340.1(a) and 11344, **OAL reserves for the State of California the right to make available electronically to the public, including the Internet, any of the regulations of the State of California in any form it chooses.** Pursuant to Government Code Section 6270(a), on behalf of the State of California, OAL reserves the right for a state agency to satisfy requests under the California Public Records Act by providing directly to the requester a copy of the agency's provisions of the Official CCR. Notwithstanding any other provision of this CCR publication contract, no agency of the State of California may, during the term of this CCR publication contract, create or maintain a hard copy "subscription service" in which weekly updates to the California Code of Regulations, or any part thereof, are distributed to subscribers. [JN Note: emphasis indicated by ** **. This section implies that OAL might choose to provide an accessible set of pages if the West Group were unable to provide an accessible Internet format without excess cost. Parallel pages could be linked and maintained by any other contractor OAL might wish to enlist for such a project, should OAL determine that the current contractor is unable to bring the site up to Federal standards during the duration of the current contract period.] ========= RFP OAL 8008 p VI-2: B. PUBLICATION FORMAT -- Internet Publication OAL requires the internet CCR to be published in a standard professional format (refer to Appendix A, Attachment 2, for minimum requirements). The bidder must provide a sample web address representative of the product to be produced for OAL. Minimum formats are defined in Appendix A and the final formats will be approved by the OAL prior to acceptance. [JN Note: Nothing in this section or in Appendix A refers to universal accessibility standards. Hopefully future RFPs will include standards permitting users with disabilities and low-end computer systems to access the Internet pages.] ========= RFP OAL 8008 pp VI-14-16 Internet Content Requirements [selected for relevance to accessibility] M=Mandatory, D=Desired R=WestGroup Response 25 Tables of Contents allows user to a user-identified Title/Section in a convenient method (i.e. hyperlinks) D R=Y 28 Technical drawings, diagrams, charts, forms, etc. are viewable online. Bidders must state the format to be used (e.g. TTF, bitmap, etc.) with no special additional software. M R=Y, TIFF 29 Forms can be printed, downloaded, and/or usable and the form is appropriately sized (fits 8 1/2 x 11 paper in most cases). D R=Y 31 User is not required to download or install any additional software (only a browser and an Internet connection are required) in order to view CCR online including graphics. M R=Y Other Requirements [selected for relevance to accessibility] 59 The browser level must be a level 3 and provide advanced search capabilities. M R=Y [JN Note: Nothing in the content or the search capability requirements is related to the accessibility of the forms, including the search forms. No mention is made of alternative texts, long or short, in cases where materials (mentioned here as technical drawings, diagrams, charts, forms, etc.). Forms can be created which are accessible, although W3C standards require alternative methods of capturing user supplied information, such as an email form. Browser Level 3 is fine so long as W3C standards are maintained. Hyperlinks should be reachable with keystrokes alone.] ========= RFP OAL 8008 APPENDIX A, ATTACHMENT 2: Format for Internet Publication of CCR The Internet Publication of the CCR shall be in a standard format as follows: FORMAT: The CCR shall be in a professional and standard format. Font size shall be no smaller than 10 point. [JN Note: Font size of 10 point is invisible to persons with low vision. The font size should be created so that it is scalable in the individual's own browser (that is, not placed in a graphic). This should be stated in the RFP.] HIERARCHY: The hierarchical structure of the existing California Code of Regulations shall be maintained and easily readable; that is, the Title, Division, Chapter, SubChapter, Group and SubGroup where applicable, Article, SubArticle, and Section, and so on. [JN Note: There should be a set of pages which provide this hierarchy in full. The existing pages allow one to see the top levels, but one can only "drill down" into lower levels to see how the CCR is laid out if one already knows how the CCR is laid out. Searches often bring up much unrelated materials unless one already knows the Title/Division etc. that one is headed for. Even then, the result of a search is often a fragmented set of Articles and Sections, and much related material is missed.] ACCESSIBLE: The CCR shall be accessible by the public with standard Internet browser software. The public must be able to search and query the CCR database. The search engine must have the ability to increase or narrow searches at the user's option. Refer to Section VI, Scope of Services, of RFP OAL-8008. [JN Note: The RFP should define what is meant by a "standard Internet browser," and presentation should not preclude other access where that is necessary either by the use of adaptive equipment or by the use of low-end computers.] SCALABILITY: The CCR must be able to process approximately 300,000 "hits" per month. The system must be capable of modification to meet future needs. [JN Note: We are in the process of defining a future need. Hope that West Group can be responsive to it!] MASTER TABLE OF CONTENTS: The Contractor shall make available on the Internet a Master Table of Contents with a complete display of all regulations in all Titles (excluding Title 24) by Title, Division, Chapter, SubChapter, Group and SubGroup where applicable, Article, SubArticle, and Section, and so on. [JN Note: See my note under HIERARCHY, above. I do not find it possible to quickly scan an entire Title with its subunits, without "drilling down" through many pages of detail.] [BACK TO STATE INITIATIVES] University of Minnesota and the State of MNFrom a conversation offline after one of Jonathan Young's conference callsSee Digital Divide Subj: Re: [DD] Follow up on our call with Jonathan Young Date: 00-04-13 09:47:38 EDT From: pmk@boombox.micro.umn.edu (Philip M. Kragnes) To: JEANNANDI@aol.com Jean, It was a pleasure meeting you as well. I have visited your personal Web site. I am impressed with your tenacity and ingenuity. Yesterday's conference call left me a bit disappointed. The "Digital Divide" seems to be more about ethnic minorities and low income populations. While I agree that these are important issues, the plight of people with disabilities is certainly not understood and seems to be a more minor concern. During all the talk about the places the President will be visiting, there was never mention of disabilities. As was evident from Jonathan's reaction to my comment regarding the "25% of people with disabilities," the government collects a great deal of data but do not understand the underlying factors. There are so many points that were raised by yesterday's call. I will not burden you with more of my rantings in this area, as I am sure you have many of the same issues and concerns. I am glad the federal government is starting to take an interest and become aware. As I mentioned on the phone, I am a member of the Governor's Advisory Council on Adaptive Technology for People with Disabilities. The Council oversees the STAR (System of Technology to Achieve Results) program, which is Minnesota's Tech Act project. You can learn more by visiting their Web site: http://www.admin.state.mn.us/assistivetechnology/ You may also wish to write or call Ronna Linroth, the Executive Director of the STAR program. Ronna Linroth Acting Executive Director Minnesota STAR Program 658 Cedar Street, Rm. 360 St. Paul, MN 55155 651-297-1554 I also invite you to visit my personal Web site: http://www.millcomm.com/~pmk I think the "Disability Depot" section of my site will provide you with some good resources. I also invite you to visit my University of Minnesota Computer Accommodations Program (CAP) site as well. You will find the address for the CAP Home page at the bottom of my signature. I look forward to continued contact with you. Take care and keep up the fight. Philip M. Kragnes Adaptive Technology Specialist University Gateway 200 Oak Street SE, Suite 180 Minneapolis, MN 55455-2002 Voice: (612) 626-0365 Fax: (612) 626-9654 http://cap.umn.edu [Please feel free to share my letter with your organization. I do ask that you make it clear that these are my observations and opinions. They are not necessarily the position of the University of Minnesota. Thanks.] Web Accessibility Guidelines on the University of Minnesota Website [From Phil's reference, above, to http://cap.umn.edu/ -- These guidelines are excellent, and I include them here for the information of SF BAND members who may want to code webpages and/or just find out what the heck we are talking about when we discuss web accessibility! JN] http://cap.umn.edu/WebSiteAccessibility.html -- University of Minnesota [BACK TO STATE INITIATIVES] [TOP] [Back to SF BAND homepage ] SF BAND finds problems with new Electronic Signatures Law
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