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We will ensure we give you a high quality content that will give you a good grade. I have the same question Report abuse. Details required :. Cancel Submit. Previous Next. Please see the advise from Sumit. How satisfied are you with this reply? Thanks for your feedback, it helps us improve the site. Sumit Independent Advisor Independent Advisor. Hi Paruyr, I am Sumit here to assist you with this question.
Windows does not support or sell Windows on ARM licenses. The insider copies are intended just for evaluation. You would not be able to change editions. There is no need to buy paid products to fix your computers as they do more harm than good sometimes. In reply to Sumit Independent Advisor 's post on December 14, In reply to JohnnyVasquez's post on February 24, Hello, It is possible to buy a Windows 11 license through the Microsoft Store.
Regards, Aditya Khullar. Joe13 B- 2. In reply to fredMugunga's post on February 25, Any current value s , and any set or range of allowable values associated with an object, shall be programmatically determinable. Values that can be set by the user shall be capable of being set programmatically, including through assistive technology.
Any relationship that a component has as a label for another component, or of being labeled by another component, shall be programmatically determinable. Any hierarchical parent-child relationship that a component has as a container for, or being contained by, another component shall be programmatically determinable. The content of text objects, text attributes, and the boundary of text rendered to the screen, shall be programmatically determinable.
Text that can be set by the user shall be capable of being set programmatically, including through assistive technology.
A list of all actions that can be executed on an object shall be programmatically determinable. Applications shall allow assistive technology to programmatically execute available actions on objects.
Applications shall expose information and mechanisms necessary to track focus, text insertion point, and selection attributes of user interface components. Focus, text insertion point, and selection attributes that can be set by the user shall be capable of being set programmatically, including through the use of assistive technology. Applications shall permit user preferences from platform settings for color, contrast, font type, font size, and focus cursor.
Where an application provides an alternative user interface that functions as assistive technology, the application shall use platform and other industry standard accessibility services. Where user controls are provided for volume adjustment, ICT shall provide user controls for the selection of captions at the same menu level as the user controls for volume or program selection.
Where user controls are provided for program selection, ICT shall provide user controls for the selection of audio descriptions at the same menu level as the user controls for volume or program selection. Where an application is an authoring tool, the application shall conform to to the extent that information required for accessibility is supported by the destination format.
Authoring tools shall permit authors the option of overriding information required for accessibility. Authoring tools shall, when converting content from one format to another or saving content in multiple formats, preserve the information required for accessibility to the extent that the information is supported by the destination format. The technical requirements in Chapter 6 shall apply to ICT support documentation and services where required by Chapter 2 Scoping Requirements , Chapter 2 Scoping Requirements , and where otherwise referenced in any other chapter of the Revised Standards or Revised Guidelines.
Documentation shall list and explain how to use the accessibility and compatibility features required by Chapters 4 and 5. Documentation shall include accessibility features that are built-in and accessibility features that provide compatibility with assistive technology.
Where support documentation is only provided in non-electronic formats, alternate formats usable by individuals with disabilities shall be provided upon request.
ICT support services including, but not limited to, help desks, call centers, training services, and automated self-service technical support, shall conform to ICT support services shall include information on the accessibility and compatibility features required by Support services shall be provided directly to the user or through a referral to a point of contact.
Such ICT support services shall accommodate the communication needs of individuals with disabilities. The Director of the Office of the Federal Register has approved these standards for incorporation by reference into this part in accordance with 5 U. Copies of the referenced standards may be inspected at the U. Box , Santa Monica, CA — Box , Los Alamitos, CA — Series E. Overall Network Operation, Telephone Service, Service Operation and Human Factors—International operation - Numbering plan of the international telephone service, Arrangement of digits, letters and symbols on telephones and other devices that can be used for gaining access to a telephone network, February Series G.
Copies of the referenced standard may be obtained from the Internet Engineering Task Force. Definition of the Opus Codec, September , J. Valin, Mozilla Corporation, K. Vos, Skype Technologies S. Terriberry, Mozilla Corporation. Redesignated and amended at 82 FR , Jan. The purpose of this part is to implement section of the Rehabilitation Act of , as amended 29 U. Section requires that when Federal agencies develop, procure, maintain, or use electronic and information technology, Federal employees with disabilities have access to and use of information and data that is comparable to the access and use by Federal employees who are not individuals with disabilities, unless an undue burden would be imposed on the agency.
Section also requires that individuals with disabilities, who are members of the public 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 public who are not individuals with disabilities, unless an undue burden would be imposed on the agency.
When developing, procuring, maintaining, or using electronic and information technology, each agency shall ensure that the products comply with the applicable provisions of this part, unless an undue burden would be imposed on the agency.
Agencies cannot claim a product as a whole is not commercially available because no product in the marketplace meets all the standards. If products are commercially available that meet some but not all of the standards, the agency must procure the product that best meets the standards. Systems which are critical to the direct fulfillment of military or intelligence missions do not include a system that is to be used for routine administrative and business applications including payroll, finance, logistics, and personnel management applications.
Nothing in this part is intended to prevent the use of designs or technologies as alternatives to those prescribed in this part provided they result in substantially equivalent or greater access to and use of a product for people with disabilities. Applications also shall not disrupt or disable activated features of any operating system that are identified as accessibility features where the application programming interface for those accessibility features has been documented by the manufacturer of the operating system and is available to the product developer.
The focus shall be programmatically exposed so that assistive technology can track focus and focus changes. When an image represents a program element, the information conveyed by the image must also be available in text. The minimum information that shall be made available is text content, text input caret location, and text attributes. The content of the text-only page shall be updated whenever the primary page changes.
Paragraphs l , m , n , o , and p of this section are different from WCAG 1. Web pages that conform to WCAG 1. WCAG 1. Microphones shall be capable of being turned on and off to allow the user to intermix speech with TTY use.
For incremental volume control, at least one intermediate step of 12 dB of gain shall be provided. Technologies which use encoding, signal compression, format transformation, or similar techniques shall not remove information needed for access or shall restore it upon delivery.
The force required to activate controls and keys shall be 5 lbs. Key repeat rate shall be adjustable to 2 seconds per character. As soon as practicable, but not later than July 1, , widescreen digital television DTV displays measuring at least 7. Personal headsets for private listening are not assistive technology. The product must provide the ability to interrupt, pause, and restart the audio at anytime. 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.
Published in the Federal Register on January 18, and amended on March 23, SUMMARY: We, the Architectural and Transportation Barriers Compliance Board Access Board or Board , are revising and updating, in a single rulemaking, our standards for electronic and information technology developed, procured, maintained, or used by Federal agencies covered by section of the Rehabilitation Act of , as well as our guidelines for telecommunications equipment and customer premises equipment covered by Section of the Communications Act of The revisions and updates to the section based standards and section based guidelines are intended to ensure that information and communication technology covered by the respective statutes is accessible to and usable by individuals with disabilities.
Compliance with the section based guidelines is not required until the guidelines are adopted by the Federal Communications Commission. The incorporation by reference of certain publications listed in the final rule is approved by the Director of the Federal Register as of March 20, Telephone: — voice or — TTY. Telephone: — voice or — TTY E-mail addresses: access-board.
In this final rule, the Access Board is updating its existing Electronic and Information Technology Accessibility Standards under section of the Rehabilitation Act of , " Standards" , as well as our Telecommunications Act Accessibility Guidelines under Section of the Communications Act of " Guidelines". Given the passage of nearly two decades since their issuance, the existing Standards and Guidelines are in need of a "refresh" in several important respects.
This final rule is intended to, among other things, address advances in information and communication technology that have occurred since the guidelines and standards were issued in and respectively, harmonize with accessibility standards developed by standards organizations worldwide in recent years, and ensure consistency with the Board's regulations that have been promulgated since the late s.
The Revised Standards and Guidelines support the access needs of individuals with disabilities, while also taking into account the costs of providing accessible information and communication technology to Federal agencies, as well as manufacturers of telecommunications equipment and customer premises equipment.
The final rule also reflects a significantly revamped organizational structure relative to the existing standards and guidelines. Appendix A provides general application and scoping for Section , while Appendix B does likewise for Section Appendix C contains seven separate chapters setting forth the functional performance criteria and technical accessibility standards that apply to both covered and covered ICT.
These chapters are, generally speaking, broken down by functional area e. Lastly, Appendix D republishes the existing Standards, which, as discussed below, may be needed to evaluate Section covered existing legacy ICT under the safe harbor provision. Additionally, the term "information and communication technology" ICT is used widely throughout this preamble. Unless otherwise noted, it is intended to broadly encompass electronic and information technology covered by Section , as well as telecommunications products, interconnected Voice over Internet Protocol VoIP products, and Customer Premises Equipment CPE covered by Section Examples of ICT include computers, information kiosks and transaction machines, telecommunications equipment, multifunction office machines, software, Web sites, and electronic documents.
Section of the Rehabilitation Act of hereafter, "Section " , as amended, mandates that Federal agencies "develop, procure, maintain, or use" ICT in a manner that ensures Federal employees with disabilities have comparable access to, and use of, such information and data relative to other Federal employees, unless doing so would impose an undue burden. Section also requires Federal agencies to ensure that members of the public with disabilities have comparable access to publicly-available information and services unless doing so would impose an undue burden on the agency.
In accordance with section a 2 A , the Access Board must publish standards that define electronic and information technology along with the technical and functional performance criteria necessary for accessibility, and periodically review and amend the standards as appropriate.
When the Board revises its existing Standards whether to keep up with technological changes or otherwise , Section mandates that, within six months, both the Federal Acquisition Regulatory Council FAR Council and Federal agencies incorporate these revised standards into their respective acquisition regulations and procurement policies and directives.
Thus, with respect to procurement-related matters, the Access Board's Standards are not self-enforcing; rather, these standards take legal effect when adopted by the FAR Council. Section of the Communications Act hereafter, "Section " , requires telecommunications equipment and services to be accessible to, and usable by, individuals with disabilities, where readily achievable.
In determining whether an access feature is readily achievable, the Federal Communications Commission FCC , which has exclusive implementation and enforcement authority under Section , has directed telecommunications equipment manufacturers and service providers to weigh the nature and cost of that feature against the individual company's overall financial resources, taking into account such factors as the type, size, and nature of its business operation.
Section tasks the Access Board, in conjunction with the FCC, with the development of guidelines for the accessibility of telecommunications equipment and customer premises equipment, as well as their periodic review and update.
The FCC, however, has exclusive authority under Section to issue implementing regulations and carry out enforcement activities. Moreover, when issuing implementing regulations, the FCC is not bound to adopt the Access Board's guidelines as its own or to use them as minimum requirements.
The Revised Standards and Guidelines replace the current product-based regulatory approach with an approach based on ICT functions. The revised technical requirements, which are organized along the lines of ICT functionality, provide requirements to ensure that covered hardware, software, electronic content, and support documentation and services are accessible to people with disabilities.
In addition, the revised requirements include functional performance criteria, which are outcome-based provisions that apply in two limited instances: when the technical requirements do not address one or more features of ICT or when evaluation of an alternative design or technology is needed under equivalent facilitation. Some of the key provisions and updates reflected in the Revised Standards and Guidelines relative to the existing standards and guidelines include:.
Technological advances over the past two decades have resulted in the widespread use of multifunction devices that called into question the ongoing utility of the product-by-product approach used in the Board's existing Standards and Guidelines. Consequently, one of the primary purposes of the final rule is to replace the current product-based approach with requirements based on functionality, and, thereby, ensure that accessibility for people with disabilities keeps pace with advances in ICT.
To ensure that compliance under both laws, to the maximum extent possible, can be measured against a common set of technical requirements, the implementing regulations have been consolidated into a single part: 36 CFR part As discussed below, this is a new organizational format for the Standards and Guidelines that mirrors the formatting of other standards and guidelines issued by the Access Board over the past decade.
Appendix A applies only to Section covered ICT and consists of Chapter 1, which sets forth general application and administration provisions, while Chapter 2 contains scoping requirements which, in turn, prescribe which ICT — and, in some cases, how many — must comply with the technical specifications.
Appendix B, which applies to covered ICT only, is organized similarly with Chapter 1 setting forth general application and administration provisions and Chapter 2 containing scoping requirements. Appendix C sets forth technical specifications that apply equally to ICT covered under Sections or Appendix C includes five chapters, each of which with the exception of the final chapter address a separate ICT functional area.
Lastly, in Appendix D, the existing Standards are republished in full albeit with a revised section numbering system for reference when evaluating Section covered existing legacy ICT under the "safe harbor" provision. See discussion infra Section IV.
For Section covered ICT, all covered Web and non-Web content and software — including, for example, Web sites, intranets, word processing documents, portable document format documents, and project management software — is required, with a few specific exceptions, to conform to WCAG 2.
By applying a single set of requirements to Web sites, electronic documents, and software, the revised requirements adapt the existing Standards to reflect the newer multifunction technologies e. For Section covered ICT, electronic content and software that is integral to the use of telecommunications and customer premise equipment is required to conform to WCAG 2.
There are several exceptions related to non-Web documents and software. From the outset, one of the Access Board's primary goals in this rulemaking has been to increase harmonization with international standards relating to ICT accessibility that have been developed worldwide over the past decade. Some of these standards such as WCAG 2.
For other standards such as EN , which is the European accessibility standard for public ICT procurement , harmonization comes in the form of ensuring that the relevant accessibility specifications in such standard and the final rule can both be met simultaneously without conflict.
Harmonization with international standards and guidelines creates a larger marketplace for accessibility solutions, thereby attracting more offerings and increasing the likelihood of commercial availability of accessible ICT options.
The Revised Standards specify that all types of public-facing content, as well as nine categories of non-public-facing content that communicate agency official business, have to be accessible, with "content" encompassing all forms of electronic information and data. The existing standards require Federal agencies to make electronic information and data accessible, but do not delineate clearly the scope of covered information and data.
As a result, document accessibility has been inconsistent across Federal agencies. By focusing on public-facing content and certain types of agency official communications that are not public facing, the revised requirements bring needed clarity to the scope of electronic content covered by the Standards and, thereby, help Federal agencies make electronic content accessible more consistently. The existing standards require ICT to be compatible with assistive technology — that is, hardware or software that increases or maintains functional capabilities of individuals with disabilities e.
However, in the past the existing requirement resulted in ambiguity of application. The ensuing confusion led, in some cases, to unnecessary delay in procurements intended to provide reasonable accommodations to employees under Section , creating a hardship for both agencies and their employees with disabilities.
The final rule provides more specificity about how operating systems, software development toolkits, and software applications should interact with assistive technology. The final rule also specifically exempts assistive technology from the interoperability provisions.
The Board expects the final rule to improve software interoperability with assistive technology, allowing users better access to the functionalities that ICT products provide. Federal agencies will have one year from publication of this final rule to comply with the Revised Standards. This extended period for compliance is responsive to some agencies' concerns about the time it will take them to make ICT compliant with the Revised Standards.
In addition, the Revised Standards include a "safe harbor" provision for existing i. Under this safe harbor, unaltered, existing ICT including content that complies with the existing Standards need not be modified or upgraded to conform to the Revised Standards.
This safe harbor applies on an element-by-element basis in that each component or portion of existing ICT is assessed separately. Corresponding definitions have also been added for "existing ICT" and "alteration. Notably, the extended compliance date and safe harbor provision apply only to Section covered ICT; these provisions do not apply to telecommunications equipment and customer premises equipment covered by Section Since compliance with the Revised Guidelines is not required unless and until they are adopted by the FCC, matters addressed in these two provisions fall within the commission's province.
Consistent with the obligation under Executive Orders and that Federal agencies promulgate regulations only upon a reasoned determination that benefits justify costs, the final rule has been evaluated from a benefit-cost perspective in a final regulatory impact analysis Final RIA prepared by the Board's consulting economic firm. The focus of the Final RIA is to define and, where possible, quantify and monetize the potential incremental benefits and costs of the Revised Standards and Guidelines.
We summarize its methodology and results below. To estimate likely incremental compliance costs attributable to the final rule, the Final RIA estimates, quantifies, and monetizes costs in the following broad areas: 1 costs to Federal agencies and contractors related to policy development, employee training, development of accessible ICT, evaluation of ICT, and creation of accessible electronic documents; 2 costs to Federal agencies of ensuring that speech-output enabled hardware with closed functionality has braille instructions e.
On the benefits side, the Final RIA estimates likely incremental benefits by monetizing the value of three categories of benefits expected to accrue from the Revised Standards: a increased productivity of Federal employees with certain disabilities who are expected to benefit from improved ICT accessibility; b time saved by members of the public with certain disabilities when using more accessible Federal Web sites; and c reduced phone calls to Federal agencies as members of the public with certain disabilities shift their inquiries and transactions online due to improved accessibility of Federal Web sites.
The Final RIA, for analytical purposes, defines the beneficiary population as persons with vision, hearing, speech, learning, and intellectual disabilities, as well as those with manipulation, reach, or strength limitations.
The Final RIA does not formally quantify or monetize benefits accruing from the Revised Guidelines due to insufficient data and methodological constraints. Table 1 below summarizes the results from the Final RIA with respect to the likely monetized benefits and costs, on an annualized basis, from the Revised Standards and Guidelines.
All monetized benefits and costs are incremental to the applicable baseline, and were estimated for a year time horizon starting in since the final rule requires Federal agencies to comply one year after its publication and converted to annualized values using discount rates of 7 and 3 percent. Three scenarios of incremental benefits and costs are presented using alternative parameters that are assumptions-based.
These scenarios include: a low net benefit scenario using parameters which results in lower benefits and higher costs , an expected scenario consisting of expected values for assumed parameters , and a high net benefit scenario using parameters which results in higher benefits and lower costs. While the Final RIA monetizes likely incremental benefits and costs attributable to the final rule, this represents only part of the regulatory picture. Today, though ICT is now woven into the very fabric of everyday life, millions of Americans with disabilities often find themselves unable to use — or use effectively — computers, mobile devices, Federal agency Web sites, or electronic content.
The Board's existing standards and guidelines are greatly in need of a "refresh" to keep up with technological changes over the past fifteen years. The Board expects this final rule to be a major step toward ensuring that ICT is more accessible to and usable by individuals with disabilities — both in the Federal workplace and society generally. Indeed, much — if not most — of the significant benefits expected to accrue from the final rule are difficult, if not impossible, to quantify, including: greater social equality, human dignity, and fairness.
Each of these values is explicitly recognized by Executive Order as important qualitative considerations in regulatory analyses. Moreover, American companies that manufacture telecommunications equipment and ICT-related products will likely derive significant benefits from the Access Board's concerted efforts to harmonize the accessibility requirements in the Revised Standards and Guidelines with voluntary consensus standards. Given the relative lack of existing national and globally-recognized standards for accessibility of mobile technologies, telecommunications equipment manufacturers will, we believe, greatly benefit from harmonization of the Revised Guidelines with consensus standards.
Similar benefits will likely accrue more generally to manufacturers of all ICT-related products as a result of harmonization. It is also equally important to note that some potentially substantial incremental costs arising from the final rule are not evaluated in the Final RIA, either because such costs could not be quantified or monetized due to lack of data or for other methodological reasons or are inherently qualitative.
For example, due to lack of information, the Final RIA does not assess the cost impact of new or revised requirements in the Revised Guidelines on computer and telecommunications equipment manufacturers. The Access Board issued the existing Guidelines for telecommunications equipment and customer premises equipment in Two years later, in , the Board published the existing Standards. In this preamble, all citations to 36 CFR part refer to the existing Guidelines in force since , while all citations to 36 CFR Part refer to the existing Standards in force since The existing Standards require Federal agencies to ensure that persons with disabilities — namely, Federal employees with disabilities and members of the public with disabilities — have comparable access to, and use of, electronic and information technology regardless of the type of medium absent a showing of undue burden.
Among other things, these standards: define key terms such as "electronic and information technology" and "undue burden" ; establish technical requirements and functional performance criteria for covered electronic and information technologies; require agencies to document undue burden determinations when procuring covered products; and mandate accessibility of support documentation and services. Generally speaking, the existing Standards take a product-based regulatory approach in that technical requirements for electronic and information technology are grouped by product type: software applications and operating systems; Web-based intranet and Internet information and applications; telecommunications products; self-contained, closed products; and desktop and portable computers.
The existing Guidelines require manufacturers of telecommunications equipment and customer premises equipment to ensure that new and substantially upgraded existing equipment is accessible to, and usable by, individuals with disabilities when readily achievable. The existing guidelines, as with the Standards, define key terms such as "telecommunications equipment" and "readily achievable" and establish technical requirements for covered equipment, software, and support documentation.
These guidelines also require manufacturers of covered equipment to consider inclusion of individuals with disabilities in their respective processes for product design, testing, trials, or market research. In the years following our initial promulgation of the existing Standards and Guidelines, technology has continued to evolve at a rapid pace.
Pursuant to our statutory mandate, the Access Board deemed it necessary and appropriate to review and update the existing Standards and Guidelines in order to make them consistent with one another and reflective of technological changes. See Advisory Committee Report, U. Access Board Apr. This TEITAC Report provided a set of recommended updates to the existing Standards and Guidelines, which, the committee noted, were intended to balance two competing considerations: the need for clear and specific standards that facilitate compliance, and the recognition that static standards "consisting of design specification[s] and fixed checklists" would tend to "stifle innovation" and "delay the availability of technology advancements to people with disabilities.
To address these considerations, the TEITAC Advisory Committee recommended that the Access Board jettison its existing product-based regulatory approach in favor of technical requirements to achieve accessibility based on ICT functions or features. The Committee also noted the importance of harmonizing with international standards to both spur development of accessible ICT products and reduce manufacturers' costs in the global market. All told, the TEITAC Report provided a comprehensive recommended set of technical requirements applicable to a broad range of ICT functions and features, including: closed functionality; hardware with and without speech output; user interfaces; electronic content; processing and display of captions and audio description; RTT; authoring tools; and, product support documentation and services.
While the majority of the proposed requirements in the draft rule were not substantively changed from the existing Standards and Guidelines, there were some notable proposed substantive revisions. Two of the most significant were the proposals to require that Federal agencies make electronic content of specified official communications accessible, and to harmonize with WCAG 2.
In the draft rule, the proposed standards and guidelines shared a common set of functional performance criteria Chapter 2 and technical design criteria Chapters , but had separate introductory chapters Chapters 1 and 2 , which outlined the respective scoping, application, and definitions for the revised Standards and Guidelines. We also received written comments during the comment period. Comments came from industry, Federal and state governments, foreign and domestic companies specializing in information technology, disability advocacy groups, manufacturers of hardware and software, trade associations, institutions of higher education, research and trade organizations, accessibility consultants, assistive technology industry and related organizations, and individuals.
In general, commenters agreed with our approach to addressing the accessibility of ICT through functionality rather than discrete product types. For example, commenters noted confusion by virtue of the fact that some chapters focused on functional features of accessibility while others addressed specific types of technology, or that the meaning of "ICT" seemed to vary depending on the context of the specific chapter. Other commenters opined that deviations from WCAG 2.
By the following year, in , the Access Board was poised to invite public comment on a revised version of the draft rule.
The Board acknowledged that, based on comments to the ANPRM, the draft rule needed to be reorganized and made more concise. More importantly, we needed to obtain further comment on major issues and harmonize with the European Commission's ICT standardization efforts that were already underway at that time.
To address comments criticizing the length and organization of the ANPRM as unwieldy, the revised draft rule consolidated and streamlined provisions into six chapters from ten , consolidated advisories, and reduced the page count from close to to less than We also made revisions to improve the clarity of various proposed provisions and ensure a consistent organizational structure throughout this draft rule.
See, e. Additionally, to address commenters' collective concern that rephrasing of WCAG 2. In issuing the ANPRM, the Access Board also took notice of the standardization work going on in Europe at the time, stating: [T]he Board is interested in harmonizing with standards efforts around the world in a timely way.
Accordingly, the Board is now releasing this second Advance Notice of Proposed Rulemaking ANPRM to seek further comment on specific questions and to harmonize with contemporaneous standardization efforts underway by the European Commission. Comments came from industry, Federal and state governments, foreign and domestic companies specializing in information technology, disability advocacy groups, manufacturers of hardware and software, trade associations and trade organizations, institutions of higher education and research, accessibility consultants, assistive technology industry and related organizations, and individual stakeholders who did not identify with any of these groups.
In general, commenters continued to agree with our approach to address ICT accessibility by focusing on features, rather than discrete product types. Commenters supported the conciseness of the proposed provisions in the ANPRM, and asked for further streamlining where possible.
Commenters also generally voiced strong support for the Board's decision to incorporate by reference WCAG 2. In , the Access Board formally commenced the rulemaking process by issuing a notice of proposed rulemaking to update the existing Standards and Guidelines. This proposed rule—while making editorial changes and other updates in response to comments on the ANPRM— retained the same overall structure and approach to referencing WCAG 2.
Additionally, written comments were received in response to the NPRM. Comments came from industry, Federal and state governments, disability advocacy groups, manufacturers of hardware and software, trade associations and trade organizations, institutions of higher education and research, and individuals who did not identify with any of these groups.
Overall, we received about comments in response to the NPRM, including written comments and oral testimony from witnesses at the three public hearings. These commenters represented, when excluding multiple submissions, about different entities or individuals. By general category, these NPRM commenters can be broken down as follows: individuals 59 ; disability advocacy organizations 59 ; ICT companies 10 ; accessible ICT services providers 11 ; trade associations representing ITC and telecommunications companies 11 ; individuals or groups identifying themselves as ICT subject matter experts 13 ; academicians 6 ; state or local governmental agencies 7 ; standards development organizations 3 ; international disability advocacy organizations 9 ; and, anonymous 4.
In general, commenters spoke positively about the proposed rule, and noted that it was much improved from earlier iterations in the and ANPRMs.
By a wide margin, the single most commented-upon aspect of the proposed rule and the issue on which commenters expressed the greatest unanimity was timing. Characterizing refresh of the Standards and Guidelines as "long overdue," these commenters urged the Access Board to issue its final rule as expeditiously as possible.
On substantive matters, a large number of commenters addressed some aspect of the requirements for electronic content, with the bulk of these comments relating to Section covered content. Another technical area receiving sizeable comment was our proposal that, under both Sections and , WCAG 2. Additionally, real-time text RTT was a subject of great interest to NPRM commenters, with most commenters representing disability advocacy organizations and academicians supporting the Board's RTT proposal, while ITC manufacturers and trade groups expressed opposition.
Further, the issue of harmonization with EN received considerable comment. In general, ITC industry-related commenters urged the Board to harmonize more closely with this European specification. Disability advocacy organizations and consumer-related commenters, on the other hand, viewed the proposed rule and EN as well harmonized already and expressed concern that further harmonization would be improvident because, in their view, EN set forth weaker accessibility requirements in some areas.
Lastly, the Board received multiple comments from individuals or entities addressing various types of electromagnetic sensitivities. These commenters requested that the final rule require accommodations for people with electromagnetic intolerances, so that they might use Federal buildings and Federally-funded facilities.
The Board acknowledges the challenges faced by individuals with electromagnetic sensitivities, and notes that electromagnetic sensitivities may be considered a disability under the ADA if the sensitivity so severely impairs the neurological, respiratory, or other functions of an individual that it substantially limits one or more of the individual's major life activities.
However, most of the accommodations suggested by these commenters are beyond the scope of this rulemaking or our statutory jurisdiction.
