Thread Subject: Access Board Response to 8/22/07 Audio/Video S/C Question

From: James Elekes
Date: Thu, Aug 23 2007 11:50 AM

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All, recall I took responsibility to forward our
inquiry to David Capozzi. The Board's Staff response contained herein.

-Jim

James J. Elekes, Chairman
Telecommunications, Electronic/Information Technologies Committee
United States Access Board

(O) 888.564.8430


Hi Jim,

Thank you for your question. The simple answer is
yes about the captioning requirement. We are
assuming that this question refers to a
multimedia video where there is both visual and audio information.

Essentially the question is one of equivalent
facilitation. The issue is about why it would be
necessary to provide captions to people who are
deaf if they are already getting the same information via sign language.

My argument falls under the spirit of comparable
access. We know that 95% of people with hearing
loss are not culturally Deaf with a capital D. In
this context, I mean that most people with
hearing loss do not know sign language and
therefore would not benefit from the sign
language interpreter. If the captions were not
provided, then people who are hard of hearing or
who are late deafened will miss out on essential
audio information. Therefore, this attempt at
providing equivalent facilitation would fail to
pass the test of providing access that is
equivalent or greater than the access provided
through the Subpart B technical provisions, which
specifically call out the captioning requirement.

In terms of specific 508 provisions, here are the two sources:
* § 1194.5 Equivalent facilitation
* § 1194.24(c) Video and multimedia products.

This is not preclude the value of providing both
captions AND interpreting together. We know that
there are people who are deaf who find it
difficult to read English in text. Out of respect
to such preferences, the TEITAC is certainly
welcome to provide an advisory recommendation
about this combined option. For reference, an
informative example in the federal sector is the
new CDC video PSA series related hurricanes:
http://www.bt.cdc.gov/disasters/hurricanes/psa.asp

Regards,
David

David Baquis
Accessibility Specialist
U.S. Access Board
1331 F Street, NW, #1000
Washington, DC 20004
800-USA-ABLE; (202) 272-0013 (desk tel); 240-855-1682 (cell)
www.access-board.gov;
= EMAIL ADDRESS REMOVED = "Leading the way to excellence in accessibility"

"Thank you for your questions concerning section
508 of the Rehabilitation Act Amendments of
1998. Section 508 authorizes the Access Board to
provide technical assistance to individuals and
Federal departments and agencies concerning the
requirements of this section. This technical
assistance is intended solely as informal
guidance; it is not a determination of the legal
rights or responsibilities of entities subject to section 508."

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