specific sensory experience, 5) a Completely Automated Public Turing test to tell Computers and Humans Apart (CAPTCHA), or 6) a decoration, formatting, or invisible. Most of these exceptions permit the text alternative to at least provide descriptive identification of the non-text content. With such broad exceptions intended to address technically challenging situations specifically built into the success criteria, an undue burden or fundamental alteration defense for using a conforming alternate version rather than rendering a Web page directly compliant with the Level AA success criteria will be a very high bar to meet. If, despite the exceptions built into the WCAG 2.0 standard, a carrier believes an undue burden defense is justified with respect to a particular Web page, we would emphasize that the determination must be based on an individualized assessment of a number of factors showing that directly converting the Web page would cause significant difficulty or expense to the carrier. Those factors include: the size of the primary Web site; the type of change needed to carrier’s bring the particular Web page into compliance; the cost of making the change as compared to the cost of bringing the Web site as a whole into compliance; the overall financial resources of the carrier; the number of carrier employees; the effect that making the change would have on the expenses and resources of the carrier; whether the carrier is part of a larger entity and its relationship to the larger entity; and the impact of making the change on the operation. carrier’s Compliance Monitoring The SNPRM: In the September 2011 SNPRM, the Department discussed several issues relating to ensuring and monitoring compliance with the WCAG 2.0 accessibility carriers’ standard. We discussed, but did not propose to require, that carriers post WCAG 2.0 on their Web sites. (A is term of art for a “conformance claims” “conformance claim” W3C’s statement by an entity giving a brief description of one Web page, a series of pages, or multiple
specific sensory experience, 5) a Completely Automated Public Turing test to tell Computers and Humans Apart (CAPTCHA), or 6) a decoration, formatting, or invisible. Most of these exceptions permit the text alternative to at least provide descriptive identification of the non-text content. With such broad exceptions intended to address technically challenging situations specifically built into the success criteria, an undue burden or fundamental alteration defense for using a conforming alternate version rather than rendering a Web page directly compliant with the Level AA success criteria will be a very high bar to meet. If, despite the exceptions built into the WCAG 2.0 standard, a carrier believes an undue burden defense is justified with respect to a particular Web page, we would emphasize that the determination must be based on an individualized assessment of a number of factors showing that directly converting the Web page would cause significant difficulty or expense to the carrier. Those factors include: the size of the carrier’s primary Web site; the type of change needed to bring the particular Web page into compliance; the cost of making the change as compared to the cost of bringing the Web site as a whole into compliance; the overall financial resources of the carrier; the number of carrier employees; the effect that making the change would have on the expenses and resources of the carrier; whether the carrier is part of a larger entity and its relationship to the larger entity; and the impact of making the change on the carrier’s operation. Compliance Monitoring The SNPRM: In the September 2011 SNPRM, the Department discussed several issues relating to ensuring and monitoring carriers’ compliance with the WCAG 2.0 accessibility standard. We discussed, but did not propose to require, that carriers post WCAG 2.0 “conformance claims” on their Web sites. (A “conformance claim” is W3C’s term of art for a statement by an entity giving a brief description of one Web page, a series of pages, or multiple
ACAA%20Kiosk%20and%20Web%20Site%20Final%20Rule%20October%2023%202013%20original%20signed%201_0.docx