Comment on the proposed Title II rule on Web Accessibility Addressing Visual Communications

Here is a comment I posted addressing the use of maps, data visualizations, and other largely visual methods of communication to the proposed rule on web accessibility under Title II of the Americans with Disabilities Act.


Local governments are increasingly using maps, data visualizations, and other methods of communication that are inherently visual in nature to provide information about their activities, programs, and services. In some potentially dangerous situations, they are also using these inherently visual methods of communication to share information about emergencies.

To make this issue more concerning, WCAG does not offer much in the way of guidance for how these kinds of visual methods of communication can be made accessible to users of assistive technologies, especially those of us who use screen readers.

If WCAG is adopted as the standard of compliance under Title II and DOJ does not expressly address inherently visual methods of communication, those of us with disabilities will be left further-and-further behind as these visual methods of communication become even more popular.

Those of us with disabilities will have the right to request information originally communicated through the use of not very accessible methods of communication, but if we die in a flood before accessing that ` we will be unable to request information about the flood in an accessible format.

DOJ’S effective communication requirement and its guidance on accessible emergency preparedness both call for accessible emergency communications. But unless DOJ clearly communicates how emergency information and other critical information is to be communicated, local governments will continue using visual methods of communication as the sole method of communicating information that could save lives or negatively impact our ability to participate in their activities, programs, and services.

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