NetCentric Accessibility Newsletter: June 1, 2015

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Welcome to the June issue of NetCentric’s Accessibility Newsletter!

This month, we’re focusing on accessibility and municipal governments. As access to civic life by people with disabilities is a fundamental goal of the American with Disabilities Act, we’ve taken a closer look at the ways that municipal governments are affected by accessibility regulations in contrast to International, Federal, and State laws.

We’ve also spent some time with the City of LA, learning how they’re conquering the seemingly insurmountable task of implementing an accessibility program that is truly revolutionary amongst municipalities of its size.

And NetCentric answers the burning question on everyone’s mind, “Will today’s electronic documents be good for the 508 Refresh?”

As always, we welcome your suggestions for upcoming topics and would like to know what you think of NetCentric’s Accessibility Newsletter.

Use this link to share your comments or story ideas with the NetCentric Accessibility Newsletter staff.

We Hope You Enjoy!

NetCentric Technologies


Will Your Documents Survive The Refresh?


A major concern facing individuals and organizations when anticipating and preparing for the upcoming Section 508 Refresh is how electronic documents that are compliant under the current standards will be affected by the new standards. The question facing many organizations is, “How much additional effort will be required to make electronic documents that are compliant according to today’s Section 508 standard accessible under the standards proposed for the upcoming refresh?”

In an attempt to address this issue, The Access Board has created a comprehensive table comparing WCAG 2.0 Level A and AA Success Criteria to the corresponding requirements in the existing 508 Standards. The table can be found on the Access Board website.

The WCAG 2.0 Success Criteria are more explicit than the existing 508 Standards.   In addition, unlike the existing 508 Standards, WCAG 2.0 is written in a way that is technology neutral and is therefore directly applicable to a wide range of content types and formats.  The access board developed the  table comparing the WCAG 2.0 Level A and AA Success Criteria and the corresponding requirements in the existing 508 Standards to clarify the differences.  Where a WCAG 2.0 success criterion is new and does not correspond to a provision in the existing 508 standards, it addresses a deficiency with the existing 508 Standards as identified by the developers of WCAG.

There are 38 Level A and AA Success Criteria.  Of these, 22 are phrased differently but equivalent in substance to current 508 requirements.  Content that meets the current 508 requirements would not have to be changed to meet the corresponding success criteria.

The remaining sixteen success criteria are new and content that meets the current 508 requirements might not meet these success criteria. It is conceivable that a document that previously passed the older 508 may fail the new 508 (based on WCAG 2.0 AA or PDF/UA) especially in those 16 areas defined as “New”, meaning there was no equivalent requirement under the old 508.

The sixteen new criteria which the Access Board has defined as “new” are listed here for your convenience:

Item WCAG 2 Criteria WCAG 2.0 Level Summary
1 1.3.2 Meaningful Sequence A Provides for a reasonable and logical reading order  when using assistive technology
2 1.3.3 Sensory Characteristics A Provides that instructions are not conveyed only through sound, shape, size, or visual orientation
3 1.4.2 Audio Control A Provides that there is a way to stop, pause, mute, or adjust volume with audio that plays automatically
4 1.4.3 Contrast (Minimum) AA Provides for specified contrast between foreground and background of text and images of text
5 1.4.4 Resize Text AA Provides for content that remains readable and functional when the font size is doubled
6 2.1.2 No Keyboard Trap A Provides that the keyboard focus is not trapped when the keyboard is used for navigation
7 2.4.3 Focus Order A Provides for a keyboard-oriented navigation order that is reasonable and logical. Provides that links, form elements, and other user interface controls and components have a reasonable and logical navigation order.
8 2.4.4 Link Purpose (In Context) A Provides that the purpose of any link is understandable from its text or context
9 2.4.5 Multiple Ways AA Provides for two or more means to locate content
10 2.4.6 Headings and Labels AA Provides that headings and labels are descriptive
11 3.1.1 Language of Page A Provides that the default language of content is exposed  to assistive technology
12 3.1.2 Language of Parts AA Provides that changes in language are exposed to assistive technology
13 3.2.3 Consistent Navigation AA Provides that repeated navigational components occur in the same relative order each time they are encountered
14 3.3.3 Error Suggestion AA Provides that the system makes suggestions for correction when input errors are automatically detected and suggestions are available
15 3.3.4 Error Prevention (Legal, Financial, Data) AA Provides that when legal, financial, or test data can be changed or deleted the changes or deletions can be reversed, verified, or confirmed
16 4.1.1 Parsing A Provides that significant HTML/XHTML validation and parsing errors in source code are avoided


In addition to the applicability of WCAG 2.0 A and AA to all Information Communications Technology, the PDF/UA standard is also acceptable where applicable – in other words, for those instances where the electronic document is a PDF file.

In upcoming issues of the newsletter, we will provide an explanation and examples of proper implementation for these new criteria.

How can you quickly assess your current inventory of PDF documents for compliance with both the current and proposed document accessibility standards?  There’s no need to wait to get ready. You can get started today and reduce the anxiety of continued compliance by relying upon NetCentric Technologies and  CommonLook PDF GlobalAccess.  With CommonLook PDF GlobalAccess you have a versatile tool that can perform fast, reliable, automated testing of PDF files which will quickly reveal whether your current PDF files which pass today’s Section 508 Accessibility Standard will also pass not just the WCAG A and AA criteria, but also concurrently supports PDF/UA which will also be acceptable for PDF files.

There’s another benefit CommonLook PDF GlobalAccess provides, and it’s important, as the new regulations won’t take affect for at least one year. CommonLook PDF GlobalAccess can analyze and repair PDF files in accordance with the current Section 508 standard, WCAG 2.0, and PDF/UA – all in one application. There’s no need to experience anxiety and rely on guesswork, CommonLook PDF GlobalAccess lets you prepare documents today that will past the tests of time for now and into the future.


Industry Spotlight:  

The ADA, Accessibility Regulations and Municipalities 


City Hall Image
Our article on the City of Los Angeles providing accessible emergency preparedness information to persons with disabilities is especially appropriate on this, the 25th anniversary year of the Americans with Disabilities Act (ADA).

The ADA represents a particularly important concern for state and local governments as an entire Title of the law is devoted to Nondiscrimination on the Basis of Disability in State and Local Government Services. Title II of the ADA – Nondiscrimination on the Basis of Disability in State and Local Government Services – describes the municipal obligation to provide total program access to persons with disabilities.

Accessibility does not end with compliance with the Web Content Accessibility Guidelines (WCAG) and Section 508. In fact, adoption of such standards, while important, represents merely one component of total program access to government services for persons with disabilities as defined by the Americans with Disabilities Act (ADA).

Many government services and activities are provided on websites because the public is able to participate in them at any time of day and without the assistance of government personnel. Many government websites offer a low cost, quick, and convenient way of filing tax returns, paying bills, renewing licenses, signing up for programs, applying for permits or funding, submitting job applications, and performing a wide variety of other activities.

The guiding principle for government services under Title II is one of total program access, a recognition that an accessible website is only part of the story. A first line of defense is to make the PDFs and web pages on the state/local government website accessible. But even if the web pages and PDF’s are accessible, it is theoretically possible that a person’s disability prevents them from accessing it (e.g. in the case of cognitive disabilities).  In this case, you would still have to ensure program access— and this still means providing alternative accessible ways at getting at that information.

In its best practices toolkit, the Justice Department recommends developing an 8 step action plan for providing accessible websites. Steps six and eight address the need to provide accommodations beyond the website, even if it is accessible.

VI. Provide a way for visitors to request accessible information or services by posting a telephone number or email address on your home page. Establish procedures that ensure a quick response to users with disabilities who are trying to obtain information or services in this way.

VIII. Ensure that there are alternative ways for people with disabilities to access the information and services that are provided on your website. Remember, some people may not have, or be able to use, a computer.

Here are all 8 steps in the recommended action plan:

  1. Establish, implement, and post online a policy that your webpages will be accessible and create a process for implementation.
  2. Ensure that all new and modified webpages and content are accessible.
  3. Develop a plan for making your existing web content accessible. Describe your plan on an accessible webpage, and encourage input on how accessibility can be improved. Let visitors to your website know about the standards or guidelines that you are using to make your website accessible. When setting timeframes for accessibility modifications to your website, make more popular webpages a priority.
  4. When updating webpages, remember to ensure that updates are accessible. For example, when images change, the text equivalents in “alt” tags and long descriptions need to be changed so they match the new images.
  5. Ensure that in-house staff and contractors responsible for webpage and content development are properly trained. Distribute the Department of Justice technical assistance document “Accessibility of State and Local Government Websites to People with Disabilities” to these in-house staff and contractors on an annual basis as a reminder. This technical assistance document is available on the ADA Home Page at
  6. Provide a way for visitors to request accessible information or services by posting a telephone number or email address on your home page. Establish procedures that ensure a quick response to users with disabilities who are trying to obtain information or services in this way.
  7. Periodically enlist disability groups to test your pages for ease of use; use the feedback they provide to increase the accessibility of your website.
  8. Ensure that there are alternative ways for people with disabilities to access the Ensure that there are alternative ways for people with disabilities to access the information and services that are provided on your website. Remember, some people may not have, or be able to use, a computer.

The United States Department of Justice maintains a website providing information and technical assistance on the Americans with Disabilities Act at

The United States Justice Department publishes a best practices toolkit for State and Local Governments.

Technical Assistance for accessible State and Local Government websites is available from the United States Justice Department

[Ken Nakata from our strategic partner, Cryptzone (formerly HiSoftware) makers of HiSoftware Compliance Sheriff, contributed to this article]


Access and The City: 

Los Angeles’ Groundbreaking Municipal Accessibility Program

Los Angeles City Hall

Close your eyes for a moment and imagine the city you live in is facing a natural disaster – it could be a fire, flood, hurricane, or some other natural or man-made catastrophe.

Whatever the situation may be, you’re in immediate need of important information on how to secure your safety and survival and that of your loved ones.  You log on to your computer and visit your city’s emergency management agency’s website, seeking information on shelter locations, evacuation plans, and other emergency communications from your governing officials. In a matter of moments, you have the elements of a disaster plan you can put into action, thanks to the speed and easy access of information via the World Wide Web.

Now imagine for a moment this same scenario, except one thing is different – you are blind. Logging onto the very same website, you now find that the vital information you seek is not accessible to you, unreadable by your screen reader. In a moment like this, what do you do?

It’s a situation that many individuals with disabilities – visual or otherwise – have confronted and, in a moment of peril, been forced to quickly come to terms with.

Disasters of a Digital Landscape

Natural disasters in our nation’s recent history provide us with an opportunity to consider the problem of providing accessible emergency information to persons with disabilities. Like anyone who may be in the path of nature’s wrath, persons with disabilities turn to government officials for information on disaster preparedness, evacuation details, and survival guides in times of impending danger. Like anyone who may be in the path of nature’s wrath, persons with disabilities  turn to government emergency management agencies for information on disaster preparedness, evacuation details, and survival guides in times of impending danger. While it is certainly never the intention of a municipal government to exclude disabled members of their communities from having equal access to vital, potentially life-saving information, the fact is that many municipalities are falling short in providing equal access on their websites, inadvertently jeopardizing the safety of those with disabilities.

In a post-American Disabilities Act era, municipal governments, like any other organizations, are challenged with creating web content that is accessible to everyone. The undertaking requires creating and implementing a system that works fundamentally across an organization, often times across multiple departments. It can be a daunting task, requiring experts who are not only experts in the field of disaster planning but in the special needs of persons with disabilities. As accessibility is still a relatively new concept in today’s digital landscape, it’s understandable that many municipalities are faced with a significant challenge in providing disaster preparedness information for persons with disabilities.

The City of Accessibility

Spurred by a landmark injunction less than 5 years ago, the City of Los Angeles has made groundbreaking progress that is arguably the first of its kind in the country when it comes to implementing an accessibility plan across a municipal government encompassing 27 different departments. While still in the initial stages of development, the progress they’ve made is significant.

Key Players

Balmore Botero works for LA’s Information Technology Agency (ITA) and serves as the technology liaison and Section 508 conformance auditor for the city.  Nicole Willett is the City’s Public Information Officer for the Department on Disability (DoD).  Their separate entities have been jointly spearheading the city’s accessibility initiative, and Botero and Willett serve as key players and catalysts.

“A few years ago, the city needed to come up with a solid strategy for identifying and correcting emergency documents for Section 508 compliance,” says Botero.  Since that time, the ITA has been has been working closely with Willett and the DoD to create and implement a large-scale, municipal accessibility solution.

Finding a Solution

The ITA and DoD’s first task was to identify a set of tools that would enable city departments to find and fix inaccessible documents, as well as create accessible documents moving forward.

“Our first step was to look at Adobe Acrobat Pro,” says Botero.  “The product could do the job of fixing a document but the learning curve was high and there was no way of discovering which documents were compliant or not.”

The groups also needed to ensure the solution they chose would allow them to test for accessibility against an established standard – in their case, WCAG 2.0. “In order to provide clear guidance, we found that using WCAG 2.0 to test against was a simpler way to “score” a document’s accessibility,” says Botero.  “So whatever product we chose to use had to follow the WCAG 2.0 standard.”

As they researched solutions for their document accessibility issues, they came upon NetCentric and the company’s CommonLook tools. “We found that was a great resource and they listed CommonLook as a useful tool for PDF repair,” says Botero.  “Upon further investigation, we discovered the Clarity product. Clarity would discover and CommonLook Office Pro and CommonLook PDF GlobalAccess would help in the correction process.”

“By using the CommonLook Office software, it provides a simpler tool to check whether a Word or PowerPoint document is accessible,” adds Willett. “It provides a much less cumbersome process than using a screen reader to do so.”

Easy as 1, 2 … 27?!

Once the city had chosen the CommonLook tools as the solution for its departments’ electronic document accessibility needs, implementation was the next step.  Considering the City of LA is a large municipality comprising 27 different departments, it was a sizeable task.

“We’re well underway in the implementation process,” says Botero, “but it sometimes feels like taking baby steps up a mountain.”

“The biggest challenge is the scale,” says Willett.  “There are over 30,000 city employees. Not all create documents, but many do, and we need to ensure the accessibility of those documents moving forward.”

The city made a strategic decision to begin implementation with departments that provided emergency preparedness information. The accessibility of its emergency plans was made a priority in order to ensure a safer environment for all in the event of a natural disaster.  “A huge push came for emergency departments and emergency information to be made accessible,” says Botero. “It was a matter of logistics to say, ‘We’ve got to start small, so let’s start there.’ If we had just gone straight out to all departments and said, ‘Everybody, now, get this done, you’ve got one year’ – it had failure written all over it.”

As a result, the ITA is working in conjunction with the DoD in a tactical fashion, having begun with those departments containing emergency information. Over time, the lessons learned from the emergency preparedness implementation will expand to eventually include all 27 City of LA departments.

Putting the Tools to Work

Using the CommonLook Clarity tool for PDF accessibility testing, Botero runs reports on all departments’ PDF documents containing emergency information. After generating the Clarity reports, it is Botero’s job to explain the reports to the departments and determine how many licenses of the CommonLook PDF GlobalAccess and CommonLook Office Pro tools, which are housed in the DoD, will be needed to proceed.  Botero helps design a workflow, a process that requires a different approach for each department based upon their unique needs and the individuals involved, and Willett is responsible for training employees on creating accessible documents to meet compliance standards using the CommonLook Office Pro tool.  “There was a good deal of resistance to the new layer of work to be done,” Botero admits, “but with just a little bit of practice, they became very good at it.  Selling the concept was a little tricky but with screen reader demos and clear explanations of the errors, people understood.”

CommonLook Training was key to this understanding and to getting stakeholders tasked with ensuring accessibility of their department’s documents on board.  “Training has been and will be essential,” says Botero. “People really have to come to understand why this work has to be done.  As they sit in the training session and ask questions the objective comes into focus.  From there we hope that the trained staff go out to their offices and evangelize the good that comes from creating accessible PDFs.”

An All-Inclusive Culture

While Botero, Willett, and their colleagues at the City of LA may be taking “baby steps up a mountain,” the steps they have made thus far are immeasurable in creating a more accessible city for all of LA’s inhabitants.  “It’s been a big eye-opener for everyone,” says Botero of the process.  “This information is out there and it has to be out there for everyone. It’s all-inclusive. This initiative has really helped the culture of information dissemination.”

Iconic for many reasons, Los Angeles can now add to its many distinctions the creation of a culture of accessibility that will serve as an exemplar for municipalities nationwide, paving the way for them to follow suit.



Accessible Instructional Materials and Technology Summit

Columbia, MD

June 18-19, 2015


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State College, PA

June 22-23, 2015


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