In a letter to the Department of Justice, SIIA expresses support for enhanced web accessibility under Title II of the ADA and the WCAG. However, SIIA raises concerns:

  1. Disproportionate Impact on Smaller Entities: SIIA suggests a longer phase-in period for smaller public entities to comply.
  2. Embracing Innovation: SIIA emphasizes the potential of innovative technologies in improving accessibility.
  3. Conforming Alternate Versions: We stress the importance of maintaining the ability to provide alternative versions of materials.
  4. Remediation for Non-Conformance: SIIA recommends allowing remediation for isolated and temporary non-conformance.
  5. Tailored Compliance: We suggest considering factors like annual budget when setting compliance requirements.
  6. Live-Audio Content Captioning: SIIA agrees with deferred compliance for live-audio captioning.
  7. Third-Party Web Content: SIIA acknowledges third-party efforts to meet accessibility standards.
  8. Course Content Accessibility: We propose a later compliance date for remediating existing content.
  9. Measuring Compliance: SIIA mentions the use of the Voluntary Product Accessibility Template (VPAT) and emphasizes the need for clear policies.

SIIA supports the goal of accessibility but raises concerns about the potential impact of the proposed rules on various entities, especially smaller ones. We advocate for flexibility, innovation, and consideration of practical challenges in implementing web accessibility standards.