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Agenda Item # 13

BOARD MEMORANDUM

FOR INFORMATION ONLY

The attached proposed policy is being presented to the Committee for Transit Accessibility for its review and comment.   VTA requests that the CTA provide its input and feedback to staff by the next CTA regular meeting on January 9, 2008.   This item will be added to the agenda for discussion.

The policy reflects VTA’s commitment to ensuring that information issued by VTA is effectively communicated. The policy applies to documents created or generated by VTA or its contractors in the performance of work on behalf of VTA and to internal and external official web pages developed or maintained by VTA or for VTA.

This policy, once adopted and implemented, will comply with Federal, State and local regulations that require information from VTA to be accessible by the public, including those with visual, physical or developmental disabilities.  Under this policy, VTA adopts the standards set forth in 36 CFR §§1194.21 and 1194.22, which implement Section 508 of the Rehabilitation Act of 1973, as amended, and with the Web Content Accessibility Guidelines Version 1.0 Priority 1 of the World Wide Web Consortium.   The Committee’s review and comment will provide an essential perspective on the policy.

After receipt of the feedback from the Committee, the General Manager will provide the final review and approval.

There are no practical alternatives.

There is no fiscal impact.

DRAFT accessible information policy – documents and web-based intranet and interneT

• Policy:

VTA is committed to ensuring that communications to its employees and members of the public are effective and that information is provided in a means that is accessible to all users, including individuals with disabilities, as mandated by the American with Disabilities Act of 1990 (42 U.S.C. §§ 12101 et seq.); Part 35 of Title 28 of the Code of Federal Regulations; Section 504 of the Federal Rehabilitation Act of 1973 (29 U.S.C. §794); and California’s Unruh Civil Rights Act (Cal. Civil Code §51 et seq.).

To afford an individual with a disability an opportunity to participate in a VTA service, program, or activity, VTA shall furnish, at the request of any person, auxiliary aids and services (as defined in 28 CFR §35.104) to the individual with the disability to assist the individual in using or understanding VTA documents or web-based content, unless furnishing such auxiliary aid or service would create an undue financial and administrative burden on VTA or would result in a fundamental alteration in the nature of the service, program or activity.

As one form of auxiliary aid and service, VTA shall create documents or web-based content in a manner that complies with the standards set forth in 36 CFR § 1194.22, which implements Section 508 of the Rehabilitation Act of 1973, as amended, and with the Web Content Accessibility Guidelines Version 1.0 Priority 1 of the World Wide Web Consortium (www.w3.org).   VTA adopts these standards as its Document and Web Content Accessibility Standards (“Accessibility Standards”), and shall ensure that its documents and web-based content are in compliance with these standards.   At least annually, VTA shall review the Accessibility Standards for updates.

Scope:

• Compliance:

In creating documents or web-based content, every employee shall comply with VTA Accessibility Standards.   Managers shall ensure that documents created or generated by VTA’s contractors at VTA’s request are compliant with the Standards.  The VTA Office of Civil Rights of the Employee Relations Department shall ensure compliance with this policy and shall maintain records of, and investigate complaints regarding accessibility.

4.0       Exceptions:

If VTA is unable to provide a document or web-based content in a manner that complies with the Accessibility Standards  due to technical limitations, commercial non-availability, undue burden (i.e., VTA would incur significant expense or difficulty in order to comply with the particular standard), or if complying with the Standards would result in a fundamental alteration in the nature of VTA’s service, program, or activity, the Accessible Services Manager (or his or her designee) in collaboration with the Client Relationship Supervisor of the Information Technology Department (or his or her designee), shall identify which VTA Accessibility Standards cannot be met and the reason therefor.  If meeting the Standards would create an undue burden or would result in a fundamental alteration in the nature of the service, program, or activity, then the Accessible Services Manager and the Client Relationship Supervisor shall document the difficulty or explain why the expense is prohibitive.  The Accessible Services Manager and the Client Relationship Supervisor shall also address whether other auxiliary aids and services are available to the person requesting such aid or service and shall also document reasons why such aid or service is unavailable.  The Accessible Services Manager shall prepare and send to the Office of Civil Rights a report setting forth those findings.  In cases where the document or web-based content does not meet VTA Accessibility Standards, or if no other auxiliary aids and services are available that would enable a user to access the document or web-based content, the Accessible Services Manager shall contact and so notify the person requesting the aid or service.

            5.2       World Wide Web Consortium (W3C):    An international consortium jointly run by the (a) Massachusetts Institute of Technology (MIT) in the United States of America; (b) National Institute for Research in Computer Science in France; and       (c) Keio University in Japan, that provides information for developers and users; sets standards and demonstrate the use of new technology, with the fundamental purpose of maximizing the operability and accessibility of web content.

5.3       Web Content Accessibility Guidelines:   Guidelines developed by the W3C to help designers make web pages as accessible as possible to the widest range of users, including users with disabilities.   Guidelines are available by logging on to www.w3.org,: or call – (617) 253-2613; or write to:

MIT

32 Vassar Street , Room 32-G515

Cambridge , MA 021339

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