Good day ladies and gentlemen, and welcome to the We''re Not Done Yet DOJ Proposed Will Making and Update conference call. At this time all participants are on a listen only mode. Later we will conduct a question and answer session, and instructions will follow at that time. If anyone should require operator assistance during the conference please press star and then zero on your touch tone telephone. As a reminder, this conference call is being recorded. I would now like to turn the call over to your host Robin Jones. Please go ahead.
Well good afternoon, or good morning to everyone and thank you for joining us today for the ADA Audio Conference Series. This program is being brought to you by the ADA National Network which is the national network of centers across the country addressing ADA related issues and funded by the National Institute on Disability Rehabilitation and Research within the U.S. Department of Education. I''m glad that all of you could participate in today''s session, and I hope you''re all looking forward to hearing some more information from our speaker about the Notice of Proposed Rule Making, which is really kind of what my perspective helping us to catch up to where we would have liked to have been or should have been a while ago in regards to the mainstream community in public in the areas of accessibility of web-based information and equipment and furniture and things of that nature. Movie captioning and, and all of those topics that you''re going to be hearing about today. Hopefully some of you have seen some of the articles that have been published on this, and John will talk a little bit about the efforts that they have to do some public hearings, one of which is going to be in Chicago this Wednesday. We just want, Thursday, I''m sorry. We wanted to also let people know that we are recording this session, and the transcript of this session will be provided to the Department of Justice to be entered in as part of that comments that will be considered in this rule making process. So we just wanted to let people know about that as well. We do have people joining us, on a variety of different methods today. We have individuals who are on the telephone, we have people who are following us through streaming audio on the internet, and then we also have real time captioning on the internet. As I indicated, we are recording this particular session and it will be made available as an archive on our website within 10 days following the session. And accompanied by a transcript for the session. As preparation for this session today, we did refer you to the Notice of Proposed Rule Making that was posted on the U.S. Department of Justice''s ADA website at www, www.ADA.org, and hopefully you were able to take a look at those in advance. If not, hopefully you''ll go back and look at them afterwards, and again John will talk a little bit about how you can continue to give public comment up until the January cut off dates. So those are things that he''ll specifically talk about with us today. We will have a presentation by John and then we will turn it over to him to do question and answer as well. So everyone who does have questions, hopefully, will get a chance to have those answered and the operator will give you instructions as we go along. I just want to do a real brief introduction of John. Many of you know him because he''s been a friend of the ADA Audio Conference Series over the years that we have actually been participating in this type of a program. He is the chief of the disability rights section within the civil rights division of the U.S. Department of Justice. He is a civil rights attorney, with over 30 years of experience in the federal government, and specializing in the rights of persons with disabilities. In his particular position, he''s responsible for enforcement of Titles 1 as they pertain to state and local government, 2 and 3 of the Americans with Disabilities Act, and he plays a key role in developing administrative policy on the ADA and was instrumental in moving the Title 2 and Title 3 regulation revisions forward. And has been on the hot seat I guess I want to say for those, John, for the last couple years, as everyone every time they saw you or talked to you they would be saying to him, John when are those regulations going to come out. So he''s the point person for that, and has been the key individual for those regulations as well. But we do want to make sure that everyone is clear. But today our focus is going to be on the Notice of Proposed Rule Making, and that''s where we really want you to keep your thoughts and your questions as we go forward. So without further ado, I''m going to go ahead and turn it over to you John, go ahead. John: Well thank you very much Robin, I appreciate your kind introduction, as well as your willingness to host this event. We''re going to talk today about four proposed rule makings that the Department of Justice put out in July. What I hope to do in the, the next hour or so is go over our, our four proposals, provide a description of, of each one of them, discuss a couple of the issues on each one. And what I really hope is that this session will wet your appetite and spur all of you who are participating today to comment on the proposals we have. This really is your chance to influence the rule making process before any decisions are made by any officials at the Department of Justice. I encourage you to go to our website, ADA.gov, and, and take a look at the proposals themselves, and to send us your comments, and your views. I''m going to go through each of, of the four rule makings just so you sort of get a lay of the land. We''re going to talk about the proposal on making websites accessible. Then I''ll talk about the one on movie captioning and video description of movies. Then one on accessible equipment. And then one on what we call next generation 911. Let''s start with the accessibility of web information and services provided by entities covered by the ADA. When the ADA was enacted, the internet as we know it now just did not exist. Now websites play a critical role in our daily lives, our personal lives, professional lives, civic and business life. And state and local governments and local entities covered by the ADA are providing their goods and services and their programs to the public through their, their websites. Unfortunately, it''s been brought to our attention that many of these websites are not accessible to individuals with disabilities. Now when we put out our, I think all of you realize we just finished on an ADA rule making process. But when we put out the MPRM in 2008 we did not address the issue of web accessibility and thus, when we put our, our just published rules out we did not include any provision on web access. We did get a lot of comments through that rule making asking us to address the issue of web accessibility. So in response to those comments we issued this, what we call an ANPRM, or an Advanced Notice of Provision Rules Making, or a Pre-Rule Beginning of the rule making process. And we really asked the public for answers to a series of questions. And these go to what an ADA rule by the Department of Justice and web accessibility should contain. And in particular we are interested in information on the costs and benefits of any requirements that the department might adopt. I want you to keep in mind though that the department has made clear in the past that the ADA already applies to websites that are owned or operated by state and local governments, or one of the 12 categories of public accommodations when they use these websites to provide goods and services. And we''ve provided guidance, I think some of you know the guidance we have on state and local government and making websites accessible that''s on ADA.gov. Although we have been consistent and clear that, that the ADA covers websites, we have not, to this point provided any detailed guidance or requirements in the form of a regulation. And what we are now doing is seeking to do just that. Our goal is that any regulation that the department adopts must provide specificity so that it insures web access for persons without disability, but do so without hampering innovation and technological advancement on the worldwide web. Okay. So what''s the problem? Why, why do we have to address this? And the real problem is that many websites do not recognize or provide for the use of assistive technology. So for example, individuals who do not have the use of their hands may use speech recognition software to work on , on a website. Individuals who are blind, may be rely on a screen reader that will convert the visual information on the screen on a website into speech. Many websites fail to incorporate or, or activate features that enable users with disabilities to access all of the sites, information or elements. Other examples, individuals who are deaf, are unable to access information in web videos or multi-media presentations if they don''t have captions. Individuals with low vision may be unable to read websites that don''t allow them to adjust the font size or color contrast on the site''s page so that they can have access to it. Individuals with limited manual dexterity, who may use assistive technology, can''t do so if the website doesn''t give them keyboard alternatives to mouse commands. Similarly people with intellectual disabilities may have difficulty using portions of websites that require timed responses from users but don''t give those users the ability to indicate that they need more time in order to, to respond. Individuals who are blind or have low vision probably in, in our experience have confronted significant barriers to web access. And this is because the many web, websites provide information visually without features that allow screen readers or other assistive technology to retrieve the information on the site so it can be presented to them in an accessible manner. Most, you know these are fairly simple. The most common barrier is an image or a photograph without correspondence texts describing the, the image. Or it may be charts or graphs or online forms, all of which can be made accessible but if the web designer or operator hasn''t taken the steps to do so it won''t be useable by those who use assistive technology. Now why is this important? Because being unable to access websites put individuals at a great disadvantage in today''s society. On the economic front, websites that, that are ecommerce, offer consumers often a wider selection and lower prices than the, the traditional store, brick and mortar stores. And you have the added convenience of you can shop without having to leave your home. In fact, for individuals with disabilities who have barriers to, in their ability to travel or to leave their homes, the internet may be their only source to really have good access to goods and services. Beyond ecommerce the, there''s a growing use of the web in the education world. It''s really becoming a gateway to education. Schools at all levels are offering programs and classroom instruction through their websites. Some colleges offer whole degree programs online. Some just do courses. Some have their entire program online. Even those that aren''t online all the time may rely on websites and other internet related technologies for the application process, for housing eligibility, for a course registration, for assignments, for a variety of, of ways. And even at the elementary and secondary school level, there''s an increasing use of the internet. Sometimes in the risk, the ability of teachers to deal with parents, or administrators to deal with parents to communicate grades, assignments, administrative matters. The internet has also changed the way state and local governments operate. They''re, they''re used by a way for the public to get information and correspond with local officials. You can pay fines, apply for benefits, register to vote, file taxes, do a whole variety of activities online. And I don''t think we should leave out that the, the internet has become a way that individuals socialize and seek entertainment. Social networks and other online meeting places really are providing a unique way for individuals to meet and keep in touch with, with one another. And keep in mind, so the, the basis for our concern is when you look at the ADA the ADA is really a, a guarantee, a promise to people with disabilities that they should be able to participate in every day American life. And American life has shifted in some ways to this web based front. And so we want to be able to address that. So what is our goal in this rule? And our goal is a simple one. To, to take the ADA''s promise to provide an equal opportunity for people with disabilities to participate in and benefit from all aspects of our life. And do so in a way that allows access in today''s technologically advanced society. So we put off this advance notice after all of that collaborative. And, and we are seeking information regarding a, a series of questions. I, I won''t go through all of the questions for, for you today, but I''ll just give you an idea of a couple of the major ones so you, you can address those, but keep in mind there are other issues raised in, in these rules. In the ANPM web access one of the issues is okay what are the standards for what is an accessible website? What should we do about that? And we''re really looking for your guidance on the subject. And we''ve put forth a couple of ideas. One of them is you know we''re aware of the guidelines of the web accessibility initiative of the worldwide web consortium. What is often known as the WC3. And they have established sort of standards. And these standards have three conformance levels. They call them A, AA, and AAA. AA is an intermediate level of standard and it provides a comprehensive level of access, the one that still appears it''s not the ultimate gold standard, but one that appears to be feasible for most web content developers to follow. So our, our question is, should the department adopt this level AA success criteria as our standard for website accessibility? It has one of the advantages of trying to harmonize public and private standards. Is, is that what which we should do? If we do that, should we use the AA standards? Should we use something else? Or should we use the Section 508 standard that, that the, the federal government uses. Section 508 is a section 508 of the Rehabilitation Act, and the access board of the architectural and transportation barriers compliance board has issued standards for the federal government that includes standards for what an accessible website is. So our question is, okay should maybe we should use instead of the WC3 standard maybe we should use the section 508 standard. Or should we say that you can use either one of them and that would constitute the compliance with the ADA. Or perhaps the other idea we put out is maybe we shouldn''t address a specific standard because standards will change drastically over time, and maybe we should have performance standard rather than any set of specific tactical standards. So you can see there are a series of questions that we''re asking around this. And we would like your, your views. You may have experience with these standards, you may have views on what you think is appropriate for the federal government to do. Another, and, and keep in mind this is your opportunity to help shape the, what will be the standard for the next generation of ADA regulations. And we''re interested from comments, from all affected state holders. From people with disabilities, organizations of people with disabilities, businesses, state and local governments, the general public, people with expertise in web access. Another issue involves the effective date. So once we have a standard and say websites have to be accessible, according to the standard when should it kick in? One idea is that for all newly created web pages, six months after the final date of the rule then all new websites should be accessible. Is that a feasible or even an appropriate approach? Can you in fact make your newly designed web pages accessible if the rest of the pages are not? That''s another issue. Is six months the right amount of time? Does that give the business community enough time to change websites? Should there be some different standard for small businesses? What kind of guidance should be provided? So the, you can see that''s the kind of, that''s another very important issue. The, there are other questions that are there. I won''t, I won''t go through them all, but one whole other area that we''re very much interested in is the costs of making websites accessible, as well as the benefits of making them. Its likely that we will have to do a fairly detailed analysis of the cost of any requirements that we would propose in a proposed rule making, and so as much detailed information that we can get at the earliest possible stage and the cost of these rules is very important to us. So in, in and just in mind that there are 19 questions on, on issues of making websites accessible. If this is your premiere issue, I ask you to go and, and look at those standards. Now I''m going to shift gears to remember we put out in July 23rd, four separate rule, rule makings. The next one, next one is on Moving Captioning and Video Description of Movies. The ADA was enacted 20 years ago, and since then technologies have been developed to include close captions and video descriptions and movies being shown on movie theaters. Some movie studios have responded by producing and distributing movies that have captioning and video description on them. Some movie chains and some theaters have found a way to, to show these to the public. But I think generally, I think it''s fair to say that generally movies are not being shown at movie houses around the country in an accessible fashion in terms of captioning and video description. We, so again we''re going through the process of asking your views on whether this is an appropriate avenue for the Department of Justice to develop rules and to get information on the technology that''s out there, and to, so we have proposed a series of questions. In fact there are 26 of them in, in this particular proposed rule. Seeking comments and suggestions on what a future rule should, should suggest. So for example, one of the things that, that we were considering is revising our rule under Title 3 which applies to public accommodations to require movie theater owners and operators to show movies with closed captions and video descriptions in their theaters at least, and we just threw this out for comment at 60 percent of the time. The idea of this whole rule making is, is to have a debate. And so, but before I get to the 50 percent, let me, just so you know, we''re talking about with closed captioning and, and what we mean by video description. Closed captioning is as it displays the written text of the dialogue of the movie, and other sounds, or sound makers only to those individuals who request it. It''s different than open captioning which is captions on the, on the screen that everyone can see. It''s our understanding from work we''ve done that there are a variety of types of closed captioning systems that are either in use or development around the country. They include the rear window system. Some have hand held displays that are similar to a PDA or a Personal Digital Assistant. Some have been like eyeglasses fitted with something that a user would wear that would have the captions appear for them. It''s also our understanding that at present the only system that has gained a foothold in the, the marketplace really is the rear window system. A video description is a different technology. It enables individuals who are blind or have low vision to enjoy the movies by having, by giving them a spoken narration of the key visual elements of the movie, such as the actions, the settings, facial expressions, costumes and scene changes. A video description is a little less known by the general public than closed captions, but if you''re unfamiliar with this technology there are a number of TV shows that you can go to your TV and, and turn on the video description to get an idea of, of what it is. It really, it requires the creation of a separate script by a specially trained writers who prepare a script for the video description. It''s recorded either on a CD or an audio tape and it''s synchronized with the film. And the script is usually transmitted to a user through either infra red or FM transmission to wireless headsets that are worn by the person who needs the video description. Okay. So that, that''s sort of the idea. And so what we were proposing, let me go back to the idea. We were proposing for consideration a sliding compliance schedule where a percentage of the movie screens offering closed caption and video description increases on a yearly basis. So in the first year after the regulation was out, 10 percent would have to be accessible. Going up to the fifth year and 50 percent. So we''ve through that out, does this approach achieve the proper balance between providing accessibility for individuals with sensory disabilities, and at the same time give movie theaters and owners sufficient time to acquire the technology and equipment necessary to exhibit movies with closed captioning and video descriptions? And even if that''s right, how do we count the 50 percent? Should it be the number of screens at a particular theater? Should it be the number of screens owned by a particular movie company? Should it have some relation to the number of different movies being screened in a theater facility? Should it be some combination of these? This is your chance to tell us what you think the right combination in that approach should be. In addition to this notice, the department has other questions that we''re asking. It''s not just about the, the number of screens or what the standards should be. We raised a number of issues, the movie theater is going through a conversion to digital cinema which is a fairly expensive proposition, especially for the theater owners. So we have to be aware of the costs that they''re incurring and what the cost of this rule would be for them. So we, we''ve asked for a lot of guidance on that information on it. And what the relationship of any new regulatory provisions we have should be to the, the conversion of digital cinema. Should it be linked to that? Should it be divorced from that? We want your, your views. Another area of inquiry that we would really like guidance on is what the technologies exist that are out there. And we''re hoping those that are the techies of the world, people working in this area will provide us with information for what are the technologies that exist. I, I think we want to be careful in any regulation that we do not to, to hamper or restrict the development of new technologies. But we also want to be reasonable about what we require. So we are hoping that we will be able to get information about the technologies that exist, both from the developers of them, and from the people who use them. So that we''ll get in a sense of what''s effective and what works well for people with disabilities. And of course, just as in the other rule, we want to know about the costs that such a rule will, will place on theater, theater owners, on movie companies, and as well as the benefits that, that will accrue to people with disabilities with the ability to actually go and enjoy one of America''s premiere industries. Keep in mind that, that I''ve been talking all this time about closed captioning and that''s what we were proposing. We also are associating comments on whether movie theater owners and operators should be encouraged to screen movies with open captions, even though we''re not requiring open captions, as an alternate way to achieve compliance with the regulation. We''re also asking whether there''s certain categories of movie theater owners and operators that should be exempt from any regulation. We''ve been told that there may not be, that drive in movies for example, may present a problem. That 3D movies may present a problem. So we''re, we''re looking for information on the whole range of making the movie going experience accessible to people who are deaf, hard of hearing, blind or, or have low vision. Okay. Let''s move on to our third proposed rule, and this one involves equipment and furniture. And this is some fairly wide ranging proposal. And we''ve had 20 years of experience with enforcing the ADA. And we have a better understanding now than we have had in, as we''ve developed over time, about the barriers that have been posed by inaccessible equipment and furniture. We know that changes in technology have resulted in the development and proved availability of accessible equipment and furniture that benefit individuals with disabilities. And when I''m trying to arranging from accessible medical exam tables for individuals who use wheelchairs to talking ATMs and interactive kiosks. Accessible equipment and furniture is often critical to an entity''s ability to provide an individual with a disability equal access to its services. In light of all of these developments, again the department would like to develop new and appropriate regulatory standards that, that do, that provide guidance so that entities covered by the ADA understand what their obligations are and so that people with disabilities will be able to enjoy the goods and services of state and local governments, as well as public accommodations because of the availability of accessible equipment. So we, we, in, the advance notice again seeks your input. Seeks answers to, to specific questions. And I should point out that the fact that we are asking specific questions doesn''t mean that you are not free to provide us with any information that''s relevant to what we''re asking about it, even though we haven''t asked specific questions about it. You should feel free to provide us comments or information that you think would be helpful to us as we ponder these initiatives. But we raised some specific issues in the equipment and furniture one. And the general areas that, that are listed include medical equipment and exercise equipment. And the medical equipment includes examination tables and chairs and doctors offices. Scales, radiologica diagnositic equipment, and the lifts necessary to use some of that equipment. We also have some questions about the height of accessible beds in hotels. We''ve gotten a lot of complaints and issues as hotels have become provided more luxurious experiences, what we''re finding is that the beds are getting plusher and higher and in fact, for a number of people with disabilities making them inaccessible or at least the equivalent of an Olympic event to get in and out of bed. Similarly those, the height of the accessible beds also applies for hospitals and nursing homes. Another area of inquiry that we have some specific questions are, are accessible golf cars, particularly the use of single user golf cars for people with mobility disabilities usually who cannot get out of the car but can play golf from a single user cart. And then of course there''s the whole range of electronic technology including ATMs, the expanding use of kiosks and point of sale devices. Let me focus for a minute on medical equipment itself. I think you realize that without accessible medical exam tables, dental chairs, radiological diagnostic equipment, weight scales, rehabilitation equipment, individuals with disabilities do not have an equal opportunity to receive medical care. People with disabilities may be less likely to get routine preventative medical care than people without disabilities because of these barriers to getting access to medical care. In fact we, the department has gotten complaints over the years we''ve entered into a couple settlement agreements with major medical care providers that have required the medical care provider to purchase accessible equipment and furniture for its facilities, including for example at least one accessible examination table in each medical department of a hospital. And additional accessible exam tables, radiological equipment scales, beds, and lifting devices as needed. If you''re interested in, in what we have done in the past I urge you to go to our website ADA.gov and, and look up some of those agreements to get an idea of the, what we think has been necessary to include, for people with disabilities access to medical care. Keep in mind we''ve also issued technical assistance on this issue. We have a document called access to medical care for individuals with mobility disabilities, which we have issued jointly with the department of health human services. And it''s also available on our website if you''re interested in, in more information on the subject. Should also keep in mind that there is, you know we have passed a new healthcare reform law, the Patient Protection and Affordable Care Act. And it added a new section, Section 510 to the Rehab Act. And Section 510 directs the Access Board to propagate regulatory standards setting forth what are called minimal technical criteria for medical diagnostic equipment used in or in conjunction with doctors offices, clinics, emergency rooms, hospitals and, and other medical settings. These standards, the idea behind them is to ensure that such equipment is accessible to and useful by individuals with accessibility needs. And allow independent entry to use of and exit from the equipment. The Access Board has begun work on this. They''ve announced that they will draft new design standards for medical diagnostic equipment. Now of course, just you know we are asking questions about medical equipment, and we are doing this in concert with the Access Board. And we have made it clear that we do not intend to issue a final rule on medical equipment until after the Access Board has completed its development of medical diagnostic equipment standards. When those standards are completed we will then have the option, one of the options it will have. And our rule is to adopt them for ADA implementation. So we are hoping that the Access Board will come up with what is an accessible exam table. What is an accessible scale. And we will then have a rule that will develop specific scoping requirements that will say how many of those kinds of accessible diagnostic elements you will have to have for specific disability types. Now keep in mind the access board''s direction is to provide information on medical diagnostic equipment, the ADA''s requirements go beyond just diagnostic medical equipment to medical equipment that could be used for treatment, rehabilitative or other purposes. So our rule, we''ll use that, the Access Board''s standards as a basis and proceed from there. So now that''s, that''s sort of the background on medical equipment. We invite your comments. We have a, a number of specific questions on types of medical equipment, what''s available now, how much it costs, how it''s used, what kind of training is required for medical personnel to ensure that it''s used well. Situations where it would work, situations where it wouldn''t. We have to keep in mind we''re also talking about small businesses when we''re talking about fairly small medical practices. What would be the requirements for a small business compared to a large comprehensive hospital. And again, we are asking for cost and benefit information. The, the more information we have, the better informed our rule making will be. Keep in mind that we''re also inviting this rule isn''t just about medical equipment, it''s about all types of equipment that could be used by state and local governments by the whole range of entities covered. I assume we will get a lot of comments on kiosks and point of sale devices. But even if we haven''t raised a specific kind of equipment that you think we should be addressing specifically, we hope you will be giving us comments. So for example, people have raised with me you know under our new ADA standards one of the things that, that we will see cropping up in the American environment more are pools that will have slope entries. The, we have standards now for what that kind of pool should look like. But we haven''t said anything about you know is there a requirement for an entity that has such an accessible swimming pool to provide pool chairs for people with mobility disabilities who obviously wouldn''t be taking their own chair into the pool. And if so, what kind of chair would, would that be? Should there be some design criteria? Similarly, hotel rooms that, that provide roll in showers for someone who wouldn''t be using the seat in the roll in shower, but needs a shower chair. Is that something that we should be dealing with in the regulations, if so how should we scope that? Should it be a number of them, and, and how should we define it. So they''re, they''re really a wide range of questions on equipment and we look forward to the, your comments and issues that you might raise. Okay now onto the fourth and final of our rules. I''ll try to be a little more succinct here. So we''ll have some time for all of you to ask questions or give comments. This one talks about what, the accessibility of what we call next generation 911. Here we''re dealing with communication technologies in our society and I think you all recognize how rapidly communication technologies are changing and developing. And many people with disabilities, particularly people who are deaf or hard of hearing are transitioning away from analog or what they call legacy devices to digital, digital and what are internet based or internet protocol based devices. Our concern here is state and local governments that have emergency or 911 call taking centers. Many, if not all or most of these are not yet equipped to receive text or video calls or text calls over the internet. But more and more of these centers are thinking about this and moving towards an internet enabled network which is where the term next generation 911 comes from. This would allow the general public to make a 911 call via voice or text or video over the internet and directly communicate with personnel at, at the 911 emergency centers. So what we''re trying to do is interject ourselves into this debate and assist 911 centers who of how they should address this changing environment. And we would, we''re reviewing the standards for how 911 centers should provide direct access to people with disabilities who use this, the variety of information services. Our goal here is to ensure that as centers moved to NG and 911 they will be able to directly receive various kinds of texts and video based calls by persons with disabilities. So our, our aim term here raises these issues and asks a series of questions and possible approaches. Really though we''re, I, I guess it comes down to a couple basic questions. One is there are a lot of devices out there, more are being developed. What devices and modes of communication, should it be text, should it be video, are individuals with disabilities using to make emergency calls or calls to state and local government. So what, what is the, the nature of the devices people are using? And how do we ensure that any new internet protocol based centers can receive direct calls from these? Because state and local governments are going to have to, you know, right now we have, we have spent the last 20 years ensuring that these centers will be able to receive calls from TTYs. And it''s really been our experience that, that most deaf people in the United States now have moved away from TTYs and have gone to a variety of other internet based devices for their communication needs. They, they, and we want to ensure that state and local governments to the extent that they are going to incur expenses and move to a new system, moves to one that addresses the needs of the disability community and is cost effective for the state and local governments as they, they make these changes. So the department is, is soliciting your comments on, on these changes. There, there are a number of specific things there. Texting options, whether we should deal with real time texts, short message service, instant messaging, email, a, a variety of those things. Should they deal with video communications, direct video to video calls between a person with disability and the 911 call center? Should they, how should they deal with video interpreters? Whether our, our rules should have performance standards, as opposed to technical standards, again the same issue that, that we addressed on the web address area. And how, basically how should state and local governments deal with these issues. We urge you to spend some time, especially the techies out there on, on these issues to send us your views so that we can come up with a rule that, that makes sense for the state and local governments and for people with disabilities. Now okay so, how do, how do we proceed? What, what''s going to happen in the comment period on these, these rules is open until January 24th. The next steps after that will be, we will review these comments and then the next step will be the development of a proposal by the department which we will then put out for public comment again. So you will get another shot at what happens as a result of this process. But I encourage you don''t, yeah I encourage you not to say okay we''re going to wait until the next time around when it''s, when the, the battle lines are drawn a little bit more. But now, you know, we haven''t really formed our impressions about what these rules should be. We are open to a variety of, of approaches. And now is the time to really weight in and, and be able to shape what, what we''re going to do. So how do you do that? How do you send comments to us? If you go to our website there''s a lot of discussion on, on the ways that you can do that. The easiest way is to provide web comments, comments over the web. There''s a federal e-rule making website. It''s called www.regulations.gov. And there are instructions on that website for submitting comments. So if you want to provide comments that is probably, and you have access to the internet, that is one way for you to do it. You can also go to that website and review the comments that other people have sent. So you can see what other people are saying, and you should feel free to review them and respond to the comments that you see. We hope people will continue to send us comments, and they all, you all won''t wait until the last day to send them in. But we hope that you send, sent them in. So that, that is one way to do that. You can also send them to us in the regular mail, and or you can hand deliver them. In order to, and there are directions for that on, on our website, on ADA.gov. You can get there and there are, there will be explanations for how you can send your comments in. Also as, as Robin mentioned before, in order to spur comment, we have decided to hold three public hearings on these proposed AMPRMs. If you go to our website there''s information on them. The first of them is going to be this week in Chicago. It will be at the offices of Access Living on it''s November 18th from 9:30 to 4:00. There will be a hearing in D.C. on December 16th at the offices of the Access Board. And we will hold a hearing in, on January 10th in San Francisco at the Merritt Marquee Hotel. The, the hearing that we''re going to hold this week, we are going to, we are going to video tape and after a couple days that video tape will be up on our website. So even if you, or if you''re not in the Chicago area and you want to see what people said, a few days from now that, that will be up on our website and will be there through January 24th. The hearing that will be held in the District of Columbia on December 16th will be live screened over the internet. There will be more guidance coming to you on how you will be able to participate and, and listen, and listen in to the people who are testifying at that hearing. We will also keep that, that on our website through January 24th and we''re still working out the details for the hearing that will be held in San Francisco. At a minimum we will video tape it and put it up on the website. But because it''s so close to the end of the comment period we are hoping we''ll be able to also simulcast that live on the web so that people will be able to see what, what people are saying. So that is probably more information than you wanted on, on all of those subjects. I, I think what I, I hope we can do is spend some of the remaining time to hear questions that you may have or you should feel free to have the opportunity to raise issues that you think are important to us. Keep in mind that the transcript of this session will be put into our record on regulations.gov so that it will be treated as a formal comment in, in the comment process. And with that Robin if I can turn this back to you.
That''s great. In a minute I''ll have, go ahead and have the operator give the instructions to participants. Individuals in, who are in streaming audio please submit your questions using the options that you have available to you to do so. So go ahead operator and give them some instructions please.
Ladies and gentlemen if you have a question at this time please press star then one on your touchtone telephone. If your question has been answered, or you wish to remove yourself from the queue, please press the pound key. Again, if you have a question, please press star then one on your touchtone telephone. Robin Jones: While we''re waiting for folks to queue up, John we had an email submission here. And this is first a comment and then a question. This individual says, we all know that requiring manufacturers of equipment and furniture, particularly in medical settings is long overdue. Too often manufacturers think that their product is quote unquote ADA compliant, market it as such and architects facilities managers and owners believe it to be true as they would look to seeing like an underwriter''s laboratory or UL symbol. The question is, will the enforcement and penalty processes be similar for manufacturers who fail to design and construct ADA compliant equipment, furniture, etc. as they are for built environment? Will there possibly be the same provisions for the protection and reporting of fraud, i.e., clearly advertising a product as ADA complaint when it is not, as there is for fraudulently ordering, you know, accessible seats in an arena or assembly areas as an example?
Okay. It''s an interesting question. I have to take a step back to give an answer to that. The, the, we have to look at what the ADA requires. And the ADA reaches state and local governments and it reaches 12 categories of places of public accommodation. Manufacturers, per se, are not covered by the ADA itself and therefore what we are doing is not direct regulation of the manufacturers. What the ADA does is regulate the uses to which this equipment can be so that the violation of the ADA would be for a hospital that doesn''t have accessible beds, or it doesn''t have accessible radiologic equipment. What we hope to do to, to deal with that issue, however, is to work with manufacturers throughout this process so that they are familiar with the requirements that are going to be there because they are what we will be doing in effect is creating a market for them. Keep in mind however, that there are other federal laws and that the FCC, the Federal Communications Commission has some responsibility for the development of accessible information technology and devices. And the Access Board itself has some responsibilities under the Federal Communications Act for ensuring that some devices are accessible. That''s a separate rule making, a separate approach from this. The, the other part of the, the question dealing with fraud and other issues in, in the same way we''ve dealt with some of those issues as they''ve developed here we will be dealing with them in the same way in, in this arena. Keep in mind that a lot of the fraud issues are, are not, they are tangentially violations of the ADA. And if they are in violations in any way we will proceed and take care of them. Some of them may be violations of the criminal laws of the United States or of states. And we will, if they are federal violations, other parts of the Department of Justice will follow up and, and deal with those issues.
Great thank for responding to that. And now do we have any questions from the audience that we would like to queue in at this time?
Once again, if you have a question please press star then one on your touchtone telephone.
So I guess that means we got either folks are thinking, debating or, or whatever. Who knows. John, with the relationship to the accessibility standards, or for internet, whatever those might be or, or those come about.
Right.
Etc., can you just discuss, you know, I know you''re asking the question and you''re looking at the issue between, you know, adopting 508 standard versus looking at, you know, other guidelines that are out there already. In fact, what would be the pros and cons of it, is there a discussion about that in regards to.
Well the idea here, it''s similar with, we''re trying to draw on our experience from the multitude of standards that have developed for accessible buildings? Robin Jones: Yeah.
And the confusion that that has created by having different standards in different states and different private standards, different standards for federal buildings, for federally assisted buildings. And, and we have spent a lot of the last 15 years trying to harmonize standards so that building designers, architects and others, so the process can be simplified for them. I think part of what we''re looking at here is trying to avoid the multiplication of standards for different types of entities. Because when you''re really talking about, you know, what''s an accessible website, there should be certain key things that, that you know that you have to do in order to do that. And so part of our, the questions we''re asking is, how we should go about that. And, and the standards that the two that are best known are the WC3 standards which are, are private standards and the standards that the Access Board put out under section 508. We don''t want to really introduce a separate set of standards. We are hoping that we can harmonize these and it may be that one of the options we consider is that if you comply with either of those, then, then that is, will be deemed compliance with, with the ADA. But I, I think we''re trying to get a sense from the people who use those, who have developed them, what they think the pros and cons are. For example, the WC3 has three levels of conformance. And one of, and we suggested the middle level. And part, you may wonder well why did you do that? And, and part of our thinking was that the, the triple A standard is really a gold standard. And if we said that is what''s required by the ADA our fear is that everyone in the United States would be out of compliance immediately. And it would be almost impossible for some of them to come into compliance. And, and it''s appropriate for a private body to, to set something that is really the ultimate standard. But what are the minimum standards for, for what''s accessibility and, and we thought that maybe the single A standard maybe was too low a standard, but, but that''s why we asked for comment on, on that. So we really are open to that and I, I think we know from entities that we''ve worked with is that there''s a thirst by the entities covered by the ADA to know what, okay what''s required of them. There''s a great deal of understanding that they, they know there''s an audience for their goods and services. They want to be able to reach it. But they want to know what it is that they have to do so that they can address that issue. Similarly, some of the small businesses have said to us, you know what might be appropriate for a major corporation in the United States might be really inappropriate for a mom and pop internet business. And so how do we deal with those issues in terms of the standards and the general approaches.
And can you just address briefly the whole issue of, of course as we all understand in the, you know, the protections and the coverage available under Title 2 and Title 3 for particularly Title 3, is the whole concept of place of public accommodation. And that''s always been a big debate when it gets into the virtual world as to what constitutes a place of public accommodation. And as far as you know the web applicability and such. Can you just comment on that? Or are those additional issues that obviously you''re still looking at?
No, no, I think that we, the, the Department of Justice has long held the view that web access is covered. Now the reason that there''s some confusion about this, and some courts have disagreed, I have to be frank about that with our, our position. Is because when the ADA was enacted, the web as we know it did not exist. But if you look at the structure of the ADA itself, it talks about facilities. And the fact of place-ness in the ADA is an important one but there isn''t in our view websites in terms of every, every website that, that is being operated here has a facility of some kind. They have computers. They have some facilities that are providing the information, although it is virtual in a different sense, it is still, there are still some facilities. A comparable way of looking at this in a totally different area to draw a parallel, we have had cases where we''re dealing with a plumbing service. The plumbing service doesn''t have an office you go to, they come to your house. Say that a plumbing service refused to go to the house of someone who is HIV positive, that is an ADA violation, even though there''s no place, they do have a vehicle, they do have equipment they are offering goods and services. Similarly, an enterprise in the United States that is offering its goods and services, over the internet, has some web capability, they have, they have hardware and software that, that communicate so they have a facility equipment is covered under our definition of facility under the ADA. And they have, they may have a warehouse where they house the goods and services they are sending. So in that regard it''s not placed in the same sense as going to the retail shopping mall and going into the store. And it''s virtual in that sense. But they do have facilities. They are not just operating virtually, there are facilities that they are using. And in our view that qualifies it under the ADA''s requirements for place-ness.
Great. Thank you for saying that. I just wanted to get that out there because we, that''s one of the biggest things that we continue to struggle with in our offices as part of the ADA network is those kinds of questions about, you know what really constitutes the coverage there because I think it is still a gray area or a muddy area for some people. So I''ve got a couple of questions that have been submitted electronically here, so I''m going to feed those into you at this time. This is a follow up to the answer related to the email question. And that is, if manufacturers have no quote unquote hammer, under which to comply, that this person is concerned that hospital purchasing agents, etc., will be no, you will no, go no further. Do you have any thoughts on that?
Yes. If I can. I''ll tell you, I, I understand the, the whoever is raising that as an issue and, and basically it''s really the purchasing power of entities covered by the ADA that will spur change. I guess I can take you, those of you who follow our enforcement activities may have noticed that we work on an issue involving colleges and universities and e-readers. And we, if you go to our website you''ll see we have a series of agreements with six colleges. They were using one particular e-reader that didn''t have a, a sufficient text to speech function, and therefore in our view didn''t provide an opportunity for students with disabilities to participate. We told the colleges and universities that if they continued to use that kind of service after the pilot project was over that that would constitute a violation of the ADA because they were providing goods and services to the students that couldn''t be provided to students with disabilities. So in, in essence we were not dealing with the manufacturer, we were dealing with the entities that used it. As a result of that manufacturer fairly quickly decided to change their device so that it would have those functions, because they''re, you know it''s, they''re in the business of selling their devices, they were realizing that, that there wasn''t going to be a market for their device because it discriminated. It''s really using the incentives of capitalistic system to provide accessibility. It, it''s different than direct regulation of the manufacturers, but we don''t have that under the ADA so this is the mechanism that, that we have. It, it''s, it may be viewed as inefficient through those who are, are understand markets and economics. But it is the system that we have in place.
And this is similar to what we''re dealing with in the built environment with all of the, you know, plumbing manufacturers and such of that nature who put out the, you know, accessable quote unquote, you know, sink or water fountain or whatever that we find don''t actually meet the specifications but they, you know, market it as such.
That, that''s correct.
Yeah it''s kind of similar in that way. I have another question that was submitted by an individual who is a, has a significant hearing loss they indicate in their, in their comment, question. And it''s, their comment is specific to rear window captioning. There, they say that they have not found the rear window captioning to be beneficial because one, you have to sit in a certain area to use it, and two if you are short that, and you need to use the gooseneck to move things around, the gooseneck often flops and does not stay still. And that this person is strongly suggesting that option caption of movies is more re, more preferred or recommended than use of these other kinds of technologies. John: And I appreciate that comment. We''ll add that to our list. I can tell you that''s not the first time that we have heard from people, particularly people who are deaf, that rear window technology hasn''t worked for them in, in certain environments. And so we''re anxious to hear about that. And we, we know that rear window technology is used in many places. We also know that other technologies are being developed and that open captioning is, which is why I raised that as, as an issue. But I, I should say on the subject of open captioning that when the ADA was enacted there was legislative history that is binding on the department that said that the ADA wasn''t, wouldn''t itself require open captioning. Now that was based on the technology that was available at that time. So we are certainly open to hearing public comment. But that is why we talk about in our proposal closed captioning. Robin Jones: Okay. Great. Well that''s a little bit of tidbit of history that a lot of people are probably not familiar with in that regulatory process. Can you also speak just a second. Obviously in the new house care act there was some call for the access board to do some, some work in the area of medical equipment and such. How does your process interface at all with what their charges under the, the healthcare legislation? John: A very good question as well. We are, keep in mind that the Access Board is an interesting independent federal agency. It has, it is composed of members appointed by the president, as well as several federal agencies. So we, at the Department of Justice, are a member of the Access Board. So we will be actively involved in the development of the standards for medical diagnostic equipment that the Access Board has begun the process of working through. And so we will be working with them on those. We will coordinate very closely with them so that there is a relationship between what the Access Board is doing and what we''re doing. The Access Board certainly is a very sophisticated agency with a great deal of technical expertise. And we are hoping that what the Access Board will do through its process is do things, decide things like what is an accessible, you know what is the appropriate height for an accessible exam table? Should it go to 17 to 9 inches and then be able to move to another height? You know that kind of technical expertise is what we expect the Access Board will review and develop. We will then be adopting that. We will have gone through that with them, and so have the benefit of the experience of developing those standards. And then we will take that and apply it through the ADA process and come up with scoping, you know, how many exam tables should there be in a hospital if the doctor''s office has how many employees, or how many exam rooms, how many exam tables should be accessible. What, you know, how, how should the lift work with the other diagnostic equipment. So we, we are working closely with them, and will continue to do so.
Great. Thank you. I know that that''s, we''ve had some questions in our office and a lot of people are not, well actually that was an area, the healthcare act that was not well publicized or did not get as much attention. So a lot of people have not necessarily been aware of that or became aware of it after the fact after later down the line as there was so much of that obviously that, that legislation. Can I go back to the operator here to see whether or not we have anybody who, form our telephone participants has indicated they would like to ask a question or comment?
We do have a question from Andrew Moody.
Great. Go ahead.
Hello. Andrew actually made the reservation for me. My name is Susan. I''m, I think this was probably a question for Mr. Wodash. I, I didn''t hear a discussion of material that makes me think that the indoor environmental quality report that the Access Board did has been incorporated into what you''re working on. And I''m wondering if you could clarify for me whether the access points that were made in that report are going to be addressed? They would especially be applicable in, in, oh instances where furnishings are going to be purchased or used. And of course electronic features, lighting for offices and so forth. And in terms of the websites and cinema issues, I haven''t seen a way for, for people who are seizure prone. I don''t know how to tell in advance that a movie''s going to be unsuitable for, for a seizure prone person to attend. Many times I tried to go to the movies and wound up wasting 18 dollars and getting carried out. And I don''t, I didn''t hear you mention that aspect of the strobes and flashing that are in, in, under discussion right now.
Thank you very much for both, both of those, those comments. I, I don''t think any of the rules that, that we put out specifically addressed any of the issues that you''re raising, but they are all legitimate issues to be raised. And for us to consider and, and address. In terms of, I''m not sure what you mean by the indoor quality report from the Access Board, although we will follow up and try and, and see if that, I wasn''t sure if you''re talking about perhaps issues of, of people who have environmental illness, and whether equipment should address those issues. But we are certainly open to comments on that. And lighting for offices I, I know has been as well as acoustics in areas like classrooms are, are issues that the Access Board is, is still looking at. And it may be premature for some of those issues for, for this rule making if the Access Board is still considering them. But if, if people have comments on those kinds of issues, equipment that you know not just the height of the equipment, or the size of the equipment, or how you access it, or how its electronics work. But if there are, you know, the fit and finish, or the, the nature of the materials are things that should be considered, you know, anything that has an impact on the accessibility and usability of the equipment for the wide range of people with disabilities that are covered by the ADA are fair game for comment and for us to, to consider. The, the second issue on, on persons who may have seizure conditions is also a new one in terms of anything that, that I have heard. And it''s certainly worth pursuing in terms of how you know what, what the standards would be that, that would allow someone to un, to have some guidance. I''ve certainly and this is only a personal anecdote have been to performances, live performances where there has been indications both on the website and outside the theater that strobes and other devices will be used in the performance and so that, that provides information to persons who are attending it. I''ve never seen anything similar to that, but if you have information you can provide to us in the form of comments I hope you will, will do so. Robin Jones: Great. Thank you. Any additional comments or questions from our audience at this time?
I''m showing no further questions or comments. Robin Jones: Okay. I''m going to go back in here then with you John. I''m honestly not sure why our participants are just quiet, or shy, or maybe they are wanting or waiting to enter their comments and questions in writing per se. Or maybe they just came today to get educated so that they can submit their, their comments and questions. But we''ll see what happens and hopefully I think that it, that it will generate something out there. In regards to the, the small businesses and their potential reaction to the, this particular, I guess go back to the beginning or to the website. And the number of questions you''ve asked about that. You know does size of business make a difference and you raised those issues related to, you know, retrofitting a site versus other kinds of things and what might be feasible for one entity or another. How does the department think about, or have they not got to that point where that will be the next point. The whole idea of how you would go about enforcing the internet, given that the internet is one of these things that is, you know, exploding. And when you think about the difficulty of, of trying to, and challenges, I don''t want to say difficulty, challenges of enforcing the current standards that are, you know, pertain to the architectural world, or the regulations you know that govern our policies, practices and procedures. What, in regards to the enforcement arena, is the Department of Justice thinking about or questions are you asking in that regard?
Well let me say. You know it''s, although we don''t have specific regulatory standards, we are, we have received complaints about inaccessible websites. I think those of you who are familiar with projects specific access where we deal with state and local governments we have, I think probably over 100 agreements with towns and counties and communities that where we have gone and looked at their websites and really used section 508 as our guide for that kind of process. But required them to make their websites accessible. I, I think it''s not a new area for us. It obviously makes our enforcement obligations, it makes them broader and gives us more to do. But it''s not outside the ability of, of what we have to do. And I think the enforcement issues will, will be there for us. And it will be a matter of prioritizing and, and responding to complaints. And, and we still get those and, and are dealing with those issues. But let me take a step back to your, and so I don''t see that as that will make our, our job more challenging. But not, not impossible, and not, just different in scale from what, what we are doing now. But the issues of the small businesses is one that we hope we will get comments about. We''ve asked whether there should be limitations on coverage, the, the small businesses are concerned that, that they, they won''t have the knowledge of how to make their websites accessible, especially if they''re, you know, how to do alt tags for images they put up. Or if they put up video how they can go about in a cost effective way ensuring that the video is captioned for people who are deaf, or maybe video described for people who are blind, and, and is it reasonable to ask small entities to do that. And so our, our question is, is it unreasonable to do that? Are there services out there that will be able to do that in a cost effective way for small businesses. And then what is a small business? How small are we talking about? Even some large entities. Think about major colleges and universities or local libraries that are making more and more of their, their books available online. How do, how far do they go back? What books do they make accessible online? How is a blind person going to have access, the same kind of access that other people have. Should there be exceptions? Should there be limitations? So there, there is a wide range of areas that we are hoping to get people''s views on, as well as the costs of, the cost of doing things, the services that are available for businesses large and small and for state and local governments. Because keep in mind we do look at goods and services are being provided over the internet. In, in a lot of circumstances it''s a way to have easy access to cheaper goods and services, and it would certainly be a violation of the ADA not to have those available to people because of their disability. Robin Jones: Great. Thank you for the clarification on that. Another comment or a question here is related to YouTube. Somebody submitted this. And asking where would they fit in if at all, to the standards that are, or the rule making? Or would they be a video, you know, captioning coverage or would they be related to internet requirement or neither?
Oh that''s a very good question. And we, we ask for some questions on the social networking sites, and things of that nature. One of, one of the concerns we had, and keep in mind there, there are those who think that we shouldn''t be regulating at all because the internet should be really free of, of regulation and, and the, the that set of using it. Often comes down to a social networking sites whether we''re talking about YouTube or Facebook or, or other social media where individuals put up something. And the, the ADA regulates public accommodations and it regulates state and local governments. It doesn''t regulate private conductive individuals. And so one way we have looked at this, and is that the entity that has, is doing YouTube, or that is doing Facebook, has to ensure that just like if they were building a building that the structure of the building has to be accessible. But if someone puts up something that''s inaccessible does that mean they can''t put it up. I, I think that given the nature of our society I''d, we ask the question whether we can or should regulate individual conduct of that nature and, and hold open the possibility that of course the structure of these websites should be accessible, but the fact that an individual puts up something that individual isn''t regulated and may be able to do something that isn''t. So if they''re putting up their home video or if their, their son or daughter excels at the swim meet and they put it up on their page, is that or should that be regulated? Should they have to describe that in an alt tag? Should they have to have captioning? One of the things that we suggest is perhaps those are beyond the scope of what we are trying to do. We are trying to get ecommerce government, education programs, accessible not the program, not, not individual websites of, of that kind of nature. But we, we have laid those questions out and have asked for people''s comments on them.
Great. Thank you very much. Any additional comments or anything from anybody on the telephone? And this is a.
And again if you have.
Go ahead. Operator: Again if you have a question or a comment please press star one. Robin Jones: And this is the last time for anybody who is just streaming on the audio, or through the captioning to submit a question, because I''m going to be wrapping things up. We''re a little bit early but it seems like I guess everybody either thought John you did a great job and answered everything, or they are again going to go back and contemplate and end up doing something else. So. John: If I can just encourage those who are listening, to think about these issues. I know when we give someone 180 days for comments, I know what my indication would be that I would in January start paying attention to this if the deadline was January 24th. But I hope that you will spend some time and look at this. Your comment does not have to be elaborate. We are interested in your views, large and small on regulations.gov. It''s, you can go ahead and put your own comment or respond to comments that are there. We encourage you to give us your views and we will carefully consider every comment that, that we receive.
Great. Thank you. And I, I will attest to the fact that if anyone, that they really do listen to what you have to say and it does make a difference. Anyone who''s really gone through the process of reviewing the most recent changes to the regulations and the comments and the response from the department as they consider the final regulations that came out in September will understand that. That they really do seek it and use that in framing the final regulations. So I again encourage everybody to participate in this process. John also if beyond these four issues that you are looking at, if individuals have other areas and things, I mean I''ll just use as an example our office will often get people who will contact us about things that are not within the scope of where the ADA currently is at. And we are often referring them to contact the agencies with their concerns for potential future rule making. Is that something that you know you as a department do really encourage people to do? Or take to heart?
Certainly, you know, if these four rates wouldn''t be the vehicle to do that, the, the, I suppose the easiest way to do that is to call us on our ADA information line. Or to send us a letter or email if, if there are areas you think we should be regulating in or not regulating in. We are open to those. I should let you all know of course all that, that the next regulation other than these four that we will be dealing with will be dealing with the amendments to the ADA that dealt with the definition of disability under the ADA amendments act. Equal employment opportunity commission has put out a proposed rule making. Once they have done a final rule, we will be issuing an ADA rule that will change the definition of disability according to the, the changes in the federal law. So that will be in terms of our regulatory agenda. One of the next issues. As will be changing the 504 regulations of the department of justice, and over 100 other federal agencies to change to the 2010 ADA standards. And, and if I can do a, a promo in the minutes that we have Robin, I would note to all of you that we published on our website yesterday a version of the 2010 standards. These are the standards that these are building standards that we are now accessible facilities. But combining the 2004 ADAAG with those provisions of our new rules that apply to the built environment and they''re in one place on our website. They are there electronically. We will eventually have them there as a physical document that we will be able to provide to you as well. So if you''re interested in that particular issue, go to ADA.gov and check them out. Robin Jones: Great. Thank you. And again that''s one place. And also make sure that you go and visit the website for the additional information on this rule making as there are documents there that go into more detail on all of the questions that are being asked that you can respond to aside from just some of those real major highlights and things that John covered today. And again that''s www.ADA.gov. So make sure that you visit that site. And the best place to get to that is right on the front page of their site. They have a link that will take you to the page that lists all of those documents that are available for you for the regulation. Remember the date of January 24th of 2011, as the deadline for submission of those comments and they can be done electronically as well as in, in writing. And the instructions to do that are also on that website as well. So John I want to thank you very much for taking time out of your very busy schedule as you''re getting ready to fly to Chicago and engage in the first of your three public hearings on this particular issue. And we really appreciate you joining us and allowing us in the forum today. And as I said everyone, we will be submitting this information to the Department of Justice for part of the public record. And John can you just clarify again that people will be able to view the comments that come out of the various public meetings and things of that nature on your website as they are submitted? John: Yes they will all be. The, the comments will all be on, we will put them on regulations.gov, but we will also have a video tape a few days after each session that will be on our website that will run so you can observe the hearings as well.
Great. Great. All right. So I assume that you''ll put, as you do for people who have signed up for your email blasts, that when something new is put on to the website that that will come on as part of that.
You will hear about it. Yes.
Great. Okay. And again if you have other question and issues related to the Americans With Disabilities Act, you can please contact your regional ADA center at 800-949-4232. And I want to again thank everyone for joining us today. Our next session is in January. We will not have a December session due to the third Tuesday of the month falls very close to the holiday. And it''s just a survey that we conducted we found that many, many people would not be around, or be on vacation because of the way that that week falls in this calendar year. So our next session will be in January and it will focus on the issue of ereaders, and the ADA, and the use of those and some of the controversies and the things around those from meeting the various requirements under the ADA as well. So we welcome you to join us for that session. So thank everyone, and we will now disconnect.
Ladies and gentlemen thank you for your participation in today''s conference. This concludes the conference and you may now disconnect.