Captioning Part 2 - 1194.24(c)

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Mark

The question that got raised was why would 508 even apply to that situation and Deborah's response was, that 508 is neutral as to situation, other than, as stipulated in paragraph C was that if its training or informational and the content is necessary for comprehension, and that is why 508 applied.

Deborah

The people are here from procurement because 508 affects procurement, but 508 covers more than procurement.

Doug

And, the answer also is that 508 addresses the architecture of technology. Videotapes must be captioned. Videotapes must be audio described. Webpages must have alt attributes, text equivalent for non-text elements. It doesn't say that people should have access to that information in any form that an agency chooses. I use this alot as the absolute prime difference, and if I said this yesterday, then you can stop me.

Speaker 4

But, I thought you also talked about the interpretation that if it is a birthday party obviously it doesn't apply.

Doug

Because it doesn't support the agency's mission.

Deborah

And teaching certainly does.

Doug

That's why that phrase came in, ...and supports the agency's mission.

Deborah

Well, it then becomes a risk management issue.

Speaker 4

I know, but there must be another way other than that.

Deborah

Well, and that's what the new rules that are being written now, we'll see what happens. We'll propose that all video and audio, all videos being captioned and audio described. I mean there's just a practical problem with that.

Speaker 4

Right, right.

Deborah

There aren't enough captioners and audio describers available to carry out that requirement. Even if somebody had the money to make it all happen. The drafting of these rules is very political. And the advocates, who have a very valid point of view are afraid that any language that gives exceptions will be broadened and broadened to interpretation so as to become the rule rather than the exception. And so, it's really a political battle between the advocates and people who have to implement. And it'll be interesting to see how that comes out. That'll, I think, be the most controversial of the new rules. I mean if you think this is hard.

Doug

I think they'll have to change this section.

Deborah

There aren't...audio description is just a very small field.

Doug

And audio description is very expensive and so is captioning.

Deborah

In the end, you do end up having to make your own judgment about what you're going to pay for.

Speaker 4

Some professors even though it's not your situation Mark are taking the position that they're not going to offer videos if that's what it's coming to.

Doug

By taking out any ability to predict the audience, what happened was I received calls from the FAA concerning captioning and audio describing. I'm not making this up, believe me.

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