We received four comments on this provision. All four commenters generally approved of the proposed provision. Three of these commenters, one from an ICT trade association and two ICT companies, requested guidance on allowable alternatives to color. In response, the Board notes that the supporting materials for the WCAG 2.0 Success Criteria contain technical assistance on the use of color. The remaining commenter, a coalition of disability rights organizations, recommended that we add the word \"visual\" to clarify the mode of operation. We agree with this comment and have added the word \"visual\" to describe the mode of operation in the final rule.
Two commenters (a coalition of disability rights organizations and an academic research institution) requested that the Board add a requirement for audio cutoff. The intention of the recommendation was to ensure privacy for users of headsets. When users plugged their audio connectors into a standard connection port of ICT that delivers output through an external speaker that broadcasts information in public, the sound from the speakers would be cut off. The Board has declined to add a requirement for audio cutoff as it has determined that it is overly prescriptive, and the objective is already addressed in the final rule by 405, which addresses privacy of input and output for all individuals.
The NPRM proposed that at least one tactilely discernible control be provided for each function. Devices for personal use with input controls that were audibly discernible without activation and operable by touch were exempted from this requirement. Several commenters (a disability advocacy organization, two ICT trade organizations, and three ICT companies) recommended providing an exception for tactile discernibility for products that are discernable audibly or products that used other non-tactile methods to be discernable without vision. We have determined that these suggestions would make the exception overly broad. For example, tactile discernibility is essential for devices located in public spaces, such as an information transaction machine, where ambient sound may interfere with an individual's ability to perceive instructions given solely in the form of audible output. Likewise, an exception that permitted a device to rely solely on gesture controls might not be accessible to individuals who are blind or who are unable to gesture. We have retained the exception proposed in the NPRM, which is limited to personal use devices that are discernable audibly without activation (proposed 407.3; final 407.3).
The proposed rule included a provision related to timed responses, which proposed that a user be alerted visually, as well as by touch or sound, when a timed response was required. In addition, the user was to be provided the opportunity to request an extension of time to complete their response. We received several comments from industry (an ICT trade association and an ICT company), suggesting that the provision be deleted because a similar requirement was proposed for software (WCAG 2.0 Success Criterial 2.2.1 Timing Adjustable). The requirement for hardware to give the user the ability to extend the time for a response is found in the existing 508 Standards 1194.22(p) and we have determined that this is an important feature for a number of users, including individuals with manual dexterity issues, among others. We disagreed with the assertion by the commenters that a hardware provision for key repeat was unnecessary and could be adequately addressed solely by a provision addressing software. Accordingly, we made no change in the final rule (proposed 407.5; final 407).
The NPRM proposed that all status indicators should be visually discernible and discernible by either touch or sound. The provision contained examples of the types of controls or keys that should be discernible. A commenter (ICT company) found this approach confusing and asked whether discernibility was a feature that needed to be available all the time, or whether it only needed to be discernible when a change of status occurred. In response, the Board removed the reference to examples of types of controls and keys. We did not specify a limitation on when discernibility was required, but have determined that a single notification of a change of state is sufficient (proposed 407.6; final 409). 781b155fdc