My name is Karl Groves. I’ve been involved in Web Development, Usability, and Accessibility since the late 1990s. Living in the Washington DC area, and working in accessibility my professional career in this field has always involved Section 508.

In 2006 I was excited to hear about the Refresh process. As a web developer, the advent of technologies like Asynchronous JavaScript blurred the lines between software and web and the rapid changes in mobile computing meant that the technologies that drove the old standards were quickly made obsolete. The Refresh was exciting to me because the standards could be made more relevant.

The TEITAC committee’s membership included representatives from industry, disability groups, standard-setting bodies in the U.S. and abroad, and government agencies, among others. Members were selected from applications received in response to a Board notice published in April of 2006. In the spirit of international cooperation, the Access Board also included representatives from the European Commission, Japan, Canada, and Australia.

In 2008 I was also excited to hear that the TEITAC committee had delivered their report.

[long pause]


[long pause]


The same year this nation saw its first Black President. Since that time, we’ve seen the overthrow and creation of governments in the middle east. The US Economy dove into and crawled out of a massive economic crisis.

Congress approved and implemented the Affordable Care Act – including all of the years of partisan fighting and surviving a challenge at the US Supreme Court and to date 7.3 million people had enrolled through the marketplace and paid their premiums.

Osama Bin Laden was successfully brought to justice for 9-11

Barack Obama was re-elected for his 2nd term.

And the Section 508 Refresh has still not made it to Final Rule.

Why is it that we can see the creation and implementation of the most sweeping change to our nation’s healthcare system in roughly 20% of the time it has taken to get to this hearing?

NOT having a new Final Rule has resulted in chaos within the compliance space at the Federal, State, and Local levels as well as higher education institutions. While only the Federal Executive Branch is required to adhere to Section 508, these others have often adopted Section 508 and use it to guide their own ICT procurements. It has resulted in chaos for contractors who are told by their public sector clients that they have to conform to grossly out of date standards while their private sector clients want conformance to WCAG.

I’m pleased to provide my voice to this process and want to encourage you to the best of my abilities to make haste. There will be plenty of people today who will say that the new standards aren’t enough. Incorporating WCAG by reference means, to many, that it doesn’t go far enough for persons with low vision or cognitive disorders. As the father of a child with severe learning disabilities, this resonates with me. But we must remain aware that the “perfect” is the enemy of the good. We must commit ourselves to the pragmatic understanding that what the Refresh proposes now is far far better than what currently exists in Subpart B and Subpart C of the Section 508 we now have. The lack of a final rule is, in my opinion, a failure on the Access Board’s part to achieve its mission to protect citizens with disabilities.

You must not delay this process any longer. You must make haste. Finish what so many people have worked so hard on. Make haste toward an actual Final Rule.

Thank you.

My company, AFixt exists to do one thing: Fix accessibility issues in websites, apps, and software. If you need help, get in touch with me now!