Comment from Belov, Charles

In regard to question 6 "For example the Board is considering whether to allow an exception to subsection 402.4 for text size for ICT which has a smaller screen...Should a minimum text size be specified for display on a screen?" concerning an exception to "Characters shall be 3/16 inch (4.8 mm) high minimum based on the uppercase letter 'I' with reference to WCAG 2.0 1.4.4 Resize text: Except for captions and images of text, text can be resized without assistive technology up to 200 percent without loss of content or functionality. (Level AA). Comment: In light of San Francisco Municipal Transportation Agency (SFMTA) exploration of use of smart phones to convey transportation information, I have determined it is to our customers' benefit to allow for the broadest array of customers to access transportation and wayfinding information. In support of a broad customer base, I make the following comment. It would make sense to allow for an exception to the smallest font size for small screens provided the exception does not also correspondingly reduce the requirement for the minimum largest font size. That is, 200% of 3/16 inch (4.8 mm) would be 3/8 inch (9.6 mm). If an exception were allowed to permit small screens to use, say, 3/32 inch (2.4 mm) as a minimum font size then the ICT ought still be required to support at least a largest size of 3/8 inch (9.6 mm), i.e. 200% of the original standard, not 200% of the revised small-screen standard.