Comment from Quesenbery, Whitney

I have one very specific comment about the timing of this update -- and future updates. This process began in 2006. Since it began, the iPhone was released, Android and other smartphones became part of daily life for many, tablets have proliferated, and new technologies such as cameras, location-aware devices, image recognition, and voice command have moved from specialized products into common mobile devices. With the length of time it takes to develop a regulation, it seems doomed to be outdated before it is even adopted. With that in mind, I urge the Access Board to consider a mechanism that will allow: - Review of the regulation against the current and emerging technology landscape to determine whether the current regulations are adequate. - Issuing targeted guidance for new or disruptive technologies, where there is question about how to apply the provisions of Section 508 to them. - Opening sections of the regulation for update to take new technology into account, making the interim updates faster to review and implement. - Setting target dates (or intervals) for the next major update. All of these will allow the accessibility requirements to meet the real, day-to-day needs of people with disabilities, while also allowing both purchasing agencies and ICT companies to plan ahead. Thank you.