Comment on FR Doc # 2010-18334

CRT Docket No. 110's proposal to expand ADA's accessibility rules to cover public accommodations on the World Wide Web represents an interesting and generally productive move. I have long been frustrated by web sites that are overdesigned so that they only display marginally well if you use the right Web browser with your window sized just right. This will hit those web sites quite hard and with a very heavy hammer so long as they are within the class that the rulemaking addresses. However, I am concerned by part B, Coverage limitations, which states: "It is the Department´s intention to regulate only governmental entities and public accommodations covered by the ADA that provide goods, services, programs, or activities to the public via websites on the Internet." The question is, where is this line to be drawn? I teach computer science at the University of Iowa, and in the course of my work, I place a considerable amount of material on the Web. I have no doubt that the university's primary web site and my department's primary web site should meet the requirements of this rule. These are the front doors to the institution. What concerns me are the myriad web sites maintained by individual faculty and researchers on the University's servers. If it applies to all such web sites, I fear that the proposed rules could place a significant damper on my ability to use the web. I make a good faith effort to keep my web site accessible, but some material is inherently inaccessible (electronic schematics are inherently visual). Furthermore, no resources are provided by my institution to help faculty with the accessibility of their material. I am worried that I and many of my colleagues may face a choice between removing material from the web or expending inordinate amounts of personal effort to make it accessible. I do not want these rules to lead to restrictions to or delays in the posting of scholarly work to the web.