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NCAC: National File Format: Supplemental Award to NCAC

Supplemental Award to the National Center on Accessing the General Curriculum

At CAST, Inc. (Center for Applied Special Technology)
40 Harvard Mills Square, Suite 3
Wakefield, MA 01880-3233

Background

The National Center on Accessing the General Curriculum (NCAC), a five year cooperative agreement funded by the Office of Special Education Programs (OSEP) at the U. S. Department of Education, is awarded a supplement to extend its activities by coordinating and facilitating the establishment of a voluntary national standard for accessible digital instructional materials for students with disabilities.

No Child Left Behind requires accountability for the educational progress of all students, including students with disabilities. Therefore, schools throughout the nation are faced with the urgent need to use evidence-based practices and emerging technologies to bridge the achievement gap for students with disabilities. As a result of this new accountability for all students and existing requirements under IDEA '97 to assure that students with disabilities have access to, participate and progress in the general education curriculum; as well as participation in large-scale assessments; the availability of accessible core curriculum materials has become critically important to state and local educational agencies. Recently several key states - California, Texas, New York, Kentucky, and Maryland - have enacted new or amended legislation requiring the consideration of accessibility in the instructional materials procurement process. The intent of these state legislative initiatives is to ensure that students with disabilities have access to appropriate learning resources at the same time that "traditional" materials are made available to their non-disabled peers. Authentic access, participation and progress of students with disabilities in the general education curriculum will not occur until accessible, flexible, and customizable learning resources are widely available to all students, particularly those who are print impaired.

Developing an efficient system for consumers and all parties involved in the production and distribution of accessible core curriculum instructional materials is of fundamental and primary concern to the U. S. Department of Education. To this end, the creation of a national file format is of significant importance to students, educators, publishers, technology specialists, and advocacy groups. Existing and emerging standards related to electronic publishing provide for the designation of a flexible core format that separates the content of instructional materials from its presentation, allowing for output of multiple accessible versions of materials from a single source. The designation of a national instructional materials accessibility standard would:

• Promote an agreed-upon file format that is sufficiently flexible to create multiple output transformations (Braille-ready, ANSI/NISO Z39.86, ebook, etc.) from the same source file - eliminating the need for repetitious and often ineffective transformations (print-to-Braille; print-to-ebook, etc.);
• Ensure the quality, consistency, and timely distribution of accessible curriculum materials - a step toward eliminating the need for publishers to produce many formats for multiple separate requirements; the often inefficient and duplicative local efforts to digitize textbooks; and the subsequent long delay in getting materials to some students;
• Establish a unified approach for the development of accessible learning materials; and
• Facilitate, at the state level, the development of a systemic approach to providing accommodations for diverse learners by increasing their capacity to acquire and transform digital curricular materials, thereby eliminating the struggle to implement solutions to the need to provide instructional materials on a student-by-student basis (particularly for blind and print impaired students).

National instructional materials accessibility standard has the potential to significantly enhance the learning opportunities available to all students. The mandate for Expert Panel members to achieve agreement on a national file format will drive the creation of solutions to a number of problems. For example, one specific issue that currently impedes the widespread availability of accessible digital materials is the technological conflict between accessibility and Digital Rights Management (DRM), technology-based security that limits unauthorized distribution. At the present time, for DRM to be effective, the text in ebooks must be "locked" so that it cannot be copied. Almost all screen reader and supported reading software currently in use relies on copying text, which the program then "speaks" aloud. These popular assistive technology tools are rendered useless when trying to read locked text. The development of a voluntary standard for accessible instructional materials will need to address this, and other issues.

Scope of Work

To achieve a voluntary standard for accessible instructional materials NCAC will complete, as part of its cooperative agreement, the following activities:

In collaboration with the National Institute of Standards and Technology (NIST) at the Department of Commerce, the NCAC will convene an Expert Panel from each of the following groups:

• Organizations that represent consumers (e.g., blind or print disabilities);
• Organizations that represent parents of students with disabilities (e.g., blind or print disabilities);
• Instructional materials publishers or their organizational designees (e.g., School Division, Association of American Publishers);
• Assistive technology developers or their organizational designees (e.g., Assistive Technology Industry Association);
• Producers of materials in specialized formats (e.g., Recordings for the Blind and Dyslexic, American Printing House for the Blind, BookShare, etc.);
• State special education program administrators or their organizational designees (e.g., National Association of State Directors of Special Education);
• Special educators and local administrators;
• State textbook administrators from adoption states or their organizational designees (e.g., National Association of State Textbook Administrators) and equivalent personnel from non-adoption states;
• Developers of accessibility, publishing software and supporting technologies;
• Information technology standards organizations; (e.g., The Access Board);
• Data transformation organizations with substantial experience in accessible file format preparation and automated conversion technologies;
• Any other organization or interest that the Secretary of Education determines to be appropriate.

In addition to delegates from the constituencies listed above, the Panel will solicit commentary and guidance from NCAC partner members, including Harvard University Law School. The Secretary of Education will designate at least one employee from the Department as an ex-officio member of the Expert Panel.

The Expert Panel will meet three times to develop and detail a proposed instructional materials accessibility standard in compliance with the copyright constraints of 2U.S.C. 15a, "An Act to Provide Books for the Adult Blind" and subsequent copyright amendments built upon that Act (e. g., the 1996 "Chafee Amendment") which authorize the provision of accessible versions of non-dramatic works to students with qualifying print disabilities. Additional discussion among panel participants will occur in a secure online forum developed and maintained by CAST.

The initial meeting of the panel will establish the areas of need, the next meeting will review proposed technical solutions and standards, and the final meeting will draft a document of recommendations. All meetings of the Expert Panel will be open to the public; and dates, times, and locations of Expert Panel meetings will be posted on the NCAC website.

The Expert Panel will be charged with providing the Secretary of Education with a set of technical specifications to facilitate the efficient delivery of accessible instructional materials, a timeline for the implementation of the proposed standards, and process for assessing the success of standards implementation. The Secretary of Education will publish the proposed standards in the Federal Register for public comment.

NCAC Capacity

NCAC is in a unique position to initiate and oversee the work of this Expert Panel. The Center has a proven capacity to convene diverse groups with convergent interests and achieve a unified perspective. In Fall 2002, the Center will jointly host, with Harvard Law School and the Association of American Publishers School Division, Policy, Property and Permissions: A Discussion of Accessible Curriculum Materials, an OSEP-supported national forum on the challenges facing those desiring accessible digital curriculum materials, copyright holders, and publishers.

Further, NCAC can draw upon the expertise of a number of CAST staff that have:

• Emerged as national experts in the adaptation of inflexible print materials into accessible digital versions;
• Acquired considerable expertise in the automated transformation of core curriculum materials into a variety of file formats;
• Contributed to American Foundation for the Blind’s "Solutions Forum" (which authored the IMAA), the Open eBook Forum, and the DAISY Consortium, and;
• Served as expert advisors to legislatures in Kentucky, California and Arizona in the development of accessible textbook legislation.