Comment on FR Doc # 2026-07663
Anonymous AnonymousOpposeIndividual
Summary: An individual, likely a faculty member or student, argues against the proposed accessibility requirements for materials within a Learning Management System (LMS). They contend that because students with disabilities already receive individualized accommodations and the public cannot access these materials, requiring full accessibility for all LMS content is unnecessary and would hinder real-time teaching methods like handwritten notes.
I strongly urge DOJ to exempt course materials within a LMS such as Canvas to be exempted from the accessibility requirements:
1. Materials within the LMS can ONLY be accessed by students enrolled in that class. The general public CANNOT obtain them.
2. Any disabled students enrolled in that class will already have special accommodations to ensure all materials are usable by them. These accommodations are tailored to the specific needs of each disabled student by the University's Disability Support office. Therefore any disabled students WILL have full access to all class materials in a format especially designed for their individual situations.
3. Requiring full accessibility even when there are NO disabled students in a class will make it impossible to post within the LMS slides handwritten in real-time. Particularly in the sciences and engineering, many faculty do not use PowerPoint slides. Instead they write out equations etc. as the lecture proceeds; this permits adjustment to questions from the class. Automated systems do NOT read handwriting accurately.
Simply exempting materials held within a LMS such as Canvas from the requirements solves #3 without affecting any disabled students in the class since they will have accommodations that ensure access (#2).