Comment on FR Doc # 2026-07663
Anonymous AnonymousSupportGovernment
Summary: A representative of a public entity supports the Department of Justice's decision to extend the Title II compliance deadlines due to resource and staffing limitations. The commenter requests that the DOJ provide concrete operational playbooks, procurement standards, and clear guidance on legacy content and third-party software to help public entities meet these mandates.
To Whom It May Concern,
As a representative of a public entity, I support the Department of Justice’s decision to extend the Title II compliance deadlines. This extension provides necessary time to address severe resource, staffing, and vendor limitations. However, to ensure public entities can successfully meet these mandates, we urgently request that the DOJ issue concrete compliance standards, operational guidelines, and technical assistance playbooks during this interim period.
Specifically, we request that the DOJ provide:
1. Operational Playbooks and Procurement Standards: While WCAG 2.1 Level AA provides a technical framework, local governments require standardized IT testing protocols, official vendor procurement templates, and clearer definitions regarding what constitutes an "undue financial and administrative burden."
2. Definitive Guidance on Third-Party and Legacy Content: Public entities require explicit "safe-harbor" boundaries for archiving legacy documents (such as historical PDFs) and clear liability rules when essential third-party software vendors fail to provide accessible integration options.
Without formalized, practical guidance from the DOJ, public entities face ongoing litigation risks and compliance confusion despite the extended timeline. We appreciate the Department’s consideration of these operational needs.