UNDUE BURDEN DETERMINATION UNDER 36 CFR 1194.2

The following determination covers dynamically generated geospatial database and digital information and web-based mapping applications, including ArcView projects.

Findings

1. These dynamically generated products typically involve retrieval of data in various formats dependent on user requirements, resulting in a map or other graphic display. These visual representations contain large quantities of information not accessible to people visually impaired. This information may be presented on the Internet or Intranet web pages, or in web-based publications issued on compact disk or similar media.



2. Images produced by these products are dynamically generated resulting in an output image that will vary depending on the selection criteria determined by the user. This makes it impossible to prepare in advance a long description or other text alternative for those images which would provide "substantially equivalent or greater access to and use of" information contained in these pages and products. There are no products yet available that could dynamically generate a text alternative containing information comparable to that found in the image. A text alternative for even a static map image cannot adequately convey the information that is visually perceived.



3. The nature of these types of products is visual, either a representation of geospatial data or database information plotted on a digital spatial coverage, such as a map. Currently there exists no alternate technology for generation of geospatial information in a format that allows access via assistive technology. Modification of these pages and products to comply with these standards would require a fundamental alteration in the nature of the product.



4. The standards applicable to web pages and electronic publications are found in §1194.22, Web-based intranet and internet information and applications. Web pages and web-based products and publications using dynamically generated geospatial database and digital information and web-based mapping applications are unable to meet standards in 1194.22(a),(c), (e), (f), (k), (l), (m).



5. Unless covered by a separate determination, the web pages and web-based products can and will meet the remaining individual standards in 1194.22, as applicable.



6. As there exists no technology capable of producing dynamically generated geospatial images in an alternative manner accessible to individuals who are visually impaired, compliance with those standards is not possible at this time.

Alternative Means of Access

Publication of web pages and web-based products with inaccessible dynamically generated visual representations would mean significant amounts of the information in these products would not be available to individuals who are visually impaired. As an alternative, USGS will point to metadata when possible, permitting the user to access a limited textual description of the product or page. Pages and products will also include a telephone number and/or email contact for individuals with visual disabilities to contact for assistance extracting information from these products. This assistance will not extend to interpretive or analytical services not available without charge to users without visual impairments.

Determination Based on the foregoing information, I have determined that compliance with the accessibility standards in 1194.22(a),(c), (e), (f), (k), (l), and (m) for web pages and web-based products using dynamically generated geospatial database and digital information and web-based mapping applications, including ArcView projects, would impose an undue burden on the agency. However, these products and projects will follow the guidelines under 'Alternative Means of Access' (above).

This determination is effective for 12 months from the date signed.

Associate Director for Geology:

/signed/ P. Patrick Leahy 8/27/01