NATIONAL FILE FORMAT NEEDS STATEMENT

NATIONAL FILE FORMAT (NFF) EXPERT PANEL

As part of its efforts to ensure that No Child is Left Behind, The U.S. Department of Education seeks to ensure that no child face an inaccessible curriculum - that raises barriers to progress rather than opportunities for learning. Unfortunately, too many students with disabilities do find inaccessible curricula in their classrooms.

As a step towards overcoming that impediment, the Department has asked the National Center on Accessing the Curriculum, housed at the Center for Applied Special Technologies (CAST), to lead an effort to develop a voluntary National File Format for the electronic transmission of instructional materials for students with disabilities.

1. The Need for A National File Format
• The promise of digital materials for accessibility

The traditional print-based materials that dominate classrooms raise barriers for many students with disabilities. For students who cannot see the words or images on a page, cannot hold a book or turn its pages, cannot decode the text or cannot comprehend the syntax that supports the written word, each experience different challenges, and each may require different supports to extract meaning from information that is "book bound." For each of them, however, there is a common barrier - the centuries old fixed format of the printed book.

Modern digital materials can present the same content as printed books, but in a format that is much more flexible and accessible. For students who cannot see the words or images, the digital version can be produced in Braille or voice, and provide descriptions of the images. For students who cannot hold the printed book or turn its pages, the virtual pages of a digital book can be turned with a slight press of a switch. For students who cannot decode the text, any word can be automatically read aloud. For students who lack the background vocabulary in the text, definitions (in English or another language) can be provided with a simple click.

The advantage of digital books is that these alternatives, and many others, can be available on an individual basis - available for students who need them, invisible or non-distracting for those who don't. Such customizable alternatives can substantially reduce the barriers found in traditional texts, reducing the effects of what are commonly called "print disabilities."

• The promise unfulfilled: barriers to access.

There is great promise in using new electronic materials to improve access to the curriculum, but that promise is not being adequately realized. Very few students with disabilities presently have access to the accessible books they need for several reasons. In some cases, the problem is technical - schools do not have the technology they need to properly provide accessible versions to students, even if they had such versions. In other cases, the problem is ignorance - many teachers and schools do not understand the issue of access or the potential solutions that are available.

But for many students the problem is a frustrating distribution system; students cannot obtain the accessible materials they need in a timely fashion. Present policies and procedures for disseminating accessible materials are archaic and inefficient, raising barriers rather than opportunities. Indeed, every element of the complex distribution system faces impediments:

1. Publishers are presently unable, largely because of outdated copyright policies, to manufacture and distribute accessible digital versions directly to students in much the same efficient way they do their print versions. Instead they, and their consumers, must depend upon various independent third parties to render the printed books accessible. This dependency on third parties for re-designing and re-distributing accessible materials is not only an impediment to efficient distribution, it also raises concerns for the publisher and consumer about quality control, digital rights management, etc. Most importantly, this process ensures that there are no financial incentives to the publisher for facilitating the process of getting materials to students who need them, or for improving the quality of their original materials for students with disabilities. Publishers who nonetheless try to support the process by providing digital versions of their materials to third parties face a bewildering array of requests for different formats and versions from different states, disability organizations and individual teachers and students.
2. Since schools and school districts cannot get accessible versions of their curricular materials from the same sources as they get their "regular" materials, they must turn to other agencies and organizations that specialize in "re-publishing" accessible versions, or they must create them themselves. Either path is complicated and time consuming: districts must identify the format (or formats) they will need for individual students and for the differing technologies available in their various schools and classrooms, select a vendor or process for creating the necessary formats and then order materials, develop a repository and distribution system to match versions to individual students and technologies, and develop local capacity for utilizing and supporting teaches in using accessible versions. All of this is vastly complicated by the fact that there are a variety of technologies and formats. These complicated procedures interpose a delay that often stretches for months and all too often results in materials arriving in classrooms long after the need has passed.
3. Not-for-profit agencies or vendors have emerged to meet the widespread need for accessible materials in schools. These agencies - called "authorized entities" in the Chafee amendment - transform inaccessible published materials (like books) into more accessible versions. The largest of these (like RFB+D, APB) are national and have long served students by creating alternative versions (audio, large print, Braille, etc.) of print materials. Because of the advantages of digital materials, many of these agencies have begun migrating to digital versions as a better way to serve their clients. But their progress is hampered by the diversity of potential formats. For example, differing publishers tend to use different proprietary formats or templates for digital production and distribution. As a result of that format complexity, it is difficult for "authorized entities" to develop an efficient process - most find it easier to begin with the printed book itself, then recreate a digital version backwards from that. Format complexities similarly inhibit the production and distribution from vendors to students. Since there is no standard format, different states and districts (even schools or classrooms) may request differing formats or versions, enormously complicating the processes of production and distribution. The lack of uniform format thus impedes both the evolution to superior digital materials, and their timely delivery to individual students.
4. Teachers, in turn, face many impediments to using digital accessible versions in their classrooms, impediments that are exacerbated by complexities in format and technology. They have two choices. First, they can determine a format that is appropriate for their student(s) and compatible with their existing classroom technology and then find a vendor or repository that can supply it. Or, they can accept a format provided for them and then adapt their classroom technologies to the format provided for them and find training in how to navigate and use it in their classrooms. Either of these is complicated when each vendor or repository may provide different formats and player technologies that teachers will have to learn to use.
5. Students with disabilities continue to face learning materials that are inaccessible in many different formats, from print to digital.

 

• Fulfilling the promise: a national file format.

While there are many barriers to accessibility, the problems that are caused by multiple formats are particularly frustrating and easily remedied. The adoption of a common, or standard, format is a simplifying step that has been crucial to progress in many other fields - from railroads (adopting a common track gauge), to video technology (adopting a common format for DVD, and HDTV). Similarly, progress in accessibility will be greatly abetted by defining a common national file format. With that single change, a number of barriers in the educational materials distribution system can be addressed.

1. With one clear and consistent file format to produce, publishers would be able to deliver a high quality digital version expeditiously and simultaneously to all authorized entities for further conversion and distribution.
2. With one consistent file format coming from different publishers, "authorized entities" would be able to efficiently transform these common formats into accessible formats (accessible digital versions and printed Braille, for example) and deliver them to local schools and school districts expeditiously.
3. With one basic digital format from vendors, schools and school districts could adopt vastly simpler, less costly, and more timely methods for acquiring materials, storing and retrieving them, purchasing additional assistive technologies, and training teachers and others in their use.
4. With one basic digital format from their districts, teachers could get their accessible materials in a timely fashion, in a consistent format that will work with their classroom technologies, and in a consistent format that will be easier for them to learn.
5. With one basic file format, students would finally get the accessible materials they need, when they need them.

 

2. The Process for Defining a National File Format
• What is a National File Format?

A file format is a specification for filing electronic information so that the content can be accurately and efficiently retrieved. Just as a library or home filing system requires some sort of organizational scheme to retrieve the information from it, an electronic book or file also requires a consistent organization or format to retrieve the information from it.

Slightly more technically, electronic information is stored in an electronic file type with a data structure, referred to as the format, so that the content stored is usable by one or more application programs (word processor, web browser, assistive technology program). Because of the consistent format, an application program can recognize and access data within the file. Several common file formats are Microsoft WORD documents (.doc), Adobe Acrobat (.pdf), and web pages (.html).

Some file formats have been developed specifically to enhance accessibility - for example to facilitate the use of assistive technologies, like screenreaders. Some examples of formats developed to enhance accessibility are accessible HTML, ANSI/NISO Z39.86-2002 (DAISY Digital Talking Book) and "tagged" PDF.

The goal of the National File Format Expert Panel is to assemble a National File Format (NFF) that will represent the best attempt of a broad team of knowledgeable experts and consumers to define a common format, one that can serve as a foundation for accessible educational materials. Such a common format will benefit the entire nation: states, districts, publishers, advocates, disability organizations, parents, and, most importantly, students with a range of disabilities.

• What is the process for arriving at a National File Format?

At the direction of and in consultation with the Department of Education, the National Center has assembled a NFF Expert Panel consisting of 40 members, representing: 1) consumers, including advocacy groups and state and local educational representatives; 2) technical experts such as assistive technology professionals, textbook administrators, software developers, standards organizations, and data conversion experts; and 3) feasibility experts encompassing national standards agencies, curriculum publishers, technology researchers, and ex-officio members from the Department of Education. The charge of the Expert Panel is to present 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."

In order to accomplish this work, the National Center for Accessing the General Curriculum (NCAC) intends to convene a series of at least three Expert Panel meetings over the next seven months to address the interests of each of the three key constituencies represented by the panel members: the Consumer Group, the Technical Group, and the Feasibility Group. The Department of Education has established a compressed timeline for this work, which underscores the urgent need to assure a highly efficient design for each meeting.

For the first convening, scheduled on January 7, 2003, the Expert Panel will address the needs of the Consumer constituency, and begin the process of developing a list of the features and functionality that the NFF must address. CAST is requesting that each participating organization representing the Consumer constituency submit a "wish list" of the features and functionality that would benefit their constituent students. The Consumer Group should provide this information to Skip Stahl at CAST, sstahl@cast.org no later than January 2, 2003, before the first Expert Panel meeting. During this same period, CAST will be seeking comments from other interested consumers who are not members of the Expert Panel.

These public comments and Consumer Group "wish lists" will inform the initial discussion at the January 7, 2003 convening. Based on the discussion and input from this Expert Panel meeting, CAST will consolidate and prioritize these "wish lists" into a proposed NFF features and functionality working list. By the end of January 2003, CAST will circulate this proposed working list among the Expert Panel members for comment and feedback. Expert Panel members will have the opportunity to discuss and revise the proposed working list through online discussions at the web site CAST has established for the Expert Panel. Additionally, CAST will schedule a brief follow-up meeting/telephone conference in early February to approve the recommended features and functionality. (Accommodations can be arranged for those participants residing outside the Washington metropolitan area who are unable to utilize the telephone conference service).

At the second convening on March 11, 2003, the Expert Panel will address the interests of the Technical Group, and begin the process of developing the technical specifications for a NFF for accessible instructional materials. Prior to the meeting, representatives from the Technical Group will be asked to review existing file formats, accessibility guidelines and emerging technologies in the context of the "wish list" and submit their recommendations and concerns relevant to the technical specifications no later than March 4, 2003. The goal of this Expert Panel meeting will be to initiate the process for defining standards to implement the features and functionality list. As with the first convening, CAST will coordinate the comments and feedback provided by the Expert Panel members, and will circulate proposed technical standards by the middle of March 2003. Expert Panel members will have the opportunity to discuss and revise these proposed technical standards at the NFF Expert Panel web site, and a follow-up meeting/telephone conference at the end of March 2003.

At the third and final convening, currently scheduled for June 10, 2003, the Expert Panel will assess the market influences, the intellectual property constraints, and the protocols and procedures necessary to ensure the widespread adoption of voluntary standards. As with the previous convenings, the Feasibility Group representatives will be asked to submit their comments to CAST no later than June 2, 2003. Once again, CAST will circulate a proposed set of recommendations to the Expert Panel members following the convening, and provide the Expert Panel with an opportunity to discuss and revise the recommendations through the NFF web site and a follow-up meeting/telephone conference.

• What are the Background Technical Assumptions for developing a National File Format?

The NFF is envisioned to be the foundation format provided by publishers and other curriculum developers for subsequent transformation into accessible digital outputs. Most considerations relating to the NFF have centered on XML (Extensible Markup Language) as the core technology for the storage of digital information. Extensible Markup Language (XML) is a syntax for marking up data or information. One of the most significant benefits of XML is that it is possible to generate multiple output formats easily and efficiently from a single XML source. This would be considerably more difficult if the source formats were HTML, PDF, Quark or RTF.

3. The Role of CAST and the National Center on Accessing the General Curriculum

CAST's investment in convening the NFF Expert Panel is a logical extension of its leadership of the National Center on Accessing the General Curriculum (NCAC). The mandate for the National Center was established by the Office of Special Education Programs following the authorization of IDEA '97, which anticipated the need for a national entity to identify and assess instructional and curriculum-based practices, procedures and policies that would facilitate the achievement of students with special needs: to expand their access, participation and progress in the general education curriculum.

The NFF initiative clearly addresses the "access" component of the IDEA '97 mandate. Students who are unable to access instructional materials usually find it impossible to participate, let alone progress, in classroom activities. Because the National Center partners and CAST believe that the provision of accessible, flexible curriculum materials is a fundamental pre-requisite to enhancing achievement, stewardship of the NFF Expert Panel was a welcome assignment.

CAST and the National Center partners believe that accessible curriculum resources are essential components of a responsive system of instruction. We also believe that accessibility is the first step towards guaranteeing both the full participation and optimal progress of students with special needs.

CAST and the National Center bring not only its experience to the NFF initiative, but a strong commitment to all three components of the IDEA '97 mandate: access, participation and progress. We believe that the NFF deliberations can significantly address this mandate with technical specifications that are: 1) extensible (able to be added to in the future); and 2) open and non-proprietary (to maximize the possibility of unfettered and continual contribution by stakeholders).