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Universal Design for Learning (UDL) is a scientifically-valid framework for designing learning environments to support all learners. To date, no instrument has been created to measure how well UDL is applied to guide learning environment design. This study is part of a larger project that aims to develop and validate a student self-report instrument called UDL-aligned Environment Assessment Inventory (UDL-EAI) as a tool to collect learner needs data to inform better design of UDL environment. This paper presented a conceptual framework for developing UDL-EAI and reported a content validity study as an initial investigation to validate the instrument.