Thread Subject: Re: Prioritization of 508 technical standards-feedback provided to Subpart A subcommittee
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From: Lybarger, Barbara (MOD)
Date: Mon, Dec 18 2006 12:30 PM
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Although I generally agree with Gregg and others who have spoken against
prioritization, there may be one area where either some notion of
priorities or other forms of concrete guidance might make sense. That
is where no fully accessible product is available and/or bid for a given
project. This trigger an evaluation of available defenses, the criteria
for which are about as clear as mud.
When two or more bids offer some but not all the elements of access, a
better notion of how to evaluate their relative inadequacies would
significantly enhance the ability of a subsequent court to assess the
quality of the agency's decision to declare a defense. I think most
folks would agree it's more complicated than just counting how many
access element each bidder has. If possible, it would be helpful for
agencies trying to choose between the lesser of two or more evils, which
features have the broadest impact on the accessibility of the system
being bid. If a priority list poses too many cross disability issues,
is it possible to establish clearer guidance on what objective factors
one assess in establishing each of the defenses?
Barbara E. Lybarger, General Counsel
Massachusetts Office on Disability
One Ashburton Place, #1305
Boston, MA 02108
 727-0965 FAX
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Gregg
Sent: Monday, December 18, 2006 11:50 AM
To: 'TEITAC Web/Software Subcommittee'
Subject: Re: [teitac-websoftware] Prioritization of 508 technical
standards- feedback provided to Subpart A subcommittee
When prioritization is introduced, it is usually not to reduce the
minimum requirements but rather to allow the incorporation of additional
provisions that did not make the cut for minimum.
I think one of the instructions going into this from the access board
that the guidelines should not be weaker. Taking the minimum required
dividing them into levels of priority would tend to do this I would
Updating 508 & 255 to make them apply better to new technologies was the
focus I thought. And making them easier to implement and use.
That said, one thing that WAS discussed at the last meeting was
introducing additional 'advisory' items - and how they would be handled.
That would be a priority level of sort. But advisory items would be
added not subtracted
from the current requirements.
Gregg C Vanderheiden Ph.D.
> -----Original Message-----
> From: = EMAIL ADDRESS REMOVED =
> [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Andi
> Sent: Friday, December 15, 2006 12:04 PM
> To: = EMAIL ADDRESS REMOVED =
> Cc: = EMAIL ADDRESS REMOVED =
> Subject: [teitac-websoftware] Prioritization of 508 technical
> standards - feedback provided to Subpart A subcommittee
> Wednesday at the Web and Software subcommittee call we discussed the
> question of prioritization of the 508 technical standards for which
> the subpart A subcommittee is seeking feedback.
> Opinions are mixed. Here is a summary of the points raised:
> - some thought that some supplemental guidance on which checkpoints
> support specific disabilities would be useful to agencies. Others
> oppose this idea because it may lead to prioritization based on
> disability type which is not good..
> - some feel strongly that 508 is the minimum set and no further
> prioritization should be done. Others thought that if agencies are
> doing it anyway, then a consistent set would be good.
> - some pointed out though that the priority is dependent on the
> context of the agency and the application. For example, in a Web
> application, the forms requirement is high priority but in a website
> where the use of forms is very limited, such as on a Contact Us page,
> the forms requirement might not be so important