Thread Subject: Re: Meeting Reminder for December 19

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From: Diane Golden
Date: Tue, Dec 19 2006 9:25 AM

I can't be on the call today -- but wanted to send some quick thoughts and
questions on this issue. I agree completely that there is a need for the
rules to address this issue as it is one we have struggled with on an
implementation level. It seems that perhaps what is being described is a
"readily substitutable" option that can be applied in certain situations
instead of requiring built-in access or compatibility with add-on AT.
Questions are as follows:

Is this issue limited to only "closed or self-contained" or "appliance-type
IT" (to use Debbie's descriptive term) products? What about substituting
a TTY, VCO or HCO product for a voice only one? The telecom technical
standards would appear to allow that (don't require every telecom product
itself to have TTY, VCO, and HCO capabilities built-in or be compatible with
add-on such products, in fact that is not really much of an option for VCO
and HCO). However, the functional performance standards require all
products have either built-in access or "support for AT" which has usually
been interpreted to mean add-on access, not access delivered by a substitute
product.

What about the requirements for captioning and video description? Does this
concept of "readily substitutable" have a role there? Should the standards
really require that 100% of products have captions and video description or
could you have an option for availability of a substitute product with
captions/description?

How difficult will it be to define a concept like "readily available
substitute" so it does not provide an unintended decrease in the level of
access delivered? Is this more of an application issue (Subpart A) than an
exception for one product type?

And last, I would suggest staying away from the terminology "reasonable
accommodation" because it has a well defined scope that includes lots of
options other than providing a fully accessible substitute end product (e.g.
human assistance and other accommodations.)

Diane Golden, NASCIO


-----Original Message-----
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ]On Behalf Of Debbie Cook
Sent: Monday, December 18, 2006 3:16 PM
To: = EMAIL ADDRESS REMOVED =
Subject: [teitac-closed] Meeting Reminder for December 19


We have a call scheduled for tomorrow. I apologize to all of you for not
doing a better job of keeping things up-to-date etc. We have had this
meeting on the radar, but I have just remembered to formally submit it to
the calendar. Details are as follows:
December 19: 4:00 Eastern
Phone: 408-974-8478; pass code 1212

FEDRCC: 616394

Hand-raising: Closed Products



We also have a meeting scheduled for January 2. Since this is immediately
following the holidays and the first day back for many people, we determined
to move that call to January 9th. I will ask Tom to cancel captioning for
the 2nd and reschedule for the 9th and for the 23rd. This will get us to the
next TEITAC meeting.



This subcommittee has really struggled with issues of scope and what
constitutes a closed product. I'm hoping some of this will sort itself
eventually as we move toward a group product (which I hope isn't closed.)
So, for tomorrow I would like to determine the criteria for what
constitutes:

The exception for appliance-type IT, like calculators.

It has been proposed and widely accepted that we would "...grant an
exception because suitable alternative appliances are available. That is,
don't require an agency to purchase only talking calculators [or ones with
accessible keypads] because it's burdensome and because talking calculators
are available."

Question:

If we grant this exception, how does an agency demonstrate that the
availability is true for the specific products they wish to purchase. What
characteristics must those alternatives possess or is it enough to say that
the agency can "reasonably accommodate" and therefore wishes to wave its 508
obligation? Does the solution provider become responsible for providing the
alternatives to the agency?



We need to describe what qualifies for such an exception and how it will be
measured.



Deb

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