Thread Subject: Re: "very readily achievable" ?
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From: Owen Rachal
Date: Tue, Jan 02 2007 9:50 AM
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I whole-heartedly agree with this idea, and suggest that we propose a
similar list to the plenary as a standard outcome for all the
subcommittees. Additionally, I think we should consider some kind of
adoption curve for the future, so that as new access features are
developed and become readily achievable over time, they can be regularly
and systematically evaluated for inclusion in the guidelines. A second
adoption curve might also cover new technologies such that as they
become more standard they are automatically covered by the new
guidelines. I believe Mr. Tobias proposed something similar to this
second idea some weeks back.
What I'd like to propose is some kind of "iterative method" approach
that enables an enforcement body to evaluate the environment for
technologies/access features, then study them for adoption rates (such
as how many consumers use them, etc.), evaluate the approximate cost of
adopting them for design purposes by manufacturers, determine whether or
not they are "readily achievable", then lather, rinse and repeat. The
same approach could be used by an enforcement body for determining
whether a given technology (such as VoIP and future,
not-yet-a-gleam-in-its-mother's-eye technologies) should be included in
the guidelines. Let me know if I'm too ambitious here.
Finally, a question: can the TEITAC actually propose the formation of
enforcement bodies? I can immediately see the need for at least two very
important enforcement bodies that may go a long way towards
strengthening the power of the guidelines: One, a body at the DOJ or
elsewhere that is actually responsible for enforcing the guidelines
(this may already exist, since I know the DOJ has the responsibility,
but I don't know who has the accountability with the DOJ), and two, a
body at the Access Board or other third party for objective evaluation
of technologies and access features.
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