Thread Subject: Re: "very readily achievable"

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From: Karen Peltz Strauss
Date: Wed, Jan 03 2007 7:50 AM

It would seem to me that this is most definitely within the purview of our
committee.

Karen

----- Original Message -----
From: "Owen Rachal" < = EMAIL ADDRESS REMOVED = >
To: "TEITAC Telecommunications Subcommittee"
< = EMAIL ADDRESS REMOVED = >
Sent: Tuesday, January 02, 2007 3:51 PM
Subject: [teitac-telecom] "very readily achievable"


> Thank you. In that case, can we still build criteria for evaluation, or
> does that constitute enforcement advisory? In other words, can the
> TEITAC advise "mandatory" adoption curves for access features and new
> technology inclusion without specifying who or what must be responsible
> for taking action?
>
> Owen Rachal
>
> -----Original Message-----
> From: = EMAIL ADDRESS REMOVED =
> [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Brooner
> Mary-AMB004
> Sent: Tuesday, January 02, 2007 12:49 PM
> To: = EMAIL ADDRESS REMOVED =
> Subject: Re: [teitac-telecom] teitac-telecom Digest, Vol 4, Issue 3
>
> The TEITAC does not have enforcement advisory authority. This was
> discussed by David Capozzi on the first day of meetings.
> Mary Brooner
>
>
> -----Original Message-----
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> Subject: teitac-telecom Digest, Vol 4, Issue 3
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> 1. Re: [teitac-subparta] "very readily achievable" ? (Owen Rachal)
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> ----------------------------------------------------------------------
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> Message: 1
> Date: Tue, 2 Jan 2007 10:47:29 -0600
> From: "Owen Rachal" < = EMAIL ADDRESS REMOVED = >
> Subject: Re: [teitac-telecom] [teitac-subparta] "very readily
> achievable" ?
> To: "TEITAC Telecommunications Subcommittee"
> < = EMAIL ADDRESS REMOVED = >, < = EMAIL ADDRESS REMOVED = >
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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.
>
>
>
> Owen Rachal
>
> Tenacity, Inc.
>
> 337-735-9513
>
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>
>
>

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