Thread Subject: Re: "very readily achievable"

Note

This archival content is maintained by WebAIM and NCDAE on behalf of TEITAC and the U.S. Access Board . Additional details on the updates to section 508 and section 255 can be found at the Access Board web site.

From: terry.weaver@gsa.gov
Date: Wed, Jan 03 2007 11:30 AM

I applaud the notion of defining evaluation criteria - I think that would
go far in making Section 508 more easy to understand and, subsequently,
more easy to comply with. It seems to be well within scope of the
committee's charge from the Access Board.

I do not support the concept of a list of products or readily achievable
features. Its implementation would be a nightmare, which we would seem to
be ducking in making such a recommendation. As to an adoption curve, that
is also something that is very subjective. What would be the basis of
determining such a curve? Agencies have different technological
environments with their own unique constraints. Making one universal
decision seems akin to saying that all vehicles will have rear side-impact
airbags by a certain date - it ignores the fact that older vehicles would
need enormously expensive retrofitting or how would it apply to a
two-seater sports car, or a pick-up truck or a rag-top jeep or a
motorcycle. We would still have the policy impact of applying a
more-rigid Standard in a non-standard environment. Creating a
organizational structure to oversee this would be a major undertaking.





"Karen Peltz Strauss" < = EMAIL ADDRESS REMOVED = >
Sent by: = EMAIL ADDRESS REMOVED =
01/03/2007 09:49 AM
Please respond to
"TEITAC Telecommunications Subcommittee" < = EMAIL ADDRESS REMOVED = >


To
"TEITAC Telecommunications Subcommittee" < = EMAIL ADDRESS REMOVED = >
cc

Subject
Re: [teitac-telecom] "very readily achievable"






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-----
> From: = EMAIL ADDRESS REMOVED =
> [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of
> = EMAIL ADDRESS REMOVED =
> Sent: Tuesday, January 02, 2007 10:48 AM
> To: = EMAIL ADDRESS REMOVED =
> Subject: teitac-telecom Digest, Vol 4, Issue 3
>
> Send teitac-telecom mailing list submissions to
> = EMAIL ADDRESS REMOVED =
>
> To subscribe or unsubscribe via the World Wide Web, visit
> http://list.teitac.org/mailman/listinfo/teitac-telecom
> or, via email, send a message with subject or body 'help' to
> = EMAIL ADDRESS REMOVED =
>
> You can reach the person managing the list at
> = EMAIL ADDRESS REMOVED =
>
> When replying, please edit your Subject line so it is more specific than
> "Re: Conten72 Dornach Terrace
> Highgate Hill
> Brisbane 4101
> Queenslandts of teitac-telecom digest..."
>
>
> Today's Topics:
>
> 1. Re: [teitac-subparta] "very readily achievable" ? (Owen Rachal)
>
>
> ----------------------------------------------------------------------
>
> 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 = >
> Message-ID:
>
> < = EMAIL ADDRESS REMOVED = >
>
> Content-Type: text/plain; charset="us-ascii"
>
> 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
>
> = EMAIL ADDRESS REMOVED =
>
>
>
>

WebAIM is an initiative of:
Center for Persons with Disabilities (CPD) Utah State University