Thread Subject: Re: AT Interoperability

Note

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From: Peter Korn
Date: Tue, Aug 14 2007 1:10 PM

Hi Randy,

The "consensus" I was referring to was that we weren't going to require
AT to support an API, or make any other explicit requirements on AT in
Section 508. This was something I understood was particularly important
to ATIA. What I see you saying now, below, is that you hope to be able
to change the wording of Section 508 to place a requirement on AT (you
wrote: 'Someday, I hope we will be able to change the wording of Section
508 to say something like "AT and IT products must conform to the
ABC123XXX interoperability standard".'). Doing that would essentially
mean that AT that didn't conform to your theoretical ABC123XXX
interoperability standard could NOT be acquired by agencies under 508.

You also wrote (below): "Section 508 doesn't have to tell the AT and IT
industries /how/ they should cooperate - only that it is necessary. Let
the two industries work it out from there." Section 508's testable,
technical provisions have to include a "how". Otherwise they aren't
testable. An agency can't know whether a product did or did not meet
the provision. In the non-testable FPC we can note that cooperation
"should" happen. But agencies cannot test against something like that
(how does an agency know whether cooperation happened or not? how much
cooperation is sufficient for a test? what about AT and IT that work
together even though no formal cooperation occurred)?

One thing I argued for was that we enumerate a set of sufficient
techniques for each platform, where we would be able to say something
closer to your "conform to the ABC123XXX interoperability standard" -
specifically we could identify that on Windows, Macintosh, and UNIX, the
defined platform accessibility services are XXX, YYY, ZZZ, and
implementing support for them is sufficient (but not the only way) to
meet this standard. We should further have a means of adding to that
list over time.

That route was objected to on multiple grounds. But without something
like that, and without a formal recognition that Section 508 must apply
to AT, and without placing a formal burden on AT to work with IT (if we
place a formal burden on IT to work with AT), then I don't see what more
we can do here.


What, specifically, do you suggest we do for this revision of 508?


Regards,

Peter Korn
Accessibility Architect,
Sun Microsystems, Inc.

> I'm sorry, but I don't concur.
>
> I may have missed the meeting where the "consensus" Peter refers to
> was reached, but this definitely is not the way AT sees things. If
> you remove the the requirement for IT to actually work with AT, then
> what's the point? You will end up with IT products that meet Section
> 508, but that people with disabilities still can't use.
>
> We agreed that we can't make lists of AT products that IT must be
> compatible with, nor can we create an API as part of Section 508. But
> that doesn't mean we're saying interoperability between AT and IT is
> not a requirement. Until we have actual technical interoperability
> standards that we can point to and test against, references to the
> interaction between IT and AT must necessarily remain vague. But that
> vagueness should not be extended to the point where IT is only
> required to design what they consider to be an interoperability
> gateway, but not be required to ensure that their products actually
> work with AT.
>
> Someday, I hope we will be able to change the wording of Section 508
> to say something like "AT and IT products must conform to the
> ABC123XXX interoperability standard". But until that technical
> standard(s) exists, all we can do is express the notion in general
> terms that AT and IT must work together, but not spell out how that is
> done. From AT's standpoint, we hope it is done through mutual
> cooperation between AT and IT companies, through developing standards,
> and through the prodding of laws such as Section 508 that should
> encourage (not discourage) such cooperation. Section 508 doesn't have
> to tell the AT and IT industries /how/ they should cooperate - only
> that it is necessary. Let the two industries work it out from there.
>
> -Randy Marsden
> Assistive Technology Industry Association (ATIA)
>
>
> On Aug 14, 2007, at 11:22 AM, Hoffman, Allen wrote:
>
>> Thanks Peter, you summarized this better than I and I concur with all of
>> it.
>>
>>
>>
>> Allen Hoffman -- = EMAIL ADDRESS REMOVED =
>> <mailto: = EMAIL ADDRESS REMOVED = >; v: 202-447-0303
>>
>> -----Original Message-----
>> From: = EMAIL ADDRESS REMOVED =
>> <mailto: = EMAIL ADDRESS REMOVED = >
>> [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Peter
>> Korn
>> Sent: Tuesday, August 14, 2007 1:21 PM
>> To: TEITAC Web/Software Subcommittee
>> Subject: Re: [teitac-websoftware] AT Interoperability
>>
>> Hi Gregg,
>>
>> We have more or less come to the consensus that we don't want to write
>> specific provisions for assistive technologies (e.g. requiring that AT
>> purchased by the government must implement support for platform
>> accessibility services, let alone any API that any application chooses
>> to invent and use). Unless that changes, we cannot insist that AT and IT
>> must work together. Further, we cannot tell IT that it has the sole,
>> unshared burden of working with AT.
>>
>> I feel this provision is nearly the best that is possible within those
>> constraints. Pushing IT to use platform accessibility services where
>> they exist (and by implication encouraging platforms to define and
>> promulgate such services) will go a long way to improving AT-IT
>> interoperability.
>>
>> But at AT and IT typically come from different companies, there is no
>> way one can control the other. And since government-wide regulations
>> like 508 must be technology neutral, 508 itself cannot say "your IT must
>> work with the Gregorian Screen Reader". Individual agencies can (and
>> do!) do that, but that is part of how they define their business need.
>>
>>
>> Regards,
>>
>> Peter Korn
>> Accessibility Architect,
>> Sun Microsystems, Inc.
>
> Randy Marsden
> President, Madentec Limited
> Tel: 780-450-8926 Ext. 223
> Fax: 780-988-6182
> = EMAIL ADDRESS REMOVED = <mailto: = EMAIL ADDRESS REMOVED = >
>
>
>
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