Thread Subject: Re: FAQ info and URL

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From: Weinstein, Michael
Date: Fri, Aug 17 2007 8:00 AM

My understanding is that the functional performance criteria in subpart
c was included as a means of encouraging innovation. Does this criteria
need to be revised?


Michael Weinstein, Esq.
Contracts
Systems Research and Applications Corporation
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-----Original Message-----
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Diane
Golden
Sent: Thursday, August 16, 2007 7:44 PM
To: 'TEITAC Subpart A Subcommittee'; 'TEITAC General Interface
Accessibility Subcommittee'
Subject: Re: [teitac-subparta] [teitac-general] FAQ info and URL

So I'll ask the obvious question -- weren't the existing technical
standards (and the current draft revisions) developed to "fully address"
the accessibility of a particular product or service? If there are
issues not addressed in the technical standards, shouldn't additional
technical requirements be developed rather than relying on functional
requirements to fill the gap? Obviously not set of standards is ever
going to address every possible access issue or need - but it seemed in
both the original development and this current revision that the goal
was for the technical standards to be comprehensive.

Unfortunately, application of the functional standards in a procurement
requires highly subjective judgments which must be made without the
benefit of standardized, valid, reliable measurment protocols which
renders those judgements extremely difficult to defend, especially in a
legal action. (I just spent the day with my procurement folks and got
more than an earful about the functional performance standards . . . )
They are wonderful design guidelines and to use Peter's teminology could
be "aspirational" for EIT products, but to include them as a core,
mandatory requirement in a procurement is very difficult.

Diane Golden
NASCIO

-----Original Message-----
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ]On Behalf Of Gregg
Vanderheiden
Sent: Thursday, August 16, 2007 5:30 PM
To: 'TEITAC General Interface Accessibility Subcommittee'; 'TEITAC
Subpart A Subcommittee'
Subject: Re: [teitac-subparta] [teitac-general] FAQ info and URL


Interesting point Allen.

Another example of this was touch screens. In current 508 you can meet
all the technical provisions for a phone and create one with no physical
buttons - just a touch screen. (not 255 but 508)

Of course it would not pass FPC. But if one felt that technical would
obviate FPC then one might conclude that meeting the technical
provisions would equate to automatically meeting the FPC.

The interesting thing is the words "fully address the product or service
being procured". Clearly in both your case and the case above, they
technical provisions did not fully address the product. There were
aspects of the product that affected accessibility that were not covered
by the technical provisions.

Interestingly, the only easy way I know of to determine if the
technical provisions "fully address the product or service being
procured" is to apply the technical provisions to a product and then
check the product or design against the functional performance criteria.

Does anyone know of any other way for people to determine if the
technical provisions "fully address the product or service being
procured"?

It would seem that the statement
If there are applicable provisions in Subpart B that fully address
the product or service being procured, then the agency need not look to
Subpart C.
is easy to misread as
If there are applicable provisions in Subpart B that address the
product or service being procured, then the agency need not look to
Subpart C.

We need to provide guidance on how to test whether the technical
(subpart B) fully address the product or whether the FPC (Subpart C) are
actually required in the process somewhere.



Gregg
-- ------------------------------
Gregg C Vanderheiden Ph.D.





From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Hoffman,
Allen
Sent: Thursday, August 16, 2007 3:15 PM
To: TEITAC General Interface Accessibility Subcommittee
Subject: Re: [teitac-general] FAQ info and URL let me document my
interpretation here, and if folks concur, then i concur with this
language.

For web sites or applications, almost all agree keyboard accessibility
is required, but not listed currently in the 1194.22 provisions. This
would indicate to me that functional performance criteria must be used
until keyboard access is part of the "applicable" provisions.

If there are applicable provisions in Subpart B that fully address the
product or service being procured, then the agency need not look to
Subpart C.

My basic logic for considering FPC(s) applicable always is that they are
related to the disability, not the EIT, and the disabilities, except
when specifically contra-indicated by fundamental alteration, are not
changed for technical reasons of product selection. I think saying that
part C is fully dependent upon technical adherence to part B just
doesn't reflect the complicated world we live in.




Allen Hoffman -- = EMAIL ADDRESS REMOVED = ; v: 202-447-0303





From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Baker,
Robert C.
Sent: Thursday, August 16, 2007 3:02 PM
To: TEITAC General Interface Accessibility Subcommittee
Subject: Re: [teitac-general] FAQ info and URL I would concur -
"provided that a fundamental alteration would not be required to meet
the FPC." Thank you for taking the leadership to provide clarity to the
FPC language.

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