Thread Subject: Re: FPCs
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From: Phill Jenkins
Date: Fri, Sep 21 2007 1:05 PM
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> I'd say that the Technical Provisions (TPs) do not monopolize 508, nor
do they "outweigh" the FPCs.
> One way to visualize this is to say that a product that meets all the
FPCs but fails all the TPs passes 508.
> That's certainly the social goal, and we are free to put that into our
I agree (and I think everyone else agrees) that's the social goal, but my
discussion is at a very different level and needs to stay at this level to
make progress and to make it clear what we the General Committee documents
for the TEITAC and Access Board.
With respect to whether the product supports AT or whether it doesn't need
AT - changes the whole role of the FPC and TPs. That's my whole point! And
only when 508 changes scope to include applicability to AT can we change
that. If you think 508 applies to AT or are recommending that, then we
need language saying that and we need a bunch of TPs that tell the AT what
they need to do. Gregg and I and others agree that some of the TPs are
direct, meaning the product needs to comply with or without AT, some are
provisions that support interoperability with AT, and some have dual roles
- so maybe we do need to identify them explicitly. But whether we do that
or not does not change the role of FPCs and TPs with respect to products
that support (need) AT vs products that do not require AT.
If the product requires AT, then the product needs to support the TPs
first. If it fails some of the TPs, but has some equiv facil then the FPC
may have a role. If the product does not require AT, then many of the TPs
don't apply and the FPC has a role to verify one mode works without
No-one has answered my previous questions:
1. ...so you're saying that 'access provided in another way (i.e. through
equiv facil)' can be anything? including AT customization?
2. Are you saying that equiv facil is a means of meeting 508?
3. So does 508 require the agency, vendor, or AT to take responsibility to
provide the AT customization?
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