Thread Subject: Draft Rationale for 255
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From: BLACKLER, ELLEN (ATTSI)
Date: Wed, Dec 19 2007 7:15 AM
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Judy and I have developed the following proposal to handle the
rationales for 255 related provisions in the document. Please let us
know your thoughts in response.
Instead of re-examining and revising the rationale for every provision
in the TEITAC document, we propose applying a blanket rationale to all
of the 255 provisions.
In establishing the rules implementing Section 255, the FCC has defined
the types of products and services which must comply with the rules.
The FCC has determined that the 255 rules also apply to information and
documentation associated with the covered products, as well as
information and documentation necessary to use the covered products.
This information and documentation includes user guides, bills,
installation guides for end-user installable devices, and product
support communications. Technical standards that would improve the
accessibility of any of the items covered by section 255, whether a
phone, a printed user guide, or a web-based billing function, would be
candidates for inclusion in the Access Board's Section 255 guidelines.
Unless otherwise noted, the technical standards apply to section 255,
because they are necessary to make the covered products accessible to
and usable by people with disabilities, consistent with section 255.
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