Thread Subject: View Point on 3.VV

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From: Jessica M. Brodey
Date: Thu, Mar 27 2008 9:55 PM

3.VV Assistive Technology

ATIA vehemently opposes the inclusion of provision 3.VV in the 508
regulations. First, the professed purpose of the mandate is to improve
interoperability between AT and E&IT. Unfortunately, it is a fallacy to
believe that merely requiring AT to utilize APIs will result in automatic
plug and play interoperability. At this point in time, neither AT nor E&IT
can guarantee that the products will work seamlessly without further
efforts, testing, and some degree of customization with respect to more
complex AT. Use of an API should never serve as a proxy for actual
interoperability. Interoperability is a process, and this provision creates
the misimpression that if both E&IT and AT utilize an API, we will have
magically solved interoperability problems. Indeed, it is quite possible
for both E&IT and AT to utilize APIs and still be incompatible. ATIA
believes that APIs are a significant improvement in technology that will go
a long way towards improving interoperability. However, there are numerous
circumstances in which APIs fall short, or improper implementation of APIs
makes it impossible for AT to utilize APIs to achieve access. To that end,
AT must have the discretion to utilize APIs as appropriate in developing AT,
and E&IT should provide those APIs. As E&IT improves the implementation and
depth of their APIs, that process alone will encourage more AT to adopt and
utilize the APIs.

Additionally, the provision also misunderstands the nature of most Federal
Government acquisition of AT. Most purchases of AT are not made under the
traditional Section 508 purchase processes, but rather under Section 504 as
an accommodation for specific individuals with disabilities. Consequently,
the provision will not be applied in most AT purchases, and will therefore
not have an impact on the AT industry, or prevent the federal government
from acquiring AT that fails to use APIs. ATIA believes this provision
exceeds the mandate of the TEITAC because it is overbroad to the extent that
it touches on 504 purchases of AT.

Finally, ATIA is concerned that this provision will reduce the cooperative
effort that has existed between AT and E&IT since the first 508 regulations.
For the past 5 years, AT and IT have increasingly been working closely
together to improve interoperability. These relationships run deep, and we
expect they will continue in the future. We believe that the regulations
should reflect an understanding of how our industries work together to
arrive at interoperability. We should not encourage a situation in which
E&IT could say "we utilized the API, however, there is nothing else we can
or will do to ensure interoperability with AT" and we believe that the
inclusion of this provision would do just that for some companies. We do
agree that procurement officers should consider interoperability and the
extent to which AT utilizes APIs in determining the likelihood of
accessibility between the AT and E&IT it purchases, but we see this as a
recommendation that should be made in the FAR rather than in the 508
regulations.

Jessica Brodey

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