Thread Subject: Re: teitac-subparta Digest, Vol 9, Issue 16
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From: Baker, Robert C.
Date: Mon, Jun 04 2007 1:05 PM
Subject: Re: teitac-subparta Digest, Vol 9, Issue 16
Diana wrote:
> Proposed New Definition of Comparable Access Comparable access means
> that individuals with disabilities have access to and use of
> information and data that is timely, accurate, complete and efficient
> when compared to that available to individuals without disabilities.
> Timely access ensures that individuals with disabilities have
> information and data available to them at the same time as individuals
> without disabilities. Accurate and complete access ensures that the
> information and data reflects the intended meaning especially when
> converted into another form or media. Efficiency of access includes
> consideration of the speed with which a person with a disability can
> use electronic and information technology to access information or
> perform a task as compared to an individual without disabilities.
>
> Does changing this to a definition help address the concerns about how
> this would be used or not used in solicitations?
>
Robert Baker's Response,
The definition is getting better - but once again I would re-iterate
that I believe this spells out a responsibility to the agencies for
implementing Section 508, as opposed to something that should go into a
solicitation. This has a lot to do with how technology is implemented -
not just what technology is purchased.
From: Hoffman, Allen
Date: Mon, Jun 04 2007 1:10 PM
Subject: Re: teitac-subparta Digest, Vol 9, Issue 16
This is purely a definition of what is meant by "comparable access".
The standard really doesn't have the capacity to tell folks how to
implement it specifically in contracts.
Allen Hoffman -- = EMAIL ADDRESS REMOVED = ; v: 202-447-0303
-----Original Message-----
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Baker,
Robert C.
Sent: Monday, June 04, 2007 3:01 PM
To: = EMAIL ADDRESS REMOVED =
Subject: Re: [teitac-subparta] teitac-subparta Digest, Vol 9, Issue 16
Diana wrote:
> Proposed New Definition of Comparable Access Comparable access means
> that individuals with disabilities have access to and use of
> information and data that is timely, accurate, complete and efficient
> when compared to that available to individuals without disabilities.
> Timely access ensures that individuals with disabilities have
> information and data available to them at the same time as individuals
> without disabilities. Accurate and complete access ensures that the
> information and data reflects the intended meaning especially when
> converted into another form or media. Efficiency of access includes
> consideration of the speed with which a person with a disability can
> use electronic and information technology to access information or
> perform a task as compared to an individual without disabilities.
>
> Does changing this to a definition help address the concerns about how
> this would be used or not used in solicitations?
>
Robert Baker's Response,
The definition is getting better - but once again I would re-iterate
that I believe this spells out a responsibility to the agencies for
implementing Section 508, as opposed to something that should go into a
solicitation. This has a lot to do with how technology is implemented -
not just what technology is purchased.
From: Deborah Buck
Date: Mon, Jun 04 2007 1:20 PM
Subject: Re: teitac-subparta Digest, Vol 9, Issue 16
I think that Robert has captured an important distinction. "This has a lot
to do with how technology is implemented - not just what technology is
purchased." Equivalent Facilitation is the what - " use of designs or
technologies as alternatives to those prescribed in this part provided that
they result in substantially equivalent or greater access to and use of a
product for people with disabilities." The definition for Comparable Access
is used by the agency to determine if in fact the expected outcome of
equivalent or greater access is achieved via the alternative designs or
technologies.
-----Original Message-----
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Hoffman, Allen
Sent: Monday, June 04, 2007 3:06 PM
To: TEITAC Subpart A Subcommittee
Subject: Re: [teitac-subparta] teitac-subparta Digest, Vol 9, Issue 16
This is purely a definition of what is meant by "comparable access".
The standard really doesn't have the capacity to tell folks how to
implement it specifically in contracts.
Allen Hoffman -- = EMAIL ADDRESS REMOVED = ; v: 202-447-0303
-----Original Message-----
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Baker,
Robert C.
Sent: Monday, June 04, 2007 3:01 PM
To: = EMAIL ADDRESS REMOVED =
Subject: Re: [teitac-subparta] teitac-subparta Digest, Vol 9, Issue 16
Diana wrote:
> Proposed New Definition of Comparable Access Comparable access means
> that individuals with disabilities have access to and use of
> information and data that is timely, accurate, complete and efficient
> when compared to that available to individuals without disabilities.
> Timely access ensures that individuals with disabilities have
> information and data available to them at the same time as individuals
> without disabilities. Accurate and complete access ensures that the
> information and data reflects the intended meaning especially when
> converted into another form or media. Efficiency of access includes
> consideration of the speed with which a person with a disability can
> use electronic and information technology to access information or
> perform a task as compared to an individual without disabilities.
>
> Does changing this to a definition help address the concerns about how
> this would be used or not used in solicitations?
>
Robert Baker's Response,
The definition is getting better - but once again I would re-iterate
that I believe this spells out a responsibility to the agencies for
implementing Section 508, as opposed to something that should go into a
solicitation. This has a lot to do with how technology is implemented -
not just what technology is purchased.
From: Karen Peltz Strauss
Date: Mon, Jun 04 2007 1:30 PM
Subject: Re: teitac-subparta Digest, Vol 9, Issue 16
Section 508 encompasses both - the purchase of technology as well as how it
should be used/implemented by the agencies to ensure access. So it is very
appropriate to have guidance of this sort given to federal agencies.
Karen
----- Original Message -----
From: "Baker, Robert C." < = EMAIL ADDRESS REMOVED = >
To: < = EMAIL ADDRESS REMOVED = >
Sent: Monday, June 04, 2007 2:01 PM
Subject: Re: [teitac-subparta] teitac-subparta Digest, Vol 9, Issue 16
> Diana wrote:
>
>> Proposed New Definition of Comparable Access Comparable access means
>> that individuals with disabilities have access to and use of
>> information and data that is timely, accurate, complete and efficient
>> when compared to that available to individuals without disabilities.
>> Timely access ensures that individuals with disabilities have
>> information and data available to them at the same time as individuals
>
>> without disabilities. Accurate and complete access ensures that the
>> information and data reflects the intended meaning especially when
>> converted into another form or media. Efficiency of access includes
>> consideration of the speed with which a person with a disability can
>> use electronic and information technology to access information or
>> perform a task as compared to an individual without disabilities.
>>
>> Does changing this to a definition help address the concerns about how
>
>> this would be used or not used in solicitations?
>>
>
> Robert Baker's Response,
> The definition is getting better - but once again I would re-iterate
> that I believe this spells out a responsibility to the agencies for
> implementing Section 508, as opposed to something that should go into a
> solicitation. This has a lot to do with how technology is implemented -
> not just what technology is purchased.
>
>
From: Hoffman, Allen
Date: Mon, Jun 04 2007 1:45 PM
Subject: Re: teitac-subparta Digest, Vol 9, Issue 16
I concur with the language.
Allen Hoffman -- = EMAIL ADDRESS REMOVED = ; v: 202-447-0303
-----Original Message-----
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Karen
Peltz Strauss
Sent: Monday, June 04, 2007 4:29 PM
To: TEITAC Subpart A Subcommittee
Subject: Re: [teitac-subparta] teitac-subparta Digest, Vol 9, Issue 16
Section 508 encompasses both - the purchase of technology as well as how
it should be used/implemented by the agencies to ensure access. So it
is very appropriate to have guidance of this sort given to federal
agencies.
Karen
----- Original Message -----
From: "Baker, Robert C." < = EMAIL ADDRESS REMOVED = >
To: < = EMAIL ADDRESS REMOVED = >
Sent: Monday, June 04, 2007 2:01 PM
Subject: Re: [teitac-subparta] teitac-subparta Digest, Vol 9, Issue 16
> Diana wrote:
>
>> Proposed New Definition of Comparable Access Comparable access means
>> that individuals with disabilities have access to and use of
>> information and data that is timely, accurate, complete and efficient
>> when compared to that available to individuals without disabilities.
>> Timely access ensures that individuals with disabilities have
>> information and data available to them at the same time as
individuals
>
>> without disabilities. Accurate and complete access ensures that the
>> information and data reflects the intended meaning especially when
>> converted into another form or media. Efficiency of access includes
>> consideration of the speed with which a person with a disability can
>> use electronic and information technology to access information or
>> perform a task as compared to an individual without disabilities.
>>
>> Does changing this to a definition help address the concerns about
how
>
>> this would be used or not used in solicitations?
>>
>
> Robert Baker's Response,
> The definition is getting better - but once again I would re-iterate
> that I believe this spells out a responsibility to the agencies for
> implementing Section 508, as opposed to something that should go into
a
> solicitation. This has a lot to do with how technology is implemented
-
> not just what technology is purchased.
>
>
From: Jim Tobias
Date: Mon, Jun 04 2007 1:55 PM
Subject: Re: teitac-subparta Digest, Vol 9, Issue 16
This brings me back to the "Accessibility Value Chain" concept: there
is no guarantee that an accessibility feature found in the "raw"
technology will be available to an end user. There may be a technical
problem in the way (e.g. stripping out captions during digital
encoding) or a non-technical problem (network manager doesn't configure
voice mail system to permit TTY messages). Our technical provisions
can only guard against most of the technical barriers; some remain, and
require attention. (Some would argue that non-procurement,
non-technological
provisions are out of our scope. The Access Board staff assures us that
all of our recommendations can be made relevant, even if they should be
directed
to agencies, FAR Council, FCC, etc.)
Look at the language that the Telecom SC put together to address the issue
of agency implementation:
"5.A. In complying with this subpart, each agency shall:
1. Activate accessibility features and configure telecommunications products
so that
they are accessible to and usable by people with disabilities."
Should we consider globalizing this provision so that it applies to all
E&IT?
***
Jim Tobias
Inclusive Technologies
+1.732.441.0831 v/tty
+1.908.907.2387 mobile
skype jimtobias
> -----Original Message-----
> From: Karen Peltz Strauss [mailto: = EMAIL ADDRESS REMOVED = ]
> Sent: Monday, June 04, 2007 4:29 PM
> To: TEITAC Subpart A Subcommittee
> Subject: Re: [teitac-subparta] teitac-subparta Digest, Vol 9, Issue 16
>
> Section 508 encompasses both - the purchase of technology as
> well as how it should be used/implemented by the agencies to
> ensure access. So it is very appropriate to have guidance of
> this sort given to federal agencies.
>
> Karen
>
> ----- Original Message -----
> From: "Baker, Robert C." < = EMAIL ADDRESS REMOVED = >
> To: < = EMAIL ADDRESS REMOVED = >
> Sent: Monday, June 04, 2007 2:01 PM
> Subject: Re: [teitac-subparta] teitac-subparta Digest, Vol 9, Issue 16
>
>
> > Diana wrote:
> >
> >> Proposed New Definition of Comparable Access Comparable
> access means
> >> that individuals with disabilities have access to and use of
> >> information and data that is timely, accurate, complete
> and efficient
> >> when compared to that available to individuals without
> disabilities.
> >> Timely access ensures that individuals with disabilities have
> >> information and data available to them at the same time as
> individuals
> >
> >> without disabilities. Accurate and complete access
> ensures that the
> >> information and data reflects the intended meaning especially when
> >> converted into another form or media. Efficiency of
> access includes
> >> consideration of the speed with which a person with a
> disability can
> >> use electronic and information technology to access information or
> >> perform a task as compared to an individual without disabilities.
> >>
> >> Does changing this to a definition help address the
> concerns about how
> >
> >> this would be used or not used in solicitations?
> >>
> >
> > Robert Baker's Response,
> > The definition is getting better - but once again I would re-iterate
> > that I believe this spells out a responsibility to the agencies for
> > implementing Section 508, as opposed to something that
> should go into a
> > solicitation. This has a lot to do with how technology is
> implemented -
> > not just what technology is purchased.
> >
> >
From: Jim Tobias
Date: Mon, Jun 04 2007 2:05 PM
Subject: Re: teitac-subparta Digest, Vol 9, Issue 16
This brings me back to the "Accessibility Value Chain" concept: there
is no guarantee that an accessibility feature found in the "raw"
technology will be available to an end user. There may be a technical
problem in the way (e.g. stripping out captions during digital
encoding) or a non-technical problem (network manager doesn't configure
voice mail system to permit TTY messages). Our technical provisions
can only guard against most of the technical barriers; some remain, and
require attention. (Some would argue that non-procurement,
non-technological
provisions are out of our scope. The Access Board staff assures us that
all of our recommendations can be made relevant, even if they should be
directed
to agencies, FAR Council, FCC, etc.)
Look at the language that the Telecom SC put together to address the issue
of agency implementation:
"5.A. In complying with this subpart, each agency shall:
1. Activate accessibility features and configure telecommunications products
so that
they are accessible to and usable by people with disabilities."
Should we consider globalizing this provision so that it applies to all
E&IT?
***
Jim Tobias
Inclusive Technologies
+1.732.441.0831 v/tty
+1.908.907.2387 mobile
skype jimtobias
> -----Original Message-----
> From: Karen Peltz Strauss [mailto: = EMAIL ADDRESS REMOVED = ]
> Sent: Monday, June 04, 2007 4:29 PM
> To: TEITAC Subpart A Subcommittee
> Subject: Re: [teitac-subparta] teitac-subparta Digest, Vol 9, Issue 16
>
> Section 508 encompasses both - the purchase of technology as
> well as how it should be used/implemented by the agencies to
> ensure access. So it is very appropriate to have guidance of
> this sort given to federal agencies.
>
> Karen
>
> ----- Original Message -----
> From: "Baker, Robert C." < = EMAIL ADDRESS REMOVED = >
> To: < = EMAIL ADDRESS REMOVED = >
> Sent: Monday, June 04, 2007 2:01 PM
> Subject: Re: [teitac-subparta] teitac-subparta Digest, Vol 9, Issue 16
>
>
> > Diana wrote:
> >
> >> Proposed New Definition of Comparable Access Comparable
> access means
> >> that individuals with disabilities have access to and use of
> >> information and data that is timely, accurate, complete
> and efficient
> >> when compared to that available to individuals without
> disabilities.
> >> Timely access ensures that individuals with disabilities have
> >> information and data available to them at the same time as
> individuals
> >
> >> without disabilities. Accurate and complete access
> ensures that the
> >> information and data reflects the intended meaning especially when
> >> converted into another form or media. Efficiency of
> access includes
> >> consideration of the speed with which a person with a
> disability can
> >> use electronic and information technology to access information or
> >> perform a task as compared to an individual without disabilities.
> >>
> >> Does changing this to a definition help address the
> concerns about how
> >
> >> this would be used or not used in solicitations?
> >>
> >
> > Robert Baker's Response,
> > The definition is getting better - but once again I would re-iterate
> > that I believe this spells out a responsibility to the agencies for
> > implementing Section 508, as opposed to something that
> should go into a
> > solicitation. This has a lot to do with how technology is
> implemented -
> > not just what technology is purchased.
> >
> >
From: Gregg Vanderheiden
Date: Mon, Jun 04 2007 2:15 PM
Subject: Re: teitac-subparta Digest, Vol 9, Issue 16
Hmmmm
>From the discussions this sounds like a very good idea.
Globalizing looks like just removing "telecommunications".
And it is a requirement on government - not on manufacturers.
5.A. In complying with this subpart, each agency shall:
1. Activate accessibility features and configure products so that they are
accessible to and usable by people with disabilities."
Gregg
-- ------------------------------
Gregg C Vanderheiden Ph.D.
> -----Original Message-----
> From: = EMAIL ADDRESS REMOVED =
> [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of
> Jim Tobias
> Sent: Monday, June 04, 2007 2:52 PM
> To: 'TEITAC Subpart A Subcommittee'
> Cc: 'TEITAC Telecommunications Subcommittee'
> Subject: Re: [teitac-subparta] teitac-subparta Digest, Vol 9, Issue 16
>
> This brings me back to the "Accessibility Value Chain"
> concept: there is no guarantee that an accessibility feature
> found in the "raw"
> technology will be available to an end user. There may be a
> technical problem in the way (e.g. stripping out captions
> during digital
> encoding) or a non-technical problem (network manager doesn't
> configure voice mail system to permit TTY messages). Our
> technical provisions can only guard against most of the
> technical barriers; some remain, and require attention.
> (Some would argue that non-procurement, non-technological
> provisions are out of our scope. The Access Board staff
> assures us that all of our recommendations can be made
> relevant, even if they should be directed to agencies, FAR
> Council, FCC, etc.)
>
> Look at the language that the Telecom SC put together to
> address the issue of agency implementation:
>
> "5.A. In complying with this subpart, each agency shall:
> 1. Activate accessibility features and configure
> telecommunications products so that they are accessible to
> and usable by people with disabilities."
>
> Should we consider globalizing this provision so that it
> applies to all E&IT?
>
>
> ***
> Jim Tobias
> Inclusive Technologies
> +1.732.441.0831 v/tty
> +1.908.907.2387 mobile
> skype jimtobias
>
>
> > -----Original Message-----
> > From: Karen Peltz Strauss [mailto: = EMAIL ADDRESS REMOVED = ]
> > Sent: Monday, June 04, 2007 4:29 PM
> > To: TEITAC Subpart A Subcommittee
> > Subject: Re: [teitac-subparta] teitac-subparta Digest, Vol
> 9, Issue 16
> >
> > Section 508 encompasses both - the purchase of technology
> as well as
> > how it should be used/implemented by the agencies to ensure
> access.
> > So it is very appropriate to have guidance of this sort given to
> > federal agencies.
> >
> > Karen
> >
> > ----- Original Message -----
> > From: "Baker, Robert C." < = EMAIL ADDRESS REMOVED = >
> > To: < = EMAIL ADDRESS REMOVED = >
> > Sent: Monday, June 04, 2007 2:01 PM
> > Subject: Re: [teitac-subparta] teitac-subparta Digest, Vol
> 9, Issue 16
> >
> >
> > > Diana wrote:
> > >
> > >> Proposed New Definition of Comparable Access Comparable
> > access means
> > >> that individuals with disabilities have access to and use of
> > >> information and data that is timely, accurate, complete
> > and efficient
> > >> when compared to that available to individuals without
> > disabilities.
> > >> Timely access ensures that individuals with disabilities have
> > >> information and data available to them at the same time as
> > individuals
> > >
> > >> without disabilities. Accurate and complete access
> > ensures that the
> > >> information and data reflects the intended meaning
> especially when
> > >> converted into another form or media. Efficiency of
> > access includes
> > >> consideration of the speed with which a person with a
> > disability can
> > >> use electronic and information technology to access
> information or
> > >> perform a task as compared to an individual without disabilities.
> > >>
> > >> Does changing this to a definition help address the
> > concerns about how
> > >
> > >> this would be used or not used in solicitations?
> > >>
> > >
> > > Robert Baker's Response,
> > > The definition is getting better - but once again I would
> re-iterate
> > > that I believe this spells out a responsibility to the
> agencies for
> > > implementing Section 508, as opposed to something that
> > should go into a
> > > solicitation. This has a lot to do with how technology is
> > implemented -
> > > not just what technology is purchased.
> > >
> > >
From: Gregg Vanderheiden
Date: Mon, Jun 04 2007 2:20 PM
Subject: Re: teitac-subparta Digest, Vol 9, Issue 16
Hmmmm
>From the discussions this sounds like a very good idea.
Globalizing looks like just removing "telecommunications".
And it is a requirement on government - not on manufacturers.
5.A. In complying with this subpart, each agency shall:
1. Activate accessibility features and configure products so that they are
accessible to and usable by people with disabilities."
Gregg
-- ------------------------------
Gregg C Vanderheiden Ph.D.
> -----Original Message-----
> From: = EMAIL ADDRESS REMOVED =
> [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of
> Jim Tobias
> Sent: Monday, June 04, 2007 2:52 PM
> To: 'TEITAC Subpart A Subcommittee'
> Cc: 'TEITAC Telecommunications Subcommittee'
> Subject: Re: [teitac-subparta] teitac-subparta Digest, Vol 9, Issue 16
>
> This brings me back to the "Accessibility Value Chain"
> concept: there is no guarantee that an accessibility feature
> found in the "raw"
> technology will be available to an end user. There may be a
> technical problem in the way (e.g. stripping out captions
> during digital
> encoding) or a non-technical problem (network manager doesn't
> configure voice mail system to permit TTY messages). Our
> technical provisions can only guard against most of the
> technical barriers; some remain, and require attention.
> (Some would argue that non-procurement, non-technological
> provisions are out of our scope. The Access Board staff
> assures us that all of our recommendations can be made
> relevant, even if they should be directed to agencies, FAR
> Council, FCC, etc.)
>
> Look at the language that the Telecom SC put together to
> address the issue of agency implementation:
>
> "5.A. In complying with this subpart, each agency shall:
> 1. Activate accessibility features and configure
> telecommunications products so that they are accessible to
> and usable by people with disabilities."
>
> Should we consider globalizing this provision so that it
> applies to all E&IT?
>
>
> ***
> Jim Tobias
> Inclusive Technologies
> +1.732.441.0831 v/tty
> +1.908.907.2387 mobile
> skype jimtobias
>
>
> > -----Original Message-----
> > From: Karen Peltz Strauss [mailto: = EMAIL ADDRESS REMOVED = ]
> > Sent: Monday, June 04, 2007 4:29 PM
> > To: TEITAC Subpart A Subcommittee
> > Subject: Re: [teitac-subparta] teitac-subparta Digest, Vol
> 9, Issue 16
> >
> > Section 508 encompasses both - the purchase of technology
> as well as
> > how it should be used/implemented by the agencies to ensure
> access.
> > So it is very appropriate to have guidance of this sort given to
> > federal agencies.
> >
> > Karen
> >
> > ----- Original Message -----
> > From: "Baker, Robert C." < = EMAIL ADDRESS REMOVED = >
> > To: < = EMAIL ADDRESS REMOVED = >
> > Sent: Monday, June 04, 2007 2:01 PM
> > Subject: Re: [teitac-subparta] teitac-subparta Digest, Vol
> 9, Issue 16
> >
> >
> > > Diana wrote:
> > >
> > >> Proposed New Definition of Comparable Access Comparable
> > access means
> > >> that individuals with disabilities have access to and use of
> > >> information and data that is timely, accurate, complete
> > and efficient
> > >> when compared to that available to individuals without
> > disabilities.
> > >> Timely access ensures that individuals with disabilities have
> > >> information and data available to them at the same time as
> > individuals
> > >
> > >> without disabilities. Accurate and complete access
> > ensures that the
> > >> information and data reflects the intended meaning
> especially when
> > >> converted into another form or media. Efficiency of
> > access includes
> > >> consideration of the speed with which a person with a
> > disability can
> > >> use electronic and information technology to access
> information or
> > >> perform a task as compared to an individual without disabilities.
> > >>
> > >> Does changing this to a definition help address the
> > concerns about how
> > >
> > >> this would be used or not used in solicitations?
> > >>
> > >
> > > Robert Baker's Response,
> > > The definition is getting better - but once again I would
> re-iterate
> > > that I believe this spells out a responsibility to the
> agencies for
> > > implementing Section 508, as opposed to something that
> > should go into a
> > > solicitation. This has a lot to do with how technology is
> > implemented -
> > > not just what technology is purchased.
> > >
> > >
From: Brenda Battat
Date: Mon, Jun 04 2007 2:30 PM
Subject: Re: teitac-subparta Digest, Vol 9, Issue 16
This is the language TC SC had recommended and were open to where it
should be placed - we thought not necessarily under Telecomm but rather
as a general/global provision
In complying with this subpart, each agency shall:
1) Activate accessibility features and configure telecommunications
products so that they are accessible to and usable by people with
disabilities
-----Original Message-----
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Gregg
Vanderheiden
Sent: Monday, June 04, 2007 4:10 PM
To: 'TEITAC Subpart A Subcommittee'
Cc: 'TEITAC Telecommunications Subcommittee'
Subject: Re: [teitac-telecom] [teitac-subparta] teitac-subparta Digest,
Vol 9,Issue 16
Hmmmm
>From the discussions this sounds like a very good idea.
Globalizing looks like just removing "telecommunications".
And it is a requirement on government - not on manufacturers.
5.A. In complying with this subpart, each agency shall:
1. Activate accessibility features and configure products so that they
are accessible to and usable by people with disabilities."
Gregg
-- ------------------------------
Gregg C Vanderheiden Ph.D.
> -----Original Message-----
> From: = EMAIL ADDRESS REMOVED =
> [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Jim
> Tobias
> Sent: Monday, June 04, 2007 2:52 PM
> To: 'TEITAC Subpart A Subcommittee'
> Cc: 'TEITAC Telecommunications Subcommittee'
> Subject: Re: [teitac-subparta] teitac-subparta Digest, Vol 9, Issue 16
>
> This brings me back to the "Accessibility Value Chain"
> concept: there is no guarantee that an accessibility feature found in
> the "raw"
> technology will be available to an end user. There may be a technical
> problem in the way (e.g. stripping out captions during digital
> encoding) or a non-technical problem (network manager doesn't
> configure voice mail system to permit TTY messages). Our technical
> provisions can only guard against most of the technical barriers; some
> remain, and require attention.
> (Some would argue that non-procurement, non-technological provisions
> are out of our scope. The Access Board staff assures us that all of
> our recommendations can be made relevant, even if they should be
> directed to agencies, FAR Council, FCC, etc.)
>
> Look at the language that the Telecom SC put together to address the
> issue of agency implementation:
>
> "5.A. In complying with this subpart, each agency shall:
> 1. Activate accessibility features and configure telecommunications
> products so that they are accessible to and usable by people with
> disabilities."
>
> Should we consider globalizing this provision so that it applies to
> all E&IT?
>
>
> ***
> Jim Tobias
> Inclusive Technologies
> +1.732.441.0831 v/tty
> +1.908.907.2387 mobile
> skype jimtobias
>
>
> > -----Original Message-----
> > From: Karen Peltz Strauss [mailto: = EMAIL ADDRESS REMOVED = ]
> > Sent: Monday, June 04, 2007 4:29 PM
> > To: TEITAC Subpart A Subcommittee
> > Subject: Re: [teitac-subparta] teitac-subparta Digest, Vol
> 9, Issue 16
> >
> > Section 508 encompasses both - the purchase of technology
> as well as
> > how it should be used/implemented by the agencies to ensure
> access.
> > So it is very appropriate to have guidance of this sort given to
> > federal agencies.
> >
> > Karen
> >
> > ----- Original Message -----
> > From: "Baker, Robert C." < = EMAIL ADDRESS REMOVED = >
> > To: < = EMAIL ADDRESS REMOVED = >
> > Sent: Monday, June 04, 2007 2:01 PM
> > Subject: Re: [teitac-subparta] teitac-subparta Digest, Vol
> 9, Issue 16
> >
> >
> > > Diana wrote:
> > >
> > >> Proposed New Definition of Comparable Access Comparable
> > access means
> > >> that individuals with disabilities have access to and use of
> > >> information and data that is timely, accurate, complete
> > and efficient
> > >> when compared to that available to individuals without
> > disabilities.
> > >> Timely access ensures that individuals with disabilities have
> > >> information and data available to them at the same time as
> > individuals
> > >
> > >> without disabilities. Accurate and complete access
> > ensures that the
> > >> information and data reflects the intended meaning
> especially when
> > >> converted into another form or media. Efficiency of
> > access includes
> > >> consideration of the speed with which a person with a
> > disability can
> > >> use electronic and information technology to access
> information or
> > >> perform a task as compared to an individual without disabilities.
> > >>
> > >> Does changing this to a definition help address the
> > concerns about how
> > >
> > >> this would be used or not used in solicitations?
> > >>
> > >
> > > Robert Baker's Response,
> > > The definition is getting better - but once again I would
> re-iterate
> > > that I believe this spells out a responsibility to the
> agencies for
> > > implementing Section 508, as opposed to something that
> > should go into a
> > > solicitation. This has a lot to do with how technology is
> > implemented -
> > > not just what technology is purchased.
> > >
> > >
From: Gregg Vanderheiden
Date: Mon, Jun 04 2007 2:35 PM
Subject: Re: teitac-subparta Digest, Vol 9, Issue 16
Agree.
The 508 standards apply to what the agencies do - not just what they
procure.
Gregg
-- ------------------------------
Gregg C Vanderheiden Ph.D.
> -----Original Message-----
> From: = EMAIL ADDRESS REMOVED =
> [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of
> Baker, Robert C.
> Sent: Monday, June 04, 2007 2:01 PM
> To: = EMAIL ADDRESS REMOVED =
> Subject: Re: [teitac-subparta] teitac-subparta Digest, Vol 9, Issue 16
>
> Diana wrote:
>
> > Proposed New Definition of Comparable Access Comparable
> access means
> > that individuals with disabilities have access to and use of
> > information and data that is timely, accurate, complete and
> efficient
> > when compared to that available to individuals without disabilities.
> > Timely access ensures that individuals with disabilities have
> > information and data available to them at the same time as
> individuals
>
> > without disabilities. Accurate and complete access ensures
> that the
> > information and data reflects the intended meaning especially when
> > converted into another form or media. Efficiency of access
> includes
> > consideration of the speed with which a person with a
> disability can
> > use electronic and information technology to access information or
> > perform a task as compared to an individual without disabilities.
> >
> > Does changing this to a definition help address the
> concerns about how
>
> > this would be used or not used in solicitations?
> >
>
> Robert Baker's Response,
> The definition is getting better - but once again I would
> re-iterate that I believe this spells out a responsibility to
> the agencies for implementing Section 508, as opposed to
> something that should go into a solicitation. This has a lot
> to do with how technology is implemented - not just what
> technology is purchased.
>
>
From: Diane Golden
Date: Mon, Jun 04 2007 3:10 PM
Subject: Re: teitac-subparta Digest, Vol 9, Issue 16
I'm confused. Is the suggestion that this requirement should be added into
Subpart A? I thought the idea was that it would be in General.
Diane
-----Original Message-----
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ]On Behalf Of Gregg
Vanderheiden
Sent: Monday, June 04, 2007 3:10 PM
To: 'TEITAC Subpart A Subcommittee'
Cc: 'TEITAC Telecommunications Subcommittee'
Subject: Re: [teitac-subparta] teitac-subparta Digest, Vol 9, Issue 16
Hmmmm
>From the discussions this sounds like a very good idea.
Globalizing looks like just removing "telecommunications".
And it is a requirement on government - not on manufacturers.
5.A. In complying with this subpart, each agency shall:
1. Activate accessibility features and configure products so that they are
accessible to and usable by people with disabilities."
Gregg
-- ------------------------------
Gregg C Vanderheiden Ph.D.
> -----Original Message-----
> From: = EMAIL ADDRESS REMOVED =
> [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of
> Jim Tobias
> Sent: Monday, June 04, 2007 2:52 PM
> To: 'TEITAC Subpart A Subcommittee'
> Cc: 'TEITAC Telecommunications Subcommittee'
> Subject: Re: [teitac-subparta] teitac-subparta Digest, Vol 9, Issue 16
>
> This brings me back to the "Accessibility Value Chain"
> concept: there is no guarantee that an accessibility feature
> found in the "raw"
> technology will be available to an end user. There may be a
> technical problem in the way (e.g. stripping out captions
> during digital
> encoding) or a non-technical problem (network manager doesn't
> configure voice mail system to permit TTY messages). Our
> technical provisions can only guard against most of the
> technical barriers; some remain, and require attention.
> (Some would argue that non-procurement, non-technological
> provisions are out of our scope. The Access Board staff
> assures us that all of our recommendations can be made
> relevant, even if they should be directed to agencies, FAR
> Council, FCC, etc.)
>
> Look at the language that the Telecom SC put together to
> address the issue of agency implementation:
>
> "5.A. In complying with this subpart, each agency shall:
> 1. Activate accessibility features and configure
> telecommunications products so that they are accessible to
> and usable by people with disabilities."
>
> Should we consider globalizing this provision so that it
> applies to all E&IT?
>
>
> ***
> Jim Tobias
> Inclusive Technologies
> +1.732.441.0831 v/tty
> +1.908.907.2387 mobile
> skype jimtobias
>
>
> > -----Original Message-----
> > From: Karen Peltz Strauss [mailto: = EMAIL ADDRESS REMOVED = ]
> > Sent: Monday, June 04, 2007 4:29 PM
> > To: TEITAC Subpart A Subcommittee
> > Subject: Re: [teitac-subparta] teitac-subparta Digest, Vol
> 9, Issue 16
> >
> > Section 508 encompasses both - the purchase of technology
> as well as
> > how it should be used/implemented by the agencies to ensure
> access.
> > So it is very appropriate to have guidance of this sort given to
> > federal agencies.
> >
> > Karen
> >
> > ----- Original Message -----
> > From: "Baker, Robert C." < = EMAIL ADDRESS REMOVED = >
> > To: < = EMAIL ADDRESS REMOVED = >
> > Sent: Monday, June 04, 2007 2:01 PM
> > Subject: Re: [teitac-subparta] teitac-subparta Digest, Vol
> 9, Issue 16
> >
> >
> > > Diana wrote:
> > >
> > >> Proposed New Definition of Comparable Access Comparable
> > access means
> > >> that individuals with disabilities have access to and use of
> > >> information and data that is timely, accurate, complete
> > and efficient
> > >> when compared to that available to individuals without
> > disabilities.
> > >> Timely access ensures that individuals with disabilities have
> > >> information and data available to them at the same time as
> > individuals
> > >
> > >> without disabilities. Accurate and complete access
> > ensures that the
> > >> information and data reflects the intended meaning
> especially when
> > >> converted into another form or media. Efficiency of
> > access includes
> > >> consideration of the speed with which a person with a
> > disability can
> > >> use electronic and information technology to access
> information or
> > >> perform a task as compared to an individual without disabilities.
> > >>
> > >> Does changing this to a definition help address the
> > concerns about how
> > >
> > >> this would be used or not used in solicitations?
> > >>
> > >
> > > Robert Baker's Response,
> > > The definition is getting better - but once again I would
> re-iterate
> > > that I believe this spells out a responsibility to the
> agencies for
> > > implementing Section 508, as opposed to something that
> > should go into a
> > > solicitation. This has a lot to do with how technology is
> > implemented -
> > > not just what technology is purchased.
> > >
> > >
From: Tom Brett
Date: Mon, Jun 04 2007 3:35 PM
Subject: Re: teitac-subparta Digest, Vol 9, Issue 16
Yes and no...
An agency is required by the FAR to comply with 508. There are legal
penalties if the agency does not. An agency should follow 508 when they
deploy or be subject to political embarrassment. An agency can implement in
a non compliant manner. They must only have such an implementation when
they are challenged under 504.
Tom Brett
-----Original Message-----
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Gregg
Vanderheiden
Sent: Monday, June 04, 2007 4:25 PM
To: 'TEITAC Subpart A Subcommittee'
Subject: Re: [teitac-subparta] teitac-subparta Digest, Vol 9, Issue 16
Agree.
The 508 standards apply to what the agencies do - not just what they
procure.
Gregg
-- ------------------------------
Gregg C Vanderheiden Ph.D.
> -----Original Message-----
> From: = EMAIL ADDRESS REMOVED =
> [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of
> Baker, Robert C.
> Sent: Monday, June 04, 2007 2:01 PM
> To: = EMAIL ADDRESS REMOVED =
> Subject: Re: [teitac-subparta] teitac-subparta Digest, Vol 9, Issue 16
>
> Diana wrote:
>
> > Proposed New Definition of Comparable Access Comparable
> access means
> > that individuals with disabilities have access to and use of
> > information and data that is timely, accurate, complete and
> efficient
> > when compared to that available to individuals without disabilities.
> > Timely access ensures that individuals with disabilities have
> > information and data available to them at the same time as
> individuals
>
> > without disabilities. Accurate and complete access ensures
> that the
> > information and data reflects the intended meaning especially when
> > converted into another form or media. Efficiency of access
> includes
> > consideration of the speed with which a person with a
> disability can
> > use electronic and information technology to access information or
> > perform a task as compared to an individual without disabilities.
> >
> > Does changing this to a definition help address the
> concerns about how
>
> > this would be used or not used in solicitations?
> >
>
> Robert Baker's Response,
> The definition is getting better - but once again I would
> re-iterate that I believe this spells out a responsibility to
> the agencies for implementing Section 508, as opposed to
> something that should go into a solicitation. This has a lot
> to do with how technology is implemented - not just what
> technology is purchased.
>
>
From: Diane Golden
Date: Mon, Jun 04 2007 4:10 PM
Subject: Re: teitac-subparta Digest, Vol 9, Issue 16
I'm confused. Is the suggestion that this requirement should be added into
Subpart A? I thought the idea was that it would be in General.
Diane
-----Original Message-----
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ]On Behalf Of Gregg
Vanderheiden
Sent: Monday, June 04, 2007 3:10 PM
To: 'TEITAC Subpart A Subcommittee'
Cc: 'TEITAC Telecommunications Subcommittee'
Subject: Re: [teitac-subparta] teitac-subparta Digest, Vol 9, Issue 16
Hmmmm
>From the discussions this sounds like a very good idea.
Globalizing looks like just removing "telecommunications".
And it is a requirement on government - not on manufacturers.
5.A. In complying with this subpart, each agency shall:
1. Activate accessibility features and configure products so that they are
accessible to and usable by people with disabilities."
Gregg
-- ------------------------------
Gregg C Vanderheiden Ph.D.
> -----Original Message-----
> From: = EMAIL ADDRESS REMOVED =
> [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of
> Jim Tobias
> Sent: Monday, June 04, 2007 2:52 PM
> To: 'TEITAC Subpart A Subcommittee'
> Cc: 'TEITAC Telecommunications Subcommittee'
> Subject: Re: [teitac-subparta] teitac-subparta Digest, Vol 9, Issue 16
>
> This brings me back to the "Accessibility Value Chain"
> concept: there is no guarantee that an accessibility feature
> found in the "raw"
> technology will be available to an end user. There may be a
> technical problem in the way (e.g. stripping out captions
> during digital
> encoding) or a non-technical problem (network manager doesn't
> configure voice mail system to permit TTY messages). Our
> technical provisions can only guard against most of the
> technical barriers; some remain, and require attention.
> (Some would argue that non-procurement, non-technological
> provisions are out of our scope. The Access Board staff
> assures us that all of our recommendations can be made
> relevant, even if they should be directed to agencies, FAR
> Council, FCC, etc.)
>
> Look at the language that the Telecom SC put together to
> address the issue of agency implementation:
>
> "5.A. In complying with this subpart, each agency shall:
> 1. Activate accessibility features and configure
> telecommunications products so that they are accessible to
> and usable by people with disabilities."
>
> Should we consider globalizing this provision so that it
> applies to all E&IT?
>
>
> ***
> Jim Tobias
> Inclusive Technologies
> +1.732.441.0831 v/tty
> +1.908.907.2387 mobile
> skype jimtobias
>
>
> > -----Original Message-----
> > From: Karen Peltz Strauss [mailto: = EMAIL ADDRESS REMOVED = ]
> > Sent: Monday, June 04, 2007 4:29 PM
> > To: TEITAC Subpart A Subcommittee
> > Subject: Re: [teitac-subparta] teitac-subparta Digest, Vol
> 9, Issue 16
> >
> > Section 508 encompasses both - the purchase of technology
> as well as
> > how it should be used/implemented by the agencies to ensure
> access.
> > So it is very appropriate to have guidance of this sort given to
> > federal agencies.
> >
> > Karen
> >
> > ----- Original Message -----
> > From: "Baker, Robert C." < = EMAIL ADDRESS REMOVED = >
> > To: < = EMAIL ADDRESS REMOVED = >
> > Sent: Monday, June 04, 2007 2:01 PM
> > Subject: Re: [teitac-subparta] teitac-subparta Digest, Vol
> 9, Issue 16
> >
> >
> > > Diana wrote:
> > >
> > >> Proposed New Definition of Comparable Access Comparable
> > access means
> > >> that individuals with disabilities have access to and use of
> > >> information and data that is timely, accurate, complete
> > and efficient
> > >> when compared to that available to individuals without
> > disabilities.
> > >> Timely access ensures that individuals with disabilities have
> > >> information and data available to them at the same time as
> > individuals
> > >
> > >> without disabilities. Accurate and complete access
> > ensures that the
> > >> information and data reflects the intended meaning
> especially when
> > >> converted into another form or media. Efficiency of
> > access includes
> > >> consideration of the speed with which a person with a
> > disability can
> > >> use electronic and information technology to access
> information or
> > >> perform a task as compared to an individual without disabilities.
> > >>
> > >> Does changing this to a definition help address the
> > concerns about how
> > >
> > >> this would be used or not used in solicitations?
> > >>
> > >
> > > Robert Baker's Response,
> > > The definition is getting better - but once again I would
> re-iterate
> > > that I believe this spells out a responsibility to the
> agencies for
> > > implementing Section 508, as opposed to something that
> > should go into a
> > > solicitation. This has a lot to do with how technology is
> > implemented -
> > > not just what technology is purchased.
> > >
> > >
From: Tom Brett
Date: Tue, Jun 05 2007 10:45 AM
Subject: Re: teitac-subparta Digest, Vol 9, Issue 16
Ask this question of the lawyers....
To sue in court requires that you have standing. Just being a person who
think that the agency is implementing 508 in accordance with the standing
does not give you standing.
Tom Brett
-----Original Message-----
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Gregg
Vanderheiden
Sent: Tuesday, June 05, 2007 12:35 PM
To: 'TEITAC Subpart A Subcommittee'
Subject: Re: [teitac-subparta] teitac-subparta Digest, Vol 9, Issue 16
Actually, (and I checked with the lawyers to confirm) 508 has the right of
private action. So any employee can sue their agency in court for not
complying with 508.
Gregg
-- ------------------------------
Gregg C Vanderheiden Ph.D.
> -----Original Message-----
> From: = EMAIL ADDRESS REMOVED =
> [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of
> Tom Brett
> Sent: Monday, June 04, 2007 3:58 PM
> To: 'TEITAC Subpart A Subcommittee'
> Subject: Re: [teitac-subparta] teitac-subparta Digest, Vol 9, Issue 16
>
> Yes and no...
>
> An agency is required by the FAR to comply with 508. There
> are legal penalties if the agency does not. An agency should
> follow 508 when they deploy or be subject to political
> embarrassment. An agency can implement in a non compliant
> manner. They must only have such an implementation when they
> are challenged under 504.
>
> Tom Brett
>
>
> -----Original Message-----
> From: = EMAIL ADDRESS REMOVED =
> [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of
> Gregg Vanderheiden
> Sent: Monday, June 04, 2007 4:25 PM
> To: 'TEITAC Subpart A Subcommittee'
> Subject: Re: [teitac-subparta] teitac-subparta Digest, Vol 9, Issue 16
>
> Agree.
>
> The 508 standards apply to what the agencies do - not just
> what they procure.
>
>
> Gregg
> -- ------------------------------
> Gregg C Vanderheiden Ph.D.
>
>
>
> > -----Original Message-----
> > From: = EMAIL ADDRESS REMOVED =
> > [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf
> Of Baker,
> > Robert C.
> > Sent: Monday, June 04, 2007 2:01 PM
> > To: = EMAIL ADDRESS REMOVED =
> > Subject: Re: [teitac-subparta] teitac-subparta Digest, Vol
> 9, Issue 16
> >
> > Diana wrote:
> >
> > > Proposed New Definition of Comparable Access Comparable
> > access means
> > > that individuals with disabilities have access to and use of
> > > information and data that is timely, accurate, complete and
> > efficient
> > > when compared to that available to individuals without
> disabilities.
> > > Timely access ensures that individuals with disabilities have
> > > information and data available to them at the same time as
> > individuals
> >
> > > without disabilities. Accurate and complete access ensures
> > that the
> > > information and data reflects the intended meaning
> especially when
> > > converted into another form or media. Efficiency of access
> > includes
> > > consideration of the speed with which a person with a
> > disability can
> > > use electronic and information technology to access
> information or
> > > perform a task as compared to an individual without disabilities.
> > >
> > > Does changing this to a definition help address the
> > concerns about how
> >
> > > this would be used or not used in solicitations?
> > >
> >
> > Robert Baker's Response,
> > The definition is getting better - but once again I would
> re-iterate
> > that I believe this spells out a responsibility to the agencies for
> > implementing Section 508, as opposed to something that
> should go into
> > a solicitation. This has a lot to do with how technology is
> > implemented - not just what technology is purchased.
> >
> >
From: Gregg Vanderheiden
Date: Tue, Jun 05 2007 10:55 AM
Subject: Re: teitac-subparta Digest, Vol 9, Issue 16
Actually, (and I checked with the lawyers to confirm) 508 has the right of
private action. So any employee can sue their agency in court for not
complying with 508.
Gregg
-- ------------------------------
Gregg C Vanderheiden Ph.D.
> -----Original Message-----
> From: = EMAIL ADDRESS REMOVED =
> [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of
> Tom Brett
> Sent: Monday, June 04, 2007 3:58 PM
> To: 'TEITAC Subpart A Subcommittee'
> Subject: Re: [teitac-subparta] teitac-subparta Digest, Vol 9, Issue 16
>
> Yes and no...
>
> An agency is required by the FAR to comply with 508. There
> are legal penalties if the agency does not. An agency should
> follow 508 when they deploy or be subject to political
> embarrassment. An agency can implement in a non compliant
> manner. They must only have such an implementation when they
> are challenged under 504.
>
> Tom Brett
>
>
> -----Original Message-----
> From: = EMAIL ADDRESS REMOVED =
> [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of
> Gregg Vanderheiden
> Sent: Monday, June 04, 2007 4:25 PM
> To: 'TEITAC Subpart A Subcommittee'
> Subject: Re: [teitac-subparta] teitac-subparta Digest, Vol 9, Issue 16
>
> Agree.
>
> The 508 standards apply to what the agencies do - not just
> what they procure.
>
>
> Gregg
> -- ------------------------------
> Gregg C Vanderheiden Ph.D.
>
>
>
> > -----Original Message-----
> > From: = EMAIL ADDRESS REMOVED =
> > [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf
> Of Baker,
> > Robert C.
> > Sent: Monday, June 04, 2007 2:01 PM
> > To: = EMAIL ADDRESS REMOVED =
> > Subject: Re: [teitac-subparta] teitac-subparta Digest, Vol
> 9, Issue 16
> >
> > Diana wrote:
> >
> > > Proposed New Definition of Comparable Access Comparable
> > access means
> > > that individuals with disabilities have access to and use of
> > > information and data that is timely, accurate, complete and
> > efficient
> > > when compared to that available to individuals without
> disabilities.
> > > Timely access ensures that individuals with disabilities have
> > > information and data available to them at the same time as
> > individuals
> >
> > > without disabilities. Accurate and complete access ensures
> > that the
> > > information and data reflects the intended meaning
> especially when
> > > converted into another form or media. Efficiency of access
> > includes
> > > consideration of the speed with which a person with a
> > disability can
> > > use electronic and information technology to access
> information or
> > > perform a task as compared to an individual without disabilities.
> > >
> > > Does changing this to a definition help address the
> > concerns about how
> >
> > > this would be used or not used in solicitations?
> > >
> >
> > Robert Baker's Response,
> > The definition is getting better - but once again I would
> re-iterate
> > that I believe this spells out a responsibility to the agencies for
> > implementing Section 508, as opposed to something that
> should go into
> > a solicitation. This has a lot to do with how technology is
> > implemented - not just what technology is purchased.
> >
> >
From: Gregg Vanderheiden
Date: Tue, Jun 05 2007 11:05 AM
Subject: Re: teitac-subparta Digest, Vol 9, Issue 16
Yes- that is correct. The person would have to have standing. My note below
did not relate to any person but to people what are employees who are suing
their agency under 508. It was in response to the posting that
conformance to 508 would be achieved through challenges under 504. It was
only meant to point out that it could be challenged under 508. All other
conditions for suing under 508 would of course have to be true.
Gregg
-- ------------------------------
Gregg C Vanderheiden Ph.D.
> -----Original Message-----
> From: = EMAIL ADDRESS REMOVED =
> [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of
> Tom Brett
> Sent: Tuesday, June 05, 2007 11:42 AM
> To: 'TEITAC Subpart A Subcommittee'
> Subject: Re: [teitac-subparta] teitac-subparta Digest, Vol 9, Issue 16
>
> Ask this question of the lawyers....
>
> To sue in court requires that you have standing. Just being
> a person who think that the agency is implementing 508 in
> accordance with the standing does not give you standing.
>
> Tom Brett
>
>
> -----Original Message-----
> From: = EMAIL ADDRESS REMOVED =
> [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of
> Gregg Vanderheiden
> Sent: Tuesday, June 05, 2007 12:35 PM
> To: 'TEITAC Subpart A Subcommittee'
> Subject: Re: [teitac-subparta] teitac-subparta Digest, Vol 9, Issue 16
>
> Actually, (and I checked with the lawyers to confirm) 508 has
> the right of private action. So any employee can sue their
> agency in court for not complying with 508.
>
>
> Gregg
> -- ------------------------------
> Gregg C Vanderheiden Ph.D.
>
>
>
> > -----Original Message-----
> > From: = EMAIL ADDRESS REMOVED =
> > [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Tom
> > Brett
> > Sent: Monday, June 04, 2007 3:58 PM
> > To: 'TEITAC Subpart A Subcommittee'
> > Subject: Re: [teitac-subparta] teitac-subparta Digest, Vol
> 9, Issue 16
> >
> > Yes and no...
> >
> > An agency is required by the FAR to comply with 508. There
> are legal
> > penalties if the agency does not. An agency should follow 508 when
> > they deploy or be subject to political embarrassment. An
> agency can
> > implement in a non compliant manner. They must only have such an
> > implementation when they are challenged under 504.
> >
> > Tom Brett
> >
> >
> > -----Original Message-----
> > From: = EMAIL ADDRESS REMOVED =
> > [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Gregg
> > Vanderheiden
> > Sent: Monday, June 04, 2007 4:25 PM
> > To: 'TEITAC Subpart A Subcommittee'
> > Subject: Re: [teitac-subparta] teitac-subparta Digest, Vol
> 9, Issue 16
> >
> > Agree.
> >
> > The 508 standards apply to what the agencies do - not just
> what they
> > procure.
> >
> >
> > Gregg
> > -- ------------------------------
> > Gregg C Vanderheiden Ph.D.
> >
> >
> >
> > > -----Original Message-----
> > > From: = EMAIL ADDRESS REMOVED =
> > > [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf
> > Of Baker,
> > > Robert C.
> > > Sent: Monday, June 04, 2007 2:01 PM
> > > To: = EMAIL ADDRESS REMOVED =
> > > Subject: Re: [teitac-subparta] teitac-subparta Digest, Vol
> > 9, Issue 16
> > >
> > > Diana wrote:
> > >
> > > > Proposed New Definition of Comparable Access Comparable
> > > access means
> > > > that individuals with disabilities have access to and use of
> > > > information and data that is timely, accurate, complete and
> > > efficient
> > > > when compared to that available to individuals without
> > disabilities.
> > > > Timely access ensures that individuals with disabilities have
> > > > information and data available to them at the same time as
> > > individuals
> > >
> > > > without disabilities. Accurate and complete access ensures
> > > that the
> > > > information and data reflects the intended meaning
> > especially when
> > > > converted into another form or media. Efficiency of access
> > > includes
> > > > consideration of the speed with which a person with a
> > > disability can
> > > > use electronic and information technology to access
> > information or
> > > > perform a task as compared to an individual without
> disabilities.
> > > >
> > > > Does changing this to a definition help address the
> > > concerns about how
> > >
> > > > this would be used or not used in solicitations?
> > > >
> > >
> > > Robert Baker's Response,
> > > The definition is getting better - but once again I would
> > re-iterate
> > > that I believe this spells out a responsibility to the
> agencies for
> > > implementing Section 508, as opposed to something that
> > should go into
> > > a solicitation. This has a lot to do with how technology is
> > > implemented - not just what technology is purchased.
> > >
> > >
From: Tom Brett
Date: Tue, Jun 05 2007 11:20 AM
Subject: Re: teitac-subparta Digest, Vol 9, Issue 16
The point that I was trying to make is that the standards do not apply to
agency implementations unless there is a person with standing. An agency my
implement a non-compliant system because there legally they are not required
to do so. The only time they will be required to do so is if someone with a
disability would be affected by the implementation.
A small agency that develops software need not provide text labels for their
input fields if there are no blind individuals employed by that agency.
Tom Brett
-----Original Message-----
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Gregg
Vanderheiden
Sent: Tuesday, June 05, 2007 1:01 PM
To: 'TEITAC Subpart A Subcommittee'
Subject: Re: [teitac-subparta] teitac-subparta Digest, Vol 9, Issue 16
Yes- that is correct. The person would have to have standing. My note below
did not relate to any person but to people what are employees who are suing
their agency under 508. It was in response to the posting that
conformance to 508 would be achieved through challenges under 504. It was
only meant to point out that it could be challenged under 508. All other
conditions for suing under 508 would of course have to be true.
Gregg
-- ------------------------------
Gregg C Vanderheiden Ph.D.
> -----Original Message-----
> From: = EMAIL ADDRESS REMOVED =
> [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of
> Tom Brett
> Sent: Tuesday, June 05, 2007 11:42 AM
> To: 'TEITAC Subpart A Subcommittee'
> Subject: Re: [teitac-subparta] teitac-subparta Digest, Vol 9, Issue 16
>
> Ask this question of the lawyers....
>
> To sue in court requires that you have standing. Just being
> a person who think that the agency is implementing 508 in
> accordance with the standing does not give you standing.
>
> Tom Brett
>
>
> -----Original Message-----
> From: = EMAIL ADDRESS REMOVED =
> [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of
> Gregg Vanderheiden
> Sent: Tuesday, June 05, 2007 12:35 PM
> To: 'TEITAC Subpart A Subcommittee'
> Subject: Re: [teitac-subparta] teitac-subparta Digest, Vol 9, Issue 16
>
> Actually, (and I checked with the lawyers to confirm) 508 has
> the right of private action. So any employee can sue their
> agency in court for not complying with 508.
>
>
> Gregg
> -- ------------------------------
> Gregg C Vanderheiden Ph.D.
>
>
>
> > -----Original Message-----
> > From: = EMAIL ADDRESS REMOVED =
> > [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Tom
> > Brett
> > Sent: Monday, June 04, 2007 3:58 PM
> > To: 'TEITAC Subpart A Subcommittee'
> > Subject: Re: [teitac-subparta] teitac-subparta Digest, Vol
> 9, Issue 16
> >
> > Yes and no...
> >
> > An agency is required by the FAR to comply with 508. There
> are legal
> > penalties if the agency does not. An agency should follow 508 when
> > they deploy or be subject to political embarrassment. An
> agency can
> > implement in a non compliant manner. They must only have such an
> > implementation when they are challenged under 504.
> >
> > Tom Brett
> >
> >
> > -----Original Message-----
> > From: = EMAIL ADDRESS REMOVED =
> > [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Gregg
> > Vanderheiden
> > Sent: Monday, June 04, 2007 4:25 PM
> > To: 'TEITAC Subpart A Subcommittee'
> > Subject: Re: [teitac-subparta] teitac-subparta Digest, Vol
> 9, Issue 16
> >
> > Agree.
> >
> > The 508 standards apply to what the agencies do - not just
> what they
> > procure.
> >
> >
> > Gregg
> > -- ------------------------------
> > Gregg C Vanderheiden Ph.D.
> >
> >
> >
> > > -----Original Message-----
> > > From: = EMAIL ADDRESS REMOVED =
> > > [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf
> > Of Baker,
> > > Robert C.
> > > Sent: Monday, June 04, 2007 2:01 PM
> > > To: = EMAIL ADDRESS REMOVED =
> > > Subject: Re: [teitac-subparta] teitac-subparta Digest, Vol
> > 9, Issue 16
> > >
> > > Diana wrote:
> > >
> > > > Proposed New Definition of Comparable Access Comparable
> > > access means
> > > > that individuals with disabilities have access to and use of
> > > > information and data that is timely, accurate, complete and
> > > efficient
> > > > when compared to that available to individuals without
> > disabilities.
> > > > Timely access ensures that individuals with disabilities have
> > > > information and data available to them at the same time as
> > > individuals
> > >
> > > > without disabilities. Accurate and complete access ensures
> > > that the
> > > > information and data reflects the intended meaning
> > especially when
> > > > converted into another form or media. Efficiency of access
> > > includes
> > > > consideration of the speed with which a person with a
> > > disability can
> > > > use electronic and information technology to access
> > information or
> > > > perform a task as compared to an individual without
> disabilities.
> > > >
> > > > Does changing this to a definition help address the
> > > concerns about how
> > >
> > > > this would be used or not used in solicitations?
> > > >
> > >
> > > Robert Baker's Response,
> > > The definition is getting better - but once again I would
> > re-iterate
> > > that I believe this spells out a responsibility to the
> agencies for
> > > implementing Section 508, as opposed to something that
> > should go into
> > > a solicitation. This has a lot to do with how technology is
> > > implemented - not just what technology is purchased.
> > >
> > >
From: Tom Brett
Date: Tue, Jun 05 2007 11:45 AM
Subject: Re: teitac-subparta Digest, Vol 9, Issue 16
The proposed definition of Comparable access is good. The question that
comes to mind is how can comparable access be measured.
Tom Brett
-----Original Message-----
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Baker, Robert
C.
Sent: Monday, June 04, 2007 3:01 PM
To: = EMAIL ADDRESS REMOVED =
Subject: Re: [teitac-subparta] teitac-subparta Digest, Vol 9, Issue 16
Diana wrote:
> Proposed New Definition of Comparable Access Comparable access means
> that individuals with disabilities have access to and use of
> information and data that is timely, accurate, complete and efficient
> when compared to that available to individuals without disabilities.
> Timely access ensures that individuals with disabilities have
> information and data available to them at the same time as individuals
> without disabilities. Accurate and complete access ensures that the
> information and data reflects the intended meaning especially when
> converted into another form or media. Efficiency of access includes
> consideration of the speed with which a person with a disability can
> use electronic and information technology to access information or
> perform a task as compared to an individual without disabilities.
>
> Does changing this to a definition help address the concerns about how
> this would be used or not used in solicitations?
>
Robert Baker's Response,
The definition is getting better - but once again I would re-iterate
that I believe this spells out a responsibility to the agencies for
implementing Section 508, as opposed to something that should go into a
solicitation. This has a lot to do with how technology is implemented -
not just what technology is purchased.
From: Gregg Vanderheiden
Date: Tue, Jun 05 2007 12:00 PM
Subject: Re: teitac-subparta Digest, Vol 9, Issue 16
I would ask the Access Board to weigh in here.
I do not think that is correct. I believe that agencies are supposed to
follow 508 even if they do not currently have people with a particular
disability employed.
Gregg
-- ------------------------------
Gregg C Vanderheiden Ph.D.
> -----Original Message-----
> From: = EMAIL ADDRESS REMOVED =
> [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of
> Tom Brett
> Sent: Tuesday, June 05, 2007 12:17 PM
> To: 'TEITAC Subpart A Subcommittee'
> Subject: Re: [teitac-subparta] teitac-subparta Digest, Vol 9, Issue 16
>
> The point that I was trying to make is that the standards do
> not apply to agency implementations unless there is a person
> with standing. An agency my implement a non-compliant system
> because there legally they are not required to do so. The
> only time they will be required to do so is if someone with a
> disability would be affected by the implementation.
>
> A small agency that develops software need not provide text
> labels for their input fields if there are no blind
> individuals employed by that agency.
>
>
> Tom Brett
>
>
> -----Original Message-----
> From: = EMAIL ADDRESS REMOVED =
> [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of
> Gregg Vanderheiden
> Sent: Tuesday, June 05, 2007 1:01 PM
> To: 'TEITAC Subpart A Subcommittee'
> Subject: Re: [teitac-subparta] teitac-subparta Digest, Vol 9, Issue 16
>
> Yes- that is correct. The person would have to have standing.
> My note below did not relate to any person but to people
> what are employees who are suing
> their agency under 508. It was in response to the posting that
> conformance to 508 would be achieved through challenges under
> 504. It was
> only meant to point out that it could be challenged under
> 508. All other
> conditions for suing under 508 would of course have to be true.
>
> Gregg
> -- ------------------------------
> Gregg C Vanderheiden Ph.D.
>
>
>
> > -----Original Message-----
> > From: = EMAIL ADDRESS REMOVED =
> > [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Tom
> > Brett
> > Sent: Tuesday, June 05, 2007 11:42 AM
> > To: 'TEITAC Subpart A Subcommittee'
> > Subject: Re: [teitac-subparta] teitac-subparta Digest, Vol
> 9, Issue 16
> >
> > Ask this question of the lawyers....
> >
> > To sue in court requires that you have standing. Just
> being a person
> > who think that the agency is implementing 508 in accordance
> with the
> > standing does not give you standing.
> >
> > Tom Brett
> >
> >
> > -----Original Message-----
> > From: = EMAIL ADDRESS REMOVED =
> > [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Gregg
> > Vanderheiden
> > Sent: Tuesday, June 05, 2007 12:35 PM
> > To: 'TEITAC Subpart A Subcommittee'
> > Subject: Re: [teitac-subparta] teitac-subparta Digest, Vol
> 9, Issue 16
> >
> > Actually, (and I checked with the lawyers to confirm) 508 has the
> > right of private action. So any employee can sue their
> agency in court
> > for not complying with 508.
> >
> >
> > Gregg
> > -- ------------------------------
> > Gregg C Vanderheiden Ph.D.
> >
> >
> >
> > > -----Original Message-----
> > > From: = EMAIL ADDRESS REMOVED =
> > > [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Tom
> > > Brett
> > > Sent: Monday, June 04, 2007 3:58 PM
> > > To: 'TEITAC Subpart A Subcommittee'
> > > Subject: Re: [teitac-subparta] teitac-subparta Digest, Vol
> > 9, Issue 16
> > >
> > > Yes and no...
> > >
> > > An agency is required by the FAR to comply with 508. There
> > are legal
> > > penalties if the agency does not. An agency should
> follow 508 when
> > > they deploy or be subject to political embarrassment. An
> > agency can
> > > implement in a non compliant manner. They must only have such an
> > > implementation when they are challenged under 504.
> > >
> > > Tom Brett
> > >
> > >
From: Katie Haritos-Shea
Date: Tue, Jun 05 2007 12:05 PM
Subject: Re: teitac-subparta Digest, Vol 9, Issue 16
From 508 FAQs off of Section 508.gov
These is a question that was vetted through DOJ attorneys. It is an example that the standards apply (for E&IT developed, purchased, used, and maintained) even in cases where it is not enforceable.
Does Section 508 apply to a federal Intranet site intended to be used by a small group of people who do not have disabilities?
Yes, Section 508 applies in this situation because it is not audience-specific. The standards apply to federal E&IT products (electronic and information technology) that are developed, purchased, used, and maintained, although the enforcement provisions of the law apply only to procured E&IT. If the Intranet is developed inâhouse by agency personnel, it is not enforceable under Section 508 but the standards apply. This situation is called âcoveredâ but not âenforceable.â
A frequent misconception is that if a product is not enforceable then, by definition, it is not covered. If the Intranet is developed by a consultant hired by the agency (and it becomes a product owned by the federal government), the Section 508 standards apply AND it is enforceable via the Section 508 complaint procedure. The only way an Intranet could be ânon-conformantâ with the Section 508 standards but still âcompliantâ with the Section 508 law, would be if an exception from Subpart A of Section 508 was claimed. In that case, an attempt should be made to design the product to conform to as many applicable provisions as possible.
-----Original Message-----
>From: Gregg Vanderheiden < = EMAIL ADDRESS REMOVED = >
>Sent: Jun 5, 2007 1:53 PM
>To: 'TEITAC Subpart A Subcommittee' < = EMAIL ADDRESS REMOVED = >, 'Creagan Tim' < = EMAIL ADDRESS REMOVED = >, "'David Capozzi (E-mail)'" < = EMAIL ADDRESS REMOVED = >, 'Bailey Bruce' < = EMAIL ADDRESS REMOVED = >
>Subject: Re: [teitac-subparta] teitac-subparta Digest, Vol 9, Issue 16
>
>I would ask the Access Board to weigh in here.
>
>I do not think that is correct. I believe that agencies are supposed to
>follow 508 even if they do not currently have people with a particular
>disability employed.
>
>
>Gregg
> -- ------------------------------
>Gregg C Vanderheiden Ph.D.
>
>
>
>> -----Original Message-----
>> From: = EMAIL ADDRESS REMOVED =
>> [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of
>> Tom Brett
>> Sent: Tuesday, June 05, 2007 12:17 PM
>> To: 'TEITAC Subpart A Subcommittee'
>> Subject: Re: [teitac-subparta] teitac-subparta Digest, Vol 9, Issue 16
>>
>> The point that I was trying to make is that the standards do
>> not apply to agency implementations unless there is a person
>> with standing. An agency my implement a non-compliant system
>> because there legally they are not required to do so. The
>> only time they will be required to do so is if someone with a
>> disability would be affected by the implementation.
>>
>> A small agency that develops software need not provide text
>> labels for their input fields if there are no blind
>> individuals employed by that agency.
>>
>>
>> Tom Brett
>>
>>
>> -----Original Message-----
>> From: = EMAIL ADDRESS REMOVED =
>> [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of
>> Gregg Vanderheiden
>> Sent: Tuesday, June 05, 2007 1:01 PM
>> To: 'TEITAC Subpart A Subcommittee'
>> Subject: Re: [teitac-subparta] teitac-subparta Digest, Vol 9, Issue 16
>>
>> Yes- that is correct. The person would have to have standing.
>> My note below did not relate to any person but to people
>> what are employees who are suing
>> their agency under 508. It was in response to the posting that
>> conformance to 508 would be achieved through challenges under
>> 504. It was
>> only meant to point out that it could be challenged under
>> 508. All other
>> conditions for suing under 508 would of course have to be true.
>>
>> Gregg
>> -- ------------------------------
>> Gregg C Vanderheiden Ph.D.
>>
>>
>>
>> > -----Original Message-----
>> > From: = EMAIL ADDRESS REMOVED =
>> > [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Tom
>> > Brett
>> > Sent: Tuesday, June 05, 2007 11:42 AM
>> > To: 'TEITAC Subpart A Subcommittee'
>> > Subject: Re: [teitac-subparta] teitac-subparta Digest, Vol
>> 9, Issue 16
>> >
>> > Ask this question of the lawyers....
>> >
>> > To sue in court requires that you have standing. Just
>> being a person
>> > who think that the agency is implementing 508 in accordance
>> with the
>> > standing does not give you standing.
>> >
>> > Tom Brett
>> >
>> >
>> > -----Original Message-----
>> > From: = EMAIL ADDRESS REMOVED =
>> > [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Gregg
>> > Vanderheiden
>> > Sent: Tuesday, June 05, 2007 12:35 PM
>> > To: 'TEITAC Subpart A Subcommittee'
>> > Subject: Re: [teitac-subparta] teitac-subparta Digest, Vol
>> 9, Issue 16
>> >
>> > Actually, (and I checked with the lawyers to confirm) 508 has the
>> > right of private action. So any employee can sue their
>> agency in court
>> > for not complying with 508.
>> >
>> >
>> > Gregg
>> > -- ------------------------------
>> > Gregg C Vanderheiden Ph.D.
>> >
>> >
>> >
>> > > -----Original Message-----
>> > > From: = EMAIL ADDRESS REMOVED =
>> > > [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Tom
>> > > Brett
>> > > Sent: Monday, June 04, 2007 3:58 PM
>> > > To: 'TEITAC Subpart A Subcommittee'
>> > > Subject: Re: [teitac-subparta] teitac-subparta Digest, Vol
>> > 9, Issue 16
>> > >
>> > > Yes and no...
>> > >
>> > > An agency is required by the FAR to comply with 508. There
>> > are legal
>> > > penalties if the agency does not. An agency should
>> follow 508 when
>> > > they deploy or be subject to political embarrassment. An
>> > agency can
>> > > implement in a non compliant manner. They must only have such an
>> > > implementation when they are challenged under 504.
>> > >
>> > > Tom Brett
>> > >
>> > >
>
>
>_______________________________________________
>teitac-subparta mailing list
> = EMAIL ADDRESS REMOVED =
>http://list.teitac.org/mailman/listinfo/teitac-subparta
* katie *
Katie Haritos-Shea
Section 508 Technical Policy Analyst
703-371-5545
People may forget exactly what it was that you said or did,
but people will never forget how you made them feel.......
_______________________________________________
teitac-subparta mailing list
= EMAIL ADDRESS REMOVED =
http://list.teitac.org/mailman/listinfo/teitac-subparta
From: Robinson, Norman B - Washington, DC
Date: Tue, Jun 05 2007 1:30 PM
Subject: Re: teitac-subparta Digest, Vol 9, Issue 16
Tom,
I don't understand.
1. The USPS doesn't have any legal requirement to follow the
FAR, but is explicitly named in Section 508.
2. All E&IT must be Section 508 compliant, specifically with the
legal compliance that includes documenting the general exceptions where
the technical compliance (technical standards) are not met. Can you
point to a specific reference where non-compliance is allowed (either
directly in language or indirectly by missing language subject to
interpretation perhaps?). Or perhaps an example if that would help me
understand your point of view? I certainly would appreciate it.
Regards,
Norman B. Robinson
Section 508 Coordinator
IT Governance, US Postal Service
phone: 202.268.8246
-----Original Message-----
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Tom Brett
Sent: Monday, June 04, 2007 4:58 PM
To: 'TEITAC Subpart A Subcommittee'
Subject: Re: [teitac-subparta] teitac-subparta Digest, Vol 9, Issue 16
Yes and no...
An agency is required by the FAR to comply with 508. There are legal
penalties if the agency does not. An agency should follow 508 when they
deploy or be subject to political embarrassment. An agency can
implement in
a non compliant manner. They must only have such an implementation when
they are challenged under 504.
Tom Brett
-----Original Message-----
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Gregg
Vanderheiden
Sent: Monday, June 04, 2007 4:25 PM
To: 'TEITAC Subpart A Subcommittee'
Subject: Re: [teitac-subparta] teitac-subparta Digest, Vol 9, Issue 16
Agree.
The 508 standards apply to what the agencies do - not just what they
procure.
Gregg
-- ------------------------------
Gregg C Vanderheiden Ph.D.
> -----Original Message-----
> From: = EMAIL ADDRESS REMOVED =
> [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of
> Baker, Robert C.
> Sent: Monday, June 04, 2007 2:01 PM
> To: = EMAIL ADDRESS REMOVED =
> Subject: Re: [teitac-subparta] teitac-subparta Digest, Vol 9, Issue 16
>
> Diana wrote:
>
> > Proposed New Definition of Comparable Access Comparable
> access means
> > that individuals with disabilities have access to and use of
> > information and data that is timely, accurate, complete and
> efficient
> > when compared to that available to individuals without disabilities.
> > Timely access ensures that individuals with disabilities have
> > information and data available to them at the same time as
> individuals
>
> > without disabilities. Accurate and complete access ensures
> that the
> > information and data reflects the intended meaning especially when
> > converted into another form or media. Efficiency of access
> includes
> > consideration of the speed with which a person with a
> disability can
> > use electronic and information technology to access information or
> > perform a task as compared to an individual without disabilities.
> >
> > Does changing this to a definition help address the
> concerns about how
>
> > this would be used or not used in solicitations?
> >
>
> Robert Baker's Response,
> The definition is getting better - but once again I would
> re-iterate that I believe this spells out a responsibility to
> the agencies for implementing Section 508, as opposed to
> something that should go into a solicitation. This has a lot
> to do with how technology is implemented - not just what
> technology is purchased.
>
>
From: Jessica M. Brodey
Date: Wed, Jun 06 2007 6:10 AM
Subject: Re: teitac-subparta Digest, Vol 9, Issue 16
508 does mandate compliance. It is unlikely, however, that an agency would
be sued for non-compliance unless there is an individual with standing
affected by the lack of compliance. One of the difference between 504 and
508 is that 508 mandates compliance before there is a person who needs
access, and 504 requires providing a reasonable accommodation upon request
from a specific person with a disability.
Jessica
-----Original Message-----
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Gregg
Vanderheiden
Sent: Tuesday, June 05, 2007 1:53 PM
To: 'TEITAC Subpart A Subcommittee'; 'Creagan Tim'; 'David Capozzi
(E-mail)'; 'Bailey Bruce'
Subject: Re: [teitac-subparta] teitac-subparta Digest, Vol 9, Issue 16
I would ask the Access Board to weigh in here.
I do not think that is correct. I believe that agencies are supposed to
follow 508 even if they do not currently have people with a particular
disability employed.
Gregg
-- ------------------------------
Gregg C Vanderheiden Ph.D.
> -----Original Message-----
> From: = EMAIL ADDRESS REMOVED =
> [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of
> Tom Brett
> Sent: Tuesday, June 05, 2007 12:17 PM
> To: 'TEITAC Subpart A Subcommittee'
> Subject: Re: [teitac-subparta] teitac-subparta Digest, Vol 9, Issue 16
>
> The point that I was trying to make is that the standards do
> not apply to agency implementations unless there is a person
> with standing. An agency my implement a non-compliant system
> because there legally they are not required to do so. The
> only time they will be required to do so is if someone with a
> disability would be affected by the implementation.
>
> A small agency that develops software need not provide text
> labels for their input fields if there are no blind
> individuals employed by that agency.
>
>
> Tom Brett
>
>
> -----Original Message-----
> From: = EMAIL ADDRESS REMOVED =
> [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of
> Gregg Vanderheiden
> Sent: Tuesday, June 05, 2007 1:01 PM
> To: 'TEITAC Subpart A Subcommittee'
> Subject: Re: [teitac-subparta] teitac-subparta Digest, Vol 9, Issue 16
>
> Yes- that is correct. The person would have to have standing.
> My note below did not relate to any person but to people
> what are employees who are suing
> their agency under 508. It was in response to the posting that
> conformance to 508 would be achieved through challenges under
> 504. It was
> only meant to point out that it could be challenged under
> 508. All other
> conditions for suing under 508 would of course have to be true.
>
> Gregg
> -- ------------------------------
> Gregg C Vanderheiden Ph.D.
>
>
>
> > -----Original Message-----
> > From: = EMAIL ADDRESS REMOVED =
> > [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Tom
> > Brett
> > Sent: Tuesday, June 05, 2007 11:42 AM
> > To: 'TEITAC Subpart A Subcommittee'
> > Subject: Re: [teitac-subparta] teitac-subparta Digest, Vol
> 9, Issue 16
> >
> > Ask this question of the lawyers....
> >
> > To sue in court requires that you have standing. Just
> being a person
> > who think that the agency is implementing 508 in accordance
> with the
> > standing does not give you standing.
> >
> > Tom Brett
> >
> >
> > -----Original Message-----
> > From: = EMAIL ADDRESS REMOVED =
> > [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Gregg
> > Vanderheiden
> > Sent: Tuesday, June 05, 2007 12:35 PM
> > To: 'TEITAC Subpart A Subcommittee'
> > Subject: Re: [teitac-subparta] teitac-subparta Digest, Vol
> 9, Issue 16
> >
> > Actually, (and I checked with the lawyers to confirm) 508 has the
> > right of private action. So any employee can sue their
> agency in court
> > for not complying with 508.
> >
> >
> > Gregg
> > -- ------------------------------
> > Gregg C Vanderheiden Ph.D.
> >
> >
> >
> > > -----Original Message-----
> > > From: = EMAIL ADDRESS REMOVED =
> > > [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Tom
> > > Brett
> > > Sent: Monday, June 04, 2007 3:58 PM
> > > To: 'TEITAC Subpart A Subcommittee'
> > > Subject: Re: [teitac-subparta] teitac-subparta Digest, Vol
> > 9, Issue 16
> > >
> > > Yes and no...
> > >
> > > An agency is required by the FAR to comply with 508. There
> > are legal
> > > penalties if the agency does not. An agency should
> follow 508 when
> > > they deploy or be subject to political embarrassment. An
> > agency can
> > > implement in a non compliant manner. They must only have such an
> > > implementation when they are challenged under 504.
> > >
> > > Tom Brett
> > >
> > >
From: Baker, Robert C.
Date: Mon, Jun 18 2007 1:48 PM
Subject: Re: teitac-subparta Digest, Vol 9, Issue 67
Given the level of effort already expended to define comparable access, I am concerned about a definition of accessibility that may muddy the waters. If accessibility is achieved by meeting the standards - what purpose does comparable access serve? I would prefer one or the other - not both. My preference is to stick with the recommendation for clarifying comparable access and leave "accessibility" as is.
------------------------------
Robert Baker
Social Security Administration
Section 508 Coordinator
SSA Accessibility Resource Center
Office: 410.966.7602
Email: = EMAIL ADDRESS REMOVED =
Sent by Blackberry
------------------------------
----- Original Message -----
From: = EMAIL ADDRESS REMOVED = < = EMAIL ADDRESS REMOVED = >
To: = EMAIL ADDRESS REMOVED = < = EMAIL ADDRESS REMOVED = >
Sent: Wed Jun 13 14:00:11 2007
Subject: teitac-subparta Digest, Vol 9, Issue 67
Send teitac-subparta mailing list submissions to
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When replying, please edit your Subject line so it is more specific
than "Re: Contents of teitac-subparta digest..."
Today's Topics:
1. Accessibility Definition (Diane Golden)
2. No change definitions (Diane Golden)
3. Re: Accessibility Definition (David Poehlman)
4. Re: Accessibility Definition (Gregg Vanderheiden)
5. Re: Accessibility Definition (Debbie Cook)
6. Re: Accessibility Definition (Diane Golden)
7. Re: Accessibility Definition (Salaets, Ken)
----------------------------------------------------------------------
Message: 1
Date: Tue, 12 Jun 2007 16:04:55 -0500
From: "Diane Golden" < = EMAIL ADDRESS REMOVED = >
Subject: [teitac-subparta] Accessibility Definition
To: "TEITAC SubPart A listserv (E-mail)"
< = EMAIL ADDRESS REMOVED = >
Message-ID: <00ee01c7ad35$54581880$ = EMAIL ADDRESS REMOVED = >
Content-Type: text/plain; charset="iso-8859-1"
The following is the current draft of the proposed new definition of
"accessibility" with a note about some dissention. Any further
comments/discussion on this term need to be shared by Friday (June 15) via
listserv and will be synthesized into the draft due June 30.
Thanks,
Diane Golden
NASCIO
ACCESSIBILITY -- (proposed new definition)
ACCESSIBILITY MEANS CONFORMANCE TO ALL APPLICABLE PROVISIONS OF THIS
STANDARD OR EQUIVALENT FACILITATION PROVIDED THROUGH OTHER METHODS. THE
TERM, ACCESSIBILITY, MAY ALSO BE USED TO DEFINE A BROAD SET OF FEATURES AND
CAPABILITIES WHICH ENABLE PEOPLE WITH DISABILITIES TO ACCESS ELECTRONIC
INFORMATION TECHNOLOGY.
Some subcommittee members questioned the need for this new definition
dependent on whether or not the term is used in subsequent standards or not.
------------------------------
Message: 2
Date: Tue, 12 Jun 2007 16:27:23 -0500
From: "Diane Golden" < = EMAIL ADDRESS REMOVED = >
Subject: [teitac-subparta] No change definitions
To: "TEITAC SubPart A listserv (E-mail)"
< = EMAIL ADDRESS REMOVED = >
Message-ID: <00f201c7ad38$782409b0$ = EMAIL ADDRESS REMOVED = >
Content-Type: text/plain; charset="iso-8859-1"
The following definitions are under Subpart A purview and have no changes
recommended at this time:
Agency
Information Technology
Product
Undue Burden
Unless there is significant concern with any of these definitions they will
be noted as no change recommended. Again please comment via listserv by
Friday, June 15. (This takes care of all the definitions -- so no more
messages I promise!)
Thanks,
Diane Golden
NASCIO
------------------------------
Message: 3
Date: Tue, 12 Jun 2007 19:07:17 -0400
From: "David Poehlman" < = EMAIL ADDRESS REMOVED = >
Subject: Re: [teitac-subparta] Accessibility Definition
To: < = EMAIL ADDRESS REMOVED = >, "TEITAC Subpart A Subcommittee"
< = EMAIL ADDRESS REMOVED = >
Message-ID: <002401c7ad46$6d7ef020$0901a8c0@HANDS>
Content-Type: text/plain; charset="iso-8859-1"
I'd say compliance with instead of conformace to and I'm not sure I'd add
the last part about equivelant fascilitation since that seems to in some
ways defeat the purpose of the standards which should be good enough so that
compliance meets the goal of accessability.
----- Original Message -----
From: "Diane Golden" < = EMAIL ADDRESS REMOVED = >
To: "TEITAC SubPart A listserv (E-mail)" < = EMAIL ADDRESS REMOVED = >
Sent: Tuesday, June 12, 2007 5:04 PM
Subject: [teitac-subparta] Accessibility Definition
The following is the current draft of the proposed new definition of
"accessibility" with a note about some dissention. Any further
comments/discussion on this term need to be shared by Friday (June 15) via
listserv and will be synthesized into the draft due June 30.
Thanks,
Diane Golden
NASCIO
ACCESSIBILITY -- (proposed new definition)
ACCESSIBILITY MEANS CONFORMANCE TO ALL APPLICABLE PROVISIONS OF THIS
STANDARD OR EQUIVALENT FACILITATION PROVIDED THROUGH OTHER METHODS. THE
TERM, ACCESSIBILITY, MAY ALSO BE USED TO DEFINE A BROAD SET OF FEATURES AND
CAPABILITIES WHICH ENABLE PEOPLE WITH DISABILITIES TO ACCESS ELECTRONIC
INFORMATION TECHNOLOGY.
Some subcommittee members questioned the need for this new definition
dependent on whether or not the term is used in subsequent standards or not.