Thread Subject: AT and IT interoperability - the regime we are operating under today

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From: Peter Korn
Date: Tue, Oct 23 2007 7:35 PM
Subject: AT and IT interoperability - the regime we are operating under today

Hi Gregg,

In the plenary con-call earlier today, and also in e-mail discussions
elsewhere, you said that a number of folks believe(d) that the current
language in the current Functional Performance Criteria - specifically
the phrase in §1194.31(a), (b), (c), and (e) "... or support for
assistive technology used by people with disabilities shall be provided"
- means that E&IT is actually demonstrated to work with some specific
(though undefined) AT.

Meanwhile, I and others have always read this language to mean other
than that - to mean that EI&T has provided all it could to enable AT to
work with it.

However, I think my reading (and yours) is perhaps the least interesting
question. Rather, what I think is interesting is how this passage has
been read by folks implementing 508.

Gregg - are you aware of any Federal Agency that reads the current
passage as meaning that the 508 requires E&IT be either self accessible
or accessible via specific AT? Are you aware of any vendor of E&IT who
reads the current passage that way? Has there been any Federal
government employee who has made a complaint based on that reading and
if so, was the complaint sustained? If the answer is "yes" to any of
these, could you cite them please?

Separately, if anyone from the Access Board is following this
discussion, I'd be very curious whether they have a formal
interpretation/reading of that phrase in the Functional Performance
Criteria.

Because if in practice the regime we are all using is that "...support
for assistive technology use by people with disabilities shall be
provided" means E&IT must provide the information needed (and not
guarantee a specific level of interoperability with specific AT), then
what we have today in our draft is a clear and unambiguous improvement
(whether or not we all agree on the sufficiency of said improvement).
On the other hand, if the regime we are operating under today is that it
means E&IT must in fact have some demonstrated interoperability, then
Gregg's claim that language that doesn't specify interoperability would
in fact be less than what we have now would be sustained.


Regards,

Peter Korn
Accessibility Architect,
Sun Microsystems, Inc.

From: Diane Golden
Date: Wed, Oct 24 2007 10:30 AM
Subject: Re: AT and IT interoperability - the regime we areoperating under today

A number of folks from different states are meeting tomorrow to go through
the standards and develop comments. I will pose this question and get a
feel for what is happening at the state level in interpretation and
implementation.

For Missouri, I can say this interpretation/application problem is one of
the reasons we did not adopt the FPC in our state standards. Instead we use
applicable technical standards in the RFP (ask for conformance information
in a VPAT type structure) and pose a set of additional questions (narrative
in nature) that ask about interoperability. For COTS products we ask the
vendors to describe any compatibility testing that has been done with
commonly used assistive technology and then identify a short list of AT
products we know are used in Missouri since we provide most of them. If it
is app development we ask about plans for interoperability testing to be
done during development and benchmark testing along with identification of
an accessibility coordinator responsible for ensuring conformance to access
standards during product development and in the final version deployment and
a description of the accessibility coordinator?s experience and expertise in
developing accessible products. So this info is requested and reviewed as
part of the bid, but is not done as conformance to a set standards.

Diane Golden - NASCIO


-----Original Message-----
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ]On Behalf Of Peter Korn
Sent: Tuesday, October 23, 2007 8:28 PM
To: TEITAC Committee
Subject: [teitac-committee] AT and IT interoperability - the regime we
areoperating under today


Hi Gregg,

In the plenary con-call earlier today, and also in e-mail discussions
elsewhere, you said that a number of folks believe(d) that the current
language in the current Functional Performance Criteria - specifically
the phrase in §1194.31(a), (b), (c), and (e) "... or support for
assistive technology used by people with disabilities shall be provided"
- means that E&IT is actually demonstrated to work with some specific
(though undefined) AT.

Meanwhile, I and others have always read this language to mean other
than that - to mean that EI&T has provided all it could to enable AT to
work with it.

However, I think my reading (and yours) is perhaps the least interesting
question. Rather, what I think is interesting is how this passage has
been read by folks implementing 508.

Gregg - are you aware of any Federal Agency that reads the current
passage as meaning that the 508 requires E&IT be either self accessible
or accessible via specific AT? Are you aware of any vendor of E&IT who
reads the current passage that way? Has there been any Federal
government employee who has made a complaint based on that reading and
if so, was the complaint sustained? If the answer is "yes" to any of
these, could you cite them please?

Separately, if anyone from the Access Board is following this
discussion, I'd be very curious whether they have a formal
interpretation/reading of that phrase in the Functional Performance
Criteria.

Because if in practice the regime we are all using is that "...support
for assistive technology use by people with disabilities shall be
provided" means E&IT must provide the information needed (and not
guarantee a specific level of interoperability with specific AT), then
what we have today in our draft is a clear and unambiguous improvement
(whether or not we all agree on the sufficiency of said improvement).
On the other hand, if the regime we are operating under today is that it
means E&IT must in fact have some demonstrated interoperability, then
Gregg's claim that language that doesn't specify interoperability would
in fact be less than what we have now would be sustained.


Regards,

Peter Korn
Accessibility Architect,
Sun Microsystems, Inc.

From: Bailey Bruce
Date: Fri, Oct 26 2007 1:00 PM
Subject: Re: AT and IT interoperability - the regime we are operating under today

Responding to Peter's question posted to list:
http://teitac.org/mailarchives/mail_message.php?id=7381&listid=1

The Access Board is eager for TEITAC to advise on this concern. If there is not a single consensus position, multiple recommendations are welcomed. The Access Board has already addressed this issue as best we can in the preamble to the 508 rulemaking:

<begin quote>

Comment. The ITIC requested clarification as to how a manufacturer would determine the type and number of assistive technology devices for which support must be provided by a product.

Response. Manufacturers do not need to be aware of the universe of assistive technology products on the market. Each provision specifies the type of assistive technology that must be supported. For example, §1194.31(a) addresses those assistive technology devices which provide output to persons who cannot see the screen. Such devices may include screen readers, Braille displays and speech synthesizers. There are numerous resources available to manufacturers to assist them in identifying specific types of assistive technology which would be used to access their product.

Paragraph (a) provides that at least one mode of operation and information retrieval that does not require user vision shall be provided, or support for assistive technology used by people who are blind or visually impaired shall be provided. It is not expected that every software program will be self-voicing or have its own built-in screen reader. Software that complies with §1194.21 would also satisfy this provision. (See §1194.27(a) in the NPRM.) No substantive comments were received regarding this provision and no changes were made in the final rule.

<end quote>

http://www.access-board.gov/sec508/preamble.htm

From: Peter Korn
Date: Fri, Oct 26 2007 2:00 PM
Subject: Re: AT and IT interoperability - the regime we are operating under today

Hi Bruce,

Thank you very much for this clarification. From this, it seems clear
that the regime we are operating under today (as set by the Access Board
in the quote Bruce provided to us) is that E&IT manufacturers are not
expected to "be aware of the universe of AT", and that by supporting the
specific provisions in 1194.21 relating to any given AT, E&IT vendors
are understood to be satisfying the functional performance criteria.

Therefore, any and all work we do - in specifying the rich set of
information E&IT must provide to AT as we have done in 3-U, and in
setting forth platform requirements as we have done in 3-V and elsewhere
- is an improvement over the current regime and in no way a step
backward from what the Access Board expected would be the case.


Certainly this still leaves open the question of whether our drafts "go
far enough"; but I believe it closes the question of whether our drafts
"go backward" in any way. They do not.


Regards,

Peter Korn
Accessibility Architect,
Sun Microsystems, Inc.

> Responding to Peter's question posted to list:
> http://teitac.org/mailarchives/mail_message.php?id=7381&listid=1
>
> The Access Board is eager for TEITAC to advise on this concern. If there is not a single consensus position, multiple recommendations are welcomed. The Access Board has already addressed this issue as best we can in the preamble to the 508 rulemaking:
>
> <begin quote>
>
> Comment. The ITIC requested clarification as to how a manufacturer would determine the type and number of assistive technology devices for which support must be provided by a product.
>
> Response. Manufacturers do not need to be aware of the universe of assistive technology products on the market. Each provision specifies the type of assistive technology that must be supported. For example, §1194.31(a) addresses those assistive technology devices which provide output to persons who cannot see the screen. Such devices may include screen readers, Braille displays and speech synthesizers. There are numerous resources available to manufacturers to assist them in identifying specific types of assistive technology which would be used to access their product.
>
> Paragraph (a) provides that at least one mode of operation and information retrieval that does not require user vision shall be provided, or support for assistive technology used by people who are blind or visually impaired shall be provided. It is not expected that every software program will be self-voicing or have its own built-in screen reader. Software that complies with §1194.21 would also satisfy this provision. (See §1194.27(a) in the NPRM.) No substantive comments were received regarding this provision and no changes were made in the final rule.
>
> <end quote>
>
> http://www.access-board.gov/sec508/preamble.htm
>

From: Randy Marsden
Date: Fri, Oct 26 2007 2:55 PM
Subject: Re: AT and IT interoperability - the regime we are operating under today

The problem is the statement issued by the Access Board is
ambiguous. The single sentence quoted by Peter appears to suggest
that an IT manufacturer doesn't need to be aware of the "AT
universe". However, if you read the entire paragraph, the last
sentence seems to suggest the opposite: that "there are numerous
resources available to manufacturers to assist them in identifying
specific types of assistive technology which would be used with their
product". Clearly, that sentence indicates some level of
responsibility for the manufacturer to get educated about what AT
exists for their product(s). So, I don't agree with Peter that it is
clear what is meant - especially when considering the entire directive.

Bruce - I feel the directive issued by the Access Board contains
statements that can be viewed as conflicting, and is part of what has
led to the lack of consensus on this point.

Randy Marsden
ATIA



On Oct 26, 2007, at 1:56 PM, Peter Korn wrote:

> Hi Bruce,
>
> Thank you very much for this clarification. From this, it seems clear
> that the regime we are operating under today (as set by the Access
> Board
> in the quote Bruce provided to us) is that E&IT manufacturers are not
> expected to "be aware of the universe of AT", and that by
> supporting the
> specific provisions in 1194.21 relating to any given AT, E&IT vendors
> are understood to be satisfying the functional performance criteria.
>
> Therefore, any and all work we do - in specifying the rich set of
> information E&IT must provide to AT as we have done in 3-U, and in
> setting forth platform requirements as we have done in 3-V and
> elsewhere
> - is an improvement over the current regime and in no way a step
> backward from what the Access Board expected would be the case.
>
>
> Certainly this still leaves open the question of whether our drafts
> "go
> far enough"; but I believe it closes the question of whether our
> drafts
> "go backward" in any way. They do not.
>
>
> Regards,
>
> Peter Korn
> Accessibility Architect,
> Sun Microsystems, Inc.
>
>> Responding to Peter's question posted to list:
>> http://teitac.org/mailarchives/mail_message.php?id=7381&listid=1
>>
>> The Access Board is eager for TEITAC to advise on this concern.
>> If there is not a single consensus position, multiple
>> recommendations are welcomed. The Access Board has already
>> addressed this issue as best we can in the preamble to the 508
>> rulemaking:
>>
>> <begin quote>
>>
>> Comment. The ITIC requested clarification as to how a
>> manufacturer would determine the type and number of assistive
>> technology devices for which support must be provided by a product.
>>
>> Response. Manufacturers do not need to be aware of the universe
>> of assistive technology products on the market. Each provision
>> specifies the type of assistive technology that must be
>> supported. For example, §1194.31(a) addresses those assistive
>> technology devices which provide output to persons who cannot see
>> the screen. Such devices may include screen readers, Braille
>> displays and speech synthesizers. There are numerous resources
>> available to manufacturers to assist them in identifying specific
>> types of assistive technology which would be used to access their
>> product.
>>
>> Paragraph (a) provides that at least one mode of operation and
>> information retrieval that does not require user vision shall be
>> provided, or support for assistive technology used by people who
>> are blind or visually impaired shall be provided. It is not
>> expected that every software program will be self-voicing or have
>> its own built-in screen reader. Software that complies with
>> §1194.21 would also satisfy this provision. (See §1194.27(a) in
>> the NPRM.) No substantive comments were received regarding this
>> provision and no changes were made in the final rule.
>>
>> <end quote>
>>
>> http://www.access-board.gov/sec508/preamble.htm
>>

From: Peter Korn
Date: Fri, Oct 26 2007 4:40 PM
Subject: Re: AT and IT interoperability - the regime we are operating under today

Hi Randy,

I'm sorry, I just don't read this text the way you appear to be reading it.

> The problem is the statement issued by the Access Board is ambiguous.
> The single sentence quoted by Peter appears to suggest that an IT
> manufacturer doesn't need to be aware of the "AT universe".

The sentence is: "Manufacturers do not need to be aware of the universe
of assistive technology products on the market.". There is no "appears
to suggest" in this sentence. It is quite explicit.

> However, if you read the entire paragraph, the last sentence seems to
> suggest the opposite: that "there are numerous resources available to
> manufacturers to assist them in identifying specific types of
> assistive technology which would be used with their product".
> Clearly, that sentence indicates some level of responsibility for the
> manufacturer to get educated about what AT exists for their
> product(s). So, I don't agree with Peter that it is clear what is
> meant - especially when considering the entire directive.

Sorry, again I just disagree. When the government tells me as a citizen
that there are numerous tax preparers who can assist me fill out my
taxes, they aren't placing a responsibility on me to use them, to get
educated about them, or to do anything with them. You are making a
significant logic leap from a non-normative preamble to a responsibility
placed on manufacturers - especially in a document that regulates
agencies and NOT E&IT manufacturers.

> Bruce - I feel the directive issued by the Access Board contains
> statements that can be viewed as conflicting, and is part of what has
> led to the lack of consensus on this point.

Randy - separate from any interpretations of Access Board writings on
this matter - I'd like to know what *your* opinion is on this matter.
You have made it mostly pretty clear that you don't feel 508 should
require anything of acquired AT (please speak up if I have this wrong).
Do you feel that 508 should require agencies to only purchase E&IT that
has been guaranteed by the E&IT vendor to work AT? (with one AT
product? one per category? all AT? what?).


Regards,

Peter Korn
Accessibility Architect,
Sun Microsystems, Inc.

>
> Randy Marsden
> ATIA
>
>
>
> On Oct 26, 2007, at 1:56 PM, Peter Korn wrote:
>
>> Hi Bruce,
>>
>> Thank you very much for this clarification. From this, it seems clear
>> that the regime we are operating under today (as set by the Access Board
>> in the quote Bruce provided to us) is that E&IT manufacturers are not
>> expected to "be aware of the universe of AT", and that by supporting the
>> specific provisions in 1194.21 relating to any given AT, E&IT vendors
>> are understood to be satisfying the functional performance criteria.
>>
>> Therefore, any and all work we do - in specifying the rich set of
>> information E&IT must provide to AT as we have done in 3-U, and in
>> setting forth platform requirements as we have done in 3-V and elsewhere
>> - is an improvement over the current regime and in no way a step
>> backward from what the Access Board expected would be the case.
>>
>>
>> Certainly this still leaves open the question of whether our drafts "go
>> far enough"; but I believe it closes the question of whether our drafts
>> "go backward" in any way. They do not.
>>
>>
>> Regards,
>>
>> Peter Korn
>> Accessibility Architect,
>> Sun Microsystems, Inc.
>>
>>> Responding to Peter's question posted to list:
>>> http://teitac.org/mailarchives/mail_message.php?id=7381&listid=1
>>> <http://teitac.org/mailarchives/mail_message.php?id=7381&listid=1>
>>>
>>> The Access Board is eager for TEITAC to advise on this concern. If
>>> there is not a single consensus position, multiple recommendations
>>> are welcomed. The Access Board has already addressed this issue as
>>> best we can in the preamble to the 508 rulemaking:
>>>
>>> <begin quote>
>>>
>>> Comment. The ITIC requested clarification as to how a manufacturer
>>> would determine the type and number of assistive technology devices
>>> for which support must be provided by a product.
>>>
>>> Response. Manufacturers do not need to be aware of the universe of
>>> assistive technology products on the market. Each provision
>>> specifies the type of assistive technology that must be supported.
>>> For example, §1194.31(a) addresses those assistive technology
>>> devices which provide output to persons who cannot see the screen.
>>> Such devices may include screen readers, Braille displays and speech
>>> synthesizers. There are numerous resources available to
>>> manufacturers to assist them in identifying specific types of
>>> assistive technology which would be used to access their product.
>>>
>>> Paragraph (a) provides that at least one mode of operation and
>>> information retrieval that does not require user vision shall be
>>> provided, or support for assistive technology used by people who are
>>> blind or visually impaired shall be provided. It is not expected
>>> that every software program will be self-voicing or have its own
>>> built-in screen reader. Software that complies with §1194.21 would
>>> also satisfy this provision. (See §1194.27(a) in the NPRM.) No
>>> substantive comments were received regarding this provision and no
>>> changes were made in the final rule.
>>>
>>> <end quote>
>>>
>>> http://www.access-board.gov/sec508/preamble.htm
>>>

From: Randy Marsden
Date: Fri, Oct 26 2007 11:15 PM
Subject: Re: AT and IT interoperability - the regime we are operating under today

Peter:

I see both sides of the problem and, like you and everyone else, am
trying to find a workable compromise.

The point of my post was that some (me included) find the Access
Board's preamble confusing.

-Randy
ATIA


On Oct 26, 2007, at 4:35 PM, Peter Korn wrote:

> Hi Randy,
>
> I'm sorry, I just don't read this text the way you appear to be
> reading it.
>
>> The problem is the statement issued by the Access Board is ambiguous.
>> The single sentence quoted by Peter appears to suggest that an IT
>> manufacturer doesn't need to be aware of the "AT universe".
>
> The sentence is: "Manufacturers do not need to be aware of the
> universe
> of assistive technology products on the market.". There is no
> "appears
> to suggest" in this sentence. It is quite explicit.
>
>> However, if you read the entire paragraph, the last sentence seems to
>> suggest the opposite: that "there are numerous resources
>> available to
>> manufacturers to assist them in identifying specific types of
>> assistive technology which would be used with their product".
>> Clearly, that sentence indicates some level of responsibility for the
>> manufacturer to get educated about what AT exists for their
>> product(s). So, I don't agree with Peter that it is clear what is
>> meant - especially when considering the entire directive.
>
> Sorry, again I just disagree. When the government tells me as a
> citizen
> that there are numerous tax preparers who can assist me fill out my
> taxes, they aren't placing a responsibility on me to use them, to get
> educated about them, or to do anything with them. You are making a
> significant logic leap from a non-normative preamble to a
> responsibility
> placed on manufacturers - especially in a document that regulates
> agencies and NOT E&IT manufacturers.
>
>> Bruce - I feel the directive issued by the Access Board contains
>> statements that can be viewed as conflicting, and is part of what has
>> led to the lack of consensus on this point.
>
> Randy - separate from any interpretations of Access Board writings on
> this matter - I'd like to know what *your* opinion is on this matter.
> You have made it mostly pretty clear that you don't feel 508 should
> require anything of acquired AT (please speak up if I have this
> wrong).
> Do you feel that 508 should require agencies to only purchase E&IT
> that
> has been guaranteed by the E&IT vendor to work AT? (with one AT
> product? one per category? all AT? what?).
>
>
> Regards,
>
> Peter Korn
> Accessibility Architect,
> Sun Microsystems, Inc.
>
>>
>> Randy Marsden
>> ATIA
>>
>>
>>
>> On Oct 26, 2007, at 1:56 PM, Peter Korn wrote:
>>
>>> Hi Bruce,
>>>
>>> Thank you very much for this clarification. From this, it seems
>>> clear
>>> that the regime we are operating under today (as set by the
>>> Access Board
>>> in the quote Bruce provided to us) is that E&IT manufacturers are
>>> not
>>> expected to "be aware of the universe of AT", and that by
>>> supporting the
>>> specific provisions in 1194.21 relating to any given AT, E&IT
>>> vendors
>>> are understood to be satisfying the functional performance criteria.
>>>
>>> Therefore, any and all work we do - in specifying the rich set of
>>> information E&IT must provide to AT as we have done in 3-U, and in
>>> setting forth platform requirements as we have done in 3-V and
>>> elsewhere
>>> - is an improvement over the current regime and in no way a step
>>> backward from what the Access Board expected would be the case.
>>>
>>>
>>> Certainly this still leaves open the question of whether our
>>> drafts "go
>>> far enough"; but I believe it closes the question of whether our
>>> drafts
>>> "go backward" in any way. They do not.
>>>
>>>
>>> Regards,
>>>
>>> Peter Korn
>>> Accessibility Architect,
>>> Sun Microsystems, Inc.
>>>
>>>> Responding to Peter's question posted to list:
>>>> http://teitac.org/mailarchives/mail_message.php?id=7381&listid=1
>>>> <http://teitac.org/mailarchives/mail_message.php?id=7381&listid=1>
>>>>
>>>> The Access Board is eager for TEITAC to advise on this concern. If
>>>> there is not a single consensus position, multiple recommendations
>>>> are welcomed. The Access Board has already addressed this issue as
>>>> best we can in the preamble to the 508 rulemaking:
>>>>
>>>> <begin quote>
>>>>
>>>> Comment. The ITIC requested clarification as to how a manufacturer
>>>> would determine the type and number of assistive technology devices
>>>> for which support must be provided by a product.
>>>>
>>>> Response. Manufacturers do not need to be aware of the universe of
>>>> assistive technology products on the market. Each provision
>>>> specifies the type of assistive technology that must be supported.
>>>> For example, §1194.31(a) addresses those assistive technology
>>>> devices which provide output to persons who cannot see the screen.
>>>> Such devices may include screen readers, Braille displays and
>>>> speech
>>>> synthesizers. There are numerous resources available to
>>>> manufacturers to assist them in identifying specific types of
>>>> assistive technology which would be used to access their product.
>>>>
>>>> Paragraph (a) provides that at least one mode of operation and
>>>> information retrieval that does not require user vision shall be
>>>> provided, or support for assistive technology used by people who
>>>> are
>>>> blind or visually impaired shall be provided. It is not expected
>>>> that every software program will be self-voicing or have its own
>>>> built-in screen reader. Software that complies with §1194.21 would
>>>> also satisfy this provision. (See §1194.27(a) in the NPRM.) No
>>>> substantive comments were received regarding this provision and no
>>>> changes were made in the final rule.
>>>>
>>>> <end quote>
>>>>
>>>> http://www.access-board.gov/sec508/preamble.htm
>>>>

From: Peter Korn
Date: Sat, Oct 27 2007 12:20 AM
Subject: Re: AT and IT interoperability - the regime we are operating under today

Hi Randy, everyone,

So, we have the problem (three positions and it appears we can't have
all three - all attempts so far have failed to reach consensus anyway),
and we have the question of the regime we are operating under now. The
latter is the less interesting of the two, but a valid question given
the argument that we are either (a) loosing something we had, or (b)
unreservedly improving on what we had before.

Since the preamble language that Bruce pointed us to that seems clear to
me is apparently not clear to all, I would therefore I'd like to
reiterate my question:

Is anyone aware of any Federal Agency that reads the current FPC as
meaning that the 508 requires E&IT be either self accessible or
accessible via specific AT? Is anyone aware of any vendor of E&IT who
reads the current FPC that way? Has there been any Federal government
employee who has made a complaint based on that reading and if so, was
the complaint sustained? If the answer is "yes" to any of these, could
you cite them please?


Regards,

Peter Korn
Accessibility Architect,
Sun Microsystems, Inc.

>
> I see both sides of the problem and, like you and everyone else, am
> trying to find a workable compromise.
>
> The point of my post was that some (me included) find the Access
> Board's preamble confusing.
>
> -Randy
> ATIA
>
>
> On Oct 26, 2007, at 4:35 PM, Peter Korn wrote:
>
>> Hi Randy,
>>
>> I'm sorry, I just don't read this text the way you appear to be
>> reading it.
>>
>>> The problem is the statement issued by the Access Board is ambiguous.
>>> The single sentence quoted by Peter appears to suggest that an IT
>>> manufacturer doesn't need to be aware of the "AT universe".
>>
>> The sentence is: "Manufacturers do not need to be aware of the universe
>> of assistive technology products on the market.". There is no "appears
>> to suggest" in this sentence. It is quite explicit.
>>
>>> However, if you read the entire paragraph, the last sentence seems to
>>> suggest the opposite: that "there are numerous resources available to
>>> manufacturers to assist them in identifying specific types of
>>> assistive technology which would be used with their product".
>>> Clearly, that sentence indicates some level of responsibility for the
>>> manufacturer to get educated about what AT exists for their
>>> product(s). So, I don't agree with Peter that it is clear what is
>>> meant - especially when considering the entire directive.
>>
>> Sorry, again I just disagree. When the government tells me as a citizen
>> that there are numerous tax preparers who can assist me fill out my
>> taxes, they aren't placing a responsibility on me to use them, to get
>> educated about them, or to do anything with them. You are making a
>> significant logic leap from a non-normative preamble to a responsibility
>> placed on manufacturers - especially in a document that regulates
>> agencies and NOT E&IT manufacturers.
>>
>>> Bruce - I feel the directive issued by the Access Board contains
>>> statements that can be viewed as conflicting, and is part of what has
>>> led to the lack of consensus on this point.
>>
>> Randy - separate from any interpretations of Access Board writings on
>> this matter - I'd like to know what *your* opinion is on this matter.
>> You have made it mostly pretty clear that you don't feel 508 should
>> require anything of acquired AT (please speak up if I have this wrong).
>> Do you feel that 508 should require agencies to only purchase E&IT that
>> has been guaranteed by the E&IT vendor to work AT? (with one AT
>> product? one per category? all AT? what?).
>>
>>
>> Regards,
>>
>> Peter Korn
>> Accessibility Architect,
>> Sun Microsystems, Inc.
>>
>>>
>>> Randy Marsden
>>> ATIA
>>>
>>>
>>>
>>> On Oct 26, 2007, at 1:56 PM, Peter Korn wrote:
>>>
>>>> Hi Bruce,
>>>>
>>>> Thank you very much for this clarification. From this, it seems clear
>>>> that the regime we are operating under today (as set by the Access
>>>> Board
>>>> in the quote Bruce provided to us) is that E&IT manufacturers are not
>>>> expected to "be aware of the universe of AT", and that by
>>>> supporting the
>>>> specific provisions in 1194.21 relating to any given AT, E&IT vendors
>>>> are understood to be satisfying the functional performance criteria.
>>>>
>>>> Therefore, any and all work we do - in specifying the rich set of
>>>> information E&IT must provide to AT as we have done in 3-U, and in
>>>> setting forth platform requirements as we have done in 3-V and
>>>> elsewhere
>>>> - is an improvement over the current regime and in no way a step
>>>> backward from what the Access Board expected would be the case.
>>>>
>>>>
>>>> Certainly this still leaves open the question of whether our drafts
>>>> "go
>>>> far enough"; but I believe it closes the question of whether our
>>>> drafts
>>>> "go backward" in any way. They do not.
>>>>
>>>>
>>>> Regards,
>>>>
>>>> Peter Korn
>>>> Accessibility Architect,
>>>> Sun Microsystems, Inc.
>>>>
>>>>> Responding to Peter's question posted to list:
>>>>> http://teitac.org/mailarchives/mail_message.php?id=7381&listid=1
>>>>> <http://teitac.org/mailarchives/mail_message.php?id=7381&listid=1>
>>>>> <http://teitac.org/mailarchives/mail_message.php?id=7381&listid=1
>>>>> <http://teitac.org/mailarchives/mail_message.php?id=7381&listid=1>>
>>>>>
>>>>> The Access Board is eager for TEITAC to advise on this concern. If
>>>>> there is not a single consensus position, multiple recommendations
>>>>> are welcomed. The Access Board has already addressed this issue as
>>>>> best we can in the preamble to the 508 rulemaking:
>>>>>
>>>>> <begin quote>
>>>>>
>>>>> Comment. The ITIC requested clarification as to how a manufacturer
>>>>> would determine the type and number of assistive technology devices
>>>>> for which support must be provided by a product.
>>>>>
>>>>> Response. Manufacturers do not need to be aware of the universe of
>>>>> assistive technology products on the market. Each provision
>>>>> specifies the type of assistive technology that must be supported.
>>>>> For example, §1194.31(a) addresses those assistive technology
>>>>> devices which provide output to persons who cannot see the screen.
>>>>> Such devices may include screen readers, Braille displays and speech
>>>>> synthesizers. There are numerous resources available to
>>>>> manufacturers to assist them in identifying specific types of
>>>>> assistive technology which would be used to access their product.
>>>>>
>>>>> Paragraph (a) provides that at least one mode of operation and
>>>>> information retrieval that does not require user vision shall be
>>>>> provided, or support for assistive technology used by people who are
>>>>> blind or visually impaired shall be provided. It is not expected
>>>>> that every software program will be self-voicing or have its own
>>>>> built-in screen reader. Software that complies with §1194.21 would
>>>>> also satisfy this provision. (See §1194.27(a) in the NPRM.) No
>>>>> substantive comments were received regarding this provision and no
>>>>> changes were made in the final rule.
>>>>>
>>>>> <end quote>
>>>>>
>>>>> http://www.access-board.gov/sec508/preamble.htm
>>>>>

From: Gregg Vanderheiden
Date: Sat, Oct 27 2007 4:10 PM
Subject: Re: AT and IT interoperability - the regime we areoperating under today

Hi Peter,

You asked :
> Gregg - are you aware of any Federal Agency that reads the
> current passage as meaning that the 508 requires E&IT be
> either self accessible or accessible via specific AT?


The answer is no. But no one has implied that 508 does or should require
access to specific AT - so I'm not sure where the question comes from.


Please look at
<http://teitac.org/wiki/Monday_10-15-2007_General_telecon#Minutes_for_Monday
_10-15-2007_General_telecon>

Particularly the compromise position (Position #2) and the proposed
solution. This specifies that the 508 regs would NOT specify any specific
AT. Agencies might - as they do now. But the 508 standard would be moot on
this.
This is what the group came up with to discuss.


To better understand what you're asking for:

In your opinion, should a product that is not directly usable by people with
disabilities, meet the 508 requirements if there is no AT for it (but it
does provide an API)?


Thanks



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



> -----Original Message-----
> From: = EMAIL ADDRESS REMOVED =
> [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf
> Of Peter Korn
> Sent: Tuesday, October 23, 2007 8:28 PM
> To: TEITAC Committee
> Subject: [teitac-committee] AT and IT interoperability - the
> regime we areoperating under today
>
> Hi Gregg,
>
> In the plenary con-call earlier today, and also in e-mail
> discussions elsewhere, you said that a number of folks
> believe(d) that the current language in the current
> Functional Performance Criteria - specifically the phrase in
> §1194.31(a), (b), (c), and (e) "... or support for assistive
> technology used by people with disabilities shall be provided"
> - means that E&IT is actually demonstrated to work with some
> specific (though undefined) AT.
>
> Meanwhile, I and others have always read this language to
> mean other than that - to mean that EI&T has provided all it
> could to enable AT to work with it.
>
> However, I think my reading (and yours) is perhaps the least
> interesting question. Rather, what I think is interesting is
> how this passage has been read by folks implementing 508.
>
> Gregg - are you aware of any Federal Agency that reads the
> current passage as meaning that the 508 requires E&IT be
> either self accessible or accessible via specific AT? Are
> you aware of any vendor of E&IT who reads the current passage
> that way? Has there been any Federal government employee who
> has made a complaint based on that reading and if so, was the
> complaint sustained? If the answer is "yes" to any of these,
> could you cite them please?
>
> Separately, if anyone from the Access Board is following this
> discussion, I'd be very curious whether they have a formal
> interpretation/reading of that phrase in the Functional
> Performance Criteria.
>
> Because if in practice the regime we are all using is that
> "...support for assistive technology use by people with
> disabilities shall be provided" means E&IT must provide the
> information needed (and not guarantee a specific level of
> interoperability with specific AT), then what we have today
> in our draft is a clear and unambiguous improvement (whether
> or not we all agree on the sufficiency of said improvement).
> On the other hand, if the regime we are operating under today
> is that it means E&IT must in fact have some demonstrated
> interoperability, then Gregg's claim that language that
> doesn't specify interoperability would in fact be less than
> what we have now would be sustained.
>
>
> Regards,
>
> Peter Korn
> Accessibility Architect,
> Sun Microsystems, Inc.
>

From: Hoffman, Allen
Date: Mon, Oct 29 2007 6:40 AM
Subject: Re: AT and IT interoperability - the regime we areoperating under today

Just as an FYI:

When Federal agencies need to require compatibility with specific AT, for example when an AT is "the" solution in place for a large group of employees, or as a delivery mechanism for public facing EIT, it should be included as a business requirement in the solicitation. When generalized nonspecific compatibility is required, good practice would be to enumerate any items the agency would like to get specific information on to better select from responders. So, to make this work for all, purchasers need information on compatibility, and information of that type backed up with specifics is best. For the vendors of IT, providing such information is key to success, or it should be. So, basically the standards should indicate that access is provided for people with disabilities. through integrated AT or 3rd party AT is only the technique portion of how it is accomplished, unless specific agency business requirements come in to play. I think this is generally how most Federal agencies apply and interpret Section 508 currently. FPC(s) for the form, "access must be provided for people with X disabilities; via integrated AT functionality, or 3rd party AT, encapsulate this approach well. Maybe we need to develop "quickly" the language recommending that better At compatibility representation methods should be developed as part of the next Access-Board and FAR phase in order to improve the visibility for purchasers of this often confusing portion of vendor representations of compliance.








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

-----Original Message-----
From: = EMAIL ADDRESS REMOVED = [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Gregg Vanderheiden
Sent: Saturday, October 27, 2007 6:06 PM
To: 'TEITAC Committee'
Subject: Re: [teitac-committee] AT and IT interoperability - the regime we areoperating under today

Hi Peter,

You asked :
> Gregg - are you aware of any Federal Agency that reads the current
> passage as meaning that the 508 requires E&IT be either self
> accessible or accessible via specific AT?


The answer is no. But no one has implied that 508 does or should require access to specific AT - so I'm not sure where the question comes from.


Please look at
<http://teitac.org/wiki/Monday_10-15-2007_General_telecon#Minutes_for_Monday
_10-15-2007_General_telecon>

Particularly the compromise position (Position #2) and the proposed solution. This specifies that the 508 regs would NOT specify any specific AT. Agencies might - as they do now. But the 508 standard would be moot on this.
This is what the group came up with to discuss.


To better understand what you're asking for:

In your opinion, should a product that is not directly usable by people with disabilities, meet the 508 requirements if there is no AT for it (but it does provide an API)?


Thanks



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



> -----Original Message-----
> From: = EMAIL ADDRESS REMOVED =
> [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Peter
> Korn
> Sent: Tuesday, October 23, 2007 8:28 PM
> To: TEITAC Committee
> Subject: [teitac-committee] AT and IT interoperability - the regime we
> areoperating under today
>
> Hi Gregg,
>
> In the plenary con-call earlier today, and also in e-mail discussions
> elsewhere, you said that a number of folks
> believe(d) that the current language in the current Functional
> Performance Criteria - specifically the phrase in §1194.31(a), (b),
> (c), and (e) "... or support for assistive technology used by people
> with disabilities shall be provided"
> - means that E&IT is actually demonstrated to work with some specific
> (though undefined) AT.
>
> Meanwhile, I and others have always read this language to mean other
> than that - to mean that EI&T has provided all it could to enable AT
> to work with it.
>
> However, I think my reading (and yours) is perhaps the least
> interesting question. Rather, what I think is interesting is how this
> passage has been read by folks implementing 508.
>
> Gregg - are you aware of any Federal Agency that reads the current
> passage as meaning that the 508 requires E&IT be either self
> accessible or accessible via specific AT? Are you aware of any vendor
> of E&IT who reads the current passage that way? Has there been any
> Federal government employee who has made a complaint based on that
> reading and if so, was the complaint sustained? If the answer is
> "yes" to any of these, could you cite them please?
>
> Separately, if anyone from the Access Board is following this
> discussion, I'd be very curious whether they have a formal
> interpretation/reading of that phrase in the Functional Performance
> Criteria.
>
> Because if in practice the regime we are all using is that "...support
> for assistive technology use by people with disabilities shall be
> provided" means E&IT must provide the information needed (and not
> guarantee a specific level of interoperability with specific AT), then
> what we have today in our draft is a clear and unambiguous improvement
> (whether or not we all agree on the sufficiency of said improvement).
> On the other hand, if the regime we are operating under today is that
> it means E&IT must in fact have some demonstrated interoperability,
> then Gregg's claim that language that doesn't specify interoperability
> would in fact be less than what we have now would be sustained.
>
>
> Regards,
>
> Peter Korn
> Accessibility Architect,
> Sun Microsystems, Inc.
>

From: Peter Korn
Date: Tue, Oct 30 2007 12:05 AM
Subject: Re: AT and IT interoperability - the regime we areoperating under today

Hi Gregg,

> Hi Peter,
>
> You asked :
>
>> Gregg - are you aware of any Federal Agency that reads the
>> current passage as meaning that the 508 requires E&IT be
>> either self accessible or accessible via specific AT?
>>
>
>
> The answer is no. But no one has implied that 508 does or should require
> access to specific AT - so I'm not sure where the question comes from.
>

Thanks.

A follow-up/clarification question: "Are you aware of any Federal Agency
that reads the current FPC as meaning that 508 requires E&IT to be
either self-accessible or accessible via some actual AT somewhere?"
This is really the question I was trying to ask (that there is some
actual, specific, AT somewhere that the E&IT works with; not that it be
a particular AT product - to me "specific" meant "actual": one you can
point to and say "that one").

As I mentioned earlier in this thread, this question is an attempt to
establish a common understanding of what the current practice is (so we
can understand whether any new proposal we make in TEITAC goes
unambiguously beyond that current practice, or is a step backwards from
it). Such a common understanding (if we can find it) may help inform a
consensus around what we recommend going forward.


> Please look at
> <http://teitac.org/wiki/Monday_10-15-2007_General_telecon#Minutes_for_Monday
> _10-15-2007_General_telecon>
>
> Particularly the compromise position (Position #2) and the proposed
> solution. This specifies that the 508 regs would NOT specify any specific
> AT. Agencies might - as they do now. But the 508 standard would be moot on
> this.
> This is what the group came up with to discuss.
>

Position #2's first bullet is the question we have been discussing -
what does the current 508 require. I'm sorry I missed that meeting; can
you tell me whether the group was putting forth this bullet as the
consensus belief of the committee, or instead also as a point for
discussion?

Given the current FPC in the 26Oct draft, for "actual AT", I read
position #2 as requiring:
1. an actual screen reader must exist on the platform that the mE&IT
worked with at one point (or the E&IT is self-voicing) [provision 1.1-A]
2. an actual screen magnifier must exist on the platform that the E&IT
worked with at one point (or the E&IT must optionally render a user
interface that requires not more than 20/70 vision to use) [provision 1.1-B]
3. some kind of actual auditory AT (do we have an example of one of
these?) must exist on the platform that the E&IT worked with at one
point (or the E&IT must work without needing hearing) [provision 1.1-D]
4. some kind of actual auditory AT (do we have an example of one of
these?) must exist on the platform that the E&IT worked with at one
point (or the E&IT must work with undefined "enhanced audio") [provision
1.1-E]
5. some kind of actual speech input alternative AT (do we have an
example of one of these? - wouldn't a keyboard qualify?) must exist on
the platform that the E&IT worked with at one point (or the E&IT must
work without needing user speech) [provision 1.1-F]
6. at least one of the following actual AT must exist on the platform
that the E&IT worked with at one point: [either voice recognition with
control & dictation, or on-screen keyboard with switch input, or
on-screen keyboard with head/eye tracking], (or the E&IT must work
without needing much [but not defined] in the way of reach & strength,
and without requiring simultaneous actions) [provision 1.1-G]
7. at least one of the following actual AT must exist on the platform
that the E&IT worked with at one point: [either voice recognition with
control & dictation, or on-screen keyboard with head/eye tracking], (or
the E&IT must work without needing the user to physically touch the
device beyond initial connection & setup) [provision 1.1-H] - note: this
means that a device that included and relied on a switch interface or
touch-screen like the EZ-Access prototype accessible kiosk would not
meet this criteria
8. potentially some kind of actual cognitive AT (do we have an example
of one of these? what would this look like as a platform-wide AT?) must
exist on the platform that the E&IT worked with at one point (or the
E&IT must work in some fashion that accommodates [some/most/all] of the
needs of people with cognitive and/or language and/or learning
limitations) [provision 1.1-I]

So this suggests that a platform ought to have available for it or built
into it:
a. a screen reader,
b. a screen magnifier,
c. an unknown (to me) kind of auditory AT application,
d. an unknown (to me) kind of speech-input alternative AT (wouldn't a
keyboard qualify?),
e. one of either voice recognition or head/eye tracker [switch
interface is OK if 3rd party AT but cannot be built-in because it cannot
be part of the E&IT procurement and still meet the no-touch FPC language],
f. an unknown (to me) kind of cognitive/language/learning limitation AT

For c, d, and f, it may be that I'm simply not aware of all that the AT
world has to offer. What AT would we use for these? Is there, in fact,
a desktop platform that has all such actual AT that an E&IT vendor could
potentially work with? If not, how can any E&IT product meet such a set
of FPC with the "works with actual AT" provision, unless that FPC were
stated as a set of goals and not specific requirements that must be met
for a fully compliant procurement?

> To better understand what you're asking for:
>
> In your opinion, should a product that is not directly usable by people with
> disabilities, meet the 508 requirements if there is no AT for it (but it
> does provide an API)?
>

First, I need to re-state the question, because 508 is procurement
regulation. I suggest that a more germane question is: "Should
procurement of product that both: (a) never worked with a class of AT
(but provides everything that AT theoretically needs), and (b) is not
self-accessible for the set of users needing that AT, be recognized as a
procurement that fully meets 508?" [I also modified it to take into
account portions of position #2]

Gregg, I don't know. I don't have a simple opinion on this.

First off, I think I understand things fairly well with it comes to
screen readers & screen magnifiers; I'm on familiar ground there.
Likewise, I think I have a pretty good understanding of what to do to
avoid needing hearing, so even though I don't know what AT there is for
that area [voice recognition of the text coming out of the speaker that
gets show in real-time in a window on the screen?], I think I understand
how to avoid needing that kind of AT. Further, I know about on-screen
keyboards and voice control & dictation. But we haven't settled what we
will do around cognitive disabilities, and I have a real problem saying
that no E&IT procurement can be considered as fully meeting 508 without
the existence of unknown and undefined AT.

A more general and key issues for me is, we haven't defined what "works
with AT" means (has "AT for it" to use your language). There are lots
of Windows products that ZoomText magnifies very nicely; but there are
only a few for which ZoomText has implemented "DocReader" functionality
(but many more for which is theoretically could as they display
"documents"). For an E&IT product that ZoomText never implemented
DocReader support for, should we say that it "never worked with AT"
(assume further that ZoomText is the only magnifier that works with it),
and therefore should we say that procurement of that that E&IT product
fails to fully meet 508? How about an E&IT product for Windows for
which JAWS has never read some dialog boxes (and for which Supernova has
never read a different portion of the GUI but does work with those
dialog boxes)? Should procurement of that E&IT product be said to fail
to fully meet 508? How about an E&IT product in which speech dictation
worked for text entry, but to control the GUI you had to go to either
use more verbose voice commands (to insert keystrokes to active menu
items) or build a bunch of voice macros; and further for which some of
the advanced editing dictation commands were never implemented? Should
procurement of that E&IT product be said to fail to fully meet 508?

These are not abstract, theoretical thought-experiments - they are drawn
from specific product experiences I have had in my career. Every time
we discuss the general question of working with AT as a litmus test for
a fully confirming procurement, I apply the proposed language to these
various scenarios (and others) I outlined in the paragraph above. Every
proposal I've seen so far that explicitly includes the use of AT in that
litmus test has run into problems with the scenarios above for me, which
is why I haven't been able to support them.


My opinion: I would *like* to see language such that a procurement that
fully meets 508 would be accessible to people belonging to at least a
broad collection of groups of understood disabilities and disability
needs. But the way that we make things not only minimally accessible -
but fundamentally efficient and productive - is through the use of this
adjunct AT product that E&IT vendors generally don't control, and which
are typically acquired in a different procurement. Therefore we are
breaking up the procurement into two different pieces (either one of
which may occur first), and only when a "correct" pair of procurements
is made can the result realized - and yet we are having to grade one
procurement in the absence of the other (and the other doesn't get
graded at all). And therefore, I don't see a way to fully realize this
desire/opinion in the procurement regulation that is enabled by the
Section 508 legislation.

And this leads back to my fundamental issue with much of the discussion
around the FPC.


I do not think we can realize the perfection of language under which a
fully compliant E&IT procurement is guaranteed to work with AT the
agency either has or can acquire. I think we can and have done a lot to
increase the likelihood of that happening, and reduce the instances
where this result fails. I would like us to move forward with (and
perhaps polish further) the "good" that we have put together in our
technical provisions, and not let "perfection" be its enemy and the
perpetual load stone of our discussion and energy.


Regards,

Peter Korn
Accessibility Architect,
Sun Microsystems, Inc.


>
> Thanks
>
>
>
> Gregg
> -- ------------------------------
> Gregg C Vanderheiden Ph.D.
>
>
>
>
>> -----Original Message-----
>> From: = EMAIL ADDRESS REMOVED =
>> [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf
>> Of Peter Korn
>> Sent: Tuesday, October 23, 2007 8:28 PM
>> To: TEITAC Committee
>> Subject: [teitac-committee] AT and IT interoperability - the
>> regime we areoperating under today
>>
>> Hi Gregg,
>>
>> In the plenary con-call earlier today, and also in e-mail
>> discussions elsewhere, you said that a number of folks
>> believe(d) that the current language in the current
>> Functional Performance Criteria - specifically the phrase in
>> §1194.31(a), (b), (c), and (e) "... or support for assistive
>> technology used by people with disabilities shall be provided"
>> - means that E&IT is actually demonstrated to work with some
>> specific (though undefined) AT.
>>
>> Meanwhile, I and others have always read this language to
>> mean other than that - to mean that EI&T has provided all it
>> could to enable AT to work with it.
>>
>> However, I think my reading (and yours) is perhaps the least
>> interesting question. Rather, what I think is interesting is
>> how this passage has been read by folks implementing 508.
>>
>> Gregg - are you aware of any Federal Agency that reads the
>> current passage as meaning that the 508 requires E&IT be
>> either self accessible or accessible via specific AT? Are
>> you aware of any vendor of E&IT who reads the current passage
>> that way? Has there been any Federal government employee who
>> has made a complaint based on that reading and if so, was the
>> complaint sustained? If the answer is "yes" to any of these,
>> could you cite them please?
>>
>> Separately, if anyone from the Access Board is following this
>> discussion, I'd be very curious whether they have a formal
>> interpretation/reading of that phrase in the Functional
>> Performance Criteria.
>>
>> Because if in practice the regime we are all using is that
>> "...support for assistive technology use by people with
>> disabilities shall be provided" means E&IT must provide the
>> information needed (and not guarantee a specific level of
>> interoperability with specific AT), then what we have today
>> in our draft is a clear and unambiguous improvement (whether
>> or not we all agree on the sufficiency of said improvement).
>> On the other hand, if the regime we are operating under today
>> is that it means E&IT must in fact have some demonstrated
>> interoperability, then Gregg's claim that language that
>> doesn't specify interoperability would in fact be less than
>> what we have now would be sustained.
>>
>>
>> Regards,
>>
>> Peter Korn
>> Accessibility Architect,
>> Sun Microsystems, Inc.
>>