Thread Subject: Re: Subpart A- Draft -Comparable Access Definition

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From: Jagbell
Date: Fri, Mar 16 2007 3:45 AM
Subject: Re: Subpart A- Draft -Comparable Access Definition

If we use roughly the same efficiency then we need to use examples
with a "such as but not limited to" clause.

Janice
On Mar 16, 2007, at 12:40 AM, Gregg Vanderheiden wrote:

> Thanks
>
>
>
> That explains it.
>
>
>
> Ok
>
>
>
> I had proposed:
>
>
>
> All the same information and function, available at the same
> times of day, in the same locations, at the same costs, with the
> same privacy, with roughly the same efficiency, without needing to
> make special requests or wait.
>
>
>
> But from the bullets below it looks like they would like the
> efficiency bit expanded. Hmmmm How to make that general but more
> quantitative��
>
>
>
> That is a touch problem.
>
>
>
> It will often take a person who is blind many more keystrokes to
> read a page because they control there reading with keystroke while
> sighted persons use eye movements. So saying �comparable number
> of keystrokes� won't work. Even comparable time doesn�t since
> some things will be much slower no matter how well they are
> designed, while other things may be faster.
>
>
>
> I can see why they would like our help on this one.
>
>
>
> Anyone have any ideas besides the �roughly the same efficiency�?
>
>
>
>
> Gregg
> -- ------------------------------
> Gregg C Vanderheiden Ph.D.
>
>
>
>
>
> From: = EMAIL ADDRESS REMOVED = [mailto:teitac-
> = EMAIL ADDRESS REMOVED = ] On Behalf Of Deborah Buck
> Sent: Thursday, March 15, 2007 3:39 PM
> To: 'TEITAC Subpart A Subcommittee'
> Subject: Re: [teitac-subparta] Subpart A- Draft - Comparable Access
> Definition
>
> The term �Comparable to the Access�� appears in the law and the
> standard. My mistake in that the term is comparable- not comparable
> access. Yet the term �comparable� when used in the law and
> standards is tied to access. See excerpt from 508 law below. It
> also appears in the regulations in Subpart A�General § 1194.1 Purpose.
>
>
>
> This was raised as an implementation issue by some of the federal
> 508 coordinators. Here are some bullets identifying the underlying
> issue and request for the workgroup to address.
>
> · Federal agency considers comparable access to fall into
> place with productivity of employees which is evaluated very closely.
>
> · Agency has tried to define the term internally, but has
> bumped up against vendors when trying to procure products in that
> the vendor does not agree with agency interpretation of what is
> considered comparable.
>
> · If employees with disabilities cannot keep up with their
> colleagues, it has significant impact. If it takes 30 keystrokes to
> accomplish a task that requires 1 mouse click, compliance with
> Section 508 applies but the employee may not be competitive. In
> this example- the vendor may promote the product as conforming the
> standards, but the agency does not consider it comparable to the
> access provided other employees that don�t have disabilities
>
> · The basic issue for Subpart A is if there is a comparable
> access clause, it needs to be defined and quantified. If it is not
> be used in any manner, then it should be removed.
>
> · Making comparable access testable can lead to applications
> and products being more usable. We already know that a Section 508
> compliant product may not be usable. The goal should be to help
> people with disabilities use technology in a productive manner.
>
>
>
>
>
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>
> ��SEC. 508. ELECTRONIC AND INFORMATION TECHNOLOGY.
>
> ��(a) REQUIREMENTS FOR FEDERAL DEPARTMENTS AND AGENCIES.�
>
> ��(1) ACCESSIBILITY.�
>
> ��(A) DEVELOPMENT, PROCUREMENT, MAINTENANCE, OR USE OF ELECTRONIC
> AND INFORMATION TECHNOLOGY.�When developing, procuring,
> maintaining, or using electronic and
>
> information technology, each Federal department or agency,
> including the United States Postal Service, shall ensure, unless an
> undue burden would be imposed on the
>
> department or agency, that the electronic and information
> technology allows, regardless of the type of medium of the technology�
>
> ��(i) individuals with disabilities who are Federal employees to
> have access to and use of information and data that is COMPARABLE
> TO THE ACCESS to and use of the information and data by Federal
> employees who are not individuals with disabilities; and
>
> ��(ii) individuals with disabilities who are members of the public
> seeking information or services from a Federal department or agency
> to have access to and use of information and data that is
> COMPARABLE TO THE ACCESS to and use of the information and data by
> such members of the public who are not individuals with disabilities.
>
>
>
>
>
>
>
> -----Original Message-----
> From: = EMAIL ADDRESS REMOVED = [mailto:teitac-
> = EMAIL ADDRESS REMOVED = ] On Behalf Of Gregg Vanderheiden
> Sent: Wednesday, March 14, 2007 9:22 PM
> To: 'TEITAC Subpart A Subcommittee'
> Subject: Re: [teitac-subparta] Subpart A- Draft - Comparable Access
> Definition
>
>
>
> I couldn�t find where this term is used in the standards. Did I
> miss it?
>
> If not � I'm not sure why are we considering defining it in the
> definition section of the standards.
>
>
>
> The only place I could find it was in the release notice pre-amble.
>
>
>
> Not all government policies are based on maximizing economic
> efficiency. Some policies are based on furthering the rights of
> certain classes of individuals to achieve more equitable results,
> regardless of the effect on economic efficiency. Accessibility to
> electronic information and technology is an essential component of
> civil rights for persons with disabilities. The final rule will
> ensure that Federal employees with disabilities will have access to
> electronic and information technology used by the Federal
> government that is comparable to that of Federal employees without
> disabilities; and that members of the public with disabilities will
> have comparable access to information and services provided to
> members of the public without disabilities through the use of
> Federal electronic and information technology
>
>
>
> This doesn�t qualify for defining it in the standard. In all the
> standards groups I am in, terms have to be used in the standard to
> be included in the definition section of a standard.
>
>
>
> Did I miss it somewhere � or is it in someone� s proposed edit to
> the standard?
>
>
>
>
>
> If it is felt that we should be proposing how the preamble should
> be written (and providing a better definition there which is where
> it would have to be � inline ) then I would say something like:
>
>
>
> All the same information and function, available at the same times
> of day, in the same locations, at the same costs, with the same
> privacy, with roughly the same efficiency, without needing to make
> special requests or wait.
>
>
>
> It is an interesting question.
>
>
>
> But this looks out of scope for Part A.
>
>
>
>
>
>
> Gregg
>
> ------------------------
>
> Gregg Vanderheiden
>
>
>
>