Thread Subject: Re: Best Meets vs. Full UseinFunctional PerformanceCriteria

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From: Gregg Vanderheiden
Date: Tue, May 01 2007 5:45 PM
Subject: Re: Best Meets vs. Full UseinFunctional PerformanceCriteria

Best meets though is what we have all been looking at. That is - if you
can't meet all of the provisions - which product best meets them. This
would yield best accessibility which is the function of this standard.

Do I understand Best Value correctly? That it means that accessibility is
just considered another value or thing to consider in purchasing and that it
doesn?t get more weight than other business considerations? If so then I
think that is not the intent of the law. Or does it mean something else?

Thanks


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

> -----Original Message-----
> From: = EMAIL ADDRESS REMOVED = [mailto:teitac-general-
> = EMAIL ADDRESS REMOVED = ] On Behalf Of Deborah Buck
> Sent: Tuesday, May 01, 2007 4:01 PM
> To: Subpart A Workgroup TEITAC; 'TEITAC General Interface Accessibility
> Subcommittee'
> Subject: Re: [teitac-general] [teitac-subparta] Best Meets vs. Full Use
> inFunctional PerformanceCriteria
>
> I think it is still premature to say there is support to using "Best
> Meets". Many are still uncertain what that really means and it appears
> that at the federal level their is inconsistency is how Best Meets is
> viewed and implemented across federal agencies. "Best Meets" is not a
> standard practice at the state level-whereas Best Value is often a
> required practice in many state procurement laws.
> Sent from my Verizon Wireless BlackBerry
>
> -----Original Message-----
> From: = EMAIL ADDRESS REMOVED =
> Date: Tue, 01 May 2007 16:28:52
> To:"'TEITAC General Interface Accessibility Subcommittee'"<teitac-
> = EMAIL ADDRESS REMOVED = >
> Cc:'TEITAC Subpart A Subcommittee' < = EMAIL ADDRESS REMOVED = >
> Subject: [teitac-subparta] Best Meets vs. Full Use in Functional
> Performance
> Criteria
>
> "Best meets" is used by the federal government and some states to
> determine which products to procure to comply with Section 508 (in cases
> where there are no products meeting all applicable standards).  Based on
> proposals from the Subpart A Subcommittee (See
> http://teitac.org/wiki/Subpart_A:Application), there is support for using
> a best meets approach in the next version of the standards.
>
> However, including the term "full use" in the Functional Performance
> Criteria draft language (1194.31 a, b, c, d, e) appears to be in conflict
> with this principal.
> (http://teitac.org/wiki/General_April_survey-report,
> http://teitac.org/wiki/RESULTING_DRAFT)
>
> For any E&IT products not able to meet these criteria 100%, the vendor
> would have to indicate "does not meet" on any 508 documentation, such as
> the VPAT.  Therefore, it may be more difficult for agencies to determine
> which product "best meets" 508 for those product categories where there
> are no products reaching the 100% bar.
>
> The addition of new accessibility features in products would also not be
> encouraged unless they allowed full use of the E&IT.  This is discouraging
> for  manufacturers who have the goal of incorporating new accessibility
> features over time.
>
> "Full use" is a very high bar.  For many large office products, none of
> our users have access to ALL the features.  Some modes can be accessed by
> the manufacturer's/dealer's authorized service engineers only for safety
> purposes.  For these practical reasons, removing the term "full" is
> recommended.  Other alternatives welcome.
>
> Aubrey
>
> Aubrey Woolley
> Government Policy and Compliance Analyst
> Government Marketing Division
> Canon USA, Inc.
> TEL: (703) 807-3158
> = EMAIL ADDRESS REMOVED =
>




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From: terry.weaver@gsa.gov
Date: Wed, May 02 2007 4:00 PM
Subject: Re: Best Meets vs. Full UseinFunctional PerformanceCriteria

I have two suggestions regarding the proposed language:

1194.2 (2) - expand the requirement for documentation beyond procurement -
drop the phrase "when procuring a product". This is a hole in the current
standard since Section 508 compliance is mandatory for more than
procurements.

1194.2 (b) - drop the requirement for 2 or more products - different
agencies have different guidances as to what makes a product commercially
available and this contradicts that agency responsibility. I think this
new paragraph doesn't add anything and is possibly outside the scope of
TEITAC since it seems to want to change long-time FAR practices.

I also don't understand what the three options give us - is this trying to
address a problem for non-Feds? Any effort to cut and paste selected FAR
requirements isn't advisable, the FAR stands as a process in its entirety
and I fear the law of unintended consequences. If getting influence with
the FAR rewrite is the goal, then that is something that should be
achieved by other means. It would be better to include a preamble, I
think, that is addressed to the FAR IT committee (which will not be
convened until the Access Board creates a new proposed rulemaking) that
outlines what is the update.





"Deborah Buck" < = EMAIL ADDRESS REMOVED = >
Sent by: = EMAIL ADDRESS REMOVED =
05/02/2007 10:40 AM
Please respond to
= EMAIL ADDRESS REMOVED = ; Please respond to
"TEITAC Subpart A Subcommittee" < = EMAIL ADDRESS REMOVED = >


To
"Subpart A Workgroup TEITAC" < = EMAIL ADDRESS REMOVED = >, "TEITAC
General" < = EMAIL ADDRESS REMOVED = >
cc

Subject
[teitac-subparta] Fw: [teitac-general] Best Meets vs. Full UseinFunctional
PerformanceCriteria






I meant to send this to the listserv
------Original Message------
To: Greg C. Vanderheiden
Sent: May 1, 2007 7:58 PM
Subject: Re: [teitac-general] [teitac-subparta] Best Meets vs. Full
UseinFunctional PerformanceCriteria

Best Meets is only one of the approaches we have been looking at. Best
meets is what is currently in the standard. It is not implemented
consistently across federal agencies and States do not use this apporach.
There are federal agencies that use a roadmap of sorts to make
determinations and its my understanding that within that framework they
use the concept of Best Value and Best Meets. As someone mentioned earlier
(not the exact words) is it our job to improve the standards. That may
mean we end up recommending a different approach or we may recommend
changes, clearer languauge so the agencies know what Best Meets means and
when to apply it so the result is a more consistent implementation.

------Original Message------
From: Greg C. Vanderheiden
To: Deborah V. Buck
To: 'TEITAC General Interface Accessibility Subcommittee'
To: Subpart A Workgroup TEITAC
Sent: May 1, 2007 7:40 PM
Subject: RE: [teitac-general] [teitac-subparta] Best Meets vs. Full
UseinFunctional PerformanceCriteria

Best meets though is what we have all been looking at. That is - if you
can't meet all of the provisions - which product best meets them. This
would yield best accessibility which is the function of this standard.

Do I understand Best Value correctly? That it means that accessibility
is
just considered another value or thing to consider in purchasing and that
it
doesn’t get more weight than other business considerations? If so then I
think that is not the intent of the law. Or does it mean something
else?

Thanks


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

> -----Original Message-----
> From: = EMAIL ADDRESS REMOVED = [mailto:teitac-general-
> = EMAIL ADDRESS REMOVED = ] On Behalf Of Deborah Buck
> Sent: Tuesday, May 01, 2007 4:01 PM
> To: Subpart A Workgroup TEITAC; 'TEITAC General Interface Accessibility
> Subcommittee'
> Subject: Re: [teitac-general] [teitac-subparta] Best Meets vs. Full Use
> inFunctional PerformanceCriteria
>
> I think it is still premature to say there is support to using "Best
> Meets". Many are still uncertain what that really means and it appears
> that at the federal level their is inconsistency is how Best Meets is
> viewed and implemented across federal agencies. "Best Meets" is not a
> standard practice at the state level-whereas Best Value is often a
> required practice in many state procurement laws.
> Sent from my Verizon Wireless BlackBerry
>
> -----Original Message-----
> From: = EMAIL ADDRESS REMOVED =
> Date: Tue, 01 May 2007 16:28:52
> To:"'TEITAC General Interface Accessibility Subcommittee'"<teitac-
> = EMAIL ADDRESS REMOVED = >
> Cc:'TEITAC Subpart A Subcommittee' < = EMAIL ADDRESS REMOVED = >
> Subject: [teitac-subparta] Best Meets vs. Full Use in Functional
> Performance
> Criteria
>
> "Best meets" is used by the federal government and some states to
> determine which products to procure to comply with Section 508 (in cases
> where there are no products meeting all applicable standards). Based on
> proposals from the Subpart A Subcommittee (See
> http://teitac.org/wiki/Subpart_A:Application), there is support for
using
> a best meets approach in the next version of the standards.
>
> However, including the term "full use" in the Functional Performance
> Criteria draft language (1194.31 a, b, c, d, e) appears to be in
conflict
> with this principal.
> (http://teitac.org/wiki/General_April_survey-report,
> http://teitac.org/wiki/RESULTING_DRAFT)
>
> For any E&IT products not able to meet these criteria 100%, the vendor
> would have to indicate "does not meet" on any 508 documentation, such as
> the VPAT. Therefore, it may be more difficult for agencies to determine
> which product "best meets" 508 for those product categories where there
> are no products reaching the 100% bar.
>
> The addition of new accessibility features in products would also not be
> encouraged unless they allowed full use of the E&IT. This is
discouraging
> for manufacturers who have the goal of incorporating new accessibility
> features over time.
>
> "Full use" is a very high bar. For many large office products, none of
> our users have access to ALL the features. Some modes can be accessed
by
> the manufacturer's/dealer's authorized service engineers only for safety
> purposes. For these practical reasons, removing the term "full" is
> recommended. Other alternatives welcome.
>
> Aubrey
>
> Aubrey Woolley
> Government Policy and Compliance Analyst
> Government Marketing Division
> Canon USA, Inc.
> TEL: (703) 807-3158
> = EMAIL ADDRESS REMOVED =
>