# Presentation: 317627

## Slide 1

## Informal Feedback from Access Board Staff on TEITAC Draft Report

- TEITAC Plenary meeting
- September 4, 2007

## Access Board Staff508 Team

- David Capozzi
- Lisa Fairhall
- Aromie Noe
- Tim Creagan
- Bruce Bailey
- David Baquis

## Feedback based on 2 Questions

- Did TEITAC address the issues raised by the Access Board?
- Does the draft address things outside our scope or address things in a way we think we might not be able to propose?

## Comments based on 3 documents

- Presentation to TEITAC on 9-27-06 by David Capozzi
- Presentation to TEITAC on 9-27-06 by David Baquis
- TEITAC draft version 8-17-07

## Is it covered by 508?

- Agencies frequently encounter the challenge of trying to determine if a product is E&IT and want guidance to help them figure out if a 508 process needs to be kicked-in
- These products may be complex integrated systems and often you cannot determine if it is E&IT by the name alone, so you have to read a technical synopsis (e.g., “Real -Time Polymerase Chain Reaction System”, “Dual Axis Auto Tracking Telemetry Antenna”,  “High Altitude/High Opening Parachutist Navigation System”, “drift detector”, “thermal cycler”, “multichannel transceiver”, “air flow meter”, “liquid chromatograph”, “gas spectrometer”, “particle sizer”, “pressure sensor pump”, “Ball Grid Array/Surface Mounted Device Rework System”)
- Uncertainty about this 508 determination process causes a lot of stress because it is tied to procurement language, testing, paperwork, liability, and personnel hours.

## Scope of Electronic Content

- What does “electronic data and information” actually mean?
- Are e-mails covered?
- Are all documents covered? (Slide shows, spreadsheets, word processed, PDFs, etc.)
- Does it matter if the electronic content is NOT on the web? (e.g., on an office server? A CD, flash drive? Attached to an email? What if it is distributed to only one person?)

## What is E&IT?

- How is “principal function” supposed to be determined?
- More examples would be helpful to illustrate what is covered as well as what is not covered
- How to handle clarifying this definition?
- In the “applications” section?
- In the Preamble?
- In technical assistance (after the final rule)?

## Which requirements apply to a product or service?

- Which of the 100 technical requirements do I use in designing, evaluating, and requesting products? (e.g., which provisions apply to PDAs?)
- When and how to use functional performance criteria?
- Clarify what is meant by “E&IT services” (e.g., Are integration services to be mentioned in a provision?)
- How does 508 apply to GIS and GPS?

## Captioning

- To ensure that a newly purchased system does not inadvertently end up without closed caption decoder circuitry, how will the standards require this support on a system component and integrated system level?
- What is required for PDA multimedia support?
- Should the “pass through” provision apply to the issue of preventing captions from getting stripped out? (Not just to TTY signals)

## Other

- We need a rationale for **ALL** of the recommended changes in the report
- Does the Committee feel that they have addressed VoIP sufficiently enough?
- 2.2-A, Magnetic Coupling, could apply to handsets on kiosks, not just telecom products
- Is there enough guidance, with corresponding technical provisions, to support the new FPC 1.1-H for No Reach or Touch? (See how the TGDC handled it in the draft VVSG v.2)

## Interoperability

- 2.1-E, Standard Connection.
- When a product is deemed 508-conformant because the IT will connect to AT after an adaptor is attached, will the TEITAC provide a recommendation regarding how readily available that adaptor should be, if all products do not have the adaptor already attached?  (e.g., analog to digital adaptor for phone to TTY)
- 8.2-D - Evaluation Support (for authoring tools)
- “...or compatibility with evaluation tools...”
- Do you wish to reframe this as an integration requirement? In other words, for 508-conformance, an evaluation tool must either be built-in or bundled with the authoring tool?
- Prefer to use term “compatibility” only in conjunction with AT

## Terms, Definitions, Advisories

- Some terms do not seem to be in plain language or may need defining (e.g., SIP, system-product, dithered colors, intelligibility)
- Do all definitions map back to a provision? (e.g., non-crisis network traffic)
- Associate dates of release to referenced standards
- Many more advisory notes are indicated. For example, what does “similar functions” mean with regard to the Caller ID provision?  What does other location mean with respect to 1194.3-D Access by Public?

## Economic Impact

- An estimate of economic impact is missing from most of the draft design requirements
- Reminder that a “gross assessment” is acceptable
- i.e., no economic consequences, minor, major
- A rationale for the estimate would be helpful

## Access Board Concern (1)

- Emergency, Field and First Response Use
- The statute provides exemptions
- The law is indifferent as to who is benefiting
- This is contrary to our guidance about the refreshed standards not weakening the requirements that exist today

## Access Board Concern (2)

- Text Size (1.2.-H)
- As written, it is unclear what it refers to.
- If is applies to electronic content, then it may be too limiting.
- Is this intended to apply only to printed labels?

## Access Board Concern (3)

- 7.1-A (Information, Documentation, Support)
- Not likely to include this in a collapsed bundled fashion
- The way it is worded, it could weaken the existing requirement, by allowing the reader to think that it is only about providing alternative formats
- The “must” language should apply to both requirements (provide info on accessibility features, and then separate from that, provide alternative formats)