**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)