36 CFR Part 1194 - Proposed Information and Communication Technology (ICT) Standards and Guidelines NPRM - Preamble

C101.2 Equivalent Facilitation (Section-by-Section Analysis)

This proposed section addresses when telecommunications equipment manufacturers may use equivalent facilitation, and mirrors a corresponding provision in the proposed 508 Standards (E101.2). While the existing 255 Guidelines do not expressly address equivalent facilitation, the concept of allowing alternative technological solutions for accessibility beyond those specified in the guidelines derives from the Appendix to 36 CFR Part 1193 - Advisory Guidance, Introduction, paragraph 1, which notes that “Manufacturers are free to use these [suggested strategies in the Appendix] or other strategies in addressing the guidelines.” We proposed inclusion of this equivalent facilitation provision in the 2011 ANPRM and received no comments.