Ethin I'm not quoting research I just did. I'm pretty intimately familiar with CVAA already, I don't need to go give the full text yet another read, I've done that enough already over the past five years or so.
You've really got the wrong end of the stick here I'm several ways. Such us understandable enough on your first read-through, it is some pretty heavy going stuff.
CVAA explicitly applies to the games industry. It divides the games industry into three buckets; consoles, gameplay and distribution networks, and games software.
Because none of those three are primarily about communication, the FCC is able to, at it's own discretion, grant temporary waivers instead of them all having to be compliant in 2012 like most industries were.
The waivers for consoles and networks expired in October 2015. The waiver for games expires on December 31st 2018. Google ”CVAA games waiver" for more info.
Steam is a gameplay and distribution network. Therefore its waiver expired in 2015.
No one has the ability to excuse themselves on the basis of it not being achievable. How it works is that you build a case for inachievability, which is based primarily on affordability (and obviously cost to implement Vs Valve's bank balance is pretty cut and dry - https://www.pcgamer.com/market-data-fir … st-year/), and then submits that request to the FCC. It is then the FCC, not the service provider, who decides if it is achievable. You can see that in what you pasted to me - "as determinable by the commission". "The commission" refers to the FCC, the federal communications commission.
A strong factor in the FCC's decision making is whether anyone else has already done it. No one can argue to the FCC that making windows software accessible is inachievable, because many others have already done it. As of course steam had more than enough money to be able to do it, even a ground up rewrite of their UI would be a tiny drop in the ocean of Valve's finances.
So no, OCR does not cover it, because they're pretty solutions only kick in if the inachievability criteria is satisfied.
I sent you a link in the EA thread to the talk by Karen Peltz Strauss. Watching that talk will inform you about how it relates to Steam too.