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TV Remote Control Comments from APA

From: Janina Sajka <janina@rednote.net>
Date: Wed, 22 Mar 2017 10:53:28 -0400
To: public-tvcontrol@w3.org
Cc: W3C WAI Accessible Platform Architectures <public-apa@w3.org>
Message-ID: <20170322145328.GE4023@opera.rednote.net>
Colleagues:

The Accessible Platform Architectures (APA) Working Group makes the
following comments on the draft TV Control API specification at:

https://www.w3.org/tr/tvcontrol-api/

Our review and Working Group Decision in support of these comments is
logged at:
http://lists.w3.org/Archives/Public/public-apa/2017Mar/0018.html

We appreciate that an API for TV remote control could be utilized for
enabling accessible alternative Web applications to provide radio and TV
services to users with disabilities who may find it difficult or
impossible to operate any user interface supplied with a particular
browser or hardware device. This is an inherent accessibility strength
for any API that provides for sufficient feature support. Regretably, we
believe the current TV Remote Control API as currently defined lacks
required accessibility feature support.

*	alternative media support

We would draw your attention to the multiple alternative media formats
that are used by persons with disabilities as set forth in our W3C Note
publication: "Media Accessibility User Requirements (MAUR)" available
at:

http://www.w3.org/TR/media-accessibility-reqs

Please note that this document was developed in order to inform the
development of the HTML 5.0 specification itself. As a result of this
note, HTML provides sufficient feature support to support accessibility
in HTML's video and audio elements.

Our reading of the Tv Control API draft finds no way for users to learn
of the presence of any MAUR identified alternative media with any
particular TV content, nor any means to request display of alternative
content. This is a fundamental accessibility requirement on TV Controls
and we believe it must be factored into this specification.

*	Alternative Media on Second Screen Devices

APA's predecessor Working Group, Protocols and Formats WG also provided
use cases and requirements to the Second Screen Working Group on how
alternative media might be directed to second screen devices. We believe
support for directing alternative video, audio, and/or text to secondary
devices, as described in the MAUR,  is also a fundamental accessibility
requirement on TV Controls and should be supported in this API.

*	Legal Requirements

The Federal Communications Commission (FCC) in the U.S. has explicit
legally mandated regulations setting forth some strict requirements on
how certain alternative media are to be exposed to consumers. These
regulations also require accessible program guides.

We believe that developers should be flagged most especially on the requirement that
captioning must be enableable by top level controls. These FCC
requirements implement provisions of a U.S. law known as the
"Twenty-First Century Communications and Video Accessibility Act" as
explained by the FCC at:

https://www.fcc.gov/general/twenty-first-century-communications-and-video-accessibility-act-0#block-menu-block-4

The FCC's regulations pertinent to this specification were published in
December 2016 in the document: "Accessibility Requirements for
Television and Set-Top Box Controls, Menus, and Program Guides"
available at:

PDF:		https://apps.fcc.gov/edocs_public/attachmatch/DA-16-1416A1.pdf
MS-Word: https://apps.fcc.gov/edocs_public/attachmatch/DA-16-1416A1.docx

Also relevant is the document "Display of Captioning on Equipment Used
to View Video Programming" available at:

https://www.fcc.gov/consumers/guides/closed-captioning-display-requirements-equipment#block-menu-block-4

Additionally, we would request that your API reference the MAUR in your
appendices in order to assist developers in meeting both their moral and
legal requirements in support of accessibility.

-- 

Janina Sajka,	Phone:	+1.443.300.2200
			sip:janina@asterisk.rednote.net
		Email:	janina@rednote.net

Linux Foundation Fellow
Executive Chair, Accessibility Workgroup:	http://a11y.org

The World Wide Web Consortium (W3C), Web Accessibility Initiative (WAI)
Chair, Accessible Platform Architectures	http://www.w3.org/wai/apa


-- 

Janina Sajka,	Phone:	+1.443.300.2200
			sip:janina@asterisk.rednote.net
		Email:	janina@rednote.net

Linux Foundation Fellow
Executive Chair, Accessibility Workgroup:	http://a11y.org

The World Wide Web Consortium (W3C), Web Accessibility Initiative (WAI)
Chair, Accessible Platform Architectures	http://www.w3.org/wai/apa
Received on Wednesday, 22 March 2017 14:53:56 UTC

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