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Media exemption to 1.1.1

From: WCAG 2.0 Comment Form <nobody@w3.org>
Date: Tue, 22 Jan 2008 00:31:05 +0000 (GMT)
To: public-comments-wcag20@w3.org
Message-Id: <20080122003105.B6D775F70C@stu.w3.org>

Name: Roger Hudson
Email: rhudson@usability.com.au
Document: W2
Item Number: Success Criterion 1.1.1
Part of Item: 
Comment Type: technical
Summary of Issue: Media exemption to 1.1.1
Comment (Including rationale for any proposed change):
I dont fully understand the intention of the \"media\" exemption to the requirement to provide a text alternative for all non-text content under SC 1.1.1. I assume it is an attempt to accommodate the increasing presentation of audio and video material on the web by media not traditionally associated with the web; and, the need to balance the accessibility implications of this use with a desire to have guidelines that don\'t impose undue hardship on web proprietors or stifle the development of the web.

The terminology used for the Media related exemption is potentially ambiguous in the context of the broadcast industry. In particular, it appears to address just two distinctly different programming formats, \"live\" and \"prerecorded\", without providing adequate definitions for either. 

The WCAG 2.0 Glossary defines the term \"live audio-only\" as \"a time-based live presentation that contains only audio\" and a very similar definition is provided for \"live video-only\". While these definitions might be adequate for a sports broadcast or the coverage of an unfolding news event, they do no appear to be sufficient for many of the situations faced by the broadcast media today. 

The current definitions of live audio-only and live video-only need to be expanded in order to meet the real-world needs of the media. The phrase \'time-based\' is not very meaningful since within the broadcast industry all material could be said to be time-based. 

The proposed Media exemption does not recognise that sometimes a media broadcast (program) might be an amalgam of live and prerecorded material. For example, daily live radio programs often contain prerecorded segments: In some cases differences in time-zones or the schedule of the interviewee require an interview that is presented live to be prerecorded; or a live program may incorporate prerecorded documentary-style feature segments. With regard to television, it is not uncommon to have programs that are presented as live, but which in fact consist entirely of prerecorded segments with the only live component being the studio presenter who tops and tails them, and in some cases even this is prerecorded.

Also, the broadcast of live-to-air (real-time) programs that contain absolutely no prerecorded material is becoming increasingly rare; even sports broadcasts often now contain prerecorded comments from the players. It should be noted, the Guidelines indicate use of \"prerecorded\" audio and video \"files\" is covered by SC1.1.1, but no definitions are provided for the words \"prerecorded\" and \"files\". Does a prerecorded interview with a player that is stored as an audio file require a text alternative within the context of the WCAG 2.0? Or, should it be treated as being part of a live audio or video presentation and so require only a descriptive label?

The increasing convergence of media is resulting in more and more radio and television broadcast material now being presented over the web in a variety of ways. For example, ABC Radio National in Australia produces live and prerecorded programs and simultaneously \"streams\" all them over the internet at the time of broadcast. 95% of these programs are also available as \"streamed media on demand\", which means they can be listened to (but not downloaded) at a different time. In addition, over 50 of the daily or weekly programs are available for download as MP3 or Podcast files. These are primarily word based (non-music) information style programs. I understand the national broadcasters in Canada and the UK do something very similar.

The presentation of steamed media on demand and podcasts on websites may further complicate the distinction between live and prerecorded content. This material, by its very nature, is not live in the sense that it is a recording of something that has happened at sometime in the past. In some cases however, it might be a recording of a live-to-air program and as such may be considered an alternative presentation of the initial program and so exempt from the need to provide a text alternative; this assumes the initial program is a live-only program within the meaning SC1.1.1.

>From a practical point of view, it might be useful to consider making a distinction between \'scripted\' and \'non-scripted\' content since any requirement to provide a text alternative for a scripted program is likely to be less onerous. However, this should not mean that \'non-scripted\' material with historical value (e.g. an interview with someone concerning a significant world event) is exempt from the requirement to provide a text alternative when it is being presented on the web for posterity. 

Is the intention of the Media exemption to SC 1.1.1, and the associated definition, to exempt only live-to-air material from the need to provide a text alternative? And consequently, require all prerecorded material that is contained in a television or radio program to have a text alternative when it is presented on the web. If so, the considerable difficulties most broadcasters will experience in meeting such a demand is likely to lead to it being generally ignored. And, a general refusal by the broadcast industry to conform to a Level A Success Criterion could undermine the status of WCAG.

Proposed Change:
The Glossary should contain definitions for the terms \"live\" and \"prerecorded\" that relate to the current status of the broadcast industry and are likely to be meaningful to people working in the broadcast industry.

The Working Group should consider providing greater flexibility in the Media exemption to SC 1.1.1, while still retaining the overall desire for text alternatives to be provided for television and radio broadcast material that is re-presented on the web.

The Working Group might like to consider extending the Media exemption to allow programs that are presented in \"real-time\" (e.g. daily radio shows, sports broadcasts, current affairs tv) to contain a percentage of \"prerecorded\" material (e.g. 25%) without the need to provide a transcript for that material.

The Working Group might like to consider incorporating a time-dimension into the Media exemption for SC 1.1.1. For example, a text alternative for non-text content should be provided within 14 days. This would allow broadcasters sufficient time to prepare text alternatives for substantial programs and would enable them to continue to provide \"streamed media on demand\" for 14 days without the need to include a text alternative.
Received on Tuesday, 22 January 2008 00:31:15 UTC

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