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Re: WCAG and "undue hardship"

From: <pjenkins@us.ibm.com>
Date: Tue, 30 May 2000 12:01:51 -0400
To: w3c-wai-gl@w3.org
Message-ID: <852568EF.00581017.00@d54mta04.raleigh.ibm.com>

A similar discussion on JavaScript is occurring on the [Webwatch] list. I
am interested in this GL thread because of the way the US Federal
Government is using part of WCAG in section 508.  Before I post this
response to the [WEBWATCH] list, I will be following the feedback on this
w3c-wai-gl thread.:

From:  webwatch@telelists.com

Kelly wrote:
> But if you
> go the yes route, then you open up web pages to full blown Java applets,
> Shockwave and a host of other technologies that haven't a chance of being
> accessible any day soon.  So how should legal standards of web
> accessibility address this issue?

Phill proposed response:
I believe technologies such as JavaScript, Java, Shockwave, Flash, and/or
formats such as .html, .mov, .pdf, .doc, etc. should have defined
"accessibility standards" for each technology or format that will clearly
delineate where the author responsibility lies and where the assistive
technology responsibility lies.  I believe there *are* industry recognized
standards for HTML accessibility (see W3C WAI Web Content Accessibility
Guidelines [1]), for browsers [read html players], (see W3C WAI User Agent
Accessibility Guidelines [2]), and for Java applets (see IBM Java
Accessibility Guidelines [3]).  There are clear guidelines on how to add
captions and descriptions to .mov's and the players that support them.

What's missing.  I do not know of any industry recognized accessibility
standard for some technologies and formats, such as pdf, flash, and
shockwave.  I may be wrong about pdf - in that there may be some guidelines
published on an Adobe site on how to make pdf  accessible.  To make the
advancement of new technologies and formats viable - we should be
supporting "legal standards" that request that "accessibility standards" be
established for the new technology/format - as opposed to prohibiting the
technology/format or as opposed to requiring a duplicate alternative
format.  Let me explain this last statement with JavaScript as an example.

JavaScript is simply a scripting language that allows the page content to
have some smarts and interactivity.   For example, the running total in the
ACB order form.  Newer level screen readers working with newer level
browsers provide good access to pages with JavaScript.  Even self-voicing
browser *should* be able to provide access to interactive content by
supporting JavaScript.  The Home Page Reader development team is working on
this very problem.  In my opinion it would be counter productive to
"legally require" all pages that use JavaScript to also provide a
non-JavaScript alternative.  That would be like requiring all GUI
applications to also provide a non-gui version because old DOS screen
readers couldn't handle them.  I am sure we may have all felt that way a
decade ago, but we have made great strides in providing access to GUI
applications.  So why would we require all web sites to provide a
non-JavaScript alternative when it would be less expensive and better to
require assistive technologies to support JavaScript.  JavaScript was
invented to solve some real problems that could not be handled in HTML
alone, just as GUI's were invented to solve problems in old DOS command
line interfaces.  In some cases it may be impossible to provide the same
level of functionality using HTML without JavaScript - hence what we really
want is "accessible JavaScript".

[The thread on Webwatch was asking that since we do have "accessible
JavaScript" on the Windows platform with certain versions of screen readers
- then why should we encourage legislation like 508 that requires a
duplicate alternative? ]

So what do we do? I believe we should "label" technologies/formats as
accessible or not depending on whether or not there are published industry
standards for accessibility for that particular technology/format.  In my
opinion there is a problem with the current 508 standards and the W3C Web
Content Accessibility Guidelines because they heavily burden the users of
JavaScript by requiring a duplicate text/html alternative when there are
clear standards for making HTML/JavaScript accessible.  The expense of
upgrading to the new "accessible technology" and the expense of upgrading
my assistive technology to handle the new "accessible format" is a related,
but really a separate issue, and more related to can I afford the computer,
phone line, ISP, etc. to get connected to the Internet in the first place.
There are plenty of older screen readers and computers that can't handle
GUI's but we don't have legislation requiring duplicate text command line
alternatives.  So with civil rights and affordability aside for a moment,
the industry/advocacy groups should establish whether the technology/format
is fundamentally accessible or not.  The WAI has done a good job with HTML,
CSS, and SMIL.  SUN and IBM have done a good job with Java, and Microsoft
has a done a good job defining Windows application accessibility.  We
should demand "more good jobs" on technologies such as pdf, shockwave,
flash, WAP, and VoiceXML etc.  Perhaps we should be lobbying for more
"legal" spending to establish accessible standards for newer technologies
and advances in assistive technologies.

Phill Jenkins,
IBM Accessibility Center - Special Needs Systems
11501 Burnet Rd,  Austin TX  78758    http://www.ibm.com/able

[1] http://www.w3.org/TR/WAI-WEBCONTENT/
[2] http://www.w3.org/TR/UAAG/
[3] http://www.ibm.com/able/snsjavag.html
Received on Tuesday, 30 May 2000 12:11:28 UTC

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