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Re: WCAG and "undue hardship"

From: Charles McCathieNevile <charles@w3.org>
Date: Tue, 30 May 2000 19:05:24 -0400 (EDT)
To: pjenkins@us.ibm.com
cc: w3c-wai-gl@w3.org
Message-ID: <Pine.LNX.4.20.0005301904170.3581-100000@tux.w3.org>
I think Phill identifies the issues here fairly clearly, although I would
note that hte question of what is a reasonable approach for the US might not
work so well in other countries, where the markeyt for and range of assitive
technologies is much more limited. We should bear this in mind if we are
writing guidelines for a world wide web consortium.

Charles McCN

On Tue, 30 May 2000 pjenkins@us.ibm.com wrote:

  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

Charles McCathieNevile    mailto:charles@w3.org    phone: +61 (0) 409 134 136
W3C Web Accessibility Initiative                      http://www.w3.org/WAI
Location: I-cubed, 110 Victoria Street, Carlton VIC 3053
Postal: GPO Box 2476V, Melbourne 3001,  Australia 
Received on Tuesday, 30 May 2000 19:05:25 UTC

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