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Issue summary for Guideline 1.2

From: Wendy Chisholm <cwendy10@qwest.net>
Date: Mon, 17 Jan 2005 20:59:24 -0500
Message-ID: <41EC6D7C.3000508@qwest.net>
To: "wai-gl" <w3c-wai-gl@w3.org>
The summary of the 19 issues for the media-equiv guideline (Guideline 1.2)
is attached as an HTML document and included as text below.  I've divided
the issues into 3 groups:
Changes to 19 November 2004 WD should address; Reviewer verification required,
Requires further action or discussion,

                              media equiv summary


     * [1]Changes to 19 November 2004 WD should address; Reviewer
       verification required
     * [2]Requires further action or discussion
     * [3]Elephants

Changes to 19 November 2004 WD should address; Reviewer verification required

  [4]Issue 171 and [5]issue 438 - exception for accessible rebroadcasts

      [4] http://trace.wisc.edu/bugzilla_wcag/show_bug.cgi?id=171
      [5] http://trace.wisc.edu/bugzilla_wcag/show_bug.cgi?id=438

   In previous drafts, there was an exception for content that was
   rebroadcast. However, it was worded in such a way that readers
   interpreted it to mean that if content was rebroadcast it was exempt
   from captions, i.e., it did not need to have captions to be
   accessible. To address this issue, the exception became a separate
   success criteria (refer to the 19 November 2004 WD).

   Previous wording: "Exception: if content is rebroadcast from another
   medium or resource that complies to broadcast requirements for
   accessibility (independent of these guidelines), the rebroadcast
   satisfies the checkpoint if it complies with the other guidelines."

   19 November 2004 text: If multimedia content is rebroadcast from
   another medium, the accessibility features required by policy for that
   medium are intact.

   Propose that we close the issue. Verify with reviewers.

  [6]Issue 792 - Level 1 success criteria ordering and rewording proposal

      [6] http://trace.wisc.edu/bugzilla_wcag/show_bug.cgi?id=792

   This issue contains several proposals, questions, and comments. Here
   is a summary of responses (more details are available from [7]Proposal
   for combined Guideline 1.1 and 1.2, summary of issues for 1.2):
     * Wording proposals were not adopted verbatim, although were
       considered in writing proposals for Guideline 1.1 and Guidelin
     * A reordering was proposed (captions before audio descriptions).
       This order was adopted in the 19 November 2004 WD.
     * Concern about the term "video-only" since most Web pages are
       "video only presentations." A defn of "video-only" was added to
       the 19 November 2004 WD to clarify that "video-only" means, "A
       time-based presentation that only contains video."
     * Other comments are addressed by other issues (e.g., exception for

      [7] http://www.w3.org/2004/10/wcag-media-equiv2.html

   Believe that all of the issues are covered by the 19 November 2004 WD.
   Close and verify with reviewers.

  [8]Issue 793 - Clarify the Level 2 success criteria (pending)

      [8] http://trace.wisc.edu/bugzilla_wcag/show_bug.cgi?id=793

   In the [9]11 March 2004 WD, the following multi-part exception applies
   to the level 1 criteria for captioning and audio description: "if the
   content is real-time and the content is audio-only and the content is
   not time-sensitive and the content is not interactive, then a text
   transcript or other non-audio equivalent does not need to be
   synchronized with the multimedia content." Also in this draft, is a
   level 2 criterion for real-time broadcasts with an editorial note
   "There are questions about what is possible and what should be
   required for real-time audio description since there is no way to know
   when there will be gaps in audio (when descriptions could be read) and
   other issues with describing real-time events."

      [9] http://www.w3.org/TR/2004/WD-WCAG20-20040311/#media-equiv

   Of the Level 2 requirement, the reviewer asks, "What is the additional
   requirement here? The editorial note does not seem to apply to
   anything at this level. The note is talking about audio descriptions
   but the success criteria is about captions."

   In the 19 November 2004 WD, addition of terms "prerecorded" and
   "real-time" as well as a variety of other rewrites attempt to clarify
   the difference.

   Propose that we close the issue. Verify with reviewer.

  [10]Issue 980 - Making live broadcast/time-dependent content more accessible

     [10] http://trace.wisc.edu/bugzilla_wcag/show_bug.cgi?id=980

   The reviewer comments on this exception from the 24 June 2003 draft:

     When adding audio description to existing materials, the amount of
     information conveyed through audio description is constrained by
     the amount of space available in the existing audio track unless
     the audio/video program is periodically frozen to insert audio
     description. However, it is often impossible or inappropriate to
     freeze the audio/visual program to insert additional audio

   The reviewer's comment

     The note for the first required success criteria highlights a
     difficulty but does not present a solution. We would like to see
     this document place more emphasis on content providers to think
     about how they can make live broadcast/time-dependent content more
     accessible to deaf and hard of hearing people. For example, in
     modern subtitling, computer programs are used where the
     stenographer simply has to press one button to print a particularly
     common phrase, such as a description of a common pattern of play in
     sports commentary. Such solutions should be encouraged in the Best
     Practice of this guideline, without necessarily making them a
     condition of conformance.

   Believe that several changes in the 19 November 2004 WD should address
   these concerns.
    1. The note in question describes what can be accomplished in
       "extended audio description." A Level 3 success criterion was
       created to highlight that this technology exists, but that it is
       not yet appropriate for all sites: "Extended audio descriptions
       are provided for prerecorded multimedia."
    2. Definitions were moved to the glossary and not included as part of
       the success criteria

   Need to verify with the reviewer that these steps address the issue
   and if so, close the issue.

  [11]Issue 1028 - Collated text transcripts, realtime captioning, and
  describing (pending)

     [11] http://trace.wisc.edu/bugzilla_wcag/show_bug.cgi?id=1028

   The reviewer describes the difficulty and rarity of creating collated
   transcripts. Despite the cost and lack of support for these
   techniques, we hope that in the future they are more readily
   achievable. Collated text transcripts are a Level 3 criterion (of
   Guideline 1.1).

     Guideline 1.1, Level 3, #1: For multimedia content, a combined
     transcript of audio descriptions and captions is provided.

   Propose that we close the issue. Verify with the reviewer.

Requires further action or discussion

  [12]Issue 952 - Ease of access

     [12] http://trace.wisc.edu/bugzilla_wcag/show_bug.cgi?id=952

   The reviewer writes, "An audio script is recommended here and <em>ease
   of access</em> to this script should be stressed."

   For Guideline 1.1, we said "ease of access" is a user agent issue.
   However, since there is not always a means to programmatically
   associate a transcript with an audio clip, this can not be left solely
   to the user agent. It seems to depend on the definition of "explicitly
   associated" that we are waiting for from the [13]13 January 2004
   telecon. It could be a combination of user agent and markup language
   issue. Perhaps a repair technique in the meantime? Research needed.

     [13] http://www.w3.org/2005/01/13-wai-wcag-minutes.html

  [14]Issue 982 - Simultaneous reading and watching required

     [14] http://trace.wisc.edu/bugzilla_wcag/show_bug.cgi?id=982

   There is a Note in the 24 June 2003 WD that says, "the presentation
   does not require the user to read captions and the visual presentation
   simultaneously in order to understand the content."

   The reviewer says:

     This point should be a Required Success Criteria. Captions that
     need to be read at the same time as watching action on the screen
     do not provide an equivalent user experience.

   However, another reviewer (comments not available online) says that
   this is what watching captions are all about and therefore the Note
   should be dropped.

   Propose that something is said in the General Techniques or
   multimedia-specific techniques.

  [15]Issue 983 - Holes in media-equiv

     [15] http://trace.wisc.edu/bugzilla_wcag/show_bug.cgi?id=983

   This issue contains several comments.

     The definition of "media equivalents" given here is not
     sufficiently generic. No mention is made, for example, of sign
     language avatars (this definition is repeated in the Glossary).

   The phrase "media equivalents" is no longer used in the normative part
   of this guideline. "media alternatives:" is used in the benefits
   section and is used in such a way that it could be removed.

   Further, the reviewer says:

     1. Where subtitles are displayed, the designer should ensure
     sufficient contrast between foreground text and the background
     behind it (ideally, the user should be given the option to display
     a caption box behind the subtitles which has a colour that
     sufficiently contrasts the colour of the text).

     2. A minimum size and recommended font for subtitles should be
     provided (the Royal National Institute of the Blind recommends a
     minimum of 16 point Helvetica or Arial font).

     3. A minimum audio quality requirement should be specified for all
     audio description.

     4. If a sign language interpreter is to be displayed on-screen,
     either as streamed video of a human interpreter or in the form of
     an avatar showing a virtual human, then the layout of the site
     should allow for this without the avatar window overlapping in such
     a way that essential functionality or information is being hidden.
     Based on RNID research, we would recommend that an on-screen
     interpreter should, at minimum, be displayed in the Common
     Intermediate Format (CIF) of 352x288 pixels and 25 frames per

   There may also be different recommendations if it is closed versus
   open captions. Note that other reviewers have said to use any font
   except Arial.

   There is concern by another reviewer that requiring sign language
   starts us down the slippery slope of requiring translations to every
   language and that "sign languages are by definition not "in the
   language of the dialog[ue]." There is no dialogue in sign language."

   Propose close the issue and include the Best Practice suggestions in
   General Techniques (i.e., close this issue for WCAG 2.0 and open an
   issue for General techniques).

  Issues 1027, 1154, 1155: providing alternatives for live audio-only and
  video-only content

    [16]Issue 1027 - "equivalents" for multimedia (pending)

     [16] http://trace.wisc.edu/bugzilla_wcag/show_bug.cgi?id=1027

     From the June 2003 WD:

     If the web content is real-time and audio-only and not
     time-sensitive and not interactive a transcript or other non-audio
     equivalent is sufficient. [...]

     If the web content is real-time non-interactive video (e.g., a
     webcam of ambient conditions), either provide an equivalent...
     (e.g., an ongoing update of weather conditions) or link to an
     equivalent... (e.g., a link to a weather website).

     The reviewer writes:

     This guideline concerns captioning of web multimedia. Its plain
     reading requires a transcript of all real-time audio broadcasts.
     That is, every single Internet radio station would require

     Meanwhile, if you have any kind of webcam at all, you need to
     scrounge up some other site you can link to that is somehow the
     "equivalent" of the webcam's image.

   To address issue 1027, a [17]proposal from September 2004 suggests two
   level 1 success criterion:

     [17] http://lists.w3.org/Archives/Public/w3c-wai-gl/2004JulSep/0532.html

     4. A text alternative is provided for live audio-only content by
     following Guideline 1.1. (Editorial note: an internet radio stream
     would only need to provide a description of the intent/character of
     the station, *not* every song they play)

     5. A text alternative is provided for live video-only content by
     following Guideline 1.1. (Editorial note: webcams would only need a
     text alternative associated with the concept that the cam is
     pointing at, *not* every image that is captured)

   A reviewer writes:
    1. I suppose you mean dialogue-only audio. This essentially requires
       real-time captioning. Sometimes a post-facto transcript will do,
       however there is not a standard for providing real-time captions.
       [18]Issue 1154 - Real-time captioning of live audio-only content
    2. I think this is going to need a much better formulation. Aren't we
       requiring captioning and, in some cases, description? [19]Issue
       1155 - Alternatives for live video-only content (pending)]

     [18] http://trace.wisc.edu/bugzilla_wcag/show_bug.cgi?id=1154
     [19] http://trace.wisc.edu/bugzilla_wcag/show_bug.cgi?id=1155

   19 November 2004 draft attempts to clarify that neither captioning nor
   a transcript is required, only a description.

     Guideline 1.1, Level 1, #6: For live audio-only or live video-only
     content, such as internet radio or Web cameras, text alternatives
     describe the purpose of the presentation or a link is provided to
     alternative real-time content, such as traffic reports for a
     traffic Web camera

     Note: real-time content does not imply real-time captions.

   Propose that we close these issues. Verify with the reviewer.

   However, would David Poehlman agree ([20]issue 1332)? Depends on
   definition of text alternative.]

     [20] http://trace.wisc.edu/bugzilla_wcag/show_bug.cgi?id=1332

  [21]Issue 1182 - need better phrases for "synchronized media equivalents" and
  "time-dependent presentations" (pending)

     [21] http://trace.wisc.edu/bugzilla_wcag/show_bug.cgi?id=1182

   The reviewer says,

     We recommend using other phrases for "synchronized media
     equivalents" and "time-dependent presentations."

   In the 19 November 2004 draft we use, "synchronized alternatives" and
   "multimedia" - propose that we close the issue and notify the

   [However, the defn of multimedia still needs work and "synchronized
   alternatives" is not in the glossary.]


  [22]Issue 1085 - "Respond interactively" not defined.

     [22] http://trace.wisc.edu/bugzilla_wcag/show_bug.cgi?id=1085

   Related to definition of "non-text content" and the issue about when
   Guideline 4.2 applies versus when 1.1 or 1.2 apply. Still haven't
   heard or seen a good example.

   Editorial note in 19 November 2004 WD:

     How should we address presentations that contain only audio or only
     video and require users to respond interactively at specific times
     during the presentation? Since it is not multimedia, a criterion
     could be added to guideline 1.1. However, the need is for
     synchronized alternatives, therefore a criterion could be added to
     this guideline. Refer to Issue 1272.

   Related: [23]Issue 1272 - Synchronized alternatives for monomedia

     [23] http://trace.wisc.edu/bugzilla_wcag/show_bug.cgi?id=1272

     The proposed criterion is, "if there is any time-based interaction
     with audio or video presentation, alternatives have to be

     However, the current split between Guidelines 1.1 and 1.2 is that
     1.1 addresses text alternatives and 1.2 addresses synchronized
     alternatives for multimedia. Next steps: find real-world examples
     and determine requirements then determine if we need to expand 1.2
     to something like "synchronized alternatives for non-text content"
     or if we can fit it into 1.1.

   The following are notes and related references.
     * Flash is most likely best example of this. Refer to [24]Creating
       Accessible Content in Macromedia Flash MX 2004: Best Accessibility
       Practices - map these best practices to WCAG 2.0 success criteria.
     * From the [25]WebAim article -Creating Accessible Macromedia Flash
       Content , it says, "Provide textual equivalents for all non-text
       elements that convey content or provide a function." - therefore,
       part of the functionality of interactive elements is covered in
       Guideline 1.1.
          + Although, audio descriptions (for animations) are more along
            guideline 1.2, "Flash's timeline and programming language
            (ActionScript) allow constantly changing, dynamic, updating
            objects to animate, move, disappear, or duplicate themselves
            whenever the Flash developer chooses (or even randomly if
            he/she wants). In fact, accessibility for Flash could be more
            closely related to issues of television broadcast
            accessibility, except that Flash is interactive, and
            televisions are not."
          + How does this fit into the baseline issue? We want to assume
            script support, what about appropriate flash support?
            "...it will probably be vital for you to
            provide a non-Flash alternative for those that cannot or
            choose not to access your Flash multimedia" [guideline 4.2]
          + "Just because someone accesses your equivalent alternative,
            doesn't mean that they are blind and don't care about what
            the page looks like or how it functions."
          + on [26]page 2, recommends, "Text equivalents must be provided
            in Flash for every non-text element that conveys important
            content. This means that graphics, animations, and video must
            have textual equivalents that can be accessed by someone who
            cannot see those elements. Also, a textual equivalent
            (captions and/or transcripts) must be provided for all audio
            content that is not also conveyed through the visual elements
            of the presentation" [Guideline 1.1].
            "Providing captions in Flash offers accessibility to users
            who cannot hear or fully understand audio content. Because of
            the interactive nature of Flash, captions can be turned on or
            off and can be programmed to display in many ways."
            [Guideline 1.2]
            "If the Flash multimedia is primarily audio content, a
            transcript should also be provided." [Guideline 1.1]
          + Hit areas ([27]page 4 of article) - "areas within the movie
            that someone can press and cause an action. they need to have
            a text alternatives" [guideline 1.1] "and be keyboard
            operable" [guideline 2.1].
          + Using sound within Flash - Guideline 1.4, Level 2 #3: Users
            can disable background audio that plays automatically on a
            page so that it does not interfere with text reading software
            they may be using. - should this be level 1? Will it be a
            user agent feature in the future? Seems to be covered by
            [28]UAAG 1.0 Checkpoint 3.2 Toggle audio, video, animated
            images (priority 1).

     [24] http://www.macromedia.com/macromedia/accessibility/features/flash/hints.html
     [25] http://www.webaim.org/techniques/flash/
     [26] http://www.webaim.org/techniques/flash/2
     [27] http://www.webaim.org/techniques/flash/4
     [28] http://www.w3.org/TR/UAAG10/guidelines.html#tech-configure-multimedia

   Based on these examples, I do not propose any changes to Guidelines
   1.1, 1.2, or 4.2. The only possible change may be to Guideline 1.4.

  [29]Issue 1151 - Scoping requirements, relation to policy

     [29] http://trace.wisc.edu/bugzilla_wcag/show_bug.cgi?id=1151

   There are many questions about when captions and audio descriptions
   are required or not. This issue attempts to consolidate the variety of
   questions asked about *when* to provide captions and audio
   descriptions and cases where they may not be necessary.

   Reviewer suggests that we will need scoping requirements for the
     * "very little or a whole lot of multimedia
     * multimedia that will be posted only for a short time
     * multimedia that is posted as an example or counterexample of
       accessible content (including learning examples)
     * entire phase-in schedules"

   The following Editorial Note is in the 19 November 2004 draft:

     Even though there are instances where captions and audio
     descriptions are not required, this version of Guideline 1.2 does
     not attempt to address the variations. Instead, it assumes more
     detail is included in the techniques documents and that policy
     makers will clarify when captions and audio descriptions are

   comment from [30]september proposal for media-equiv guideline:

     [30] http://lists.w3.org/Archives/Public/w3c-wai-gl/2004JulSep/0532.html

     An example of such a phase-in is the Telecom act of 1996 that
     mandates the number of broadcast hours that need to be captioned.
     It increases to 100% by 1 Jan 2006. (2-6 a.m. is not included, thus
     20 of 24 hours is 100%.) 30% of programs aired before 1 Jan 1998
     must be captioned by 1 Jan 2003. 75% by 1 Jan 2008.

     Propose that WCAG 2.0 not attempt to create a phase-in schedule.
     Instead, we look at a scoping mechanism that would allow developers
     to exclude multimedia that hasn't been captioned or described and
     leave phase-in schedules to policy makers. However, there is a
     possibility that scoping could be used to ignore accessibility
     requirements and it doesn't make sense to me for someone to claim
     their site is accessible when it is not. We should stick to what we
     know: technology and only focus on creating technology requirements
     in WCAG 2.0. Leave the policy to policy makers. Until we have a
     scoping mechanism for conformance and several real-world examples
     showing how to use it, this issue remains open.

   Leaving the details to policy was discussed at the [31]30 September
   2004 telecon and scoping was discussed at the [32]23 September 2004
   telecon. At the July face-to-face, we discussed a policy "guide" for
   policy makers ([33]12 July 2004 irc log, [34]13 July 2004 irc log). We
   currenty have a paragraph for "[35]Scoping of Conformance Claims" but
   a detailed model or example should clarify what is allowed or not.
   Therefore, there are a variety of loose ends related to this issue.

     [31] http://www.w3.org/2004/09/30-wai-wcag-irc.html#T21-20-03
     [32] http://www.w3.org/2004/09/23-wai-wcag-irc.html#T20-59-12
     [33] http://www.w3.org/2004/07/12-wai-wcag-irc.html
     [34] http://www.w3.org/2004/07/13-wai-wcag-irc.html
     [35] http://www.w3.org/TR/WCAG20/#id4511881

   Related issues:
     * [36]Issue 1152 - Some video does not require description
     * [37]Issue 1153 - Radio show with interviews and songs
     * [38]Issue 1332 - 1.2: always need equivalents - "Any time there is
       audio, it needs visual substitutability and the same with visually
       presented information needing textually substitutable material. If
       it is something that is timed and interactive, an appropriate
       delivery mechanism needs to be available so that the content can
       be as barrier free as possible."

     [36] http://trace.wisc.edu/bugzilla_wcag/show_bug.cgi?id=1152
     [37] http://trace.wisc.edu/bugzilla_wcag/show_bug.cgi?id=1153
     [38] http://trace.wisc.edu/bugzilla_wcag/show_bug.cgi?id=1332

Received on Tuesday, 18 January 2005 01:59:32 UTC

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