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RE: Minutes 12 October 2006

From: Bailey, Bruce <Bruce.Bailey@ed.gov>
Date: Wed, 18 Oct 2006 08:56:12 -0400
Message-ID: <CCDBDCBFA650F74AA88830D4BACDBAB5130FA6BC@wdcrobe2m02.ed.gov>
To: "List WAI GL" <w3c-wai-gl@w3.org>
I am pleased to be continuing my track record of getting dropped from the call as soon as I am asked to say something.  Confirmation bias I am sure!


Cynthia suggested the issue difficultly with conformance claims and the debate over web unit versus web page might be ameliorated from a more task-oriented approach.  Loretta asked if my experience at the Department of Education, evaluating software and web content against the 508 Standards, lead me to the feeling that equivalent facilitation and the Functional Performance Criteria were problematic.  I said no, but I wanted to provide some exposition on my reasonably well informed opinion.


The FPC (508 Subpart C,1194.31) are very high level.  There are only six of them, and they follow a consistent pattern:
(a) At least one mode of operation and information retrieval that does not require user vision shall be provided, or support for assistive technology used by people who are blind or visually impaired shall be provided.


The reference for equivalent facilitation (1194.5) reads as follows:
Nothing in this part is intended to prevent the use of designs or technologies as alternatives to those prescribed in this part provided they result in substantially equivalent or greater access to and use of a product for people with disabilities.


The provision has created some consternation, but I think all sides (government, vendor, and consumer) are pleased to have it.  It has been clarified that “meeting the functional performance criteria in Subpart C of the Board’s standards is the test for equivalent facilitation.”  [1] Section 508 Acquisition FAQ’s, January 2002, B.3., i; search for:
i. What is equivalent facilitation?


That said, I would be hard pressed to provide great examples of developers making good use of this opportunity.


On the call I stated that at ED, we have experienced more difficulties from situations where the products satisfied the specific success criteria but were still not accessible.  Reasonable people can disagree about the wisdom of applying the FPC on top of the more specific and objective criteria.  [2] [3]


What I wish I had thought of, and my primary motivation for following up to this list on this subject, is that I wanted to point out that some of the 508 provisions are themselves quite process oriented.  Most people here probably know that most of 1194.22 comes straight from WCAG 1.0, but there are a few notable exceptions:


(l) When pages utilize scripting languages to display content, or to create interface elements, the information provided by the script shall be identified with functional text that can be read by assistive technology.


(n) When electronic forms are designed to be completed on-line, the form shall allow people using assistive technology to access the information, field elements, and functionality required for completion and submission of the form, including all directions and cues.


The conditionality of these provisions makes them, in my experience, extremely powerful and flexible.  In our evaluation process, we are comfortable deciding when they have been achieved (or not).  It would be hard, however, to have the kind of inter-rater reliability we expect from the WCAG 2.0 success criteria.


[1] http://www.section508.gov/index.cfm?FuseAction=Content&ID=75#b 

[2] http://trace.wisc.edu:8080/mailarchive/sec508/msg02531.shtml

[3] http://trace.wisc.edu:8080/mailarchive/sec508/msg02525.shtml


Received on Wednesday, 18 October 2006 12:56:41 UTC

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