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Re: LIFT Text Transcoder

From: Phill Jenkins <pjenkins@us.ibm.com>
Date: Mon, 27 Feb 2006 16:38:54 -0600
To: Access Systems <accessys@smart.net>
Cc: WAI Interest Group <w3c-wai-ig@w3.org>, w3c-wai-ig-request@w3.org
Message-ID: <OF9A2D383B.3887BE1B-ON86257122.0077A33D-86257122.007C6953@us.ibm.com>
Bob said: 
"... and to
determine what is appropriate compliance it turns to the ATBCB for
guidance and they reference back to section 508 and W3C/WAI level 3"

Can you provide a specific URL web reference where is says or implies 
this? 

When I reviewed the Architectural and Transportation Barriers Compliance 
Board (a.k.a. U.S. Access Board) site, I find no links between 504 and 
508, nor any text implying the 508 Subpart B Technical standards [see Note 
1] apply to 504, ADA, or anything else.  In fact the new ADA guidelines 
only mention 508 as applying to ATM machines that the federal government 
may purchase.  Your comment about W3C/WAI level 3 is specifically 
mentioned as NOT being included in 508 except for the one specific 
requirement about skipping to main content [see note 3 & 4]

Note 1 U.S. Access Board 508 Web requirements 1194.22 a-p
        http://www.access-board.gov/sec508/standards.htm#Subpart_b
 
Note 2 ADA guidelines (July 23, 2004)
        http://www.access-board.gov/ada-aba/index.htm
 
Note 3 Skip navigation links
        http://www.access-board.gov/sec508/guide/1194.22.htm#(o)

Note 4 Preamble discussing the scope and comments submitted on the 
technical standards:
        http://www.access-board.gov/sec508/preamble.htm#Subpart%20B

Note 4 is quoted below:
...
the EITAAC had recommended that the Board ... directly reference priority 
one and two checkpoints of the World Wide Web Consortiums' (W3C) Web 
Accessibility Initiative's (WAI) Web Content Accessibility Guidelines 1.0 
(WCAG 1.0). Rather than reference the WCAG 1.0, ... this final rule 
include provisions which are based generally on priority one checkpoints 
of the WCAG 1.0...
Comment. A number of comments were received from the WAI and others 
expressing concern that the Board was creating an alternative set of 
standards that would confuse developers as to which standards should be 
followed. WAI was further concerned that some of the provisions and 
preamble language in the NPRM were inaccurate. On the other hand, a number 
of commenters, including the ACB and several members of the EITAAC, 
supported the manner in which web access issues were addressed in the 
proposed rule.
Response. The final rule does not reference the WCAG 1.0. However, the 
first nine provisions in 1194.22, paragraphs (a) through (i), incorporate 
the exact language recommended by the WAI in its comments to the proposed 
rule or contain language that is not substantively different than the WCAG 
1.0 and was supported in its comments.
Paragraphs (j) and (k) are meant to be consistent with similar provisions 
in the WCAG 1.0, however, the final rule uses language which is more 
consistent with enforceable regulatory language. Paragraphs (l), (m), (n), 
(o), and (p) are different than any comparable provision in the WCAG 1.0 
and generally require a higher level of access or prescribe a more 
specific requirement.
The Board did not adopt or modify four of the WCAG 1.0 priority one 
checkpoints. These include WCAG 1.0 Checkpoint 4.1 which provides that web 
pages shall "[c]learly identify changes in the natural language of a 
document's text and any text equivalents (e.g., captions)."; WCAG 1.0 
Checkpoint 14.1 which provides that web pages shall "[u]se the clearest 
and simplest language appropriate for a site's content."; WCAG 1.0 
Checkpoint 1.3 which provides that "[u]ntil user agents can automatically 
read aloud the text equivalent of a visual track, provide an auditory 
description of the important information of the visual track of a 
multimedia presentation."; and WCAG 1.0 Checkpoint 6.2 which provides that 
web pages shall "[e]nsure that equivalents for dynamic content are updated 
when the dynamic content changes."
Section 1194.23(c)(3) of the proposed rule required that web pages alert a 
user when there is a change in the natural language of a page. The 
"natural language" referred to the spoken language (e.g., English or 
French) of the web page content. The WAI pointed out that the preamble to 
the NPRM misinterpreted this provision. The preamble suggested that a 
statement such as "the following paragraph is in French" would meet the 
provision. WAI responded by noting that this was not the intent of the 
provision. The WCAG 1.0 recommend that web page authors embed a code or 
markup language in a document when the language changes so that speech 
synthesizers and Braille displays could adjust output accordingly.
The Trace Center advised that only two assistive technology programs could 
interpret such coding or markup language, Home Page Reader from IBM and 
PwWebspeak from Isound. These programs contain the browser, screen reading 
functions, and the speech synthesizer in a single highly integrated 
program. However, the majority of persons who are blind use a mainstream 
browser such as Internet Explorer or Netscape Navigator in conjunction 
with a screen reader. There are also several speech synthesizers in use 
today, but the majority of those used in the United States do not have the 
capability of switching to the processing of foreign language phonemes. As 
a result, the proposed provision that web pages alert a user when there is 
a change in the natural language of a page has been deleted in the final 
rule.
The Board also did not adopt WCAG 1.0 Checkpoint 14.1 which provides that 
web pages shall "[u]se the clearest and simplest language appropriate for 
a site's content." While a worthwhile guideline, this provision was not 
included because it is difficult to enforce since a requirement to use the 
simplest language can be very subjective.
The Board did not adopt WCAG 1.0 Checkpoint 1.3 which provides that 
"[u]ntil user agents can automatically read aloud the text equivalent of a 
visual track, provide an auditory description of the important information 
of the visual track of a multimedia presentation." Although the NPRM did 
not propose addressing this issue in the web section, there was a similar 
provision in the multi-media section of the NPRM.
The Board did not adopt WCAG 1.0 Checkpoint 6.2 which provide that web 
pages shall "[e]nsure that equivalents for dynamic content are updated 
when the dynamic content changes." The NPRM had a provision that stated 
"web pages shall update equivalents for dynamic content whenever the 
dynamic content changes." The WAI stated in its comments that there was no 
difference in meaning between the NPRM and WCAG 1.0 Checkpoint 6.2. The 
NPRM provision has been deleted in the final rule as the meaning of the 
provision is unclear.
A web site required to be accessible by section 508, would be in complete 
compliance if it met paragraphs (a) through (p) of these standards. It 
could also comply if it fully met the WCAG 1.0, priority one checkpoints 
and paragraphs (l), (m), (n), (o), and (p) of these standards. A Federal 
web site that was in compliance with these standards and that wished to 
meet all of the WCAG 1.0, priority one checkpoints would also have to 
address the WAI provision regarding using the clearest and simplest 
language appropriate for a site's content (WCAG 1.0 Checkpoint 14.1), the 
provision regarding alerting a user when there is a change in the natural 
language of the page (WCAG 1.0 Checkpoint 4.1), the provision regarding 
audio descriptions (WCAG 1.0 Checkpoint 1.3), and the provision that web 
pages shall "ensure that equivalents for dynamic content are updated when 
the dynamic content changes (WCAG 1.0 Checkpoint 6.2).
The Board has as one of its goals to take a leadership role in the 
development of codes and standards for accessibility. We do this by 
working with model code organizations and voluntary consensus standards 
groups that develop and periodically revise codes and standards affecting 
accessibility. The Board acknowledges that the WAI has been at the 
forefront in developing international standards for web accessibility and 
looks forward to working with them in the future on this vitally important 
area. However, the WCAG 1.0 were not developed within the regulatory 
enforcement framework. At the time of publication of this rule, the WAI 
was developing the Web Content Accessibility Guidelines 2.0. The Board 
plans to work closely with the WAI in the future on aspects regarding 
verifiability and achievability of the Web Content Accessibility 
Guidelines 2.0.
...

Regards,
Phill Jenkins
IBM Worldwide Accessibility Center
http://www.ibm.com/able
Received on Monday, 27 February 2006 22:39:30 GMT

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