Final Draft New 508 Rules, and fail cases for 1.3

Dear WAI-IG,

I posted changes to my rule proposals at
http://www.nosetothepage.org/508/Techniques.html. This is the final draft I
will send to the US Access Board. I would like the 508 Refresh to adopt
them whether WCAG WG agrees or not. I hope WCAG WG will support this, or
even help me improve the language.

I have been criticized for slowing down the process. Here is why I am doing
it. Since 2008, when people started conforming to WCAG 2.0 instead of the
508 web rules, access for visual reading with low vision has degraded
significantly. There is no real way to write a reset style sheet followed
with a specification of the user needs that works.  With new HTML /
JavaScript sites the style specifications are simply too idiosyncratic to
admit a programmatic approach. The sandbox model that is so important for
web security prevents practical intervention with procedural languages. In
1934, talking books were established in the United States and people with
low vision were excluded. That was not corrected until 1974, sixteen years
before the technology became obsolete. The Access Board is poised to repeat
this kind of exclusionary action with the 508 Refresh in its current form.
By the time the Access Board returns to the problem, if it still exists,
inclusion of rules to support low vision to the 508 Refresh will probably
be obsolete.

I am proposing three new rules that identify content failures of
accessibility. These rules should apply to all data formats, not just HTML,
CSS and Java Script.  EPUB, MOBI, PDF and any proprietary publication
formats for ICT reading material are included. If the PDF standards
contradict these fail cases then these rules should override the PDF
standard. The rules are meant to provide access to reading all electronic
publications, not just web publications. These include but are not limited
to: professional journals, news publications in ICT format, BLOG
publications, electronic books, electronic instructional materials, and
high stakes assessment instruments used for schools and employment.

The ultimate goal of the new rules is this.  (1) Content must make sense
and can be read an used when the authors visual presentation is removed.
(2) Content is linear and in proper reading order when the author's visual
presentation is removed. (3) The author's visual presentation can be
replaced by a visual presentation format that matches the visual
requirements of the reader. Specifically, the reader of content can have
the color (back and fore), font-family, font-size, letter spacing, line
spacing and line length needed to support effective visual reading. No
reader should be subjected to horizontal scrolling when reading at any font
size so long as the line length fits at least one word per line on a view
port.

These rules are consistent with Guideline 1.3, even if the WCAG WG did not
recognize this at the time of adoption. This is because in 2008 fully
sighted people could not perceive the problem.  The Mobile Web changed
that. Fully sighted users now know what it means to read and be forced to
use horizontal scrolling.  Most people, even fully sighted readers, now
realize that if the author's visual presentation prevents effective
perception, operation or comprehension of content, and the visual
presentation cannot be replaced programmatically by one that supports the
user's visual needs then there is no access to the content. This visual
inflexibility is the current state of affairs for people with low vision.
It will remain so if the 508 Refresh is adopted unchanged.

Are there user agent changes that also need to be made to support these
content changes? Yes, but that does not mean content rules are not needed.
The best possible user agent cannot fix bad content.
Sincerely, Wayne