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Issues: Part 3 - #44 and #45

From: <ehansen@ets.org>
Date: Thu, 18 Nov 1999 16:53:55 -0500 (EST)
To: w3c-wai-ua@w3.org
Message-id: <vines.Bh0E+nJ5BsA@cips06.ets.org>
Issue #44. Document must give greater emphasis to the differential 
applicability of the guidelines to various classes of user agent, 
especially assistive technologies.

In addition to providing a new issue, this follows up on Issue #1 (re: 
Abstract) and Issue #5 (re: "natively").

Readers of the UAAG document need greater clues as to the scope of the 
document -- especially, what kinds of user agents to which the document is 
most applicable, especially with regard to assistive technologies.

The following revisions also attempt to clarify the relationship between 
user agents and assistive technologies.

Old (5 Nov 1999 - Last Call):

"Abstract:"
"This document provides guidelines to user agent developers for making 
their products -- browsers, multimedia players, plugins -- accessible to 
people with disabilities. An accessible user agent allows users with 
disabilities to retrieve and view Web content or to enable access when used 
in conjunction with other software or hardware, called assistive 
technologies. These guidelines discuss the accessibility of the user agent 
as well as how the user agent communicates with assistive technologies such 
as screen readers, screen magnifiers, braille displays, and voice input 
software."

My suggestion from Issue #1 (17 November 1999):
"Abstract:"
"This document provides guidelines to user agent developers for making 
their products -- browsers, multimedia players, and related assistive 
technologies -- accessible to people with disabilities. Developers must 
ensure: (1) that the functionalities offered by the user agent are 
accessible, and (2) that the user agent works well with other user agents 
-- especially assistive technologies -- that are necessary to access 
diverse Web content. For example, the developer of a graphical desktop Web 
browser will ensure that its functionalities are accessible by keyboard, 
since many people who are blind or have other disabilities require it. The 
developer will also use standard ways of interfacing the browser with other 
user agents, such as movie and audio players, and assistive technologies 
such as screen readers, screen magnifiers, braille displays, and voice 
input software. This document establishes criteria for three levels of user 
agent accessibility ("A", "Double-A", or "Triple-A"). User agents that are 
accessible can be more flexible, powerful, and usable for all users."

My current (17 November 1999, 16:05 hrs) suggestion:
"Abstract:"
"This document provides guidelines to user agent developers for making 
their products -- browsers, multimedia players, plug-ins, and other 
input/output technologies used to access Web content -- are accessible to 
people with disabilities. Developers must ensure: (1) that the 
functionalities offered by the user agent are accessible, and (2) that the 
user agent works well with other user agents that provide additional 
functionalities that are necessary for full access to Web content. For 
example, the developer of a graphical desktop Web browser will ensure that 
its functionalities are accessible by keyboard, since many people who are 
blind or have other disabilities require it. The developer will also use 
standard ways of interfacing the browser with other user agents, such as 
movie and audio players, and assistive technologies such as screen readers, 
screen magnifiers, braille displays, and voice input software. Not every 
guideline or checkpoint is applicable to every kind of user agent. User 
agents that are accessible can be more flexible, powerful, and usable for 
all users."

--
I suggest the following additional changes in the Priorities and 
Conformance sections.

Old:
{beginning of Old:}
1.5 Priorities
Each checkpoint in this document is assigned a priority that indicates its 
importance for users. 
[Priority 1]
This checkpoint must be satisfied by user agents as a native feature, 
otherwise one or more groups of users with disabilities will find it 
impossible to access information. Satisfying this checkpoint is a basic 
requirement for some individuals to be able to use the Web.
[Priority 2]
This checkpoint should be satisfied by user agents as a native feature, 
otherwise one or more groups of users will find it difficult to access 
information. Satisfying this checkpoint will remove significant barriers to 
accessing Web documents.
[Priority 3]
This checkpoint may be satisfied by user agents as a native feature to make 
it easier for one or more groups of users to access information. Satisfying 
this checkpoint will improve access to the Web for some individuals.
1.6 Conformance
The terms "must", "should", and "may" (and related terms) are used in this 
document in accordance with RFC 2119 ([RFC2119]).
User agents must satisfy natively all the applicable checkpoints for a 
chosen conformance level.
{End of Old}

Really new (18 November 1999):

{beginning of New:}
1.5 Priorities
Each checkpoint in this document is assigned a priority that indicates its 
importance for users WITH DISABILITIES. 
[Priority 1]
This checkpoint must be satisfied by a user agent; otherwise one or more 
groups of users with disabilities will find it impossible to access 
information. Satisfying this checkpoint is a basic Web access {or 
"accessibility"} requirement.
[Priority 2]
This checkpoint should be satisfied by a user agent; otherwise one or more 
groups of users with disabilities will find it difficult to access 
information. Satisfying this checkpoint will remove significant Web access 
{or "accessibility"} barriers.
[Priority 3]
This checkpoint may be satisfied by a user agent; otherwise one or more 
groups with disabilities will find it somewhat difficult to access 
information. Satisfying this checkpoint will improve Web access {or 
"accessibility"}.

{Note. The foregoing priority levels are unchanged from yesterday.}

Note. The terms "must", "should", and "may" (and related terms) are used in 
this document in accordance with RFC 2119 ([RFC2119]).

1.6 Applicability {This section is mostly new.}

User agents must satisfy all the _applicable checkpoints_ {extend link to 
include "checkpoints"} for a chosen conformance level. {NOTE. I DELETED THE 
WORD "NATIVELY". REMEMBER, IT IS NOT NEEDED BECAUSE IT IS ALREADY PART OF 
THE DEFINITION OF "APPLICABLE CHECKPOINT."} Not every checkpoint or 
guideline is applicable to every user agent. Generally, a user agent must 
adhere to checkpoints that ensure accessibility of functionalities that it 
offers to users, but is generally not required to address checkpoints that 
address the accessibility of functionalities that it does not provide. This 
means that for user agents such as graphical Web browsers which are 
general-purpose user agents for accessing the virtually all Web content, a 
greater portion of the checkpoints will be applicable. On the other hand, 
applications or utilities with a much narrower range of functionality will 
tend to have a smaller set of applicable checkpoints. Many of the user 
agents that are also classified as "assistive technologies" (which are 
specifically designed for people with disabilities), often have a narrow 
range of functionality and hence may a smaller set of applicable 
checkpoints. See the definition of "Applicable checkpoint" in the appendix 
("Terms and Definitions") for greater detail."

{Note. If necessary, this section could bring in more material from "Terms 
and Definitions -- Applicable checkpoint" if necessary.}

1.6 Conformance

Developers of user agents may claim any of three levels of conformance to 
this document.

{Note that I have newly inserted the word "applicable" into the definition 
of each of the conformance levels.}

Conformance Level "A": all applicable Priority 1 checkpoints are satisfied 
Conformance Level "Double-A": all applicable Priority 1 and 2 checkpoints 
are satisfied 
Conformance Level "Triple-A": all applicable Priority 1, 2, and 3 
checkpoints are satisfied 

Note. Conformance levels are spelled out in text ("Double-A" instead of 
"AA") so they may be understood when rendered as speech.

Claims of conformance to this document must use one of the following two 
forms.

[etc., etc.]

{End of New}

Issue #45. Some attention needs to be given to additional situations in 
which the UA document is not applicable. 

I wonder if there are some unexpected implications of the guidelines. For 
example, "Web authoring tools" could be considered "user agents". Do the UA 
guidelines place any additional burden upon developers of Web authoring 
tools?

I have some small concern here about whether the applicability rules are 
robust enough to avoid unnecessary burdens on developers of assistive 
technologies. Will the UA guidelines require the developers of pwWebSpeak, 
a non-graphical [at least the last time I looked] self-voicing Web browser 
be required to provide a lot more capabilities for presenting graphical 
material.  Probably not, but it might be good to ask people who develop 
different kinds of assistive technologies (screen readers, special access 
devices, etc.) how well they stack up against the UA document and whether 
they see the UA guidelines as an unnecessary burden.

Will developers of utilities for individuals who are deaf-blind be required 
to interface to multimedia-capable user agents?

Will manufacturers of new handheld Web appliances, especially some that may 
be built for individuals with disabilities, be required to provide 
capabilities that are burdensome?

Will wheelchair will classified as a user agent if it allows a person to 
sit in front of a computer. Are there any checkpoints applicable to 
wheelchairs?

These are concerns that may be unfounded. Once you try to have the document 
cover every possible case or exception, you may start down a slippery slope 
that you might not climb out of.

Yet if we have concerns, then perhaps would should do as the U.S Congress 
does: When it passes a law, it often exempts itself (the House and Senate) 
from compliance to the law <grin>. 

Seriously, if developers of assistive technologies have serious concerns 
about this, then perhaps somewhere there needs to be statement like the 
following.

"Note. Certain exceptions to the requirements of this document may be 
granted to user agents that are specifically targeted at users with 
disabilities, especially very low-incidence disabilities."

Another possible exception might be certain educational applications (which 
obscure and hide information for instructional and testing purposes). 
Probably not necessary to cite as an exception.

Perhaps these concerns are unfounded. Opinions are welcomed.
----



=============================
Eric G. Hansen, Ph.D.
Development Scientist
Educational Testing Service
ETS 12-R
Rosedale Road
Princeton, NJ 08541
(W) 609-734-5615
(Fax) 609-734-1090
E-mail: ehansen@ets.org 
Received on Thursday, 18 November 1999 16:58:43 GMT

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