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Accessibility and Conformance, etc.

From: Eric Hansen <ehansen7@hotmail.com>
Date: Sat, 19 Aug 2000 03:26:21 EDT
To: w3c-wai-ua@w3.org
Cc: ij@w3.org
Message-ID: <F104FopYC98Bi89Qtpf0000506a@hotmail.com>
To: UA List
From: Eric Hansen
Subject: Accessibility and Conformance, etc.

The public wants, and has some right to expect that the UAAG conformance 
levels -- level-A, level-AA, and level-AAA -- represent different levels of 
"accessibility" of the user agent. I think that as a working group we need 
to ask ourselves questions like the following:

Suppose that there are a large number (at least one 1000) UAAG conformance 
claims. Some claims are for isolated user agents, such as a single 
multimedia player. Others are composite user agents, i.e., composed of more 
than one constituent user agent. Assume that the full diversity of different 
kinds of user agent currently allowed by the UAAG document are represented 
(e.g., text browser, telephone browsers, etc.). Assume that all claims are 
procedurally correct, i.e., the claimants did what we ask them to do. Now 
suppose that we have an independent and reliable way of rating the 
accessibility of the user agent that is the subject of each claim (perhaps 
by a set of ratings by independent, expert accessibility judges). The key 
question is this: Are there relatively and tolerably few instances in which 
any of the following occurs?
(a) A user agent that fails to achieve even a single-A rating yet is found 
to be more accessible than one that achieves a single-A rating.
(b) A user agent that achieves a single-A rating yet is found to be more 
accessible than one that achieves a double-A rating.
(c) A user agent that achieves a double-A rating yet is found to be more 
accessible than one that achieves a triple-A rating or is less accessible 
than one that receives a single-A rating.
(d) A user agent that achieves a triple-A rating yet is found to be less 
accessible than one that receives a double-A rating.

I think that if we can't answer in the affirmative, then we need to make 
some changes in the UAAG document.

I know that within the working group we have become increasingly aware of 
the limitations UAAG ratings. I think it is very important to state some of 
these limitations in the UAAG document and/or the techniques document, but 
the public will not really understand or appreciate the fine points of these 
limitations. They will not understand why we may want to use the term 
"conformant" instead of the word "accessible". They will want to use the 
UAAG claims in buying decisions and policies that will impact user agent 
developers as well as people with disabilities. In other words, they want 
"accessibility ratings" that are valid for the important decisions that they 
are making about user agents.

Problems That I Think Could Arise

Following are some problems that I think could arise with our current 
conformance claim system.

Problem #1: A buyer of user agents says:  "According to their developers, 
user agents T and R both achieve triple-A conformance. They must be equally 
accessible." Yet a closer look at the claim shows that user agent cites 30 
inapplicable checkpoints and the other cites only 2 inapplicable 
checkpoints. Is that a fair comparison?

Problem #2: A buyer of user agents says: "According to their developers, 
user agent S achieves double-A conformance and user agent U achieves 
single-A conformance. User agent S must be more accessible than user agent 
U." Yet a closer look at the claim shows that user agent S cites 15 
inapplicable checkpoints and the other cites only 1 inapplicable checkpoint. 
Is the single-A conformant user agent really less accessible than the 
double-A conformant user agent?

Problem #3. A developer of user agent X makes a claim that says, "A 
composite user agent W composed of user agents X, Y, and Z achieves triple-A 
conformance. Wow! Agent X must be a very accessible user agent!" A closer 
look at the claim shows that there are only 3 inapplicable checkpoints. Not 
too bad! But what the conformance claim does not reveal is that user agents 
Y and Z _by themselves_ would achieve the same thing (triple-A conformance 
with 3 inapplicable checkpoints). This could occur, for example, if user 
agents X and Y were actually the same kind of user agent. Regardless of how 
inaccessible user agent X is, it does not lower the overall rating the 
composite user agent that includes user agents Y and Z. The public who reads 
the claim assumes that user agent X is highly accessible, yet in reality it 
contributes nothing to the overall rating.

A Problem That I Would Like to Be Assured Could Not Arise

Problem #4. A user agent adheres fully to the checkpoints, notably 
checkpoint 1.1 (though see Issue X below) and checkpoints in guideline 5 
("Observe system conventions and standard interfaces), but the user agent is 
not fully operable and usable by people who are blind, deaf-blind, have 
physical disabilities, etc., because although the document requires the 
prerequisites for such operability, it does not actually require that 
operability.

SOME PREREQUISITES TO SOLVING THE PROBLEMS

Generally, we need to focus clearly on who our audience is and what kinds of 
decisions we want them to be able to make based on the conformance claims.

I don't know if the following will entirely solve the problems, but I think 
that they will make considerable progress.

====

Suggestion 1. Focus more specifically on "general-purpose graphical desktop 
browsers that provide multimedia presentation capabilities".

Instead of trying to address all different kinds of user agents, I believe 
that the scope should narrow. For example, about the ideal scope that I can 
think of at this moment is: "general-purpose graphical desktop browsers that 
provide multimedia presentation capabilities".  (I can think of other 
definitions that may have technical advantages, but I don't think that they 
communicate as well.)

For the most part, I am merely suggesting a tightened focus. For at least 
months, it seems that the UAAG working group has acknowledged that the 
document has general-purpose graphical desktop browsers are of primary 
interest. I am merely suggesting lumping in the multimedia capabilities 
(audio, animation, and motion video).

I think that in this matter, we are far better off doing one thing well 
rather than trying to do too much and doing them all not so well.

====

Suggestion 2. Define the term 'fully compliant user agent'.

"For the purpose of this document, a 'fully compliant user agent' is a user 
agent that (a) achieves a triple-A rating (i.e., adheres to all applicable 
checkpoints) and (b) has _no inapplicable checkpoints_. One may also refer 
to such a user agent at a certain conformance level. For example, a 'fully 
compliant double-A user agent achieves the double-A UAAG level and has no 
inapplicable Priority 2 or Priority 1 checkpoints. "

====

Suggestion 3. Acknowledge the necessity for composite user agents.

The document should acknowledge the following:

"It is recognized that user agents that provide 'general-purpose graphical 
desktop browsers that provide multimedia presentation capabilities' may 
actually constitute a "composite user agent", i.e., a user agent that is 
composed of multiple, 'smaller', user agents such as (a) a general-purpose 
graphical desktop browser and (b) a multimedia player. Indeed, at the time 
of the publication of this document, a general-purpose graphical desktop 
browser typically relies on a distinct multimedia player for multimedia 
capabilities. "

====

Suggestion 4. Define the terms 'prime user agent' and 'supplementary user 
agent'.

New:

"Conformance claims must designate a 'prime user agent'. If the claim is for 
a composite user agent, then the prime user agent should be the user agent 
for which the claimant has the most direct interest or knowledge. For 
example, the developer of a multimedia player might designate the multimedia 
player as the prime user agent, making the other user agents, 'supplementary 
user agents'. If a claim is for a singular user agent, then that single user 
agent is the prime user agent."

====

Suggestion 5. Allow few if any inapplicable checkpoints.

I think that we need to set a maximum number of inapplicable checkpoints or 
perhaps even allow no inapplicable checkpoints. Another way of saying this 
is that any valid claim must encompass all or nearly all of the UAAG 
checkpoints. Does it really make sense to try to compare the accessibility 
of (a) a composite user agent with a vast array of functionality and (b) a 
user agent that has only a tiny fraction of the same functionality?

====

Suggestion 6. Define a clear relationship between the fully compliant user 
agent and capabilities associated with screen readers and refreshable 
braille user agents.

The relationships between the fully compliant user agent and braille and 
screen-reader-type capabilities is critical because braille and 
speech-synthesis are integral to our concept of accessibility, notably 
through the concept of text elements (including text equivalents), which 
must be understandable when output to synthesized speech and braille.

As I consider the current document (18 August 2000), the capabilities 
associated with screen readers and braille devices are _outside_ the 
boundary of the fully compliant user agent. For example, no checkpoint 
requires that a user agent be operable via screen reader/speech-output 
program. Nor does any checkpoint require that the user agent be operable via 
a refreshable braille device. I might not be so concerned about these lacks 
if there were checkpoints that specifically required _fully compatibility_ 
with screen-reader-type programs and refreshable braille devices. But no 
checkpoint specifically requires such compatibility or operability. It 
appears to me that adherence to several checkpoints in Guideline 5 ("Observe 
system conventions and standard interfaces") fulfill critical prerequisites 
for operability by facilitating communication with such devices. And 
certainly the checkpoints in guideline 7 ("Provide navigation mechanism") 
and other guidelines would be very relevant for navigating through a 
document via speech output or braille, but if they may do little good if 
there is _no actual requirement for operability_ via speech-output and 
braille device. I am concerned that there may be a gap that may be unbridged 
between the UAAG requirements and full operability via such user agents. I 
am not sure how big of a problem this is. For the purpose of the present 
discussion, suffice it to say that the capabilities associated with screen 
readers and braille devices are _outside_ the boundary of the fully 
compliant user agent.

This discussion brings to mind a comment made by at least one individual in 
a recent conversation who said approximately as follows: "We plan to comply 
with the UAAG document using our browser and JAWS for Windows." However, if 
I understand the current UAAG document correctly, the document does not 
specifically require operability via any package like JAWS for Windows.

I think that this would mean that, under the current document, the 
conformance claim for a fully compliant user agent need not actually mention 
screen reader packages or braille devices. I am again concerned that this 
may not be adequate.

By the way, I think that we need to keep in mind that it is the checkpoints 
that constitute the normative part of guidelines. The introductory material 
for guidelines and the notes attached to checkpoints are not what matter. It 
is the checkpoints themselves that are the requirements. (Please correct me 
if I am wrong in this idea.)

====

Suggestion 7. Add checkpoints that require basic graphical and multimedia 
capabilities.

I mentioned this suggestion before and saw Ian Jacob's 18 August 2000 
response [1]. Ian cited earlier discussions that resulted in the exclusion 
of such requirements. But I would say again that it makes no sense to me at 
all to set out requirements for a user agent of the type we are referring to 
in this document and fail to mention that it must be able to present 
graphics and multimedia (including audio, animation, video, etc.). Such 
media presentation capabilities are extremely important for people with a 
variety of disabilities (deaf, blind, learning disability, cognitive 
disability). Furthermore, I think that an implicit part of our accessibility 
philosophy is that people with disabilities should be free to rely on 
primary content (e.g., the text, graphics, video, audio, animation, etc., 
that is intended for people without any disability) as much as they want as 
well as to have access to secondary content that can substitute for portions 
of the primary content that is inaccessible to them. I think that failure to 
require that at fully compliant user agent to present these basic types of 
media would represent a gaping hole in the document. While there may have 
been good reason to exclude these requirements in a earlier stage of the 
development of the document, I don't think that those reasons hold any 
longer. Finally, I would add that if the working group agrees to the tighter 
focus on 'general-purpose graphical desktop browsers that provide multimedia 
presentation capabilities', then it would seem all the more puzzling to lack 
a requirement for presentation of graphics and multimedia.

====

Suggestion 8. Consider adding functional requirements that are more specific 
to the needs to particular disability audiences.

I think that it is worth considering adding more general functional 
requirements to the existing checkpoints. Such requirements might help 
ensure operability.

From the Trace R&D revision of the NPRM proposed standards [2]:

 2194.27 Functional performance criteria.
NOTE: If users would typically have related assistive technology with them 
whenever they wanted to use the E&IT then the ability of the product meet 
this criterion can be evaluated with the assistive technology(s) in place.
(1) At least one mode of operation and information presentation that does 
not require user vision and that allows full access shall be provided.
(2) At least one mode of operation and information presentation that does 
not require visual acuity greater than 20/200, that does not require audio 
perception, and that allows full access shall be provided.
(3) At least one mode of operation and information presentation that does 
not require user hearing and that allows full access shall be provided.
(4) Where audio information is important for the use of a product, at least 
one mode of operation and information presentation shall be provided in an 
enhanced auditory fashion.
(5) At least one mode of operation and information presentation that does 
not require user speech and that allows full access shall be provided.
(6) At least one mode of operation and information presentation that does 
not require fine motor control or simultaneous actions, that is operable 
with limited reach and strength, and that allows full access shall be 
provided.
(7) ADVISORY: Wherever possible products should minimize the cognitive and 
memory ability required of the user and accommodate people with learning 
disabilities.

====

Suggestion 9. Require conformance claims to indicate the identity of the 
claimant.

The claimant could be an individual, an organization, or a part of an 
organization.

====

Suggestion 10. Require that for each component in the claim, the claimant 
indicate its role.

For example, for each component, the following roles might be allowed: 
Developer, User, Other, etc.

====

Suggestion 11. Require that if two or more components of a claim are the 
same component, a rationale for this must be included.

We want to avoid claims that might contain problems like problem #3 at the 
beginning of this memo.

====

Suggestion 12. Reexamine situations in which the language of "applicability" 
occurs within checkpoints.

I think that we need to examine how the word "apply" or related words are 
used and see if we really want them associated with the concept 
applicability.

====

Suggestion 13. Define the circumstances under which a two or more user 
agents become to be counted as a single user agent.

====

Suggestion 14. Define the circumstances under which the user interface (per 
checkpoint 1.1) of a user agent comes to include the user interface of 
another user agent.

====

Suggestion 15. Explain what we think are appropriate uses of the ratings.

For example, is it appropriate to use such ratings as sole criteria in 
buying decisions? Even more modestly, are the ratings appropriately used in 
representing the accessibility factor in buying decisions.


[1] http://lists.w3.org/Archives/Public/w3c-wai-ua/2000JulSep/0263.html
[2] http://www.access-board.gov/sec508/comments-nprm/101.html

<END OF MEMO>

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Received on Saturday, 19 August 2000 03:26:53 GMT

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