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Re: Accessibility and Conformance, etc.

From: Jon Gunderson <jongund@ux1.cso.uiuc.edu>
Date: Mon, 21 Aug 2000 10:37:45 -0500
Message-Id: <4.3.1.2.20000821101413.01226700@staff.uiuc.edu>
To: "Eric Hansen" <ehansen7@hotmail.com>, w3c-wai-ua@w3.org
Cc: ij@w3.org
Eric,
There is a difference between a user agent being accessible to a person 
with a particular type of disability and conforming to the guidelines.  The 
guidelines are designed to make technologies more accessible out of the box 
and provide a means for assistive technologies to access the 
functionalities of the assistive technology.  The group has spent a lot of 
time on this issue and been over ALL of the arguments and issues that you 
have raised below. The consensus of the group is the current conformance 
statement.  For more severe disabilities assistive technologies are often 
required and it was the consensus of the group that:

1. User agents must provide accessibility for the input and output 
modalities they support.
2. User agents must be compatible with assistive technologies for 
modalities they do not support.

For people that can use the input and output modalities supported by the 
user agent then a conforming user agent should be more accessible to 
them.  For people with disabilities who cannot use the native input and/or 
output modalities of the user agent must support assistive technologies to 
provide access to the functionalities of the user agent.  Therefore many 
people will only be able to use a conforming user agent with an assistive 
technology.  There is no requirement that a user agent developer show that 
they are compatible with a particular assistive technology.  The line is 
drawn in the sand, through conformance, that they have done there part in 
making their product accessible through assistive technologies.  It is up 
to AT developers to do their part to use the features of the conforming 
user agent to provide alternative input and output capabilities.

The group has spent a considerable amount of time on the conformance issue 
and unless new information is brought to the group, we will not open it up 
for discussion.

Jon


At 03:26 AM 8/19/2000 -0400, Eric Hansen wrote:
>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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Jon Gunderson, Ph.D., ATP
Coordinator of Assistive Communication and Information Technology
Division of Rehabilitation - Education Services
MC-574
College of Applied Life Studies
University of Illinois at Urbana/Champaign
1207 S. Oak Street, Champaign, IL  61820

Voice: (217) 244-5870
Fax: (217) 333-0248

E-mail: jongund@uiuc.edu

WWW: http://www.staff.uiuc.edu/~jongund
WWW: http://www.w3.org/wai/ua
Received on Monday, 21 August 2000 11:36:26 GMT

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