Draft #1 of TV Remote Control API Comments

Colleagues:

The following draft of comments on the TV Remote Control API
specification  for our consideration previous to a CfC ...

Draft Comment

The Accessible Platform Architectures (APA) Working Group makes the
following comments on the draft TV Control API specification at:

https://www.w3.org/tr/tvcontrol-api/

*	No alternative media support

We would draw your attention to the multiple alternative media formats
that are used by persons with disabilities as set forth in our W3C Note
publication: "Media Accessibility User Requirements (MAUR)" available
at:

http://www.w3.org/TR/media-accessibility-reqs

This document describe the use of alternative media such as captions and
video descriptions.

Our reading of the Tv Control API draft finds no way for users to learn
of the presence of any MAUR identified alternative media with any
particular TV content, nor any means to request display of alternative
content. This is a fundamental accessibility requirement on TV Controls
and we believe it must be factored into this specification.

*	Alternative Media on Second Screen Devices

The above referenced MAUR notes that alternative media might be directed
to second screen devices. We believe support for directing alternative
video, audio, and/or text to secondary devices is a fundamental
accessibility requirement on TV Controls and should be supported in this
API.

http://www.w3.org/TR/media-accessibility-reqs/#requirements-on-secondary-screens-and-other-devices

*	Legal Requirements

The Federal Communications Commission (FCC) in the U.S. has explicit
requirements on how alternative media are to be exposed to consumers.
Developers should be flagged most especially on the requirement that
captioning must be enableable by top level controls. These FCC
requirements implement provisions of a U.S. law known as the
"Twenty-First Century Communications and Video Accessibility Act" as
explained by the FCC at:

https://www.fcc.gov/general/twenty-first-century-communications-and-video-accessibility-act-0#block-menu-block-4

The FCC's regulations pertinent to this specification were published in
December 2016 in the document: "Accessibility Requirements for
Television and Set-Top Box Controls, Menus, and Program Guides"
available at:

Also relevant is the document "Display of Captioning on Equipment Used
to View Video Programming" available at:

https://www.fcc.gov/consumers/guides/closed-captioning-display-requirements-equipment#block-menu-block-4

We recognize the above are comments are quite general in nature. It
seemed best to succinctly state our concerns at this time and to offer
our support toward adding support for alternative media access in the TV
Remote Control API. Please let us know how we can help.



PDF:		https://apps.fcc.gov/edocs_public/attachmatch/DA-16-1416A1.pdf
MS-Word: https://apps.fcc.gov/edocs_public/attachmatch/DA-16-1416A1.docx

-- 

Janina Sajka,	Phone:	+1.443.300.2200
			sip:janina@asterisk.rednote.net
		Email:	janina@rednote.net

Linux Foundation Fellow
Executive Chair, Accessibility Workgroup:	http://a11y.org

The World Wide Web Consortium (W3C), Web Accessibility Initiative (WAI)
Chair, Accessible Platform Architectures	http://www.w3.org/wai/apa

Received on Wednesday, 15 February 2017 16:54:53 UTC