- From: Janina Sajka <janina@rednote.net>
- Date: Wed, 22 Mar 2017 10:53:28 -0400
- To: public-tvcontrol@w3.org
- Cc: W3C WAI Accessible Platform Architectures <public-apa@w3.org>
Colleagues: 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/ Our review and Working Group Decision in support of these comments is logged at: http://lists.w3.org/Archives/Public/public-apa/2017Mar/0018.html We appreciate that an API for TV remote control could be utilized for enabling accessible alternative Web applications to provide radio and TV services to users with disabilities who may find it difficult or impossible to operate any user interface supplied with a particular browser or hardware device. This is an inherent accessibility strength for any API that provides for sufficient feature support. Regretably, we believe the current TV Remote Control API as currently defined lacks required accessibility feature support. * 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 Please note that this document was developed in order to inform the development of the HTML 5.0 specification itself. As a result of this note, HTML provides sufficient feature support to support accessibility in HTML's video and audio elements. 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 APA's predecessor Working Group, Protocols and Formats WG also provided use cases and requirements to the Second Screen Working Group on how alternative media might be directed to second screen devices. We believe support for directing alternative video, audio, and/or text to secondary devices, as described in the MAUR, is also a fundamental accessibility requirement on TV Controls and should be supported in this API. * Legal Requirements The Federal Communications Commission (FCC) in the U.S. has explicit legally mandated regulations setting forth some strict requirements on how certain alternative media are to be exposed to consumers. These regulations also require accessible program guides. We believe that 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: 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 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 Additionally, we would request that your API reference the MAUR in your appendices in order to assist developers in meeting both their moral and legal requirements in support of accessibility. -- 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 -- 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, 22 March 2017 14:53:56 UTC