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AOL LC Comments on WCAG 2

From: Arun Ranganathan <arunranga@aol.com>
Date: Fri, 23 Jun 2006 00:02:32 -0700
Message-ID: <449B9208.3080202@aol.com>
To: public-comments-wcag20@w3.org

Email: arunranga@aol.com

Affiliation: Advisory Committee Representative to the W3C for AOL LLC

Date: June 20, 2006

1) Document Abbreviation: W2

2) Item Number: 1.2

3) Part of Item (Heading): "Guideline 1.2 Provide synchronized 
alternatives for multimedia."

4) Comment Type: G.

5) Comment (Including rationale for any proposed change):

The purpose of the following LC Comment is to highlight issues that we 
believe warrant further consideration by the Web Content Accessibility 
working group before assigning a Level 1 requirement to Guideline 1.2.1: 
"captions are provided for prerecorded multimedia," particularly as the 
WAI's Web Content Accessibility guidelines are used as the benchmark for 
web accessibility by government and other policy-making bodies.

AOL LLC fully understands and supports the need for captioned 
multimedia, and we do provide the same on several of our highly 
trafficked areas. AOL was
the first commercial Internet Service Provider to offer captioned video. 
Today, we provide captions for two cartoon series "Princess Natasha" and 
on KOL, AOL's online channel for kids ages 6-12, and on video help 
tutorials developed for the AOL 9.0 software. Additionally, we are 
currently testing
delivery of captioned news and entertainment content through our video 
portal. We continue to work hard at this area, and plan on announcing 
further such
developments as they take place.

Technologies such as SMIL, Microsoft's SAMI and Apple’s QuickTime all 
enable display of closed captions on multimedia, and tools like Caption 
Keeper from the WGBH Media Access Group can be used to repurpose Line 21 
television caption data. However, AOL's research to date shows that the 
acquisition process and production model for the majority of video 
content distributed by commercial Internet portals such as AOL LLC does 
not support cost-effective and efficient processes for delivery of 
closed captions in a timely manner. A collaborative effort between the 
Internet industry, content producers and web accessibility experts is 
required to develop solutions before commercial web portals can fully 
conform to this Level 1 requirement to caption prerecorded multimedia. 
Guideline 1.2.1 assumes that the web site displaying the multimedia 
content is the producer of the content. What is not considered is the 
barriers created by the process of acquiring repurposed third party 
content, or who is responsible for captioning content produced by a 
third party and distributed via multiple web sites/services.
While AOL LLC has made substantial progress towards captioning of our 
video content, there are three barriers inhibiting AOL LLC's goal of 
complete conformance to a Level 1 success criteria:

i. Internet production units of broadcast networks prepare the content 
for streaming before the content is captioned, usually in real time. For 
field packages produced for TV networks' nightly newscasts are often 
streamed before they air. As a result, Internet portals receive the 
video asset too
far up stream in the content production workflow. This presents two 
possible scenarios:

- A content aggregator (Internet portal such as AOL's) needs to manually 
caption a video stream produced and owned by a separate content 
provider. Neither
is this scalable, nor are vendor solutions robust enough at this point 
(e.g leveraging a programmed transcript which only provides the text of 
the audio,
and excludes ambient sounds and time stamp data).

- Captions are added to the streaming video long after it has been 
published to the web site assuming the portal and partner repurpose the 
captions originally
created during the TV broadcast. This is problematic as some videos have 
a very short shelf life.

ii. Lack of information on the whereabouts of existing caption files 
when broadcast content is repurposed for the Internet. There is an 
increasing amount of "video on demand" products online that allow people 
to view archives of current or old TV series, movies, music videos, 
short films, etc. It is very likely that most of the content has been 
captioned. Unfortunately there isn't a central database that Internet 
portals or content partners can search to locate the caption agency who 
captioned a particular season of a show. It is important to note that 
the content provider to the portal may not always be the content 
producer or the entity responsible for captioning the content for 

iii. Need for a common delivery protocol. Commercial Internet portals 
receive video from many of the same content providers (broadcast 
networks, etc.).
Internet production units are generally very small in terms of staff so 
delivering multiple text formats to multiple portals is not feasible. 
Solutions are required to ensure content providers can deliver caption 
data in an efficient, cost-effective manner. This is a solvable problem, 
but identifying solutions will require cooperation from many players.

AOL LLC proposes changing the Level 1 Success Criteria for Guideline 
1.2, namely 1.2.1 and 1.2.2, to Level 2 Success Criteria. This change 
reflects the
ground realities of being a content aggregator on the Web. This proposal 
is necessitated by the current reality that content aggregators on the 
Web partner
with multiple content providers. Issues such as who is responsible for 
producing captions, delivery of caption text files and other barriers 
above must be addressed before policy-making bodies can effectively 
leverage this guideline. Alternatively, we recommend adding language 
which recognizes
the current barriers to wide scale availability of captions for 
prerecorded multimedia, and encourages development of solutions to 
resolve them.

Arun Ranganathan
System Architect, AOL LLC
Advisory Committee Representative, W3C
Received on Friday, 23 June 2006 07:01:19 UTC

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