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Your comments on WCAG 2.0 Last Call Draft of April 2006

From: Loretta Guarino Reid <lorettaguarino@google.com>
Date: Thu, 17 May 2007 16:28:04 -0700
Message-ID: <824e742c0705171628iabccd9ap5f48364e18aa02f6@mail.gmail.com>
To: "Arun Ranganathan" <arunranga@aol.com>
Cc: public-comments-WCAG20@w3.org

Dear Arun Ranganathan ,

Thank you for your comments on the 2006 Last Call Working Draft of the
Web Content Accessibility Guidelines 2.0 (WCAG 2.0
http://www.w3.org/TR/2006/WD-WCAG20-20060427/). We appreciate the
interest that you have taken in these guidelines.

We apologize for the delay in getting back to you. We received many
constructive comments, and sometimes addressing one issue would cause
us to revise wording covered by an earlier issue. We therefore waited
until all comments had been addressed before responding to commenters.

This message contains the comments you submitted and the resolutions
to your comments. Each comment includes a link to the archived copy of
your original comment on
http://lists.w3.org/Archives/Public/public-comments-wcag20/, and may
also include links to the relevant changes in the updated WCAG 2.0
Public Working Draft at http://www.w3.org/TR/2007/WD-WCAG20-20070517/.

PLEASE REVIEW the decisions  for the following comments and reply to
us by 7 June at public-comments-WCAG20@w3.org to say whether you are
satisfied with the decision taken. Note that this list is publicly

We also welcome your comments on the rest of the updated WCAG 2.0
Public Working Draft by 29 June 2007. We have revised the guidelines
and the accompanying documents substantially. A detailed summary of
issues, revisions, and rationales for changes is at
http://www.w3.org/WAI/GL/2007/05/change-summary.html . Please see
http://www.w3.org/WAI/ for more information about the current review.

Thank you,

Loretta Guarino Reid, WCAG WG Co-Chair
Gregg Vanderheiden, WCAG WG Co-Chair
Michael Cooper, WCAG WG Staff Contact

On behalf of the WCAG Working Group

Comment 1:

Source: http://www.w3.org/mid/449B9208.3080202@aol.com
(Issue ID: LC-1332)

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 "SKWOD" 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 example, 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 television.

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 described 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.

Response from Working Group:

The working group considered carefully the levels assigned to all the
GL 1.2 success criteria. SC 1.2.1 and 1.2.2 are level A success
criteria because vision and hearing impaired users will not be able to
access multimedia without this information. SC 1.2.2 can be satisfied
by a full transcript. But captioning is a much better augmentation for
the deaf than a separate transcript, since much can be communicated
non-verbally, even when there is no action.

The working group acknowledges that current acquisition process and
production model for the much of the video content distributed by
commercial Internet portals creates a problem in creating captions for
time-sensitive material in a timely manner, and that this may present
a near term barrier for multimedia that is time-sensitive.

However, without captions individuals who are deaf or hard-of-hearing
cannot access multimedia, and AT cannot compensate for lack of
captions.  There are other alternatives, like full text alternatives,
but they face similar issues and are less useful to people who are
deaf.   WCAG conformance is also based on the state of the content,
not the process by which it is produced.  Captioning therefore belongs
at Level A.

We have added the following language to How To Meet SC 1.2.1 that
recognizes the current barriers to captions.

"It is acknowledged that at the present time there may be difficulty
in creating captions for time sensitive material and this may result
in the author being faced with the choice of delaying the information
until captions are available, or publishing time-sensitive content
that is inaccessible to the deaf, at least for the interval until
captions are available.   Over time, the tools for captioning as well
as building the captioning into the delivery process can shorten or
eliminate such delays."
Received on Thursday, 17 May 2007 23:28:30 UTC

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