To the HTML Co-Chairs: comments regarding longdesc

To the HTML Co-Chairs and the HTML Working Group:

We are writing on behalf of the Digital Image and Graphic Resources for Accessible Materials Center (DIAGRAM; http://diagramcenter.org/) in support of the reinstatement of @longdesc into HTML5 (http://www.w3.org/html/wg/wiki/ChangeProposals/InstateLongdesc).  We believe that omitting @longdesc from HTML5 would be a serious blow to the cause of accessibility, and would set back nearly two decades of work by accessibility researchers, technologists and educators throughout the world.

Other international working groups, such as those developing recommendations for digital talking books (DTB) and e-books (EPUB), look to HTML5 for guidance and conformance. Without a specified method for providing long descriptions, it is entirely possible that HTML documents, e-books and DTBs will wind up providing long or detailed descriptions in independent and perhaps incompatible ways. Such confusion in the delivery of long descriptions will undoubtedly result in a delay and/or reduction in the accessibility of textbooks with obvious negative impacts for students with print disabilities. Furthermore, as textbooks, electronic media content, Web browsers, mainstream e-readers and assistive technology continue to merge and are used interchangeably, a single universal standard for providing high-quality detailed image descriptions is essential.

Removing @longdesc from HTML5 without replacing it with superior technology puts people with print disabilities at a severe disadvantage.  It is not possible to overstate the importance of having long-description support in HTML5.  In its current state, @longdesc is the only method for authors to provide externally stored descriptions in a non-visual manner to users with print disabilities. @longdesc is in widespread use (http://www.d.umn.edu/~lcarlson/research/ld.html), and it is supported by widely available access technologies. Because @longdesc can point to external resources, it can deliver high-quality, detailed descriptions in a method that no other element, attribute or property can provide today.  Without this attribute, authors of Web sites, electronic textbooks and other digital resources have no way to efficiently deliver long image descriptions to users with print disabilities.  Access to educational materials, some of which are mandated by national laws, will be disrupted for countless blind and visually impaired students worldwide.

In order to avoid a gap during which no long-description method is specified in HTML5, we strongly urge you to put @longdesc back into the recommendation before it reaches last-call status.  Please note that the HTML Accessibility Task Force is developing a consensus on the best way forward to reintegrate @longdesc into HTML5 while a new method is created to provide long descriptions not just for images, but for any element or object that needs describing.  It is our intent to work closely with the task force to reach a consensus on this issue quickly and efficiently; in fact, the signatories below are already involved in this process, either on behalf of DIAGRAM or independently as members of the HTML working group.  The impact of the loss of @longdesc during last-call status will be acute, and we therefore request that you issue a call now for alternate proposals rather than waiting until last call, which could add months to the timeline for a solution.   Working with the task force, we will provide a proposed solution within the 30-day time period provided for alternate proposals.

It is also important to note that other international working groups, such as those specified above, are on a faster track than HTML5.  A prompt decision now to reintegrate @longdesc would not only provide assurance that HTML5 will properly accommodate users with print disabilities; it will also obviate the need for these groups to develop their own long-description methods.

As more and more information is conveyed solely visually over the Web, it's crucial to have a standard approach to provide accessible versions of visual information in order for people with disabilities to have an equal opportunity for education, employment and social inclusion.  The U.S. federal government has invested significant funding in the widespread use and promotion of detailed image descriptions. A first step in requiring access to K-12 educational materials for students with print disabilities was the creation of the National Instructional Materials Accessibility Center (NIMAC) and the National Instructional Materials Accessibility Standard (NIMAS), both of which were adopted as part of the federal Individuals with Disabilities Education Act (IDEA) in 2004. These initiatives require all U.S. K-12 textbook publishers to provide both structured text content as well as all relevant graphics, to ensure students with disabilities get equal access to educational content.

The DIAGRAM Center is another such effort. DIAGRAM is a five-year collaboration launched in 2010, funded by the U.S. Department of Education, between Benetech, The U.S. Fund for DAISY and the Carl and Ruth Shapiro Family National Center for Accessible Media at WGBH (NCAM).   A primary aim of the project is to expand the field of high-quality image descriptions and interactive exploration of graphical content in electronic educational materials of all types, particularly DTBs, e-books and browser-based materials.  The exclusion from HTML5 of any method for providing detailed image descriptions will have an impact on all of these formats.

In addition, the U.S. National Science Foundation has funded five years of research and dissemination of guidelines for describing science, technology, engineering and math images. Lead by NCAM, this project has spearheaded efforts across the accessibility industry worldwide to rigorously instruct authors of Web sites and electronic books that, as of today, @longdesc is the best way to provide detailed image descriptions. The need for descriptions will continue to increase as the combined efforts of many initiatives, including those named above, further influence practice in the world.

Finally, features developed to help people with specific disabilities also assist other users, and this is true for long image descriptions. Today, for example, Firefox and Opera allow the user to open a context menu over an image and choose to see the long description on the screen, if @longdesc is included with the image. This is an excellent tool for assisting sighted students with learning disabilities who need textual reinforcement when deciphering the contents of a complicated image.  Also, as image descriptions become more widely used, it is expected that search engines can take advantage of descriptions in locating relevant images.

People with disabilities have struggled for full inclusion in society.  The positive attitude by technologists towards adding small features for accessibility into the architecture of the Web and its standards has led to tremendous progress.  As the challenge of gaining access to the text contained in books is now finally being met through major advances in electronic book accessibility, image accessibility is the next frontier.  As more and more educational, governmental, commercial and social content moves to images, now is not the time to backslide in this area.

Sincerely,

Jim Fruchterman, Founder and CEO, Benetech

George Kerscher, President, International Digital Publishing Forum (IDPF)

Geoff Freed, Project Director, Carl and Ruth Shapiro Family National Center for Accessible Media at WGBH (NCAM); member, HTML working group and HTML accessibility task force