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Re: [171] accessible rebroadcasts

From: Charles McCathieNevile <charles@w3.org>
Date: Mon, 23 Jun 2003 02:50:15 -0400 (EDT)
To: Joe Clark <joeclark@joeclark.org>
cc: WAI-GL <w3c-wai-gl@w3.org>
Message-ID: <Pine.LNX.4.30.0306230204290.17496-100000@tux.w3.org>


Policy decisions are, I believe, outside the scope and the competence of
WCAG - we need to make it possible to use WCAG in policy-making, but should
not be trying to create off-the-shelf policy. This means we should expect
people to profile WCAG and require subsets, so we should be clear about who
each requirement is serving (who will miss out if that requirement is not in
a given policy for immediate application). Not much else that is new - just
responding to some of Joe's questions.

(I've made the policy argument before too. If you've been reading this list
for three years this message might not be interesting).

details below



On Sun, 22 Jun 2003, Joe Clark wrote:

>>Internet radio is not accesible to Deaf people unless it has
>>captions or signed captions.
>"Signed captions" wouldn't be captions, because that would be a
>translation, and sign language is accessible only to the speakers of
>its translated language, while captioning is accessible to all
>speakers of the source language.

Well, technically correct, but beside the point. Is there a shorter term than
"a sign language equivalent to captions"?

>I would just like proponents of *requiring* all online audio feeds to
>be captioned to establish the following:

The point of my strawman is that in participating in WCAG I am not proposing
to require all online audio feeds to be accessible. I am helping to outline
the features that Web Content which is accessible actually have. Proposing
requirements taken into account in a given design brief is something that the
commissioning organisation should do, subject to the principles and laws of
the environment they work in.

>>WAI doesn't invalidate anything - it just lays out the technical
>>information required so that people can make sensible decisions of
>>fact (is Internet radio accessible as is?) and based on those they
>>can make policy decisions (should internet radio reqiure captions?
>>SHould all movies always require audio description? Starting
>WCAG invalidates inaccessible Web features. WCAG articulates
>principles and provides certain limited technical guidance.

>It's also seemingly contradictory here: Charles flatly states that
>net radio, to use the example, is inaccessible to deaf listeners,
>meaning he would presumably countenance fixing the problem once and
>for all. Yet here he says WCAG should simply state a problem and let
>somebody else decide to fix it.

Huh? I would indeed countenance somebody fixing the problem. I won't
countenance participating in work where we say "oh, we can fix it by
declaring that despite clear contrary evidence it isn't a problem".

And I don't believe WAI, the WCAG group, nor even W3C as a whole, has the
ability, nor the responsibility, to fix it. WCAG can describe the problem,
and what the technical requirements are to fix it.  The actual costs, and
whether they are reasonable or not, is something that varies from country to
country and case to case - and is outside the scope of this working group as
I understand it.

>And what *I* wrote was:
>>>No captions for audio-only feeds even if they're nothing but voice.
>>>I don't want WAI essentially invalidating net radio. Compact discs
>>>don't have to be made accessible to the deaf because their sound
>>>contents have no visual component, but music videos must be
>>>captioned because they do have a visual component. The same
>>>principle applies here.
>Captions would be permitted. We just wouldn't require them. I suppose
>I should have made that more obvious.

No, it seemed obvious enough to me. Things are not forbidden if they are not
required to meet WCAG conformance.

>>My interest in this group is in writing techniques. Providing
>>techniques for captioning internet radio streams is one thing, but
>>working on techniques for deciding when they become mandatory is
>>something that is best decided by policy makers, and something that
>>will be decided differently in different areas.
>WCAG *requires* certain accessibility steps be taken to achieve Level
>[X] compliance. WCAG is all *about* requirements even if the ultimate
>WCAG is verbally camouflaged as a W3C "recommendation."

Ah. You seem to confuse WCAG conformance with meeting legal requirements in
North America. In order to conform to WCAG, there are certain things you need
to do which hopefully amount to making your site accessible. With different
levels, there are sets of requirements for making your site "barely
accessible", "reasonably accessible" and "very accessible" - my personal
interpretation of the intent of levels A, double-A and triple-A.

When somebody should meet the requirements of WCAG, whether the cost is
reasonable or not, and such considerations, seem to me outside the scope of
the working group. If internet radio without captions is inaccessible in two
years, it is because it is inaccessible now. (In fact the one thing that
might change that is technology development, which complicates our

>I don't know why Charles has his knickers in a knot about this. Maybe
>he could give it another go, answering my queries above and trying
>harder to make sense this time.
>>Grace periods and exemptions to allow people to conform are not what
>>the WCAG group is about
>How are Priority 1, 2, and 3 compliance today really different from
>phased-in grace periods? Meet Priority 1 now, and later, after some
>more work, meet 2, then later still and after more work, meet 3.
>I provided my suggestions for audiovisual accessibility in direct
>response to Gregg Vanderheiden's query and in response to a couple of
>off-list requests.
>I have opted not to spend an hour and a half writing 2,000 words
>providing a technical justification for what I wrote, but trust me:
>There is neither the technology nor the funding nor the expertise in
>the world right now to caption all online video. The money part isn't
>going to go away soon. But the technology and expertise could be
>ramped up rather quickly if a deadline were looming. My suggestion
>requires *some* online video on a site to carry captions (audio
>description is a separate discussion) to meet Level [X] accessibility
>in WCAG 2.0. Two years (for example) later, that same site would have
>to caption *all* its new video to meet Level [X]. That's an audacious
>requirement, all but unprecedented, in fact. (I know of one limited

I agree with the above. I just believe that the policy bit of it needs to be
done in areas where policy is made.

>That all seems like win-win to me. As it stands, there is almost no
>video on the Web with captions. It is nearly impossible to find. For
>a multimedia-rich site, this is a severe stumbling block to meeting
>current Priority 1 accessibility *requirements* under WCAG 1.0. As I
>have explained to WAI (note well: WAI) many times in the past, if
>WCAG goes overboard in specific areas, developers will simply refuse
>to adopt the whole package. That will certainly be true if Level [X]
>compliance in 2.0 is based on an all-or-nothing group of
>requirements, as is currently the case.

[the new bit (well, new-ish)]

Yes. In explaining how to work WCAG into policy this group should be working
with the Education and Outreach Group on the importance of being able to
make profiles of WCAG to deal with implementation details like unreasonable
burdens, and on the importance of the guidelines themselves making it clear
who is not getting accessibility if a particular requirement is not met. Then
the policy makers can weigh up their situation and make better-informed
decisions, which balance the needs of "consumers" and the needs of

>>  - and they seem to be closely predicated on the application of WCAG
>>to North America - or are you arguing that a grace period of about 2
>>years would be appropriate for Vietnamese-produced net-TV and
>>educational video supplied in English/French/Bislama over the
>>internet by the government of Vanuatu?
>Canada and the United States, but certainly not Mexico, are the world
>leader in AV accessibility. Australia, merely as an example, can't
>even get its act together on TV captioning.

Canada and the United States, collectively, are an edge case - just a larger
one than my choices (I should have put a comma after Net-TV to seperate the
two examples more clearly).

Do you consider that WCAG defining a two year period (from the publication of
WCAG or from today?) would be appropriate for the expected 25-state European
Union, Mexico, Russia, Australia, South America, and those African states
that produce audiovisual Web content, or just for your local edge case?

This is the real question. If you do, then I simply disagree, but we can
leave it to the group to decide.

Otherwise, my suggestion is that we recommend that particular aspect of the
question be answered by people better-placed to weigh the additional factors
required, by describing what is required (in terms of features Web content
needs) to really fix the problem, and being clear that this description is
not a complete ready-made off the shelf piece of policy for an organisation,
government, local soccer club, etc.

Charles McCathieNevile  http://www.w3.org/People/Charles  tel: +61 409 134 136
SWAD-E http://www.w3.org/2001/sw/Europe         fax(france): +33 4 92 38 78 22
 Post:   21 Mitchell street, FOOTSCRAY Vic 3011, Australia    or
 W3C, 2004 Route des Lucioles, 06902 Sophia Antipolis Cedex, France
Received on Monday, 23 June 2003 02:50:17 UTC

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