Re: Collections of web pages

Hi Bruce, all,

I agree with Peter’s conclusion:
>  So, in other words, “set of documents” doesn’t apply to non-web documents.  It’s a non-issue.

Please keep in mind that those sort of exceptions in Access Board regulations (including the Revised 508 Standards) are permission to skip accessibility features, and not an assertion that the accessibility features are counterproductive (even in the context described by the exception).  Usually it is fairly apparent why there is an exception.  But in this case, it was just because those SC were so controversial.  Personally, I don’t think it would have hurt to have keep them (after all, WCAG2ICT allowed for them, at the end), but that they were not worth the bandwidth people would have had to spend to document implementation (for non-web documents).

WCAG2ICT had no choice about whether to “allow for them”, since the explicit charter was to find some way, any way, to provide guidance on how to make each and every WCAG 2.0 AA SC apply to things outside of the Web.   WCAG2ICT’s charter didn’t allow it to re-write criteria, only to re-define some terms and to add Notes.  I was not privy to internal discussions at the Access Board, but my understanding was that the incredibly tortured nature of what needed to be done for those SCs to find some way to apply them to non-web documents was what led the CEN/CENELEC/ETSI folks to not include them in EN 301-549’s transposition of WCAG 2.0 to non-web documents (and non-web software).

ePub doesn’t operate under those same strictures.

Dropping those SC was a pragmatic choice for 508.  Dropping those SC for EPUB is probably not the right choice!

To be clear, I’m not suggesting that the purposes of the “set of documents” criteria have no import in ePub/eBooks, or that the things they are trying to achieve in the web context shouldn’t be achieved for ePub/eBooks.  Rather, I’m saying that we should not be tied to the WCAG 2.x wording (after all, WCAG 3.0 is already under development and the door is wide open there for new criteria language).  We should go “from first principles” and write criteria that make sense for eBooks.


Regards,

Peter
--
Bruce Bailey
Accessibility IT Specialist
U.S. Access Board
1331 F Street NW, Suite 1000
Washington, DC  20004-1111
202-272-0024 (voice)
202-272-0070 (TTY)
202-272-0081 (Fax)
bailey@access-board.gov<mailto:bailey@access-board.gov>
Thank you for your questions concerning section 508 of the Rehabilitation Act Amendments of 1998.  Section 508 authorizes the Access Board to provide technical assistance to individuals and Federal departments and agencies concerning the requirements of this section.  Technical assistance provided in this email is intended solely as informal guidance; it is neither a determination of your legal rights or responsibilities, nor a statement of the official views of the U.S. Access Board or any other federal agency.  Any links to non-federal websites are provided as a courtesy and do not represent an endorsement of the linked information, products, or services.

From: Andrew Kirkpatrick <akirkpat@adobe.com>
Sent: Wednesday, April 15, 2020 9:04 AM
To: Korn, Peter <pkorn@lab126.com>; Alastair Campbell <acampbell@nomensa.com>
Cc: 'Avneesh Singh' <avneesh.sg@gmail.com>; Matt Garrish <matt.garrish@gmail.com>; 'WCAG' <w3c-wai-gl@w3.org>
Subject: Re: Collections of web pages

Ah, you’re right, forgot about that bit. And the same is true for the EN also…

Thanks,
AWK

Andrew Kirkpatrick
Head of Accessibility
Adobe

akirkpat@adobe.com<mailto:akirkpat@adobe.com>
http://twitter.com/awkawk


From: "Korn, Peter" <pkorn@lab126.com<mailto:pkorn@lab126.com>>
Date: Tuesday, April 14, 2020 at 9:39 PM
To: Andrew Kirkpatrick <akirkpat@adobe.com<mailto:akirkpat@adobe.com>>, Alastair Campbell <acampbell@nomensa.com<mailto:acampbell@nomensa.com>>
Cc: 'Avneesh Singh' <avneesh.sg@gmail.com<mailto:avneesh.sg@gmail.com>>, Matt Garrish <matt.garrish@gmail.com<mailto:matt.garrish@gmail.com>>, WCAG <w3c-wai-gl@w3.org<mailto:w3c-wai-gl@w3.org>>
Subject: Re: Collections of web pages

Andrew,

Yes – anyone who is subject to Section 508 who is putting an eBook up at a URI on their website would need to speak to how such a document meets the refreshed accessibility standard.  That doesn’t mean that it is actually the right way to conceive of eBook a11y.

And… please note: the Access Board (and the EN 301-549 folks) took a close look at the guidance “between the lines” of WCAG2ICT, and didn’t in fact make the “set of web pages” SCs required for non-web documents.

Excerpting from the Refreshed Section 508 Guidelines<https://nam01.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.access-board.gov%2Fguidelines-and-standards%2Fcommunications-and-it%2Fabout-the-ict-refresh%2Ffinal-rule%2Ftext-of-the-standards-and-guidelines&data=02%7C01%7Cbailey%40access-board.gov%7Cca9f8dee182d46486c1108d7e13d8c2f%7Cfc6093f5e55e4f93b2cf26d0822201c9%7C0%7C0%7C637225526780571102&sdata=QaQIIYQOxvIYQSM7emDC%2B4tQi1Fok%2BJtLw8bBY7noQQ%3D&reserved=0>:

EXCEPTION: Non-Web documents shall not be required to conform to the following four WCAG 2.0 Success Criteria: 2.4.1 Bypass Blocks, 2.4.5 Multiple Ways, 3.2.3 Consistent Navigation, and 3.2.4 Consistent Identification.

So, in other words, “set of documents” doesn’t apply to non-web documents.  It’s a non-issue.


Peter
--
Peter Korn | Director, Accessibility | Amazon Lab126
pkorn@amazon.com<mailto:pkorn@amazon.com>

From: Andrew Kirkpatrick <akirkpat@adobe.com<mailto:akirkpat@adobe.com>>
Date: Tuesday, April 14, 2020 at 8:17 AM
To: "Korn, Peter" <pkorn@lab126.com<mailto:pkorn@lab126.com>>, Alastair Campbell <acampbell@nomensa.com<mailto:acampbell@nomensa.com>>
Cc: 'Avneesh Singh' <avneesh.sg@gmail.com<mailto:avneesh.sg@gmail.com>>, Matt Garrish <matt.garrish@gmail.com<mailto:matt.garrish@gmail.com>>, 'WCAG' <w3c-wai-gl@w3.org<mailto:w3c-wai-gl@w3.org>>
Subject: RE: [EXTERNAL] Collections of web pages

Peter,
Why isn’t that still relevant? An EPUB would still be needing to meet WCAG 2.0 for Section 508, and even in WCAG2ICT it isn’t clear to me which applies.

Thanks,
AWK

Andrew Kirkpatrick
Head of Accessibility
Adobe

akirkpat@adobe.com<mailto:akirkpat@adobe.com>
http://twitter.com/awkawk


From: "Korn, Peter" <pkorn@lab126.com<mailto:pkorn@lab126.com>>
Date: Tuesday, April 14, 2020 at 10:38 AM
To: Andrew Kirkpatrick <akirkpat@adobe.com<mailto:akirkpat@adobe.com>>, Alastair Campbell <acampbell@nomensa.com<mailto:acampbell@nomensa.com>>
Cc: 'Avneesh Singh' <avneesh.sg@gmail.com<mailto:avneesh.sg@gmail.com>>, Matt Garrish <matt.garrish@gmail.com<mailto:matt.garrish@gmail.com>>, WCAG <w3c-wai-gl@w3.org<mailto:w3c-wai-gl@w3.org>>
Subject: Re: Collections of web pages

Andrew – I respectfully disagree with you statement “we still need to decide if the EPUB is a set or a single page”.  I think what we need to decide is which success criteria make sense for an eBook, without regard to whether the text in WCAG is “web page” or “set of web pages”.  And what additional success criteria make sense for an eBook that may not (yet) be in WCAG 2.x – to either get them into the WCAG 3 pipeline, or a 2.next, or just held aside for ePub.

Peter
--
Peter Korn | Director, Accessibility | Amazon Lab126
pkorn@amazon.com<mailto:pkorn@amazon.com>

From: Andrew Kirkpatrick <akirkpat@adobe.com<mailto:akirkpat@adobe.com>>
Date: Tuesday, April 14, 2020 at 7:35 AM
To: Alastair Campbell <acampbell@nomensa.com<mailto:acampbell@nomensa.com>>
Cc: 'Avneesh Singh' <avneesh.sg@gmail.com<mailto:avneesh.sg@gmail.com>>, Matt Garrish <matt.garrish@gmail.com<mailto:matt.garrish@gmail.com>>, 'WCAG' <w3c-wai-gl@w3.org<mailto:w3c-wai-gl@w3.org>>
Subject: RE: [EXTERNAL] Collections of web pages
Resent-From: <w3c-wai-gl@w3.org<mailto:w3c-wai-gl@w3.org>>
Resent-Date: Tuesday, April 14, 2020 at 7:33 AM


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The aspects from http://idpf.org/epub/a11y/#sec-wcag-eval<https://nam01.safelinks.protection.outlook.com/?url=http%3A%2F%2Fidpf.org%2Fepub%2Fa11y%2F%23sec-wcag-eval&data=02%7C01%7Cbailey%40access-board.gov%7Cca9f8dee182d46486c1108d7e13d8c2f%7Cfc6093f5e55e4f93b2cf26d0822201c9%7C0%7C0%7C637225526780581060&sdata=Wnn5dyg8G8tWU3QbVqhwzyEuBF2aQi8lQStskVcfwPQ%3D&reserved=0> that caught my eye as not fitting the ‘web page’ model were:

> it is not sufficient for individual Content Documents to have a logical reading order if the publication presents them in the wrong order.

AWK: My interpretation is that this is like saying that a web page that has an incorrect order for part but not all of its content still fails. Isn’t it?

> including a title for every Content Document is complementary to providing a title for the publication: the overall accessibility is affected if either is missing.

AWK: Yes, that is a difference. I haven’t looked at an EPUB reader in a while, but it seems that this is comparable to a single-page web app having the title be “Acme Reporting Tool” which would minimally meet the SC even if it would be helpful to do what Google docs does and have “Mydocument – Google Doc” which provides more specificity.

For an EPUB document, I don’t know if the expectation is that the EPUB reading system will surface the publication title at the highest level (e.g., “War and Peace”) or the more specific content page title (e.g., “War and Peace, Book One 1805, Chapter 1”). If the reading system just said the title and the user was able to easily get the rest of the context, would that be regarded as a failure?

> The inclusion of page boundary locations helps bridge this disparity by ensuring that those using reflowable media are not disadvantaged by their choice.

So Page titles comes up as an odd cross-over point, and the new SC “Explicit navigation markers” would probably benefit from a separate definition.

AWK: I think that speaks more to the need to have a way to talk about content that is presented in a way that emulates a printed publication, so maybe that is where a “digital publication” definition comes in so we can address the page boundaries, but we still need to decide if the EPUB is a set or a single page.

AWK