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Exclusion of Visual Readers with Low Vision form WCAG 2.0 and the 508 Revise

From: Wayne Dick <wayneedick@gmail.com>
Date: Mon, 17 Oct 2011 16:23:58 -0700
Message-ID: <CAJeQ8SC8jy+tkopomXj25OKWirfkFXc3ULdVaYxWLtBGYN8rRA@mail.gmail.com>
To: w3c-wai-ig@w3.org
When WCAG WG developed WCAG 2.0 they lacked the expertise needed to
write guidelines for all visual disabilities.  Two years after aproval
of WCAG 2.0 the WG made a interpretive decision that virtually
eleminated visual readers with low vision from civil rights
protection.  Subsequent revise of 508 followed this lead.  The result
is that today, visual readers with low vision have less legal
protection in the US than they did before 1980.  I worte the following
essay as a blog with Knowbility, but it was really directed at the W3C
WAI and was not read.  I am distributing it here because the exclusion
of visual readers with low vision will mean illeteracy or
semi-literacy for people in this group for at least a generation.

. Access to Literacy
.. The Commercial Disability

Visual readers with low vision (VR/LV) do not have the assistive
technology they need for the simple task of reading.  This technology
exists for W3C technologies like HTML with CSS, but even that access
is difficult to realize.  While the accessibility community focuses
all its efforts on access to active content, the basic problem of
literacy for VR/LV remains unaddressed, but not unsolved.

The technology to eliminate almost all print disabilities related to
VR/LV has been well established since adop

tion of CSS 1 (1996) and HTML 4.01 (1999). The underlying concept is
separation of information, structure and relations from presentation,
the Separation Principle. It is completely possible to give visual
readers with low vision complete individualized access to the visual
style they need to achieve advanced literacy. The only obstacle is

Today, access to style is under siege. Proprietary content vendors do
not want to recognize the need.  One vendor actually claims that zoom
is enough to meet the literacy needs of low vision. Vendors are so
stingy with the style access they permit that literacy just slips
further and further away.

Screen magnifiers just do not do the job for professional level
literacy.  They are better than nothing, but an outhouse is preferable
to going behind a bush. The claim that screen magnification is
accessibility support for visual readers with low vision is like
saying normal people get indoor plumbing, but VR/LV only can use the
outhouse. We are even supposed to be grateful for this inequity.

Vendors are under no pressure to provide literature in accessible
formats, on the web or in electronic publications, and developing a
universal technology for all of the electronic publication formats is
profoundly difficult.  The print disabilities of visual readers with
low vision should really be renamed commercial disabilities. VR/LV is
kept in a state of artificial semi-literacy because inclusion is
commercially inconvenient.

The exact problem is this:  VR/LV needs access to change the visual
style of typography.  That means they need to be able to have the
style they need even though, the document may be protected from theft
or misuse.  Vendors deserve their digital rights management, but
digital rights should not extend to visual presentation.

At present, venders dictate what style modifications readers can have.
 Adobe Reader permits very restricted enlargement, and global choice
of foreground and background color.  Their reflow option is a big
disappointment.  It does not enable text find; it loses content, and
it cannot locate bookmarks within the text.  The iBook reader permits
a small range of choice in color, font-face, and font-size. The iBook
loses the entire advantage of its largest font size because it forces
two column format in landscape view regardless of the font size.  The
Kindle does have a one column landscape mode giving a good line length
in large print mode, but the DX has many other style limits. The
smaller kindle gives more style choices, but once again there are not
enough to meet the range of needs required by VR/LV. What VR/LV needs
is full style choice.  Clearly, hardware devices like the Kindle
cannot provide color choice, but there is no reason for the Kindle
Cloud application not to give extensive style choice. No Kindle device
gives style choice for menus. Another issue with the Kindle system is
that some text cannot be modified at all.

Proprietary venders could provide this full visual access, and many
do.  Microsoft Word has a template system that rivals CSS.  Reading
Word is generally easier than other formats, and many people with
VR/LV read files into Word, adjust the styles and read the restyled
text.  What is missing today are standards and regulations that
pressure vendors across the web and electronic publishing industries
to provide access to rich visual style. The accessibility community
has successfully identified and protected access needed by blindness,
but the needs of other visually impaired people (the majority) go
neglected.  The population of VR/LV is now exploding as the baby
boomers reach old age, and age related low vision. Baby boomers are
computer users, and they will be expecting real accessibility.

The problem has gotten worse since the adoption of the Web Content
Accessibility Guidelines (WCAG 2.0) in 2008. This is because the WCAG
Working Group endorses the concept that accessibility support for
individualized access to style is not covered by the guidelines. When
the new revise of Section 508 —based on WCAG 2.0— is finished, visual
readers with low vision will have less protection under the law than
they did before the original Section 508.  It will be legal in the
United States to deny access to visual style other than magnification.
Let’s hope that Australia does not follow the American example.

.. The Exact Need

Access to typographic style is the single most important need of
visual readers with low vision.  The well known factors are: font face
color (back and fore), spacing (line, word and letter) and of course
font size.  Increase in font size must also be accompanied with full
and intelligent word wrapping.  Line length on a page is also
important.  Arbitrary choices like two column format for landscape
mode are discriminatory.

These choices must extend to the document element level.  One must be
capable of modifying headings and paragraphs differently. Global
document level choices are not nearly enough.  The essential point is
this, visual readers with low vision are visual readers first.  They
need a visual typography that is as rich a typography as the ones used
by visual readers with full sight.

Currently most technology does not come close to providing necessary
typographic access.  Safari on IOS has no style access, not even text
only enlargement. The Kindle falls short on every platform.  Google
Search engine, GMail and Google tools are inconsistent. None of them
are easy to modify.  The Flash version of GMail does not support free
choice of visual style, and GMail has taken to scolding users who need
the HTML interface.  Chrome is borderline inaccessible. Adobe PDF and
text material in Adobe Flash are inaccessible to VR/LV.

Safari (Mac and PC), Firefox, Internet Explorer and Opera are good.
Opera is by far the best. In “user” style mode Opera permits you can
turn off the author’s style sheet and load your own.  Another good
vendor is Safari Books Online.  They tried a Flash interface, and when
users complained they gave us an HTML alternative.  They support this
alternative well.  Thank you Apple, Mozilla, Microsoft, Opera and
O’Reilly for being very helpful.

Exactly what style access do people with VR/LV need?  Well that choice
must be up to the individual.  Some need very large print.  Some need
smaller print.  Color and spacing choices are all over the map.
Everything revolves around the user’s exact needs.

There are more than 30 causes of low vision, and around 15 subsystems
of the eye and brain that can be attacked to produce low vision
[Foundations of Low Vision, A. Corn, J. Erin]. There are literally
hundreds of ways partial sight can manifest itself. That extreme
variation in presentation of low vision is why I focus on visual
readers with low vision.  Being a visual reader, regardless of
physiological damage, indicates a level of visual functioning that can
benefit from customized typography. People with low vision, and their
low vision specialists are the only people who can make the final
choice on accommodation.  Today there are simply not enough choices
offered for people with low vision or their low vision specialists to
make an informed decision.

I know this because I am one of the only people in the world who has
constructed individualized solutions for myself and others.  When you
have the full power of CSS behind you, there are no typographic
changes too difficult. If you are reading this with your eyes and have
low vision, please contact me.  I can probably help you with web
content. wed@csulb.edu and 1-562-256-4458.
.. The Separation Principle Applied to Style Accessibility

Separation of information, structure and relationships from
presentation applied to the goal of full typographic access is key to
literacy for visual readers with low vision.  Any abridgement of this
access will limit literacy for some group of people in VR/LV.  For the
developers note the following: You have probably been taught the
separation principle as it applies to heading navigation and table
access.  This access is essential for blindness and helps VR/LV, but
it is not the only access needed from the separation principle.  Most
web sites that pass WCAG 2.0 at Level AA, do not support typographic
access with any grace. This is ironic because, the separation
principle was developed to provide flexible control of visual style.
Accessibility was a serendipitous after thought.

A computer program can guide the mechanical process of printing by
using specific presentation codes with complete accuracy.  However, a
program cannot understand the information, structure and relationships
in a document well enough using visual presentation codes alone to
transcribe one visual presentation of a document to another visual
presentation of the same document.

As early as 1967 this had become a serious problem.  Publishers wanted
to keep document content in a form that could be presented in a
consistent format across complete publication series.  They also
wanted to change this visual formatting at will. Below is a
description of the change from printer oriented document formats to
markup language —originally called generic coding. It appeared in the
Boston Globe in an obituary for William Tunnicliffe, the originator of
the concept.

“Historically, electronic manuscripts contained control codes or
macros that caused the document to be formatted in a particular way
(“specific coding”). In contrast, generic coding, which began in the
late 1960s, uses descriptive tags (for example, “heading”, rather than
“format-17″). Many credit the start of the generic coding movement to
a presentation made by William Tunnicliffe, chairman of the Graphic
Communications Association (GCA) Composition Committee, during a
meeting at the Canadian Government Printing Office in September 1967:
his topic — the separation of information content of documents from
their format.” [Harvey Bingham, 12 Sep 1996]

Markup language solved the problem of separation.  Unlike specific
coding language, markup language  associated content elements with
specific deterministic markers so that: (1) Information, structure and
relationships could be recognized by deterministic programs, and (2)
The information could be presented in many different presentation
formats as usage required. It took a long time and considerable effort
on the part of many people, for this concept to develop into the SGML
Standard, the parent of HTML and the web.  I define the separation
principle as follows:

A document conforms to the Separation Principle whenever all of the
information, structure and relationships in the document can be
programmatically determined.

This is the wording of WCAG 2.0 success criterion SC 1.3.1 almost
exactly. The complete wording of SC 1.3.1 permits plain text as a fall
back when markup language is unavailable, but this is an exception to
the separation principle.  Plain text lacks deterministic
identification of structure and relationships.

With good HTML, Daisy or EPub document structures, CSS can provide
completely individualized access to a visual presentation that will
serve any individual’s personal reading needs. Most modern web content
is not good enough to apply user style sheets without first
eradicating the style choices of the author.  However, if one
successfully clears the author’s style with JavaScript or another
pre-process, web pages that obey separation can be restyled to a
custom format that is very readable for most in VR/LV.

I repeat for emphasis: Most web content does not follow the separation
principle well enough for effective visual transformations.  Try a
user style sheet to see how well your page translates. To do this you
must attach a style sheet from outside your web page. Safari on the
Mac or PC makes testing user style sheets the easiest.  If you do this
you may learn a lot about how much your own style choices interfere
with the style choices of people with low vision.

The browser I use for professional access to user style is Opera on
the PC and Mac.  I also use Firefox as follows:  I store a user style
sheet “userContent.css” to my choice in the “Firefox Chrome”
directory.  When I start Firefox, I go to “View > Page Style” and
choose “no style”. That shuts off the author’s style (on page load,
and during subsequent actions), and it leaves my style in control.
Firefox, Internet Explorer, Safari (PC and Mac) and Opera are the only
browsers that give reasonable access to user stylesheets.  Opera and
Firefox are the only browsers that enables users to kill the author’s
style completely and overlay their own style.  Opera, Safari and
Internet Explorer make it ease to switch stylesheets within the same
session, or use the author’s style.
.. The WCAG Working Group  Abridges the Separation Principle to Exclude VR/LV

Late in 2009, it became clear that some proprietary formats lacked
accessibility support for using SC 1.3.1 because there was no
assistive technology to provide individualized access to style needed
for visual reading with low vision.  The matter was brought before the
WCAG Working Group for clarification, and the committee determined
that SC 1.3.1 referred to document structures like headings, tables
and lists that could not be identified without markup tag structures.
The primary purpose was for navigation and identification of
relationships (mainly spacial relationships like tables). The
committee concluded that SC 1.3.1 did not refer to an ability to
determine document structure for the purpose of changing the visual
presentation of text. Specifically, the need for accessibility support
to provide access to visual style was not implied by SC 1.3.1 or
anywhere in the guidelines.

It is not surprising that a working group with little representation
from low vision on their panel came to this conclusion.  Imagining the
difficulty of comprehending spacial relationships and identifying
visual structures from a non-visual perspective is easier than
understanding the individualized subtle style issues needed to enable
accessibility for visual reading with low vision.  It was hard for
them to imagine that significant change in visual style was also
necessary to perceive and comprehend the information, structure and
relationships on a page.  I doubt that many of them had witnessed
profound change of visual style applied to visual readers with low

The working group’s lack of experience was complicated by the fact
that no single style accommodation will work for all or even the
majority of visual readers with low vision. High contrast, for
example, will help some and harm others. From an industrial
perspective that would appear impractical, but the W3C already had
invented the magic bullet.  The W3C had already solved the problem
with HTML and CSS, and following that solution was the key to other

Some proprietary vendors just do not want to take the extra step. They
will provide navigational access and identification of some
relationships for blindness, but they will not provide open access to
visual typography.  WCAG Working Group agrees they do not need to
provide this level of separation of content from presentation, and it
is a devastating loss for VR/LV.

Even though I understand how the mistake could be made, I have always
been surprised that WCAG WG made the decision they did.  Accessibility
support for user choice of style is core to supporting visual reading
with low vision, and it is a natural outcome of programmatically
determined information, structure and relationships.  Without
application of the Separation Principle to the problem of visual
style, people in VR/LV live in semi-literacy.  WCAG 2.0 actually cites
reading assistants, programs that help users change font size, font
face, spacing and color as a form of assistive technology in their
normative definition of assistive technology.  The Working Group
thought this assistive technology was important enough to highlight in
a normative definition, but they do not feel that it is necessary
accessibility support.

I also find it ironic that a committee of the World Wide Web
Consortium came to this conclusion. The ability to obtain flexible
data to manipulate visual style was the reason Tunnicliffe proposed
separation back in 1967.  The ability to have flexible visual style
was the need that propelled the Separation Principle to become the
SGML standard. From that came HTML and the web. There would be no W3C
without this principle and its application to visual style.
.. What Can You Do?

Test alternative style sheets on your web pages.  Do not include the
alternative CSS in your own HTML code because you will not experience
the user’s problem.  You must see the problem as an outsider sees it.
Use the methods of Safari (preferences) or Internet Explorer (internet
options) to add a style sheet from the browser.  You can user Opera or
try the Firefox trick I use above.  That will not reveal as many
problems in your code, but it will show you how it could look.  My
[100 words per page ] style sheet example gives a good example of
space management in a VR/LV setting.  Here are some pages I use: [user
style sheets].

Avoid the shortcomings I identified in my [coding tips page].  Don’t
use  styles in content.  Avoid  “!important”.  Remember, user
stylesheets reveal all hidden information.  Design with the goal in
mind that some people will be viewing your page in a visual format you
never imagined, and part of your job is to help them. Apply the
Separation Principle with extreme strictness.  Make it easy for a user
to eradicate the style choices you build so carefully into your
document for your dominant audience.

Do not choose for profit proprietary formats to convey textual
content. Many of these file formats are not accessible for VR/LV,
although they may pass WCAG 2.0 at this time. If you must reference a
proprietary format, provide an alternative HTML form if your
institution permits it.
Received on Monday, 17 October 2011 23:24:27 UTC

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