PDF/UA footer artifact discussion

There is one item in PDF/UA that I believe needs to be addressed and
discussed.  I’m raising the issue here to get others opinions as it relates
to WCAG conformance.  The PDF/UA specification indicates that repeating
headers and footers, page numbers, Bates numbers, etc. must be artifacts in
order for a document to be PDF/UA conformant.      Many documents contain
very important information in the footer including page/section numbers
that do not correspond to the PDF reader’s displayed page numbers.  These
important page numbers and sections may be referenced in the document
text.  Additionally, important form information such as tax forms contain
numbers and version of the form in the footers – access to the information
is absolutely necessary for users with disabilities.  Furthermore, Bates
numbers may contain copyright information that users need access to.
Artifacting this information prevents access by users with disabilities and
would cause a document in my opinion to not conform to WCAG 2.



The Technical Implementation Guide that AIIM has posted on PDF/UA
http://www.aiim.org/Research-and-Publications/standards/committees/PDFUA/Technical-Implementation-Guideindicates
the following:



7.1 is the core of PDF/UA; it contains most of the essential concepts
pertaining to page-content.

Paragraphs 1 and 2

The following elements of a page's content should always be understood as
"Artifacts".

•Repeating headers or footers, even if entered by a user.

•Slide backgrounds, even if user-defined.

•Page numbers.

•Usually, any items that tend to repeat page after page.

•Bates numbers (NOTE: ISO 32000-2 will introduce a new type of artifact to
contain Bates numbers)

Artifacts can never be a part of the logical structure tree. As PDF/UA-1
requires that page content is either contained in the document's semantic
structure or marked as an artifact, all page content must be either
contained in the logical structure or marked as an Artifact.



Is there is a way to reconcile PDF/UA and WCAG 2 in this area?



Best Regards,



Jonathan