Re: 508 Refresh, request to delay until reasonable accommodation is possible for low vision

I was going to wait for other comment to answer them all, but the question
Olaf asks is very important.  The question you ask is what is lacking? The
answer law.

If there was a federal rule, VIP would suddenly be well funded, and Adobe
would fix its reader.  If there was a rule, HTML 4 and 5 documents would be
authored so that alternative style would be straight forward and
semantically faithful.

The problem with AT for low vision without a legal rule is that it comes
and goes.  There have been numerous false starts at reasonable
accommodation. Vicki L Hanson, WebAdaptToMe, was a phenomenal
contribution.  With no law, it was not given the support it needed to
succeed from IBM.  With a 508 rules  that directly stated the rules needed
to support low vision products like this would survive.

Microsoft Windows used to have an accessible interface with its adjustable
fonts and colors for menu, tool tips and other UI elements.  Since they
were never featured as solving problems for low vision or meeting a federal
rule they could be dropped or abandoned altogether.  Over the past five
years Windows and Windows products have become increasingly unfriendly for
low vision without realizing they were doing it. There was no malice, they
just did not know the value for low vision for what they had.

So this is why we need 508 rules.  Without rules features that support low
vision are just passing features that can be dropped without consideration
of the impact.  With a rule, developers will author products and identify
features that meet 508 rules.  These features will have to be part of a

Most people with low vision bounce from AT to AT.  The AT built for us is
not nearly adequate. We ovten use undocumented accessibility feature of
products until they are dropped.  Sometimes features like the old Windows
customizable interface were used to great advantage without the
manufacturer knowing millions of people were using these features for basic
things like reading., as an AT.

A federal rules would give people with low vision stability.  We would not
have to live in fear of a manufacturer dropping an essential feature in
ignorance of our needs.

I believe W3C has gone as far as the organization can go when trying to
bring industry forward voluntarily. The 200% limit an acceptance of
horizontal scrolling in WCAG witnesses that fact.  There needs to be law to
push disability support a step further. Guidelines give direction. Law
gives teeth.


On Sun, Mar 29, 2015 at 4:38 AM, Olaf Drümmer <>

> I would argue that (free of charge) tools exist that accommodate some of
> the needs of people with low vision when consuming tagged PDF content. The
> most specific tool (highly customisable / adjustable for low vision users)
> is VIP PDF Reader, see
> .
> Another tool requires Adobe Acrobat, but itself is free of charge: callas
> pdfGoHTML, see
> - it
> transcodes a tagged PDF to HTML and opens it in the default browser (where
> one can use various mechanisms to access the content).
> So, just to make **me** understand: what's missing?
> Olaf
> On 29 Mar 2015, at 11:35, wrote:
> Hi Wayne,
> 28.03.2015, 04:34, "Wayne Dick" <>:
> Some have asked for me to post my written comments to the US Access Board.
> Here are the written comments I posted:
> I am asking the Access Board to override the rules for low vision based on
> WCAG level AA.  This is so that people with low vision have a chance at
> receiving reasonable accommodation.
> A priori, your statement makes a lot of sense.
> And suggests that there are some concrete things we should be looking at
> as requirements for WCAG. Certainly the 200% cap on zoom requirements seems
> entirely arbitrary.
> cheers
> Chaals
> --
> Charles McCathie Nevile - web standards - CTO Office, Yandex
> - - - Find more at

Received on Sunday, 29 March 2015 17:39:08 UTC