Re: Section 508 mapping of WCAG 2 to FPC

I’ll take a shot, based on churning through this for 508 Refresh, etc.  Answered inline, <mg>like this</mg>
Mike

From: Patrick H. Lauke <redux@splintered.co.uk>
Date: Saturday, February 25, 2023 at 4:08 AM
To: w3c-wai-ig@w3.org <w3c-wai-ig@w3.org>
Cc: Bailey, Bruce <Bailey@access-board.gov>
Subject: [EXTERNAL] Section 508 mapping of WCAG 2 to FPC
Hey list, a bit of a WCAG-adjacent question, but: while reviewing
https://www.section508.gov/content/mapping-wcag-to-fpc/  for some
internal documentation, I came across a few entries that seemed odd -
I'm hoping that folks (thinking of Bruce Bailey / USAB here for
instance) can elaborate/provide some further context.
* 1.1.1 Non-text content: am I right in thinking that it's marked under
"Without Hearing" and "Limited Hearing" when the content in question is
audio (e.g. a sound cue that has no text alternative/equivalent)
<mg>Correct</mg>

* 1.2.1 Audio-only and Video-only (Prerecorded): I'm assuming that for
something that is "audio-only", that's when it falls under "Without
Hearing" and "Limited Hearing", and when it's "video-only" it falls
under "Without Vision" and "Limited Vision"
<mg>Correct</mg>

* 1.3.3 Sensory characteristics: shouldn't this also fall under "Without
Perception of Color" if the sensory characteristic being used/references
is color?
<mg>Correct
The normative text refers specifically to instructions that depend on color, amongst other things.</mg>

* 1.4.1 Use of colour: I assume this doesn't fall under "Without Vision"
if the information conveyed through just colour is also conveyed
programmatically (so that it's announced by a screen reader, for instance)
<mg> Not correct
Please see the third note:
“This criterion does not directly address the needs of users with assistive technologies. It aims to ensure that sighted users who cannot distinguish between some colors can still understand content. How information is conveyed to assistive technology users is covered separately in other criteria,…
</mg>

* 3.1.1 Language of page: why is this marked under "Without Hearing" and
"Limited Hearing"? How are these groups affected?
<mg>The fourth bullet under Benefits states: “

  *   people who rely on captions for synchronized media.
Under the intent section is also says:
Media players can show captions correctly.

I find it a stretch to say that the set language of the page is likely to have any effect on the captions. It doesn’t align with my experience, which is that a video and it’s possible captions are rarely posted by the same person who created the page. In fact, anyone who relies on a page’s lang attribute to make a decision on the video language may be in for a surprise. But I freely admit that my experience is pretty limited. </mg>

* 3.1.2 Language of parts: why is this marked under "Without Hearing"
and "Limited Hearing"? How are these groups affected?
<mg> The fourth bullet of the Benefits states:

  *   people who rely on captions to recognize language changes in the soundtrack of synchronized media content.
I think maybe someone is confusing subtitles with captions here? But even then, I think there is a pretty clear convention that information that is intended to be understood by a speaker of the source material’s native language is translated into the subtitle language.
For news reporting, where someone responds in an interview in a different language than the intended viewing audience, one of two things happens: the response is translated in the audio soundtrack (as a voice over), or subtitles are provided. In the former scenario, the captions at best would indicate in text that another language was spoken before captioning the voice-over translation. In the latter, there would be no need for captions, since that function has been provided by the subtitles.
On those rare occasions where multiple languages are in a soundtrack and the meaning of both are provided in one language (as opposed to just displaying “[French spoken]” etc), that is normally indicated textually in the subtitles themselves (e.g., not programmatically). Otherwise, the language of subtitles and captions are provided textually as a options in a menu.
Finally, if I’m submitting a video, I’ve been prompted to indicate the language for ASR. I can see there being a potential that there could be an opportunity to indicate the language.
It would be useful to hear someone who is familiar with current technologies to understand how likely/common a programmatic indicator comes into play on language of parts.</mg>

* 3.2.4 Consistent Identification: it's unclear to me why this has also
been marked under "Limited Manipulation"
<mg>Unknown</mg>

* 3.3.1 Error identification: am I correct in assuming that "Without
Perception of Colour" only applies if the reason why something fails
this SC is because they're using colour alone to indicate an error?
Otherwise, if errors are not indicated in general, would this not be
something that fails for *all* groups?
<mg>If colour was used, it would either fail Perception or it would fail Use of Color (if in the instructions). I think the germane part of this SC is that ‘information is described in text’. This failure is about the absence of identification of error and description in text.
The ‘text’ and ‘described’ parts are key, as noted in Benefits.</mg>

* 3.3.2 Labels of instructions: while I understand why this would affect
people with "Limited Language, Cognitive, and Learning Abilities", it's
unclear why "Limited Vision" has also been singled out as a group
affected by this.
<mg>I think the tie-in is having a visual label for a control. As stated in the Understanding, this is about the existence, by which I infer visual existence:
This Success Criterion does not require that labels or instructions be correctly marked up, identified, or associated with their respective controls

I agree it’s very weakly linked in the Understanding doc – and that proximity of label is a bigger (and specified) requirement for limited vision. </mg>

* 3.3.3 Error suggestion: am I right in thinking that this has been
marked under "Limited Manipulation" under the scenario where a site/app
should offer an easy way for a user to select (e.g. from a list, or
radio buttons) the correct value they intended to use - rather than in
cases where the solution would be to provide error suggestion in text
(leaving the user to still enter it/correct their entry manually)?

<mg>I agree this seems misplaced. The benefit statement is stretching it:
People with motion impairment can reduce the number of times they need to change an input value.
Partly this is a result of how unnecessarily (and poorly) isolated Error Suggestion is from Error Identification. I think Limited Manipulation should be removed. </mg>

* 3.3.4 Error prevention (legal, financial, data): wondering why this
has been marked as affecting almost all groups, *but* with the notable
omission of "Without Speech" and "Limited Reach and Strength". Is this
just because there's an overall decision that *none* of the WCAG SCs
relate to those two categories? If the intention is that a lack of error
prevention affects everybody and is important enough to flag, then I
would have thought this would affect *all* groups. Otherwise, I'd be
interested to know if there's specific rationales for the groups that
*were* marked as being affected by a failure of this criterion (and if
there's any particular nuance of failure that would only relate to
specific groups - e.g. I can't currently think of a scenario where a
lack of error prevention may be problematic for a user "Without Hearing"
and "Without Vision" but fine for a user with "Limited Reach and Strength")
<mg>I concur that it should be all groups. I can think of situations where any user may have inadvertently done something as a result of their AT, input or understanding. All can apply.<mg>

* 4.1.1 Parsing: am I right in thinking that this has been flagged under
"Limited Manipulation" only for cases where incorrect/broken markup also
results in problems relating to, say, keyboard operation/focus order?
Further, I'd be interested to know what kinds of failures of this SC
would affect people with "Limited Language, Cognitive, and Learning
Abilities".
<mg>Since parsing is going the way of the Dodo, ignoring</mg>

* 4.1.2 Name, role, value: similarly, I'm wondering why this SC is also
flagged under "Limited Manipulation" and "Limited Language, Cognitive,
and Learning Abilities". Is the assumption that users from these
categories also often use assistive technology, which will be affected
by this?

<mg>That would be my expectations. “user agents, including assistive technologies” is part of the normative text. See also Benefit statement.</mg>

Apologies for the flood of questions, but I'm hoping to bring a bit more
clarity here...

P
--
Patrick H. Lauke

https://www.splintered.co.uk/  | https://github.com/patrickhlauke
https://flickr.com/photos/redux/  | https://www.deviantart.com/redux
twitter: @patrick_h_lauke | skype: patrick_h_lauke