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Re: Issues: Part 3 - #44 and #45 - Exemption

From: <ehansen@ets.org>
Date: Mon, 22 Nov 1999 13:21:49 -0500 (EST)
To: w3c-wai-ua@w3.org
Message-id: <vines.Bh0E+xaMCsA@cips06.ets.org>
Mark Novak wrote:

"Changes are flying pretty fast, so it has been tough to keep up, but I'm 
confused as to why User agents that are designed and developed exclusively 
for people with disabilities "would be exempt" from these guidelines?"

My response:

The 5 November 1999 version of the UAAG indicates the definition of 
"applicable checkpoint" that:

"If a user agent offers a functionality, it must ensure that all users have 
access to that functionality or an equivalent alternative."

I hope that I am correct in my understanding that the equivalent 
alternative could be provided either (1) within (or "by") the user agent 
itself or (2) by working well with other user agents that are able to 
provide an equivalent alternative. This requirement is fine for user agents 
that are intended for general audiences (i.e., all users, including people 
with disabilities), but I am concerned that some assistive technologies are 
so specialized in purpose, that they are only usable by people in one 
disability group, or perhaps even only by one person with a highly unique 
disability profile. Without the exemption, wouldn't such assistive 
technologies then be obliged to provide their functionality to "all users"? 
I think we need to think about how the UAAG document would apply to 
assistive technologies such as single-switch input devices, wheelchairs, 
screen reader software, braille devices, hearing aids and other prosthetics,
 screen magnification software, telephone-audio-based Web browsers, and 
technologies ts that translate one kind of computer data into an accessible 
from (e.g., text to braille, braille to audio, etc.). All these 
technologies are user agents in the sense of being used by some people with 
disabilities to access Web content. Must they be made usable by "all users",
 including people without disabilities? That seems too tall of an order and 
may have unintended negative consequences.

At the very least, I highly recommend making the change that I previously 
recommended that changes the first sentence mentioned earlier to: 

"If a user agent offers a functionality, it must ensure that <CHANGE> 
people with disabilities </CHANGE> have access to that functionality or an 
equivalent alternative." (my revised definition of "Applicable 
checkpoint"). This change from "all users" to "people with disabilities" is,
 in my view, essential because:

1. It keeps the UAAG document within scope. We have no authority except as 
it relates to accessibility, i.e., use by people with disabilities. 
2. It may limit the unintended negative consequences by potential reducing 
(or minimizes increased burden) on developers.

What about the exemption itself?

There may be alternatives to this exemption. One could obviously redefine 
the scope of this document to say that UAAG pertains only to graphical Web 
browsers and multimedia players and not really to these other technologies. 
However, I think that that would unnecessarily limit the scope of the 
document. One could also redefine concept of "user agent". At least in my 
own mind, I see user agents has being able to contain (or being assemblages 
of) other user agents. And I think that it would be hard establish a 
minimal level of functionality for something to be classed as a user agent. 
(I would think that small, low-functionality user agents are the ones that 
might be most prone to lack or to lack good interfaces to equivalent 
alternatives.)  In the absence of redefining these terms and the document 
scope, then I think that the exemption may be appropriate.

I may be over-reacting to this issue, but I think that people who 
understand both the document and assistive technologies should examine how 
they might impinge upon each other. I would not want to see developers of 
highly specialized assistive technologies for, say, a single disability 
group (e.g., deaf-blind) be hindered by unnecessary requirements for 
accessibility for all other disability groups as well as people without 
Eric G. Hansen, Ph.D.
Development Scientist
Educational Testing Service
ETS 12-R
Rosedale Road
Princeton, NJ 08541
(W) 609-734-5615
(Fax) 609-734-1090
E-mail: ehansen@ets.org 
Received on Monday, 22 November 1999 13:26:23 UTC

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