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

From: Denis Anson <danson@miseri.edu>
Date: Mon, 22 Nov 1999 14:50:43 -0500
To: <ehansen@ets.org>, <w3c-wai-ua@w3.org>
This is an issue that is revolving around the concept of interoperability of
assistive technologies that work with user agents.  And specifically, it
deals with the fact that user agents that are developed specifically for
those with visual limitations might not want to provide full access for
physical disabilities.  However, I'll argue strongly that they must.

Based on statistics presented by Linda Petty, of the University of Toronto,
between 50 and 80% of people with severe physical disabilities also have
visual/perceptual deficits.  These people must have both assistive
technology for physical access, for also for sensory access.  If tools like
HomePage Reader do not provide for all of the physical access demands of the
mainstream graphical browser, then a person who is both physically disabled
and low/no vision still doesn't have access.  The proportion of those with
dual needs is very large, and a document that addresses issues of general
accessibility must address the issues of those with multiple disabling

Secondarily, I do not like the idea of changing the language to "people with
disabilities" because this artificially segregates those with disabilities
from the "normal" population.  This results in a stigma on those who
identify themselves as having a disability, and it also excludes those who
do not have an identified disability, but who are at the edges of the
"normal range" of performance.  One particular population here is the
elderly, who may have limitations in vision, hearing, and dexterity that are
the results of normal aging, and not of pathology, but who would benefit
from many of the features we are talking about in this document.

Denis Anson, MS, OTR
Assistant Professor
College Misericordia
301 Lake St.
Dallas, PA 18612

Member since 1989:
RESNA: An International Association of Assistive Techology Professionals
Website: http://www.resna.org
ORLANDO, FL, JUNE 28 -- July 2, 2000

-----Original Message-----
From: w3c-wai-ua-request@w3.org [mailto:w3c-wai-ua-request@w3.org]On Behalf
Of ehansen@ets.org
Sent: Monday, November 22, 1999 1:22 PM
To: w3c-wai-ua@w3.org
Subject: Re: Issues: Part 3 - #44 and #45 - Exemption

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 14:48:24 UTC

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