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

From: <ehansen@ets.org>
Date: Mon, 22 Nov 1999 16:23:25 -0500 (EST)
To: w3c-wai-ua@w3.org
Message-id: <vines.Bh0E+BFPCsA@cips06.ets.org>
Re: Exemption from UAAG requirements for user agents that are exclusively 
for people with disabilities.

Thanks for comments from Denis Anson.

DA: Denis Anson 
EH: Eric Hansen

DA wrote: "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 conditions."

EH writes: I wonder if people who develop user agents for people with 
disabilities are _already_ attuned to the requirements of the disability 
groups that they are attempting to assist. (I would expect that the 
developers of HomePage Reader would pay close attention to issues of 
compatibility with other user agents.) If so, perhaps they will simply do 
what needs to be done for their chosen audiences without having the extra 
challenge of making them accessible for yet other disability groups. While 
"universal design" (designing for everyone) is a wonderful ideal, it may 
not always be feasible, especially for highly specialized user agents 
intended for people with disabilities. I appreciate your feedback on this 

DA wrote: "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.

EH writes: I understand your concern about separating people with 
disabilities from others. I have attempted to be scrupulous in avoiding 
insensitive language. It is an important issue. I trust that if we can 
agree on what needs to be said, a sensitive way of saying it can be 

Whether it is OK to use the term "all users" instead of "people with 
disabilities" depends on the context. It is fine to refer to the  
_secondary benefits_ that might flow to "all users" from following UAAG. 
But the document should never assert or imply that concerns for people 
_without_ disabilities was a _reason or rationale_ for instituting any of 
the requirements in the document. (Note that the term "all users" includes 
people _without_ disabilities.) The UAAG document should only include 
requirements that are important for people with disabilities. If we use 
benefits for people without disabilities as reason for a requirement, then 
we have gone beyond our charter and we have no authority or credibility. 
Our charter is to address issues of accessibility of user agents (where 
something is accessible if "can be used by people with disabilities", 
definition of Accessible, WCAG 1.0). Our charter is _not_ to make user 
agents more usable for people without disabilities.

Regarding people who have limitations associated with normal aging as 
opposed to pathology: Our mission is related to people with "disabilities", 
regardless of the cause of disability. If the limitations are sufficient to 
be classified as a disability, then we have a charter to guide developers 
of user agents on how to address them. On the other hand, we have no 
business setting requirements that do not benefit people with disabilities. 
The requirements may have secondary benefits for people with non-disability 
limitations, but these are strictly secondary benefits. Furthermore, I 
think that this strict limitation on the term "all users" is the approach 
that was adopted with the WCAG and ATAG documents and the UAAG document 
ought to be consistent with them.

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 16:29:50 UTC

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