- From: Eric Hansen <ehansen7@hotmail.com>
- Date: Sat, 19 Aug 2000 03:26:21 EDT
- To: w3c-wai-ua@w3.org
- Cc: ij@w3.org
To: UA List
From: Eric Hansen
Subject: Accessibility and Conformance, etc.
The public wants, and has some right to expect that the UAAG conformance
levels -- level-A, level-AA, and level-AAA -- represent different levels of
"accessibility" of the user agent. I think that as a working group we need
to ask ourselves questions like the following:
Suppose that there are a large number (at least one 1000) UAAG conformance
claims. Some claims are for isolated user agents, such as a single
multimedia player. Others are composite user agents, i.e., composed of more
than one constituent user agent. Assume that the full diversity of different
kinds of user agent currently allowed by the UAAG document are represented
(e.g., text browser, telephone browsers, etc.). Assume that all claims are
procedurally correct, i.e., the claimants did what we ask them to do. Now
suppose that we have an independent and reliable way of rating the
accessibility of the user agent that is the subject of each claim (perhaps
by a set of ratings by independent, expert accessibility judges). The key
question is this: Are there relatively and tolerably few instances in which
any of the following occurs?
(a) A user agent that fails to achieve even a single-A rating yet is found
to be more accessible than one that achieves a single-A rating.
(b) A user agent that achieves a single-A rating yet is found to be more
accessible than one that achieves a double-A rating.
(c) A user agent that achieves a double-A rating yet is found to be more
accessible than one that achieves a triple-A rating or is less accessible
than one that receives a single-A rating.
(d) A user agent that achieves a triple-A rating yet is found to be less
accessible than one that receives a double-A rating.
I think that if we can't answer in the affirmative, then we need to make
some changes in the UAAG document.
I know that within the working group we have become increasingly aware of
the limitations UAAG ratings. I think it is very important to state some of
these limitations in the UAAG document and/or the techniques document, but
the public will not really understand or appreciate the fine points of these
limitations. They will not understand why we may want to use the term
"conformant" instead of the word "accessible". They will want to use the
UAAG claims in buying decisions and policies that will impact user agent
developers as well as people with disabilities. In other words, they want
"accessibility ratings" that are valid for the important decisions that they
are making about user agents.
Problems That I Think Could Arise
Following are some problems that I think could arise with our current
conformance claim system.
Problem #1: A buyer of user agents says: "According to their developers,
user agents T and R both achieve triple-A conformance. They must be equally
accessible." Yet a closer look at the claim shows that user agent cites 30
inapplicable checkpoints and the other cites only 2 inapplicable
checkpoints. Is that a fair comparison?
Problem #2: A buyer of user agents says: "According to their developers,
user agent S achieves double-A conformance and user agent U achieves
single-A conformance. User agent S must be more accessible than user agent
U." Yet a closer look at the claim shows that user agent S cites 15
inapplicable checkpoints and the other cites only 1 inapplicable checkpoint.
Is the single-A conformant user agent really less accessible than the
double-A conformant user agent?
Problem #3. A developer of user agent X makes a claim that says, "A
composite user agent W composed of user agents X, Y, and Z achieves triple-A
conformance. Wow! Agent X must be a very accessible user agent!" A closer
look at the claim shows that there are only 3 inapplicable checkpoints. Not
too bad! But what the conformance claim does not reveal is that user agents
Y and Z _by themselves_ would achieve the same thing (triple-A conformance
with 3 inapplicable checkpoints). This could occur, for example, if user
agents X and Y were actually the same kind of user agent. Regardless of how
inaccessible user agent X is, it does not lower the overall rating the
composite user agent that includes user agents Y and Z. The public who reads
the claim assumes that user agent X is highly accessible, yet in reality it
contributes nothing to the overall rating.
A Problem That I Would Like to Be Assured Could Not Arise
Problem #4. A user agent adheres fully to the checkpoints, notably
checkpoint 1.1 (though see Issue X below) and checkpoints in guideline 5
("Observe system conventions and standard interfaces), but the user agent is
not fully operable and usable by people who are blind, deaf-blind, have
physical disabilities, etc., because although the document requires the
prerequisites for such operability, it does not actually require that
operability.
SOME PREREQUISITES TO SOLVING THE PROBLEMS
Generally, we need to focus clearly on who our audience is and what kinds of
decisions we want them to be able to make based on the conformance claims.
I don't know if the following will entirely solve the problems, but I think
that they will make considerable progress.
====
Suggestion 1. Focus more specifically on "general-purpose graphical desktop
browsers that provide multimedia presentation capabilities".
Instead of trying to address all different kinds of user agents, I believe
that the scope should narrow. For example, about the ideal scope that I can
think of at this moment is: "general-purpose graphical desktop browsers that
provide multimedia presentation capabilities". (I can think of other
definitions that may have technical advantages, but I don't think that they
communicate as well.)
For the most part, I am merely suggesting a tightened focus. For at least
months, it seems that the UAAG working group has acknowledged that the
document has general-purpose graphical desktop browsers are of primary
interest. I am merely suggesting lumping in the multimedia capabilities
(audio, animation, and motion video).
I think that in this matter, we are far better off doing one thing well
rather than trying to do too much and doing them all not so well.
====
Suggestion 2. Define the term 'fully compliant user agent'.
"For the purpose of this document, a 'fully compliant user agent' is a user
agent that (a) achieves a triple-A rating (i.e., adheres to all applicable
checkpoints) and (b) has _no inapplicable checkpoints_. One may also refer
to such a user agent at a certain conformance level. For example, a 'fully
compliant double-A user agent achieves the double-A UAAG level and has no
inapplicable Priority 2 or Priority 1 checkpoints. "
====
Suggestion 3. Acknowledge the necessity for composite user agents.
The document should acknowledge the following:
"It is recognized that user agents that provide 'general-purpose graphical
desktop browsers that provide multimedia presentation capabilities' may
actually constitute a "composite user agent", i.e., a user agent that is
composed of multiple, 'smaller', user agents such as (a) a general-purpose
graphical desktop browser and (b) a multimedia player. Indeed, at the time
of the publication of this document, a general-purpose graphical desktop
browser typically relies on a distinct multimedia player for multimedia
capabilities. "
====
Suggestion 4. Define the terms 'prime user agent' and 'supplementary user
agent'.
New:
"Conformance claims must designate a 'prime user agent'. If the claim is for
a composite user agent, then the prime user agent should be the user agent
for which the claimant has the most direct interest or knowledge. For
example, the developer of a multimedia player might designate the multimedia
player as the prime user agent, making the other user agents, 'supplementary
user agents'. If a claim is for a singular user agent, then that single user
agent is the prime user agent."
====
Suggestion 5. Allow few if any inapplicable checkpoints.
I think that we need to set a maximum number of inapplicable checkpoints or
perhaps even allow no inapplicable checkpoints. Another way of saying this
is that any valid claim must encompass all or nearly all of the UAAG
checkpoints. Does it really make sense to try to compare the accessibility
of (a) a composite user agent with a vast array of functionality and (b) a
user agent that has only a tiny fraction of the same functionality?
====
Suggestion 6. Define a clear relationship between the fully compliant user
agent and capabilities associated with screen readers and refreshable
braille user agents.
The relationships between the fully compliant user agent and braille and
screen-reader-type capabilities is critical because braille and
speech-synthesis are integral to our concept of accessibility, notably
through the concept of text elements (including text equivalents), which
must be understandable when output to synthesized speech and braille.
As I consider the current document (18 August 2000), the capabilities
associated with screen readers and braille devices are _outside_ the
boundary of the fully compliant user agent. For example, no checkpoint
requires that a user agent be operable via screen reader/speech-output
program. Nor does any checkpoint require that the user agent be operable via
a refreshable braille device. I might not be so concerned about these lacks
if there were checkpoints that specifically required _fully compatibility_
with screen-reader-type programs and refreshable braille devices. But no
checkpoint specifically requires such compatibility or operability. It
appears to me that adherence to several checkpoints in Guideline 5 ("Observe
system conventions and standard interfaces") fulfill critical prerequisites
for operability by facilitating communication with such devices. And
certainly the checkpoints in guideline 7 ("Provide navigation mechanism")
and other guidelines would be very relevant for navigating through a
document via speech output or braille, but if they may do little good if
there is _no actual requirement for operability_ via speech-output and
braille device. I am concerned that there may be a gap that may be unbridged
between the UAAG requirements and full operability via such user agents. I
am not sure how big of a problem this is. For the purpose of the present
discussion, suffice it to say that the capabilities associated with screen
readers and braille devices are _outside_ the boundary of the fully
compliant user agent.
This discussion brings to mind a comment made by at least one individual in
a recent conversation who said approximately as follows: "We plan to comply
with the UAAG document using our browser and JAWS for Windows." However, if
I understand the current UAAG document correctly, the document does not
specifically require operability via any package like JAWS for Windows.
I think that this would mean that, under the current document, the
conformance claim for a fully compliant user agent need not actually mention
screen reader packages or braille devices. I am again concerned that this
may not be adequate.
By the way, I think that we need to keep in mind that it is the checkpoints
that constitute the normative part of guidelines. The introductory material
for guidelines and the notes attached to checkpoints are not what matter. It
is the checkpoints themselves that are the requirements. (Please correct me
if I am wrong in this idea.)
====
Suggestion 7. Add checkpoints that require basic graphical and multimedia
capabilities.
I mentioned this suggestion before and saw Ian Jacob's 18 August 2000
response [1]. Ian cited earlier discussions that resulted in the exclusion
of such requirements. But I would say again that it makes no sense to me at
all to set out requirements for a user agent of the type we are referring to
in this document and fail to mention that it must be able to present
graphics and multimedia (including audio, animation, video, etc.). Such
media presentation capabilities are extremely important for people with a
variety of disabilities (deaf, blind, learning disability, cognitive
disability). Furthermore, I think that an implicit part of our accessibility
philosophy is that people with disabilities should be free to rely on
primary content (e.g., the text, graphics, video, audio, animation, etc.,
that is intended for people without any disability) as much as they want as
well as to have access to secondary content that can substitute for portions
of the primary content that is inaccessible to them. I think that failure to
require that at fully compliant user agent to present these basic types of
media would represent a gaping hole in the document. While there may have
been good reason to exclude these requirements in a earlier stage of the
development of the document, I don't think that those reasons hold any
longer. Finally, I would add that if the working group agrees to the tighter
focus on 'general-purpose graphical desktop browsers that provide multimedia
presentation capabilities', then it would seem all the more puzzling to lack
a requirement for presentation of graphics and multimedia.
====
Suggestion 8. Consider adding functional requirements that are more specific
to the needs to particular disability audiences.
I think that it is worth considering adding more general functional
requirements to the existing checkpoints. Such requirements might help
ensure operability.
From the Trace R&D revision of the NPRM proposed standards [2]:
§ 2194.27 Functional performance criteria.
NOTE: If users would typically have related assistive technology with them
whenever they wanted to use the E&IT then the ability of the product meet
this criterion can be evaluated with the assistive technology(s) in place.
(1) At least one mode of operation and information presentation that does
not require user vision and that allows full access shall be provided.
(2) At least one mode of operation and information presentation that does
not require visual acuity greater than 20/200, that does not require audio
perception, and that allows full access shall be provided.
(3) At least one mode of operation and information presentation that does
not require user hearing and that allows full access shall be provided.
(4) Where audio information is important for the use of a product, at least
one mode of operation and information presentation shall be provided in an
enhanced auditory fashion.
(5) At least one mode of operation and information presentation that does
not require user speech and that allows full access shall be provided.
(6) At least one mode of operation and information presentation that does
not require fine motor control or simultaneous actions, that is operable
with limited reach and strength, and that allows full access shall be
provided.
(7) ADVISORY: Wherever possible products should minimize the cognitive and
memory ability required of the user and accommodate people with learning
disabilities.
====
Suggestion 9. Require conformance claims to indicate the identity of the
claimant.
The claimant could be an individual, an organization, or a part of an
organization.
====
Suggestion 10. Require that for each component in the claim, the claimant
indicate its role.
For example, for each component, the following roles might be allowed:
Developer, User, Other, etc.
====
Suggestion 11. Require that if two or more components of a claim are the
same component, a rationale for this must be included.
We want to avoid claims that might contain problems like problem #3 at the
beginning of this memo.
====
Suggestion 12. Reexamine situations in which the language of "applicability"
occurs within checkpoints.
I think that we need to examine how the word "apply" or related words are
used and see if we really want them associated with the concept
applicability.
====
Suggestion 13. Define the circumstances under which a two or more user
agents become to be counted as a single user agent.
====
Suggestion 14. Define the circumstances under which the user interface (per
checkpoint 1.1) of a user agent comes to include the user interface of
another user agent.
====
Suggestion 15. Explain what we think are appropriate uses of the ratings.
For example, is it appropriate to use such ratings as sole criteria in
buying decisions? Even more modestly, are the ratings appropriately used in
representing the accessibility factor in buying decisions.
[1] http://lists.w3.org/Archives/Public/w3c-wai-ua/2000JulSep/0263.html
[2] http://www.access-board.gov/sec508/comments-nprm/101.html
<END OF MEMO>
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Received on Saturday, 19 August 2000 03:26:53 UTC