Thread Subject: Re: Group B: 22(k) Text-only page

Note

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From: Bailey Bruce
Date: Wed, Nov 15 2006 5:30 PM

John Slatin wrote:
> If the new technology, can't be made conformant, it shouldn't be used,

This is the enigma of quote conformant with the standards unquote versus
actually being accessible. As it stands now, inaccessible E&IT is
permitted in many situations because of legitimate exceptions,
commercial non-availability being one of the more often invoked
rational. This is IMHO one of the more fundamental differences between
508 1194 and WCAG 2.0.

> or else an alternative version that does conform should be provided.

In the Federal space, assuming the commercial non-availability claim to
be valid, 504 ensures that accommodations are still required to be
provided as needed. It is only in the web arena, because of 1194.22(k),
that an alternative version is necessary by design.

> Text-only is OK for users who are blind, but it's no help at
> all to users with dyslexia, for example, unless the text is
> also written for a high degree of readability.

As Don wrote, since .22(k) maps to WCAG 1.0 Checkpoint 11.4, what
exactly qualifies as quote text-only unquote could stand to be
clarified. When I did testing at ED, we were always pleased to allow
the alternative version to be robust, just so long as it satisfies all
the other 1194.22 provisions. Sometimes the alternative versions
offered are too stripped down, they are not functionally equivalent, and
therefore they are not acceptable. If the vendor claims an alternative
version is an equivalent, it is almost always an enlightening exercise
to ask them: Why not scrap the inaccessible version and instead provide
*everyone* the alternative version?

> It seems to me that vendors interested in having their
> technologies used in sites and applications that have to meet
> 508 should also be interested in using the appropriate APIs
> and doing other work necessary for the technologies to conform.

As Don wrote, it is an issue of having a fall-back when technology
conforms by virtue of a legitimate exception rather than conforming by
satisfying all the applicable technical (Subpart B) provisions. Should
this alternative version provision be a requirement for all E&IT? Is
web content different and important enough that only it needs such a
"last resort" clause? Or, as Andrew Kirkpatrick asked, do we need this
at all?

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