Thread Subject: Re: "Content" in our subcommittee

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From: Sean Hayes
Date: Wed, Nov 01 2006 9:20 AM

> I myself have not heard a credible

>argument in favor of excluding content from 508. Can someone please
make

>such an argument, or point us to one?



Perhaps one differentiating factor is the extent to which the content is
being procured by a federal agency. For example if an agency comissions
an online help manual, it would make some sense if the manual were
treated as a product being procured and hence subject to constraints. On
the other hand, a document sent to a federal employee in the course of
an ordinary negotiation would remain copyright, and hence owned, by the
sender, and thus would not be 'procured' by the agency and so might be
exempt.



This has some practical merit - it would not be sensible for example to
fill in a VPAT for each email you need to send.



But even in the first case, content is not by itself accessible (or not)
- it has to be rendered by some software in some sensory modality; so
the question really applies to the combination of data and algorithm and
whether the algorithm is able to reconstruct the required information
from the received data.



I don't think a distinction as to whether the rendered information is
being created from data internal to the software, or received from an
external source is the problem, the important point is if the resulting
rendered form can be perceived by all users. I would argue that content
is not excluded from the current guidelines, but the guidelines sensibly
focus on outcomes.

* For example: 21(i) Color coding shall not be used as the only
means of conveying information, indicating an action, prompting a
response, or distinguishing a visual element.

Whether the colour is encoded in received data or not is not really
material, the requirement is that it not be the only means of conveying
information. The alternate means could be carried in the data, or it
could be carried in the algorithm (from an alternate built in stylesheet
for example). I think the regulations should continue to be outcome
based, and not process based.



I agree it does make some sense to require that creation tools
(particularly WYSIWYG ones) ask authors to consider alternate modalities
of presentation than the one being used to author the content as well as
other rendering tools.



---

Sean Hayes
Microsoft

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