Thread Subject: Re: intro for 8.1?

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From: Hoffman, Allen
Date: Mon, Sep 24 2007 8:55 AM

Procurement applies to information and data.
information and data are delivered in some format.

So, for example, I buy a credit reporting service which provides daily
reports in IDF (inaccessible document format), and another vendor offers
that information in (adf), accessible document format. Now, you might
infer section 3 applies, but almost nobody will in the acquisition side
of things. Without this being an explicitly described item it will, and
has gotten lost and overlooked.

I think there certainly may be some scoping tweaking that would help,
but as one who as strived desperately over the past many years to
improve the accessibility of content, delivered by various software
mechanisms, I can say this link is what is missing and sorely requires
some strong mechanism to fix it. Much of the Access-Board's initial
question of how does Section 508 apply to "content" is based around
exactly this problem in the end. We have addressed the problem only in
the surface fashion if we leave out the format portion, and history
demonstrates that that approach doesn't work. if there is an interim
mechanism we can use I'd be all for exploring it.






Allen Hoffman -- = EMAIL ADDRESS REMOVED = ; v: 202-447-0303

-----Original Message-----
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Sean
Hayes
Sent: Monday, September 24, 2007 5:25 AM
To: TEITAC Web/Software Subcommittee
Subject: Re: [teitac-websoftware] intro for 8.1?

Peter, I think your observations are valid in the context of office
documents, but when we examine the wider scope of what the term "content
format" covers I think we find problems.

It might be a valid tactic for an agency trying to meet 508 to
voluntarily reduce their complexity burden by standardising on a
specific set of technologies like OS, AT and office document types,
however as you say that is out of the scope of 508. And even if so the
agency would still need to be able to interoperate with content and
systems outside of their control, as well as ensuring that the content
which is created actually uses the accessibility features.

I agree that the group has done some good work on identifying the kind
of information software needs to be able to obtain when using a content
format in order to meet the operational provisions, but as I have
already stated, it is not always appropriate to include that information
directly in the content itself.

I'm not necessarily against recording the groups guidance somewhere but
I think there are a number of problems with recording it as specific
provisions within 508.

For one, there is the harmonisation problem, no other international
standard has such provisions (possibly for the reasons I outline below),
and that procurement applies to software and not content formats.

Then there is the issue that federal agencies between them record
terabytes of information each year, including digital photographs;
satellite imagery; cctv traffic, security, and other video; medical
scans; geographical information and so on. These are all recorded in
content formats which would not meet the proposed provisions on their
own. Even if the agencies could employ the armies of operators it would
require to create the descriptions, captions and annotations to make
this information accessible; for practical, legal and forensic reasons,
any such additional information would likely be entered into a media
management database of some sort, not by altering the original content
formats.

The proposed content rules while applicable in some specific cases, such
as office document creation, do not encompass situations where the
information is distributed over a set of content formats, such as HTML
and PNG, or DV and timed text files. They also do not accommodate
situations where data must necessarily live in an inaccessible format
for some period and would be made accessible by later processing, like
capturing a digital photograph.

So since the content provisions are already captured in a more general
way by the provisions on software, and do not create the same
operational constraints, I think we might be able to move the proposed
content provisions into notes or guidance materials for the specific
software provisions they relate to.

We also need to think about how the software rules apply to tools which
are used in the conversion of inaccessible recorded media such as
photographs and video, we may need to craft some specific exceptions
otherwise we may inadvertently prevent the agencies from procuring tools
such as Photoshop which are commonly used in the process of making such
materials accessible.

Sean Hayes
Incubation Lab
Accessibility Business Unit
Microsoft

Office: +44 118 909 5867,
Mobile: +44 7875 091385


-----Original Message-----
From: = EMAIL ADDRESS REMOVED =
[mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Peter
Korn
Sent: 22 September 2007 17:37
To: TEITAC Web/Software Subcommittee
Subject: Re: [teitac-websoftware] intro for 8.1?

Hi Sean,

I think it is true that today few if any U.S. Federal Government
agencies "procure" formats. But we have certainly seen several U.S.
States looking to formally standardize on document formats (cf.
Massachusetts). Likewise we have seen this in a number of European
countries. And I believe the U.S. Library of Congress and other
archiving organizations have been looking at like standardization.

As standardization is different from procurement, it may be that the
vehicle of Section 508 is not the right vehicle for this. But it seems
clear to me that an enumeration of the accessibility information that
must be "preservable" in/with a document format is an entirely
appropriate thing to write down, so that organizations that are looking
to standardize on some number of document formats know what they must
look for to ensure accessibility information is preservable in that
format.

And I think this subcommittee has done a very nice job of doing that in
this collection of provisions.


Regards,

Peter Korn
Accessibility Architect,
Sun Microsystems, Inc.

> Sorry, I was working from the Sept 3 draft.
>
> One logical problem, if the primary leverage applied by agencies is
procurement, is that the agency does not typically procure formats. It
procures tools that generate and consume data encoded in those formats
or maybe data encoded in formats.
>
> The content rules might be replaced by a blanket clause:
> "Agencies and their employees and agents must ensure electronic
information is developed and maintained such that any receiving party
can use software to access that information in a manner which complies
with the software provisions."
>
> Sean Hayes
> Incubation Lab
> Accessibility Business Unit
> Microsoft
>
> Office: +44 118 909 5867,
> Mobile: +44 7875 091385
>
>
> -----Original Message-----
> From: = EMAIL ADDRESS REMOVED =
> [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Jim
> Tobias
> Sent: 22 September 2007 13:13
> To: 'TEITAC Web/Software Subcommittee'
> Subject: Re: [teitac-websoftware] intro for 8.1?
>
> Thanks.
>
> The first numbers you cite -- are those the 8.1 and 8.2 provisions?
So "1"
> is actually 8.1-A in the September 14 draft?
>
> If that's the case, I still argue that although in a perfect world
> only the final product should need evaluation, we are so far from that

> perfect world that upstream provisions are still necessary. At the
> agency level they prevent mischief during use, and at the industry
> level they support the development and marketing of better tools. I
> don't see how they're overly burdensome to either party. For example,

> we're not insisting that agencies purchase tools that use the *most*
> accessible formats, nor are we imposing oversight on format
development itself.
>
> If there were no lead paint, there would be no lead painted toys.
>
> ***
> Jim Tobias
> Inclusive Technologies
> +1.732.441.0831 v/tty
> +1.908.907.2387 mobile
> skype jimtobias
>
>
>
>> -----Original Message-----
>> From: Sean Hayes [mailto: = EMAIL ADDRESS REMOVED = ]
>> Sent: Saturday, September 22, 2007 7:53 AM
>> To: TEITAC Web/Software Subcommittee
>> Subject: Re: [teitac-websoftware] intro for 8.1?
>>
>> 1 - covered by 3C
>>
>> 2 - covered by 6 A,B&C
>>
>> 4 - covered by 3K
>>
>> 5,6 & 7 - covered by 3N
>>
>> 8 - covered by 3M
>>
>> 9 - covered by 3C
>>
>> 10 - covered by a combination of 3N and 3C.
>>
>> Sean Hayes
>> Incubation Lab
>> Accessibility Business Unit
>> Microsoft
>>
>> Office: +44 118 909 5867,
>> Mobile: +44 7875 091385
>>
>>
>> -----Original Message-----
>> From: = EMAIL ADDRESS REMOVED =
>> [mailto: = EMAIL ADDRESS REMOVED = ] On Behalf Of Jim
>> Tobias
>> Sent: 22 September 2007 12:42
>> To: 'TEITAC Web/Software Subcommittee'
>> Subject: Re: [teitac-websoftware] intro for 8.1?
>>
>> Sorry -- can you point to the specific provision(s) that would have
>> the effect you claim? I'm not seeing it.
>>
>> ***
>> Jim Tobias
>> Inclusive Technologies
>> +1.732.441.0831 v/tty
>> +1.908.907.2387 mobile
>> skype jimtobias
>>
>>
>>

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