Thread Subject: Re: intro for 8.1?

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From: Jim Tobias
Date: Mon, Sep 24 2007 9:05 AM

Thanks, Allen -- you've made the need for content format provisions very
clear.

***
Jim Tobias
Inclusive Technologies
+1.732.441.0831 v/tty
+1.908.907.2387 mobile
skype jimtobias


> -----Original Message-----
> From: Hoffman, Allen [mailto: = EMAIL ADDRESS REMOVED = ]
> Sent: Monday, September 24, 2007 8:16 AM
> To: TEITAC Web/Software Subcommittee
> Subject: Re: [teitac-websoftware] intro for 8.1?
>
> 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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