Thread Subject: View Point Opinion: 1-E Visual Information

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From: Gregg Vanderheiden
Date: Fri, Mar 28 2008 2:50 AM

Comment from Trace Center and I believe AFB - but I was trapped on a plane
and unable to confirm final language with AFB. They can confirm in the AM.
(that is also why I am using Hawaii time. I only got home at midnight
California time)



1-E Visual Information is an important technical provision for individuals
who are blind. It is not covered by other technical provisions.

* The AT compatibility provisions are often cited as covering this -
but one of the key reasons this provision is necessary is for product that
have one or more (or all) features that are closed. For these features
of a product (or for products that are fully closed - such as most public
and many shared products) all of the AT compatibility or "programmatically
determined" provisions would not apply.
* According to 2.1-A - Things that are 'closed' are exempted from all
of the AT compatibility provisions including all provisions that talk about
"programmatically determinable". Instead product functionality that is
closed must meet other provisions - and this is the one for access to visual
information by those who cannot see. So removing this would mean that all
closed products are exempt from being accessible to people who are blind.
People who are blind can tell where the button are (2.1 C) but they have no
idea what the button are for, nor can the access any information on the
screens - or that is printed on the product.

* 2.1 C mechanical controls - requires only that mechanical controls
be tactilely discernible. But tactilely discernable only means that you can
tell that a key is there. It does not mean that you can identify what they
key is for.
* For example: If this provision is removed - then it would be like
taking a ticket machine and covering the screen and removing all button
labels and text on the machine - and expecting people to be able to use it.
People who are blind will have no provision that requires the visual
information be available non-visually. Clearly this provision is not
redundant with existing technical provisions - especially for a product that
has any closed function.



There was also some discussion about this not being needed because it was
covered by a Functional Performance Criterion. But ALL of the technical
provisions are covered one or more functional performance criteria. With
that argument we could remove all the technical provisions.



It was argued in discussions that this was not reasonable because visual
interfaces are so rich and relied upon in products. This is true. That is
the reason that this provision is essential. Note that the provision does
allow (for products that are not closed) use ofs the other AT compatibility
provisions. So for products where that makes sense - that is clearly an
option. But for the rest there needs to be something other than a gaping
hole.



There was also concern that this one was not specific enough. It could
easily be changed to be more specific - but this would reduce industry
options. The goal of the technical provisions generally is to be only as
specific as necessary, in order to maximize a companies options in
conforming. In this case a more general statement is possible because it is
defined enough that it can be clearly tested, (e.g. the developer can tell
if it has been met) but it does not overly specify. If it is felt that it
needs to be more constraining then it can easily be more specific.



1-E Visual Information

"All information that is needed for operation and use that is provided in
visual form must available in speech unless it can be unambiguously
represented with a simple tone , or by tactile vibration of something that
will be touching the skin throughout the operation of the product. This can
be met by providing the speech or tones directly or through the AT
compatibility provisions. (see 2.1-A for a listing) Products that
play DRM controlled visual media must provide a means to auditorily present
the visual media in a way that does not violate DRM if the media allows this
to be done.





The latter sentence deals with media controlled by DRM. Other provisions
speak to content being programmatically determinable - but DRM controlled
media are 'closed' and by definition are not 'programmatically determinable.
Where the media meets the other provisions - but maintains its closed
functionality due to DRM, the media players need to then provide a DRM
conformant way to play the information in audio. (If DRM is handled in
a different provision - then the DRM sentence could be removed here.









Gregg

------------------------

Gregg C Vanderheiden Ph.D.
Professor - Depts of Ind. Engr. & BioMed Engr.
Director - Trace R & D Center
University of Wisconsin-Madison
< <http://trace.wisc.edu/> http://trace.wisc.edu/> FAX 608/262-8848

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