Audio Video c-e proposal

First Stab at Changes to 1194.24c-e

This document is a work in progress. Please make changes to the "Proposed Standards" section, leaving the "Current Standards" as is for reference.

Current Standards

In 24:

24(c) All training and informational video and multimedia productions, either live or taped, which support the agency's mission, regardless of format, that contain speech or other audio information necessary for the comprehension of the content, shall be open or closed captioned.

24(d) All training and informational video and multimedia productions which support the agency's mission, regardless of format, that contain visual information necessary for the comprehension of the content, shall be audio described.

24(e) Display or presentation of alternate text presentation or audio descriptions shall be user-selectable unless permanent.

In 22:

22(b) Equivalent alternatives for any multimedia presentation shall be time-synchronized with the presentation.

Current related definitions

Electronic and information technology. Includes information technology and any equipment or interconnected system or subsystem of equipment, that is used in the creation, conversion, or duplication of data or information. The term electronic and information technology includes, but is not limited to, telecommunications products (such as telephones), information kiosks and transaction machines, World Wide Web sites, multimedia, and office equipment such as copiers and fax machines. The term does not include any equipment that contains embedded information technology that is used as an integral part of the product, but the principal function of which is not the acquisition, storage, manipulation, management, movement, control, display, switching, interchange, transmission, or reception of data or information. For example, HVAC (heating, ventilation, and air conditioning) equipment such as thermostats or temperature control devices, and medical equipment where information technology is integral to its operation, are not information technology.

GEOFF AND ANDREW'S PROPOSED NEW LANGUAGE (based on discussions below and on the list/call):

(begin proposed new language)
24(c) All training and informational productions containing video and/or audio which support the agency's mission, regardless of format, that contain speech or other audio information necessary for the comprehension of the content, must comply with the following:

1) productions containing prerecorded audio and no additional time-based content must provide either a transcript or synchronized captions.
2) productions containing prerecorded video with concurrent audio must provide synchronized captions and may also offer a transcript.
3) productions containing real-time audio, with or without video, must provide synchronized real-time captions. [we need to discuss the feasibility of this]

24(d) All training and informational productions containing video and/or audio which support the agency's mission, regardless of format, that contain visual information necessary for the comprehension of the content, must comply with the following:

1) productions containing prerecorded video and no audio or other additional time-based content must provide either a separate text description of the video or provide an additional audio track to convey the informational content of the video.
2a) productions containing prerecorded video with concurrent audio must provide synchronized audio descriptions to convey the informational content of the video. [this one is in line with current 508]
2b) productions containing prerecorded video with concurrent audio must provide either a separate text description of the video or provide synchronized audio descriptions to convey the informational content of the video. [this one is in line with WCAG 2 current draft]
3a) productions containing live video must provide synchronized audio descriptions in real time to convey the informational content of the video. [goes beyond WCAG 2 current draft, goes beyond current 508]
3b) [no audio descriptions for live video due to cost involved]

24(e) Audio descriptions and captions must be either (a) permanently presented to all recipients ("open") or (b) capable of being turned on and off by each individual recipient ("closed").

(end of proposed new language)

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In 24: <toby>(suggestion: insert the definition for captioning as part of the preface to ensure current and emerging captioning technologies meet the same standards for either open or closed captionining. Clarification: Any transcripts developed are not considered a captioning alternative.)</toby>

<tombrett>Shouldn't there be a provision to insure that this information is available to the Deaf/Blind thru Braille Display?</tombrett>

<toby> suggests provisions to reflect quality control assurance or requirement for full comprehension, especially in the real-time captioning environment </toby>

<geoff>I propose that we *not* include provisions for quality control in captions (or descriptions). While I do not deny that caption quality is crucial, it is out of the scope of this subcommittee.</geoff>

24(c) All training and informational productions containing video and/or audio which support the agency's mission, regardless of format, that contain speech or other audio information necessary for the comprehension of the content, shall comply with the following:

1. <toby> suggests the phrase "taped (or prerecorded) and live" </toby> productions containing both audio and video shall contain synchronized captioning. <toby>Suggests the phrase "time-synchronized"</toby>

1. productions containing audio and no additional time-based content may provide a separate transcript.

< tombrett > I'd recommend that this read: productions containing audio and no time-based content may provide a separate transcript </tombrett>

1. productions containing real-time audio shall...

<vicki>live content should be captioned</vicki> <awk>live content - you say we must caption and/describe live media. This is of course the right thing to do, but is expensive (particularly for description) and is likely to be fought hard against.</awk> <larry> As the W3C also struggled with requirements for live captioning and description, so must we. I'd say that live captioning is now widely available and accepted (see the Federal Relay Captioning service we've all been using - pretty straight-forward and in order to link it to a streamed video, also pretty doable once you know how).

Live description has been rarely used - in any environment except perhaps live theater. But descriptions are essential nonetheless for so many applicable Federal situations such as a webcast with PowerPoint sides. So if we don't ask for/require some sort of equivalent access that might not be as onerous, we might actually see some compliance with the reg. As it stands, I've heard of and seen virtually no video description (my preferred term, unless you want to use the more elegant "narrative description") under 508 regs - live or pre-produced. </larry>

24(d) All training and informational productions containing video and/or audio which support the agency's mission, regardless of format, that contain visual information necessary for the comprehension of the content, shall comply with the following:

1. productions containing both video and audio shall contain synchronized audio descriptions.
2. productions containing video and no additional time-based content may provide a separate description of the video contents to convey the video content.
3. productions containing live video shall... <vicki>...be described</vicki>

<larry> So how about we open up a discussion about the possible use of "longdesc"-like descriptions (embedded, lengthy alt-text tags, in essence), that are somehow linked to visual presentations and that will serve a useful purpose in making graphics, charts and pictures accessible to blind and visually impaired people without requiring an expert describer, trained voice-over artist, and professional mix session.

This, like textual descriptions of graphics from a presentation available before, after or during a presentation would go far toward achieving the spirit of the law and the new letter if we write it that way. It would be like a presenter who is trained to read all of his on-screen graphics instead of saying, "as you see on this slide, revenue collections have changed dramatically."

This might not work for all such live media, but it may be better than what we are getting today. </larry>

24(e) Display or presentation of captions or audio descriptions shall be user-selectable unless permanent.

<toby> suggests provisions or guidelines on spacial or multimedia design issues to reflect the access needs for proper placement of captioning for visual aspect of programming. Some months ago, someone tried to design the multimedia presentation and place the captions separately onto the right side of the TV screen (outside of the "TV box") and it is not caption-friendly for deaf/hoh users like me to follow along with the moving images. </toby>

<geoff>I'm reluctant to include language restricting design and layout because 1) there are many variables, and 2) it may actually impair innovation. If we confine the caption display to one area of the display, we won't be taking into account the need to have flexibility in order to avoid covering important visuals. Can you give some examples of "proper placement?" </geoff>

<vicki>Suggests that we should include reference to DVD talking menus in this section</vicki> <awk>I feel that DVD menu systems are software -- they are created by software tools such as final cut pro or Macromedia Director (and others) and there can be functionally identical software applications that would need to be addressed in other sections.</awk>

<geoff>PROPOSED REVISION OF 24(e):
A method for turning closed captions or closed audio descriptions on and off shall be provided. If captions and descriptions are meant by the author to be open-- that is, permanently visible or audible to everyone-- a method for turning them on and off is not required.
</geoff>

In 22:

I propose that we suggest to the Web and software group that they remove 22b entirely. We will need to make sure that people are aware that section 24 needs to be adhered to.

<geoff f> If we remove 22b, then synchronized captions or descriptions will no longer be required, correct? If that's the case, I disagree with this recommendation. "User selectable" doesn't mean "synchronized." There *are* cases where synchronized captions aren't necessarily important (in an audio-only clip, for example), but there will be many more cases where synchronized captions are required for an equivalent experience. Ditto for descriptions, although there may be a wider variety of situations where they aren't necessary. But where they are necessary, I advocate for synchronization.</geoff f>

<awk>Geoff, it's me, Andrew! Of course captions need to be synchronized! I'm proposing that we define captions and audio description in the definitions to indicate that synchronization is part of the nature of these equivalents. If they aren't synchronized, they aren't captions or audio descriptions.</awk>

<geoff f>of course! but points 1 and 2 in 24(c) and (d) leave room for interpretation that could be misused. if you remove the explicitness provided by the word "synchronized," you'll get transcripts more often then captions or descriptions. stick the word back in (e.g., "productions containing both video and audio shall contain synchronized open or closed captions") and i'll be quiet.</geoff f>

<awk>I don't believe that (the part about you being quiet). I do think that if we define captions and descriptions as synchronized that the wiggle room is removed, but I agree that it will less likely for anyone to misinterpret it if we add this into the standard also. I changed that above.</awk>

<vicki>(I think this needs to be incorporated into 24. It needs to be in both places to ensure that people comply)</vicki>

22(b) Equivalent alternatives for any multimedia presentation shall be synchronized with the presentation.

Current related definitions

Electronic and information technology. Includes ..<snip>.. but is not limited to, telecommunications products (such as telephones), information kiosks and transaction machines, web sites, software applications, audio and video information, and office equipment...<snip>

We may need a definition of "closed captions" and "video descriptions" and do indicate that synchronization is part of their nature.