Revisiting Transcripts and Audio Description (SC 1.2.3/5/8)

[bruce-usab]

The purpose of this issue is to determine whether or not WCAG 2.1, success criterion 1.2.3 Audio Description or Media Alternative (Prerecorded) is still relevant to the accessibility of web content for people with disabilities.

The initial proposal was to delete/remove SC 1.2.3 from WCAG 2.2. There may be better alternatives, so really this issue is about revisiting 1.2.3, 1.2.5, and 1.2.8.

In my experience, having one (and only one) instance of a Double A SC wholly replacing a Single A SC has proven to be a surprisingly difficult stumbling block with teaching about WCAG.

In theory, the concept is easy: At Double A, SC 1.2.3 is superseded by SC 1.2.5. In actual practice, the instruction on this detail is not worth the cognitive load required to convey this particular nuance.

Straw Poll:

• Please vote a Thumbs Up reaction to this comment if your experience teaching about 1.2.3 is similar to my own.
• Please vote a Thumbs Down reaction to this comment if you teach about WCAG and do not have any particular difficulty with 1.2.3.

In 2008, when WCAG 2.0 was published, the working assumption was that some regulatory bodies would adopt the Single A level. I submit that this (1) has proven to not be the case; and (2) therefore, having an SC that is irrelevant at Double A is harmful and counter-productive.

The simplest course of action would be for 2.2 to not include SC 1.2.3.

We might also consider promoting Success Criterion 1.2.8 Media Alternative (Prerecorded) to Single A.

This top card of this issue will be updated as discussion on the issue progresses.

• Rephrased assertions as being just my experience (6/12).
• Added a straw poll request (6/12).
• Changed issue title and added sentence noting that revisiting 1.2.3, 1.2.5, and 1.2.8 are all in scope (6/14).
• Requested survey questions to help sort this issue out (6/20).

[mbgower]

I think there may be situations where one cannot meet the synchronized requirement, for whatever reason. Being able to offer a transcript is better than nothing. I think someone being able to indicate that the transcript is provided is a definsible way to gracefully fail the AA requirement while still providing some facilitation.

[johnfoliot]

I'll also note that David remarked on the call today (06/11) that in some territories they have an explicit, policy-driven "exemption" around 1.2.5 (even if all other things considered the requirement is for WCAG AA compliance). While Section 508 has effectively made SC 1.2.3 redundant for US Federal sites (et. al.), that may not be the case everywhere. For that reason I would oppose removal of this SC. JF

…

On Tue, Jun 11, 2019 at 9:54 AM bruce-usab ***@***.***> wrote: This top card of this issue will be updated as discussion on the issue progresses. The purpose of this issue is to determine whether or not WCAG 2.1, success criterion 1.2.3 Audio Description or Media Alternative (Prerecorded) <http://www.w3.org/TR/WCAG21/#audio-description-or-media-alternative-prerecorded> is still relevant to the accessibility of web content for people with disabilities. The proposal is delete/remove SC 1.2.3 from WCAG 2.2. Having one (and only one) instance of a Double A SC wholly replacing a Single A SC has proven to be a surprisingly difficult stumbling block with teaching about WCAG. In theory, the concept is easy: At Double A, SC 1.2.3 is superseded by SC 1.2.5. In actual practice, the instruction on this detail is not worth the cognitive load required to convey this particular nuance. In 2008, when WCAG 2.0 was published, the working assumption was that some regulatory bodies would adopt the Single A level. This has not been the case. Therefore, having an SC that is irrelevant at Double A is harmful and counter-productive. The simplest course of action would be for 2.2 to not include SC 1.2.3. We might also consider promoting Success Criterion 1.2.8 Media Alternative (Prerecorded) <http://www.w3.org/TR/WCAG21/#media-alternative-prerecorded> to Single A. — You are receiving this because you are subscribed to this thread. Reply to this email directly, view it on GitHub <#782?email_source=notifications&email_token=AAJL445SX2TIZ6PAX5TNNYTPZ64DDA5CNFSM4HW7GZKKYY3PNVWWK3TUL52HS4DFUVEXG43VMWVGG33NNVSW45C7NFSM4GY2Y5MA>, or mute the thread <https://github.com/notifications/unsubscribe-auth/AAJL44Y6CI3KRCW7NTDFECDPZ64DDANCNFSM4HW7GZKA> .

-- *​John Foliot* | Principal Accessibility Strategist | W3C AC Representative Deque Systems - Accessibility for Good deque.com

[mraccess77]

I agree with the concerns that in regions 1.2.5 is exempted and that some videos don't have sufficient pauses for AD. Moving 1.2.8 to Level A should solve that issue and also ensure that there is something available for users who are deafblind. Right now transcripts are not required at Level AA and getting transcripts at Level AA seems reasonable in today's environment.

[bruce-usab]

@mbgower wrote:

I think there may be situations where one cannot meet the synchronized requirement

Can you think of some examples?

I think someone being able to indicate that the transcript is provided is a defensible way to gracefully fail the AA requirement while still providing some facilitation.

This would be passing 1.2.3 but failing 1.2.5. But is this a good argument for keeping 1.2.5 status quo?

@mraccess77 wrote:

...some videos don't have sufficient pauses for AD.

That use case would not actually fail against 1.2.5 (since, by definition, AD narration is only dubbed over the default sound track). Also, it is pretty easy to find examples of decent AD for pretty intense theatrical uses (e.g., action movies), so I am always skeptical of assertions that an A/V production does not lend itself to AD.

There are times when it is hard to do a great job with AD, and a transcript might be better for those use cases. Also, many people prefer a transcript over AD. And, of course, some users do not benefit at all from AD, but would benefit from a transcript. But I think this all argues for promoting 1.2.8 to Single A.

Moving 1.2.8 to Level A should solve that issue and also ensure that there is something available for users who are deafblind. Right now transcripts are not required at Level AA and getting transcripts at Level AA seems reasonable in today's environment.

I agree, and would also like for us to have a conversation about that!

[mraccess77]

I have seen many training videos where there is not sufficient pauses to cover what is shown in a screenshare of a system. If there isn't enough room for pauses then you can't fit in the AD and as most agree it's not a failure of 1.2.5 -- but the person who is blind doesn't get the missed information at all and the content passed WCAG A AA. If we had a transcript requirement then at least that information would be available somehow. Agree on your point that there are some types of videos like this were the video is walking through entering code where the transcript would be the preferred method of access by people who are blind. But for other situations like movies the transcript is a very separate alternative that excludes people from the experience. So it really depends on the genre of the video content.

[bruce-usab]

@mraccess77 wrote:

I have seen many training videos where there is not sufficient pauses to cover what is shown in a screenshare of a system.

That is a great and common example actually! I will even go further, to generalize to like 99% of PowerPoint style presentations where the speaker cannot be bothered to read their slides. So the presenter is talking the whole time, but someone who is listening but not watching is lost.

If a bad presenter like that is being webcast live, they do not fail WCAG at any level! We do not have an AD requirement for live web casting. Maybe we can take a look a that also for 2.2?

[bruce-usab]

@johnfoliot wrote:

I'll also note that David remarked on the call today (06/11) that in some territories they have an explicit, policy-driven “exemption” around 1.2.5 (even if all other things considered the requirement is for WCAG AA compliance).

@DavidMacDonald can you provide the cite for that? I would like to see exactly how they phrase that exception.

While Section 508 has effectively made SC 1.2.3 redundant for US Federal sites (et. al.), that may not be the case everywhere.

But it is not just 508. EN 301 549 has the same result, as does every legal settlement that I know of.

Does anyone have examples of WCAG2 being required at the Single A and not the AA Level?

Aside from the Canadian example with exempting 1.2.5, are there other examples where WCAG 2.0 Level AA has been cherry picked?

[mraccess77]

Some electronic health records requirements called out WCAG A https://www.levelaccess.com/electronic-health-records-accessibility/ but these might have been overcome by ACAA.

[bruce-usab]

Some electronic health records...

Good catch! But of course, it would be pretty unusual to have multimedia in EHR.

Here is a shortish URL for 45 CFR Part 170: www.ecfr.gov/cgi-bin/text-idx?node=pt45.1.170

To find where WCAG 2.0 Level A is applicable to EHR, search that page for “170.204(a)(1)”. (Just two instances, but they are quite significant.)

The single cite to WCAG 2.0 Level AA is written as “170.204(a)(2)” and is not actually all that helpful.
Here is that excerpt:

Such access must be consistent and in accordance with the standard adopted in §170.204(a)(1) and may alternatively be demonstrated in accordance with the standard specified in §170.204(a)(2).

So one can meet the Level A requirement by conforming to Level AA. Duh!

[bruce-usab]

I have added a straw poll to my original post, and would ask folks to use that to indicate if you find 1.2.3 particularly annoying to teach about (or not).

Please do not use the straw poll to vote if we should deprecate 1.2.3 (or not). That sort of action should wait for a survey, and after more conversation about the issue.

A simple explanation for my experience is that I am poor teacher and/or have dull students!

[awkawk]

@bruce-usab OP?

[bruce-usab]

OP == original post / sorry

[johnfoliot]

@bruce: Audio Description (prerecorded video) except where the video provides information related to health and safety of Canadians WCAG 2.0 Success Criterion 1.2.5 Audio Description Exclusions for a 10 business day grace period: - Pre-recorded videos have a 10 business day grace period from time of publication to when closed captions and transcription of videos must be provided. Live Video Captions exclusions refer to closed captioning and transcription of live video Audio Description (prerecorded Videos) are only required for videos that relate to health and safety of Canadians; for remaining prerecorded videos, audio description is not required. (source: https://www.tbs-sct.gc.ca/pol/doc-eng.aspx?id=23601 - Expand the Section "Appendix B: List of Exclusions: Published August 1, 2011 - highlight mine - the exclusion/exemption of SC 1.2.5 here means that it falls back to SC 1.2.3.) I fail to see why this is an issue: if you've met SC 1.2.5, then by default you've also met SC 1.2.3. Your presumption that every site out there is striving for AA full compliance is not based on real evidence, but rather (I will suggest) your vantage point from the US Federal Government perspective. Additionally, while I support moving SC 1.2.8 Media Alternative (Prerecorded) (a.k.a. Provide a Transcript) 'higher' in severity, jumping from AAA to A is quite radical. We could move it to a AA SC, in alignment with other video-related SC (1.2.5 Audio Descriptions and 1.2.4 Captions (Live) ) - remembering that the prioritization of A, AA, and AAA was based not only on impact to the user, but also effort on the part of the content creator. Bottom line here Bruce - I will strenuously oppose the deprecation of SC 1.2.3 in the context of any WCAG 2.x work, unless you can categorically prove that it is not relevant in the context of internationalization support. JF

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