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THE ACCESSIBILITY OF UAA'S WEB PRESENCE
Accessibility—in the context of content presentation on the Web—refers to the ability of an individual to utilize online content even when functioning under limited conditions (e.g., use of a screen reader to aid an individual with limited or no sight). The aim of making a Web site accessible is to enable more users to access the Web site effectively in more situations.

The University of Alaska has undertaken a systematic approach to revamping its Web presence to ensure that it complies with and exceeds the parameters set forth in recent federal accessibility legislation.

This overview seeks to provide a summary of the pertinent legislation, what that means in terms of Web site components that need revision, and how an Institute Web author/developer might go about making his or her site(s) compliant.

Pertinent Legislation
The Americans with Disabilities Act (ADA) of 1990 requires state and local governments to provide auxiliary aids and services where necessary to ensure effective communication with individuals with disabilities, unless doing so would result in a fundamental alteration to the program or service or in an undue burden. Section 508 of the Rehabilitation Act Amendments (RAA) of 1998 complements the ADA by specifically requiring public agencies to make online content accessible to users with special needs.

The Architectural and Transportation Barriers Compliance Board (Access Board) has issued final accessibility standards for electronic and information technology covered by section 508 of the RAA. Section 508 requires the Access Board to publish standards setting forth a definition of electronic and information technology and the technical and functional performance criteria necessary for such technology to comply with section 508. The final document draws heavily from, but does not directly mirror, the Web Content Accessibility Guidelines 1.0 (WCAG), published by the World Wide Web Consortium (W3C).

Enforcement and Effective Date
The enforcement provisions of section 508 took effect on June 21, 2001.

By statute, the enforcement provisions of section 508 apply only to electronic and information technology procured on or after the effective date. As a result, section 508 does not authorize complaints or lawsuits to retrofit technology procured before this date to meet the Board's standards. However, even though section 508's enforcement mechanisms apply only to procurement, the law does require access to technology developed, used, or maintained by a government agency.

An agency does not have to comply with the technology accessibility standards if it would impose an “undue burden” to do so. This is consistent with language used in the ADA and other civil rights legislation, where the term "undue burden" has been defined as "significant difficulty or expense." However, the agency must explain why meeting the standards would pose an undue burden for a given procurement action, and must still provide people with disabilities access to the information or data that is affected.

Compliance Criteria
A Web site required to be accessible by section 508 would be in complete compliance if it met paragraphs (a) through (p) of these standards. It could also comply if it fully met the WCAG 1.0 (as detailed in http://www.w3.org/TR/WCAG10/ ), priority one checkpoints and paragraphs (l), (m), (n), (o), and (p) of these standards. A federal Web site that was in compliance with these standards and that wished to meet all of the WCAG 1.0 priority one checkpoints would also have to address issues regarding using the clearest and simplest language appropriate for a site's content, alerting a user when there is a change in the natural language of the page, audio descriptions, and the provision that Web pages reliably update both dynamic and equivalent sites simultaneously, should they be maintained separately.

Accessibility Parameters
a) Paragraph (a) requires that a text equivalent for every non-text element shall be provided. As the Internet has developed, the use of photographs, images, and other multimedia has increased greatly. Most Web pages are created using HTML, or "HyperText Markup Language." A "page" in HTML is actually a computer file that includes the actual text of the Web page and a series of "tags" that control layout, display images (which are actually separate computer files), and essentially provide all content other than text. The tags are merely signals to the browser that tell it how to display information, and many tags allow Web designers to include a textual description of the non-textual content arranged by the tag. The provision is necessary because assistive technology cannot describe pictures, but can convey the text information to the user.

Currently, most Web page authoring programs already provide a method for Web designers to associate words with an image, and associating text with non-textual content is easy for anyone familiar with HTML. This provision requires that when an image indicates a navigational action such as "move to the next screen" or "go back to the top of the page," the image must be accompanied by actual text that states the purpose of the image, or what the image is telling you to do. This provision also requires that when an image is used to represent page content, the image must have a text description accompanying it that explains the meaning of the image. Associating text with these images makes it possible for someone who cannot see the screen to understand the content and navigate a Web page.

The types of non-text elements requiring identification are limited to those images that provide information required for comprehension of content or to facilitate navigation. Web page authors often utilize transparent graphics for spacing. Adding text to identify these elements would produce unnecessary clutter for users of screen readers.

The Board also interprets this provision to require that when audio presentations are available on a Web page (because audio is a non-textual element), text in the form of captioning must accompany the audio to allow people who are deaf or hard of hearing to comprehend the content.

b) Paragraph (b) provides that equivalent alternatives for any multimedia presentation shall be synchronized with the presentation. This would require, for example, that if an audio portion of a multimedia production was captioned as required in paragraph (a), the captioning must be synchronized with the audio. There are new techniques for providing realtime captioning that are supported by new versions of programs such as RealAudio. Providing captioning does not preclude posting a transcript of the speech for people to search or download.

c) Paragraph (c) prohibits the use of color as the single method for indicating important information on a Web page. When colors are used as the sole method for identifying screen elements or controls, persons who are color blind as well as those people who are blind or have low vision may find the Web page unusable. This provision does not prohibit the use of color to enhance identification of important features. It does, however, require that some other method of identification, such as text labels, must be combined with the use of color. For example, a Web page that directs a user to "press the green button to start" should also identify the green button in some other fashion than simply by color.

d) Paragraph (d) provides that documents must be organized so they are readable without requiring browser support for style sheets. Style sheets are a relatively new technology that lets Web site designers make visually consistent Web pages that can be easily updated. For instance, without style sheets, making headings appear in large font while not affecting the surrounding text requires separate tags hidden in the document to control font size and boldface. Each heading would require a separate set of tags.

Using style sheets, however, the Web site designer can specify in a single tag that all headings in the document should be in large font and boldface. Because style sheets can be used to easily affect the entire appearance of a page, they are often used to enhance accessibility, and this provision does not prohibit the use of style sheets. This provision requires that Web pages using style sheets be able to be read accurately by browsers that do not support style sheets and by browsers that have disabled the support for style sheets. This requirement is based on the fact that style sheets are a relatively new technology, and many users with disabilities may either not have computer software that can properly render style sheets or because they may have set their own style sheet for all Web pages that they view.

e) Paragraph (e) requires Web page designers to include redundant text links for each active region of a server-side image map on their Web pages. An "image map" is a picture on a Web page that provides different "links" to other Web pages, depending on where a user clicks on the image. There are two basic types of image maps: "client-side image maps" and "server-side image maps." With client-side image maps, each "active region" in a picture can be assigned its own "link" that specifies what Web page to retrieve when a portion of the picture is selected. HTML allows each active region to have its own alternative text, just like a picture can have alternative text.

By contrast, clicking on a location of a server-side image map only specifies the coordinates within the image when the mouse was depressed - which link or URL is ultimately selected must be deciphered by the computer serving the Web page. When a Web page uses a server-side image map to present the user with a selection of options, browsers cannot indicate to the user the URL that will be followed when a region of the map is activated. Therefore, the redundant text link is necessary to provide access to the page for anyone not able to see or accurately click on the map.

f) Paragraph (f) provides that client-side image maps shall be provided instead of server-side image maps except where the regions cannot be defined with an available geometric shape. As discussed above, there are two general categories of image maps: client-side image maps and server-side image maps. When a Web browser retrieves a specific set of instructions from a client-side image map, it also receives all the information about what action will happen when a region of the map is pressed. For this reason, client-side image maps, even though graphical in nature, can display the links related to the map in a text format that can be read with the use of assistive technology.

g) and h) Paragraphs (g) and (h) permit the use of tables, but require that the tables be coded according to the rules for developing tables of the markup language used. When tables are coded inaccurately or table codes are used for non-tabular material, some assistive technology cannot accurately read the content. Many assistive technology applications can interpret the HTML codes for tables and will most likely be updated to read the table coding of new markup languages.

The Board understands that there are currently few alternatives to the use of tables when trying to place items in predefined positions on Web pages. These provisions do not prohibit the use of table codes to format non-tabular content. They require that when a table is created, appropriate coding should be used.

i) Paragraph (i) addresses the use of frames and requires that they be titled with text to identify the frame and assist in navigating the frames. "Frames" are a technique used by Web designers to create different "portions" or "frames" of their screen that serve different functions. When a Web site uses frames, often only a single frame will update with information while the other frames remain intact. Frames can be an asset to users of screen readers and other assistive technology if the labels on the frames are explicit. Labels such as top, bottom, or left provide few clues as to what is contained in the frame. However, labels such as "navigation bar" or "main content" are more meaningful and facilitate frame identification and navigation.

j) Paragraph (j) sets limits on the blink or flicker rate of screen elements. The W3C’s Web Content Accessibility Guidelines 1.0 provide that "[u]ntil user agents allow users to control flickering, avoid causing the screen to flicker." Several technologies can cause a flashing effect, but it is the recommendation of the Board to minimize or avoid technology that will cause that to happen.

k) Paragraph (k) requires that a text-only Web page shall only be provided as a last resort method for bringing a Web site into compliance with the other accessibility requirements. Text-only pages must contain information or functionality that is equivalent to the primary pages. Also, the text-only page shall be updated whenever the primary page changes.

l) Paragraph (l) requires that when Web pages rely on special programming instructions called "scripts" to affect information displayed or to process user input, functional text shall be provided. It also requires that the text be readable by assistive technology such as screen reading software. Scripts are widely used by Web sites as an efficient method to create faster or more secure Web communications. A script is a programmatic set of instructions that is downloaded with a Web page and permits the user's computer to share the processing of information with the Web server. Without scripts, a user performs some action while viewing a Web page such as selecting a link or submitting a form, a message is sent back to the "Web server," and a new Web page is sent back to the user's computer. The more frequently an individual computer has to send and receive information from a Web server, the greater chance there is for errors in the data, loss of speed, and possible violations of security.

Also, when many users are simultaneously viewing the same Web page, the demands on the Web server may be huge. Scripts allow more work to be performed on the individual's computer instead of on the Web server, and the individual computer does not have to contact the Web server as often. Scripts can perform very complex tasks such as those necessary to complete, verify, and submit a form and verify credit information. The advantage for the user is that many actions take place almost instantly, because processing takes place on the user's computer and because communication with the Web server is often not necessary. This improves the apparent speed of a Web page and makes it appear more dynamic. JavaScript—a standardized object-oriented programming language—is a good example of a scripting language, and certain plug-ins support slightly different scripting languages. This provision requires Web page authors to ensure that all the information placed on a screen by a script shall be available in a text form to accommodate assistive technology.

Web page authors have a responsibility to provide script information in a fashion that can be read by assistive technology. When authors do not put functional text with a script, a screen reader will often read the content of the script itself in a meaningless jumble of numbers and letters. Although this jumble is text, it cannot be interpreted or used. For this reason, the provision requires that functional text—text that when read conveys an accurate message as to what is being displayed by the script—be provided. For instance, if a Web page uses a script only to fill the contents of an HTML form with basic default values, the Web page will likely comply with this requirement, as the text inserted into the form by the script may be readable by a screen reader.

By contrast, if a Web page uses a script to create a graphic map of menu choices when the user moves the pointer over an icon, the Web site designer may be required to incorporate "redundant text links" that match the menu choices because functional text for each menu choice cannot be rendered to the assistive technology. Determining whether a Web page meets this requirement may require careful testing by Web site designers, particularly as both assistive technology and the JavaScript standard continue to evolve.

m) While most Web browsers can easily read HTML and display it to the user, several private companies have developed proprietary file formats for transmitting and displaying special content, such as multimedia or very precisely defined documents. Because these file formats are proprietary, they cannot ordinarily be displayed by Web browsers. To make it possible for these files to be viewed by Web browsers, add-on programs or "plug-ins" can be downloaded and installed on the user's computer that will make it possible for their Web browsers to display or play the content of the files.

Paragraph (m) requires that Web pages that provide content such as Real Audio or PDF files also provide a link to a plug-in that will meet the software provisions. It is very common for a Web page to provide links to needed plug-ins. For example, Web pages containing Real Audio almost always have a link to a source for the necessary player. This provision places a responsibility on the Web page author to know that a compliant application exists before requiring a plug-in.

n) Paragraph (n) requires that people with disabilities have access to interactive electronic forms. Electronic forms are a popular method used by many agencies to gather information or permit a person to apply for services, benefits, or employment. The 1998 Government Paperwork Elimination Act requires that federal agencies make electronic versions of their forms available online when practicable and allows individuals and businesses to use electronic signatures to file these forms electronically. At present, the interaction between form controls and screen readers can be unpredictable, depending upon the design of the page containing these controls. Some developers place control labels and controls in different table cells; others place control labels in various locations in various distances from the controls themselves, making the response from a screen reader less than accurate many times.

This provision does not forbid the use of scripts or plug-ins, and many of the existing products support these features. If a browser does not support these features, however, paragraphs (l) and (m) require that some other method of working with the Web page must be provided.

o) Paragraph (o) provides that a method be used to facilitate the easy tracking of page content that provides users of assistive technology the option to skip repetitive navigation links.

p) Paragraph (p) addresses the accessibility problems that can occur if a Web page times-out while a user is completing a form. Web pages can be designed with scripts so that the Web page disappears or "expires" if a response is not received within a specified amount of time. Sometimes, this technique is used for security reasons or to reduce the demands on the computer serving the Web pages. A disability can have a direct impact on the speed with which a person can read, move around, or fill in a Web form. For this reason, when a timed response is required, the user shall be alerted and given sufficient time to indicate that additional time is necessary. The final rule requires only that a user be notified if a process is about to time-out and be given an opportunity to answer a prompt asking whether additional time is needed.

Summary of Requirements
All Web sites maintained by public institutions must adhere to the following parameters, in accordance with Section 508:
1. provide a text equivalent for every meaningful non-text element
2. synchronize equivalent alternatives for multimedia presentations
3. do not use color as the single method for indicating important information
4. organize content so that it is readable without requiring browser support for style sheets
5. include redundant text links for each active region of a server-side image map
6. use client-side image maps except when hotlinks can’t be defined by geometric shapes
7. make sure tables are correctly coded according to standards
8. title all frames with text to identify each frame and assist in navigating the frames
9. limit or eliminate the blink or flicker rate of screen elements
10. avoid use of text-only sites; if unavoidable, it must receive equally frequent updates
11. provide functional text when using scripts to display information—make it all readable
12. provide links to appropriate, compliant plug-ins for “non-standard” media
13. interactive electronic forms must be usable by individuals with special needs
14. users must be able to skip repetitive navigation links
15. notify user if a process is about to time-out; give user opportunity to answer a prompt

Validation
The WCAG 1.0 provides several recommendations for validation that will help to ensure that Web communications meet the aforementioned accessibility guidelines. The W3C recommends the use of automatic tools for accessibility validation, coupled with subsequent human review. “Automated methods are generally rapid and convenient, but cannot identify all accessibility issues. Human review can help ensure clarity of language and ease of navigation.”

The following are some validation methods that should be employed to make pages accessible to all audiences:

1) Use an automated accessibility tool and browser validation tool. Please note that software tools do not address all accessibility issues, such as the meaningfulness of link text, the applicability of a text equivalent, etc.
- e.g. CAST’s Bobby online accessibility analysis tool — www.cast.org/bobby
- e.g. Bobby application — bobby.cast.org/html/en/pricing.jsp

2) Validate syntax (e.g., HTML, XML, etc.).
- e.g. W3C HTML Validation Service — validator.w3.org

3) Validate style sheets (e.g., CSS).
- e.g. W3C CSS Validation Service — jigsaw.w3.org/css-validator

4) Use a text-only browser or emulator.
- e.g. Opera — www.opera.com
- e.g. Lynx — lynx.browser.org

5) Use multiple graphic browsers with:
• sounds and graphics loaded,
• graphics not loaded,
• sounds not loaded,
• no mouse,
• frames, scripts, style sheets, and applets not loaded
- e.g. Opera (see above) does an excellent job of facilitating this

6) Use several browsers, old and new.
While support of non-standards-compliant browsers is not essential, it is important to know precisely how pages will display in the older generation of browser. Pages do not have to parse perfectly, but do need to have readable, navigable content. A more exhaustive discussion of standards compliance and browser upgrades can be found at the Web Standards Project's Browser Upgrade Campaign site.

7) Use a self-voicing browser, a screen reader, magnification software, a small display, etc.
- e.g. JAWS for Windows
http://www.freedomscientific.com/fs_products/software_jaws.asp
- e.g. IBM Home Page Reader
http://www-3.ibm.com/able/hpr.html

8) Use spell and grammar checkers. A person reading a page with a speech synthesizer may not be able to decipher the synthesizer's best guess for a word with a spelling error. Eliminating grammar problems increases comprehension.

9) Review the document for clarity and simplicity. Readability statistics, such as those generated by some word processors, may be useful indicators of clarity and simplicity. Better still, ask an experienced (human) editor to review written content for clarity. Editors can also improve the usability of documents by identifying potentially sensitive cultural issues that might arise due to language or icon usage.

10) Invite people with disabilities to review documents. Expert and novice users with disabilities will provide valuable feedback about accessibility or usability problems and their severity.

Should a Web site pass all of the checks that accompany the aforementioned practices—especially Priority 1 and 2 validation from CAST’s Bobby system, and W3C HTML (and CSS, if applicable) Validation—one should assume that the site complies with Section 508 of the RAA.

References
Special note should be made that a significant portion of the contents presented in this document were direct excerpts from the following resource:

“Section 1194.22 Web-based Intranet and Internet Information and Applications”
Electronic and Information Technology Accessibility Standards
Architectural and Transportation Barriers Compliance Board
[Published in the Federal Register on December 21, 2000]
36 CFR Part 1194
[Docket No. 2000-01]
RIN 3014-AA25
http://www.access-board.gov/sec508/508standards.htm

Additional information about this resource and the specifics contained therein may be obtained by contacting Doug Wakefield, Office of Technical and Information Services, Architectural and Transportation Barriers Compliance Board, 1331 F Street, NW., suite 1000, Washington, DC 20004-1111. Phone: (202) 272-5434 extension 139 (voice); (202) 272-5449 (TTY). E-mail: wakefield@access-board.gov.

Additional accessibility information can be found by visiting the web development site: www.bluediamondwebs.com
 
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