NetCentric President testifies to US Access Board

Introduction

Mr. Chairman, my name is Duff Johnson. I’m the Project Co-Leader of the ISO Committee for ISO 32000 and the US Chair for ISO 14289, the forthcoming International Standard for accessible PDF.

It is an honor to testify today with a discussion of how PDF, the electronic document format, relates to WCAG 2.0, to the ANPRM and to Section 508. I am here to deliver the message that WCAG 2.0 Level AA conformance finds expression in PDF technology when both the PDF file and the software used to read it both conform to PDF/UA. As such, I recommend the Access Board adopt PDF/UA as the applicable technical standard whenever the ICT Standards and Guidelines would regard WCAG 2.0 level AA as applicable to a given PDF page, document, form or software application. 

Proposed edits to the Section 508 Advanced Notice of Proposed Rulemaking will be provided in a follow-up communication prior to the end of the current comment period.

Update on the PDF/UA Standards Development Process

I last appeared before the Access Board to report on progress with PDF/UA on May 12, 2010.

The normative text for ISO 14289-1 was finalized December 2011 in Bellevue, WA. The Final Draft International Standard, or “FDIS” two-month ballot will be distributed shortly. A complete mapping of WCAG 2.0 success criteria to PDF/UA subsections and paragraphs is nearing completion following the finalization of normative text for PDF/UA.

We can state with confidence that ISO 14289-1 will be formally published on the ISO website in 2012. PDF/UA is immanent. 

Supporting the new ISO Standard for accessible PDF will not be trivial. Nonetheless, some vendors are already planning support for ISO 14289 as “WCAG 2.0 for PDF”.

PDF: An Open Standard

The PDF format is no longer owned or controlled by Adobe Systems. Since 2008, PDF has been managed by the international standards process as ISO 32000. That Committee, which I have the honor and responsibility of serving as Project Co-Leader with my colleague, Cherie Ekholm of Microsoft, is presently working on PDF 2.0, which we expect to publish sometime in 2013 or 2014.

The History of PDF and Accessibility

As the Access Board knows well, PDF has a checkered past in the area of accessibility. Prior to 2000, there was literally no way to make an accessible PDF file. The essential semantic structures necessary to build up words from characters, and paragraphs from words simply didn't exist in Adobe’s Portable Document Format until PDF Reference 1.3 published by Adobe in 2000. 

For reasons connected with the overwhelming imperatives of reliability and flexibility PDF is internally complex. The technology includes broad and deep capabilities that go well beyond simple printed pages; PDF’s conceptual and operational challenges have taken a long time to resolve.

Why did it take so long to produce 23 pages? It’s a fair question. The answer, in part, is that PDF Reference 1.7, which defined PDF in 2007, became ISO 32000 in 2008, right in the middle of PDF/UA’s development.

An even greater impact to the schedule came from the publication of WCAG 2.0, also published in 2008. The general acceptance of WCAG 2.0 following publication caused the authoring committee to rewrite major sections of PDF/UA from scratch for an entirely different set of reasons – to embody WCAG 2.0 in the context of ISO 32000-1.

PDF’s vital role

I want to remind the Board of the unique position of PDF with respect to electronic documents in general and government documents in particular. Any application that can print can make a PDF. It’s critical to recognize that this self-contained, flexible paper-like PDF includes qualities that the marketplace sees as vital. These features, while part of the power of the format, also make accessible PDF a challenge for developers. It’s a vital and unavoidable one. The challenge of ensuring accessible PDFs reflects accurately the very features that make PDF the universal baseline electronic document format everywhere Section 508 will reach.

The Access Board knows this well; the Notice posted on the Access Board’s site includes a link to an appropriately accessible PDF version of the Notice at the very top of the page.

PDF technology is relied on in ways large and small throughout government and business because PDF delivers a reliable multiplatform viewing and printing experience as a “hardcopy reference”. As electronic paper, PDF is simply and objectively regarded as the default final-form medium for formal or closely designed content.

PDF/UA

PDF/UA began as a project of AIIM, the industry association for electronic content management. AIIM oversees U.S. interests in International Standards for electronic content at the ISO level. 

ISO 14289 is not for end users or even IT personnel. The standard details obligations for both software developer and content authors in spare, technical language focused on the PDF file itself and conforming Reader technologies. Many possible software features, functions and user-interface experiences are possible in accomplishing PDF/UA requirements. PDF/UA very deliberately does not prescribe any specific software design or interface, this is appropriately up to the developer.

WCAG 2.0 Level AA is fully supported by PDF/UA. PDF files that are known to comply with PDF/UA will thereby also comply with WCAG 2.0 Level AA.

Mapping to WCAG 2.0

The mapping of WCAG 2.0 Level AA to PDF/UA is under development, with a draft posted on AIIM’s PDF wiki for the US Committee for PDF/UA. The PDF/UA committees are also completing an Implementation Guide for developers of PDF technologies.

We anticipate this mapping will be available to the general public in the first half of 2012 and the implementation guide later in the year.

Future of PDF/UA

Two years ago I told the Access Board that PDF/UA would be published in early 2012. That was, it seems slightly optimistic. 

I can now say with confidence that the standard, an official mapping to WCAG 2.0 and the AIIM’s Implementation Guide for PDF/UA will all be published in 2012. 

I can say that the PDF Association has created a PDF/UA Competence Center and will shortly launch a Working Group to develop concepts for PDF/UA validation implementations. 

I can say that vendors agree that PDF/UA conformance is a means to accomplish WCAG 2.0 Level AA conformance in PDF files and software, and that several vendors are already committed to supporting PDF/UA, including Adobe Systems and ourselves at NetCentric. A Swiss non-profit, Access for All, is commissioning development of a free PDF/UA validator with support and donations from Die Post, callas, Compart, NetCentric and others. 

Several national standards bodies and government agencies outside the US have expressed interest in PDF/UA including the British Standards Institution and German DIN. Diverse advocacy and technology organizations including the American Foundation for the Blind and the DAISY Consortium are also following the Committee's efforts.

Conclusion

PDF/UA, at around 20 pages, provides authoritative restrictions and affirmative requirements on accessible usage of ISO 32000-1. The document is not for end-users, but like PDF itself, you don’t have to know how it works to like the results when it’s implemented correctly.

Thank you for this opportunity to update you on progress towards an international standard for accessible PDF. In electronic document accessibility news, 2012 will be the year of PDF/UA. 

I’ve included a list of references in my prepared remarks.

Answers to Section VI Questions in the December, 2011 ANPRM

Question 1: As discussed above, in response to public comments, the Board has made significant changes to the 2010 ANPRM by consolidating, streamlining, and removing provisions and advisories to improve readability, comprehensibility, and usability.

No comments.

Question 2: As noted above, the Board has changed the approach taken towards covered electronic content (E205.1) in the 2011 ANPRM. The proposed requirement in Section E205.1 requires electronic content falling into certain categories of official communications by federal agencies to be accessible. Should additional or different types of communications be included in this subsection? What are the benefits and costs of this approach? Would such an approach have any unintended consequences on federal agency communications?

ANSWER: As noted in my testimony, PDF plays a vital role in the dissemination of government and other communications, both formal and informal. Adoption of PDF/UA facilitates the continued usage of PDF while assuring accessibility per WCAG 2.0 Level AA.

Question 3: In the discussion above, the Board has changed the approach to the functional performance criteria for limited hearing (302.5) and limited vision (302.2) in the 2011 ANPRM to require three specific features to be provided.

No comments.

Question 4: As noted above, the 2011 ANPRM has changed the relationship between the functional performance criteria and the technical provisions (E204.1).

No comments.

Question 5: The 2011 ANPRM requires websites to be accessible to individuals with disabilities by conforming to WCAG 2.0. WCAG 2.0 allows a non-conforming (i.e., inaccessible) webpage to be considered compliant if there is an accessible mechanism for reaching an accessible version of the webpage that is up to date and contains the same information and functionality as the inaccessible webpage. A web page that meets all these criteria qualifies as a “conforming alternate version” and is intended to provide individuals with disabilities equivalent access to the same information and functionality as the non-conforming web page. However, unrestricted use of conforming alternate versions may facilitate the emergence of two separate websites: one for individuals with disabilities and another for individuals without disabilities. Alternatively, restricting the use of conforming alternate versions may result in significant costs to federal departments and agencies by limiting their options for providing accessible content.

Should the Board restrict the use of conforming alternate versions? The Board seeks comments on whether allowing inaccessible content, even with conforming alternate versions, negatively affects the usability and accessibility of websites by individuals with disabilities. The Board also requests comments on the difficulty or costs that may be incurred if federal departments or agencies are not free to use conforming alternate versions of content along with inaccessible content. 

ANSWER: PDF is already accepted in the marketplace and is integral to many electronic document implementations worldwide. The Access Board needs to accommodate PDF for the same reason as it needs to accommodate HTML, CSS and JavaScript: widespread and accepted use. Requiring users to abandon PDF would cause difficulty and costs far in excess of the difficulty and costs of compliance with PDF/UA.

It’s important to consider that user authoring processes necessary to production of accessible web content are the same essential processes as are required for compliance with PDF/UA.

Question 6: As noted above, Chapter 4 addresses features of ICT which may be used to communicate or produce electronic content or retrieve information or data. Some of the sections addressing these features of ICT include but are not limited to: Two Way Voice Communication (408), Operable Parts (407), and Standard Connections (406). The Board seeks comment on whether it should provide additional provisions to address accessibility concerns associated with features of ICT, such as content displayed on small screens, which are not otherwise addressed. For example the Board is considering whether to allow an exception to subsection 402.4 for text size for ICT which has a smaller screen. Should the Board require a minimum or maximum screen size to display content? Should a minimum text size be specified for display on a screen? When ICT communicates or produces electronic content or retrieves information or data, are there additional unique limiting features that are not adequately addressed in these provisions, such as screen and text size and battery life, which the Board should address? 

ANSWER: PDF/UA anticipates and accommodates re-use of PDF documents on screens of varying sizes, without limitation.

Question 7: The 2011 ANPRM has retained the approach of addressing features of ICT which make the ICT accessible and usable to individuals with disabilities….

No comments.

Question 8: Some modern touch screen devices, such as versions of some smartphones and tablets, have proved popular with people who are blind, despite not having keys which are tactilely discernible. Should the provision requiring that input controls be tactilely discernible (407.3) be revised to allow for such novel input methods? Should the Board add an exception to 407.3 to allow for input controls which are not tactilely discernible when access is provided in another way? If so, how should access be addressed when the controls are not tactilely discernible? Should a particular technology or method of approach be specified?

ANSWER: PDF/UA presents no special considerations for this issue.

Question 9: As discussed above, the subsection for WCAG 2.0 conformance (E207.2) for user interface components and content of platforms and applications is intended to set a single standard for user interfaces, without regard to underlying rendering mechanisms, such as web browsers, operating systems, or platforms. Is applying the WCAG 2.0 Success and Conformance criteria to electronic documents and applications outside the web browser environment sufficient and clear to users, or should the Board provide further clarification? Are there other accessibility standards more applicable to user interface components and content of platforms and applications than WCAG 2.0 that the Board should reference?

ANSWER: As discussed in my testimony, PDF/UA details the means of achieving WCAG 2.0 conformance in PDF files and applications.

References