JP2

[mattgarrish]

Many EPUB 3 publications have already been created in Japan. It is practically impossible to modify them by embedding accessibility metadata. Will bookstores be non-conformant if they continue to sell such EPUB publications

Proposed Change: See #24

(Overall)

[mattgarrish]

This sounds like a regulatory question, not something we can answer. Wouldn't it also be practically impossible to make them all accessible?

[mattgarrish]

Partially accepted

Although distribution systems are mentioned but there is no requirement mandated. The document is focused on the content, and display of metadata by book store is out of scope of this document.

Action: Improve the text of the document so that confusion of requirements for distribution, DRM and reading systems is removed.

[mattgarrish]

Most of the remaining issues are about clarifying what the specification applies to. The changes I've made so far are:

1) To modify the scope to indicate that new processing and rendering requirements are out of scope:

This document does not specify new requirements for the processing or presentation of EPUB Publications by Reading Systems.

2) I removed the Discovery class as mentioned in #20.

3) I've rewritten Clause 10 as follows:

The creation of an Accessible EPUB Publication does not in itself guarantee that the content will be obtainable or consumable by users. Depending on how the EPUB Publication is distributed, other factors will influence its overall accessibility.

This document distinguishes factors that an Author has influence over from those that they do not. For example, an accessible interface for locating and obtaining content is an essential part of the distribution process, as is the ability to search and review accessibility metadata. Such interfaces are typically out of the control of content Authors, however, as distribution of EPUB Publications is often done through third parties. This document does not require that Authors only use such accessible distribution channels or that distributors only accept accessible content. Even when an Author controls their own distribution, the accessibility of their bookstore, library and/or Reading System is outside the scope of this document.

There are, however, decisions an Author can control when their content is distributed, such as what digital rights to apply. Although these decisions are not part of the preparation of the content, their potential impact on users requires attention.

To minimize the effects of distribution on accessibility, Authors therefore shall adhere to the following distribution practices:

• the Author shall not impose restrictions that impair access by Assistive Technologies; and
• the Author shall include accessibility metadata in the record format required for distribution of an EPUB Publication when such metadata is supported by the format.

NOTE Authors are not prevented from using distributors whose digital rights management schemes impair accessibility by this section. The requirement is to not purposefully activate a feature that impairs accessibility that would normally not be active (e.g., restricting access to the text by assistive technologies).

Does this look like it will be sufficient? Were there any other specific areas discussed that need modification?

/cc @GeorgeKerscher @avneeshsingh @murata2makoto

[GeorgeKerscher]

I think this is OK.

[murata2makoto]

The use of "shall" in your last para implies that there are normative requirements on authors. Avoid "shall" if you do not intend to specify conformance requirements on EPUB publications.

[mattgarrish]

Avoid "shall" if you do not intend to specify conformance requirements on EPUB publications.

This would mean we have to remove any normative mention of external metadata records, as such records are unrelated to the epub publication itself. The record is often sent in advance of the publication.

[murata2makoto]

If this change is not accepted, Japan will have to vote NO for the DIS. Any normative requirement here is unacceptable.,

[mattgarrish]

This isn't a clarification, though, it's a significant change to the requirements of the specification.

We end up with two specifications that are supposed to be the same but that impose different requirements depending on which you read.

If we want to make changes like this, we should be doing so in conjunction with a 1.1 revision so that the full epub community has input into the changes and so we can release a new W3C document that matches the new requirements.

[murata2makoto]

I have assumed that a revised version of the EPUB A11Y has to be published as a note from W3C. I think that it should be called "1.0 (second edition)".

[mattgarrish]

I have assumed that a revised version of the EPUB A11Y has to be published as a note from W3C.

That's fine, too. I'm just a bit in the dark about what was discussed and agreed to, which is why I'm concerned about making changes like this. If the group agreed at the last call to make distribution informative, I'll make the change. I just don't see that level of detail in the notes.

[murata2makoto]

Indeed, it was agreed to make distribution informative.

[mattgarrish]

Okay, then how about this instead:

10 Distribution (informative)

The creation of an Accessible EPUB Publication does not in itself guarantee that the content will be obtainable or consumable by users. Depending on how the EPUB Publication is distributed, other factors will influence its overall accessibility.

Not all these factors are under the control of the Author. For example, an accessible interface for locating and obtaining content is an essential part of the distribution process, as is the ability to search and review accessibility metadata. Such interfaces are typically out of the control of content Authors, however, as distribution of EPUB Publications is often done through third parties. Even when an Author controls their own distribution, the accessibility of their bookstore, library and/or Reading System might be outside their control.

There are, however, decisions an Author can control when their content is distributed, such as what digital rights to apply to their EPUB Publications. Although these decisions are not part of the preparation of their EPUB Publications, their potential impact on users means attention needs to be paid to them.

To minimize the effects of distribution on accessibility, Authors are therefore advised to adhere to the following distribution practices:

• they not impose restrictions that impair access by Assistive Technologies; and
• they include accessibility metadata in the record format required for distribution of an EPUB Publication when such metadata is supported by the format.

NOTE Following the guidance in this section does not prevent Authors from using distributors whose digital rights management schemes impair accessibility. The intent is that the Author not impair accessibility by activating a feature that that would normally not be active (e.g., restricting access to the text by Assistive Technologies).

// edited to remove some minor redundancies

[murata2makoto]

I have nothing against this clause. But I would like to have a look at the entire draft.