EPUB 3 Working Group A11y Telco — Minutes

Date: 2021-01-28

See also the Agenda and the IRC Log


Present: Avneesh Singh, Gregorio Pellegrino, Matthew Chan, Matt Garrish, George Kerscher, Wendy Reid, Ben Schroeter, Cristina Mussinelli


Guests: Luc Audrain

Chair: Avneesh Singh

Scribe(s): Matthew Chan


Avneesh Singh: today’s call is mainly for mapping EUAA
… with epub a11y spec

1. Review of mapping of EPUb Accessibility to European accessibility directive

Avneesh Singh: See mapping EAA - EPUB Accessibility Guidelines.

Avneesh Singh: https://w3c.github.io/epub-specs/epub33/a11y/index.html

Avneesh Singh: luc, gregorio and christina have done a lot of this work for us
… what we need to do today is to evaluate whether the current spec is able to meet the EUAA, and whether we need to make some improvements to our spec
… are there any ambiguities that we need to clarify in the spreadsheet?
… and what is our plan going forward?

Luc Audrain: the EUAA is about products and services
… prods are mainly hardware (devices, machines, something that has a physical aspect)
… services are more digital
… in this case we are concerned about ebooks as services
… the prods side is more for people building and selling ereaders
… but it is clear that the ebooks themselves are governed by the services part
… the services sold starting 2025 will need to comply (as long as those services are sold in EU countries)
… the EUAA takes its principles from existing accessibility standards
… the EUAA is divided into several sections (1 about products, 2 about specific products, 3 about means of providing services (generic), 4 is about specific services)
… 4f is specifically about ebooks
… and ebook content
… gregorio has worked on the mapping from these section 3 and 4f to our spec

Gregorio Pellegrino: the spreadsheet > 1st col is about content creators, 2nd is about RS, 3 is about distribution channels
… since EUAA are connected to WCAG, we added links directly to the related sections of WCAG that apply to the corresponding EUAA section
… we found that there are no pieces missing from the spec
… but some areas require more investigation
… one of these is about MO
… the EUAA requires that if there is audio, then audio must be sync with text
… in spec, this is not mandatory
… also, spec allows for use of both WCAG A and AA
… might be that only AA meets EUAA
… also, we must think about DRM and RS features such as enlarging text, and changing spacing of text that are the law, but not necessarily part of the spec

George Kerscher: is an epub that can be loaded on multiple different RS a prod or a service?

Luc Audrain: that would be a service

George Kerscher: with audiobooks, does the act specify that a stand alone audiobook with no text is not allowed?

Luc Audrain: there is absolutely no mention of audiobooks in the act
… not a single occurrence of this word
… they only talk about the audio of the text (i.e. in an ebook)
… we could say that this act doesn’t cover single audiobook services

George Kerscher: this fits with our notion of an optimised publication
… can you explain the difference between the 2 sheets in the workbook?

Luc Audrain: sheet 1 is about the specific requirements applying to ebooks (i.e. 4f)
… sheet 2 is about the generic requirements (i.e. section 3)
… section 3 is mainly about the ecosystem around the provision of the service
… e.g. b is about the documentation around the service
… e.g. c is about making websites (whether mobile or traditional browser) that website must be accessible
… e.g. d says that related services like helpdesk, that must also be accessible
… these very generic methods relate to all services, like transportation, banking
… of course these are important for our purposes, but they don’t relate directly to ebooks

Wendy Reid: I was at the accessibility action group meeting for british publishers this morning
… there was a lot of confusion about standards
… and about DRM’s impact on a11y tech
… EUAA doesn’t really seem to address the DRM question
… also, there is recurring confusion about difference between audiobooks, epubs with MO, and TTS as a user agent feature
… we should clarify that if your book is being read on RS with TTS, that has nothing to do with the author
… where as if you provide audio in your ebook, then you can use MO
… and audiobooks are completely separate from the above two categories

Cristina Mussinelli: we should check the epub requirements against ISO standards
… we also suspect that the EUAA will be format agnostic
… e.g. no preference for epub, or for a specific version of epub spec
… the spec only requires that any DRM used not impede accessibility
… but checking this would be a responsibility of the retailer
… publisher often does not control this
… also, if you have ebook and audiobooks, you are not required to combine these in order to meet the EUAA requirements
… especially as the rights to these formats might be split between different parties
… BUT if an author does combine text and audio in the same book, then it must be done in an accessible way
… as far as I know, the majority of audiobooks are not produced by publishers
… we should keep that in mind

Wendy Reid: the rights question is probably fueling some of the confusion

Cristina Mussinelli: there is some fear that TTS will infringe the rights of the audiobook holder, but this is something we can manage
… we can explain that TTS is different

Avneesh Singh: just to clarify, there is no requirement in the spec that if you have text, you must have audio

Ben Schroeter: re. discoverability, when we say that there are requirements on the distributor to include an ONIX codelist value
… are we saying that this is a retailer responsibility?

Cristina Mussinelli: when the retailer takes the ONIX feed, it maybe useful for the retailer to include that information on their website
… the commission originally suggested some kind of leaflet to accompany the ebooks, but we explain that we already have metadata that travels along with the ebook

Ben Schroeter: so basically its not a requirement for distributors
… just one way for that requirement to be fulfilled

Luc Audrain: there is a requirement for displaying accessibility metadata if the publisher produces some
… in section 3

Cristina Mussinelli: we are working to mainstream accessibility content
… part of this is to make sure people are aware of whether the products they buy fit their requirements (in so far as a11y)

Avneesh Singh: (vi) ensuring that digital rights management measures do not block accessibility features.

George Kerscher: in the early days of ebooks, nothing was accessible and DRM blocked assistive tech
… this resolves those concerns
… also great that it clarifies that DRM cannot be used as a reason to block a11y tech
… also this applies to libraries, correct?

Avneesh Singh: Yes
… also, we originally had language in the a11y spec specifically saying that DRM cannot block accessibility, but this was removed to conform with ISO
… should we put this back?

Gregorio Pellegrino: for A vs AA, we need to check our spec to see which level each of these correspond to, and to see if they meet the minimum requirements of the EUAA

Avneesh Singh: re. the requirement in the EUAA that if you have audio in your ebook, that you must use MO. The a11y spec doesn’t make a parallel requirement right now

Matt Garrish: right, we don’t require use of MO
… only that if you do choose to use MO, we prescribe the way to do it
… but I don’t have any specific proposals right now

George Kerscher: if there is a podcast inserted into a book with a text transcript,
… e.g. in a details element below the element
… is that sufficient synchronization?
… or does the EUAA require synchronization at the sentence or paragraph level?

Avneesh Singh: can we get back to the EU about clarification of the requirements, instead of making the epub spec more rigid?

Luc Audrain: the text of the EUAA won’t really change at this point
… the language is generic, if there is both text and audio in the act, then the act applies
… but there is no requirement as to the level of synchronization

Cristina Mussinelli: there is also the idea of giving the user the choice as to the level of synchronization, but the act doesn’t go into such detail
… but I suspect that the number of books that include both text and audio is quite small
… our focus should be getting publishers to make their text based books accessible

Wendy Reid: i would guess the number of books that have both text and audio is < 5%

Luc Audrain: clarification, the EUAA is referring to cases where the audio in question is the audio of the text
… background music, for example, would not be included

George Kerscher: are there any references to alternative languages in the EUAA?

Gregorio Pellegrino: not specifically, other than the WCAG requirement that the content be understandable

Matt Garrish: in the spec, we could bump the SHOULD meet the requirements of the MO spec to MUST

Avneesh Singh: (vi) ensuring that digital rights management measures do not block accessibility features.

Avneesh Singh: about the DRM question, in the original spec section 8 specified that if you use DRM it shouldn’t block a11y
… because of ISO, we made this section an informative note
… should be put it back in light of EUAA?

Matt Garrish: i don’t see why I can’t put it back as a requirement
… ISO considered it out of scope
… that’s the only concern, that we’d run into the same issue if we want to go the ISO route again

Avneesh Singh: we might be able to discuss how exactly we want to implement this in another call (whether to leave it as an informative section, or otherwise)

Cristina Mussinelli: it is really the distributor has controls the DRM question, authors have little controls over this
… we should clarify this, and also not have a preference for a specific form of DRM over another

Luc Audrain: echoing George’s opinion that we should elevate the requirement that DRM not impede accessibility a MUST requirement

Avneesh Singh: the group’s recommendation is to make this a MUST, mgarrish and I will discuss the implementation
… everyone should go through the spreadsheet and open issues where you have questions
… gpellegrino and luc will respond
… we are also moving towards a FPWD in Feb
… mgarrish and I will discuss what will be included in that FPWD
… what we can put in about the EUAA, we will
… we also talked about creating a document with this mapping that we will submit to representatives of the EU

Cristina Mussinelli: i don’t think the EU would understand a spreadsheet like that
… we need a non-technical version
… luc, gpellegrino and I will consider the best way to present this to the commission
… what about changing the name of the spec?

Avneesh Singh: yes, there was some discussion about this last year, but we can’t discuss this on the remainder of this call
… this is a very deep topic
… shame that we have to end the call now

Wendy Reid: we’re hoping that we can get an overview of this topic in the epub 3 spec WG call tomorrow