Re: CVAA Accessibility Rules Now In Effect
Thank you for the reasonable questions JaceK, I appreciate it
I'm still skepitcal for a lot of reasons.
Skepticism is entirely reasonable
The FCC's involved. We all know how slowly they work. ... Even the fastest moving departments are not instant. ... There's a whole process for this given the FCC's involved. ... I may be wrong on that but hat is how it was explained to me by an industry insider who works for MS. That to me is a credible source.
That's partially correct, but not CVAA specific. In reaction to experiences with previous legislation the CVAA is set up to work very differently to other legislation. There is a process, as follows:
1. Consumer experiences accessibility barrier
2. Consumer visits FCC website, files a request for dispute assistance, which details what the problem is and what the solution would be
3. FCC opens a mediation process between the consumer, the company and the FCC, together with a 30 day window for the issue to be fixed
4. After 30 days the consumer has three options; 1. drop the issue 2. Extend the window 3. Escalate to a full complaint, which they have to pay money to be able to do and is the process you're referring to involving investigations over a period of 6 months
In the 7 years that most industries have had to be compliant there have been around 70 issues raised with the FCC, every one of them was resolved (fixed or dropped) during the mediation stage, none progressed to a complaint.
So you can see this is very different to how things have been previously, there's that whole first step for rapid remediation that wasn't there before, and everything has to go through that; it's not possible to go through courts etc, the only way to raise CVAA issues is through that process.
Question is....why are they not just using readily available open source. Is it the same reason Sony went with hardware for business reasons and a general mistrust of some open source software? Lucrative contracts with suppliers and all that?
I can't answer those questions. What I can say though is that there are cloud based speech to text services that are already being used in games to meet CVAA requirements; Forza Horizon 4 and Halo Wars 2 both use Microsoft's, via the Xbox SDK.
Okay, so the CVAA only affects NA games, right?
Any games for sale in the US market
All it'd take a developer to do would be turn off the voice chat and have a 'voice chat on' TTS to comply.
That isn't the case at all, I can't really answer in more detail because I don't understand the thinking behind how that would be the case. Below is the list of what is required. Each communication service - text, voice, video - is treated as a completely separate entity, the full set of requirements applies to each one (to the extend that it falls within reasonable effort and expense).
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(a) Generally – Manufacturers and service providers shall ensure that equipment and services covered by this part are accessible, usable, and compatible as those terms are defined in paragraphs (b) through (d) of this section.
(b) Accessible – The term accessible shall mean that:
(1) Input, control, and mechanical functions shall be locatable, identifiable, and operable in accordance with each of the following, assessed independently:
(i) Operable without vision. Provide at least one mode that does not require user vision.
(ii) Operable with low vision and limited or no hearing. Provide at least one mode that permits operation by users with visual acuity between 20/70 and 20/200, without relying on audio output.
(iii) Operable with little or no color perception. Provide at least one mode that does not require user color perception.
(iv) Operable without hearing. Provide at least one mode that does not require user auditory perception.
(v) Operable with limited manual dexterity. Provide at least one mode that does not require user fine motor control or simultaneous actions.
(vi) Operable with limited reach and strength. Provide at least one mode that is operable with user limited reach and strength.
(vii) Operable with a Prosthetic Device. Controls shall be operable without requiring body contact or close body proximity.
(viii) Operable without time dependent controls. Provide at least one mode that does not require a response time or allows response time to be by passed or adjusted by the user over a wide range.
(ix) Operable without speech. Provide at least one mode that does not require user speech.
(x) Operable with limited cognitive skills. Provide at least one mode that minimizes the cognitive, memory, language, and learning skills required of the user.
(2) All information necessary to operate and use the product, including but not limited to, text, static or dynamic images, icons, labels, sounds, or incidental operating cues, [shall] comply with each of the following, assessed independently:
(i) Availability of visual information. Provide visual information through at least one mode in auditory form.
(ii) Availability of visual information for low vision users. Provide visual information through at least one mode to users with visual acuity between 20/70 and 20/200 without relying on audio.
(iii) Access to moving text. Provide moving text in at least one static presentation mode at the option of the user.
(iv) Availability of auditory information. Provide auditory information through at least one mode in visual form and, where appropriate, in tactile form.
(v) Availability of auditory information for people who are hard of hearing. Provide audio or acoustic information, including any auditory feedback tones that are important for the use of the product, through at least one mode in enhanced auditory fashion (i.e., increased amplification, increased signal to noise ratio, or combination).
(vi) Prevention of visually induced seizures. Visual displays and indicators shall minimize visual flicker that might induce seizures in people with photosensitive epilepsy.
(c) Usable: The term usable shall mean that individuals with disabilities have access to the full functionality and documentation for the product, including instructions, product information (including accessible feature information), documentation and technical support functionally equivalent to that provided to individuals without disabilities.
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Big companies.. lawyers.. unscrupulous developers..
It doesn't work like that. Concessions are made on a balance between how much work is needed and what the financial and technical impact of doing the work would be on the product and on the company. Because big companies have larger financial and human resources at their disposal they are LESS able to get concessions
And it isn't just about money, being under investigation (through mediation progressing to complaint) means FCC officials hanging out in your offices. I'm sure you can understand why that could be a strong motivating factor in avoiding being under investigation.
Also, on the subject of influencers/Youtubers, I know for 110% that....certain big Forza streamers have a TTS set up to read out their donation messages when somebody, you guessed it...donates. However that's a specialized case as, I believe, they stream on PC and do all the setup themselves.
I'm not sure what the point being made is, sorry
Ethin has a right to be skeptical.
Again, skepticism is entirely reasonable, but what's also reasonable is accepting the word of someone who is saying not "I think CVAA will have an impact", but instead saying "I've literally seen featuresets of games coming out over the next few months that take CVAA into account". There's a big difference between healthy skepticism and willful ignorance, especially when voicing the mistaken conclusions of that willful ignorance has already actively damaged the broader accessibility effort, harming all of the community here.
Therefore it has no place here. But rather than be forcefully silenced, I'd far rather see Ethin just choose to keep a lid on it for a few months.
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