FCC / CVAA discussion

"Americans with disabilities have had a legal entitlement" but at what cost to the developers? I am no cell phone manufacturer, nor am I Skype or Google or Microsoft (who are probably lobbying for this to ruin competition and small startups)...

I am a small programmer person trying to bring joy to a small audience of my choosing.

This feels horrible and will surely destroy motivation for many novices to create multiplayer games.

I personally have removed all multiplayer functionality from my games so I don't get fined/sued.

CVAA enforcement for "games" is crap.

The FCC is also crap.

 

When I thought CVAA was already just an insane scam, then I read that part.

I don't care how good intentioned this law may appear, with scare tactics such as a one million dollar fine how the hell could anyone here get behind this craziness (unless they work at the FCC or just hate video games)???

 

I am not for it for solo to small team Indies at all. For AAA companies it makes sense. For the vast majority of people like us we have enough challenge as it is just in completing our games and reaching our audience.

Like I would like to and want to try to make even my tiny games more accessible in general even though they aren't multiplayer but I don't know if I can really do more than a bare minimum or that even if I spend the time to do it anyone would actually take advantage of it anyway.

I also get what you said about "trying to bring joy to a small audience of my choosing". That does seem strange to me in that it would seem if a person... any person... wants to make a game that is multiplayer you do give up the right to actually define your audience to one that is within your abilities and resources to both develop for and reach. There is the "not reasonable" part to consider but a developer has to keep in mind that here someone else is deciding what is reasonable or not for the developer to do.

I get what they are after... and for all of those people with friends playing all of these AAA games or super popular Indie games I can completely understand how awesome it is for them to be able to play with their friends. But it seems like there is a real lack of understanding going on that these are the exceptions... a tiny fraction of the games people are making. Most of the games being made by communities like this people are lucky if anyone outside of other developers even know they exist.

I guess it all comes back to the "it's not reasonable" line of defense but I think the FCC just has no clue how huge this is. They say people can contact them. And probably this is what every hobbyist & Indie making a multiplayer game should do. Then when in a single month they are sent thousands maybe tens of thousands of submissions to review they will understand.

I don't know. Really I think why did I even post in here again. But I wanted to clarify I guess I can understand what they are after but I think they don't understand fully that for many people seeing text about fines and such of massive size clearly intended for large corporations would scare the heck out of a lot of developers who are actually just individuals... just another person trying to make a game and decided to make it multiplayer with chat.

 

Why? This isn't about multiplayer, it's about communication. The GamaSutra blog linked points out that some people are working around this by removing chat from their game.

Honestly, if I were targeting audiences who already have chat systems in place I'd strongly consider that. My mates and I used to all join up on some voice chat system before we started whatever we played. I know that plenty of groups hang out on Discord separately from their games. Steam has built-in cross-game chat functionality.

Yes, I think it's silly that in some cases we could get in trouble for providing a more convenient service, but nuking multiplayer isn't a requirement here.

 

Cost to developers - whatever falls within reasonable effort as expense, there's detail on that.

Can confirm that the corporations were in fact not lobbying for this to crush small businesses. You can see the records of the companies lobbying against it on the FCC website, it's all publicly available.

 

My game/tools require VOIP so that my characters may utilize lip sync. Also other forms of what might get confused as advanced communication are implemented (such as live script writing - very similar to text chat).

So it is way less scary to just stay away from any of it. IMO!

Just focusing on single player only experiences.

 

The $1m cap on that fine seems... odd.

It could be an instant game-over for a small developer with limited resources who runs into an issue they can't resolve, while being a small fraction of a large, well-resourced game's development budget.

 

Ahhh, nuts. Sounds like a perfect example of mechanics and communications overlapping in ways not at all clearly covered. :-(

 

*Reasonable in FCC's opinion. Stop omitting that part, please.

 

I was thinking about this yesterday, and I have another thought.

The FCC worked on this by talking with AAA companies. The companies sent their best talkers, marketers, salespeople, lawyers, suits. The FCC had nice talks with well spoken people.

Independent devs have a wide range of social skills. Some, I wont say most, have poor social skills. Many of those are possibly due to low levels of Aspergers. Having this does give you super human level of attention to detail, an awesome skill for a programmer, but cripples your ability to communicate with others in a way that most people would consider "normal". It can also mean a lower level of empathy for others.

So the FCC wants these devs to somehow find 10-20 differently abled gamers, communicate technically and with empathy about their problems.

Does anybody see a problem with this situation, I do.

I have been watching Valley of The Boom on tv.
Now imagine Mark Andreessen or someone with worse skills interviewing these people.
Its an insurmountable task.

The FCC is helping some people but simultaneously harming others who have social problems.

 

Exactly, this is the worst of both worlds. EA can easily throw $1m at something, whereas it's game over for an indie.

Sounds like the typical journey of a bureaucratically determined law, ending up with its guns pointed at the least effective and most misery-inducing place.

 

To respond to Tzan's point:

If someone is developing games, and intending a wide enough player base that inbuilt communication tools are integral, then they already should be talking to people. Specifically, their players. If they're not already talking to people to validate their game design, art direction, and many other things, then I'd already be concerned.

This is just another component that needs validation.

I'm explicitly not weighing in on the "reasonable" term here, because I'm not sure where I stand on it, but I will reiterate that it is specifically for comms features only (though validating your entire game against vulnerable/disabled populations isn't a bad idea in general).

 

Hehe lost me with the threat of 100k to 1m. Can't be supporting that for entertainment. I appreciate a law that enables people of disability to live - access, contact with important services and people.

But this is entertainment and fines like that are simply laughable. Big businesses don't get fined that much for killing.

Doesn't seem in proportion or anything. A shame that the Chinese market is less draconian and far more appealing. I think if I focus effort on the Chinese market I might make more money respecting them.

Funny old world when you disable functionality in entertainment because you just don't have the time or energy to face the FCC/CVAA's ignorance gleefully fuelled by AAA.

Just never took well to threats you see.


Solution:

Try removing the fines and attacking the problem with positive reinforcement like adding the title to a list of highly visible games on the website that anyone with a disability can immediately view and choose from. This will be a coveted thing to have and developers will pay the small admin fee to be listed, so people with disabilities would generally prefer titles from that list. In addition the game could then be legally allowed to wear a specific icon or badge indicating it's inclusiveness.

It's called positive reinforcement and it's generally what civilised people do for results. Please learn it, Karen Peltz Strauss.

 

I think this is an exaggeration of the extent to which having a dialogue with random people is useful in game development. Good game ideas don't always sound good (and vice versa). Indies do not have access to some kind of demographically balanced, attentive and articulate customer base. Talking to half a dozen random people and building a game based on that sounds like a textbook case for some (random) information being worse than none.

In my opinion, the idea of speaking with disabled people directly as a way to ascertain the correct boundaries for compliance with a law seems like a fantastic let-down not just of game developers but disabled gamers as well. Besides being a landmine for developers, there are a lot of different disabilities out there and you would never see the full picture - and you would never be certain that you and the FCC have the same perspective.

If the FCC wanted to be useful, they might get some proper surveys done, figure out what specific solutions could solve the most problems in the most effective way, and draw some concrete guidelines from that.

 

I can't believe this article online. HAHAHAHAHA Amazing. CVAA is requiring indies to fill in forms every single year and bind ourselves. I'm simply just going to steer well clear, best design out all that hassle. It has clearly been set up for AAA shenanigans and has utterly ignored anyone they can't monetise well enough.

Anyway it's easy, just disable player vs player comms in America, and enable it for the rest of the world That's what I'll do and people will likely use the OS/Platform or their own comms instead

Who's agreeing?

 

Which may further lead to the dawn of a new golden age of early access games being finished.

 

Know what's funny? if they hadn't resorted to the threats and constant pressure to sign up on their 1990s style website, I would've still made plenty of effort.

I guess most people would've used discord or something regardless but anyway, at least until there's middleware to handle it or it's native to OS.

 

silver lining to everything.

i realize *tzan is joking, but who knows. Personally I am always dissappointed each year as more and more community-focused multiplayer games come out and fewer quality single player games come out. I just dont like playing online with kids but it seems like that's where most games are going.

Sorry don't let that derail just a side thought. Been learning a lot from reading the discussion.

 

Definitely agree that talking to random people probably won't make a better game (or even a good game!). Definitely agree that the FCC/CVAA should release guidelines, suggestions, example implementations, potentially even some libraries.

The sort of conversation I was referring to, though, is not just "chat to some random people on the street" tier. A developer should often be testing features and designs on their target markets, and confirming that they are suitable. Hallway tests are one of the best ways to determine if your game is _fun_.

If the're building a game to the level of "will need communication features because there'll be online pickup gameplay as a core feature", their game already has to be big enough to justify design validation, both in gameplay and in usability. I'm not 100% sure what that process would entail, but an hour reading the top results from a Google search would definitely steer in the right direction.

 

I think the whole "community based game" thing is why Ian and co. are concerned about the communication features. I made friends in Minecraft years ago and never corresponded with them outside of it. If I had been legally blind, that would likely not have been possible.

I'm not sure what incentive structure would be good to make accessibility more common while not just pricing indie devs out of the market. The current CVAA stuff seems to be slightly concerning in that regard, but I'm still not sure where I stand. The motivation is definitely admirable, though.

(side note: is etiquette on this forum to double-post for follow ups with no posts after them, or to edit?)

 

It's one of the four approaches listed in Ian's GamaSutra article, and is certainly something I'd consider if I were making a multiplayer game. As a player I can't remember the last time I deliberately relied on built-in communication, so I'd definitely be looking at how common that is among my players and acting accordingly.

That said, there's another related issue I noticed:

We can't so much as suggest communications channels to players unless we're willing to potentially take liability for that channel's accessibility, because the legislation doesn't account for that case. Getting critical mass for multiplayer games is hard enough as it is, even for people already successfully doing it (look at non-Conquest game modes in Battlefield), and now we're being discouraged from taking steps to organise communities using the tools that gamers like to use.

Again, I'm really glad I'm not making a multiplayer game right now.


Another option would be to not offer your game for sale in the US, so that you're not subject to their laws. Clearly that's somewhat of a nuclear option, but it could work depending on your game's audience.

Well, if you're only asking "half a dozen random people" then you're not doing it properly, because that's nowhere near enough to get a useful result. If you're aiming for something to hit a large audience then you need to canvas a significant number of relevant people.

I double post quite a bit. As long as it's a separate response I don't see an issue with it.

 

My (legally minded) friend just brought up some good points,

Conceivably, Microsoft (or any large corp.) could hire teams of disabled individuals to file complaints all day and night, flooding their competition with multiple legal battles that most could not win.

Furthermore, he mentioned this (which was genius IMO):
- If Stephen Hawkins had a talking chair, then plug that chair into the mic jack instead of adding crazy substitutes for VOIP.
- Or, if there is a color blindness issue, use a color correcting monitor (or adjust the gfx driver's color settings).

Another example I have seen personally:
- my co-woker is 100% def, but she uses a speech-to-text telephone (so she may read what the other person says) and she does quite well.

Couldn't someone provide some software to listen for spoken words and just place subtitles on the monitor? Surely you would have to turn down the sfx volume, but hey...???

Why should developers be forced to re-invent the wheel? I mean since there are many 3rd party accessories to solve these issues already available..

 

I've already pushed for OS to handle this, and that's where it should be. Be it console or desktop or phone OS.

This way, the experience would be up to par and consistent across all games, instead of random. But no, the CVAA is about punishing the individual because it's led by someone who does not know what they're doing, and really doesn't know how big the game industry is, and assumes America is the world leader in games (it's not). Simple as that.

Instead of raising the bar for gaming inclusiveness by attacking the platform, they attack world instead and encourage every indie to avoid the problem, and they will avoid the problem because it's utterly unobtainable for an indie to pass muster.

These terms can only suit AAA.

So people with disabilities have no choice but to roll their own solution (since indie games will remove integrated multiplayer comms) or stick with whatever AAA gives them. I see a theme here.

Utterly disappointing and hope microsoft, google, sony, nintendo and so on get this fixed at the native level.

 

All of what your friend said is wrong, what you said is right. You should not listen to your friend, they should listen to you

1.Accessibility legislation is not a new thing, corporations do not behave in that way. Some unscrupulous legal firms do in order to drum up revenue, but this is not possible with CVAA, CVAA is enforced through the FCC and cannot go through courts.

2. Steven Hawking did not have a talking chair. He used text to speech software. Which is exactly what CVAA is about.

3. Colourblindness cannot be addressed by drivers or monitors. CVAA requires accessibility for people who cannot see colour, therefore covering all types including people who only see in black and white.

4. "Couldn't you just use some software to listen to speech and convert it to text" - yes, that's exactly how it should work. No developer should be trying to reinvent the wheel and develop their own speech to text system, instead they should be using third party cloud services. That's how the Xbox realtime two way text <-> speech API works.

5. Why can't third party tools be used - ask Unity. That text to speech software I mentioned above exists on Xbox, PC, Mac, Android, iOS... Built into the operating system. But for it to work it had to be able to see the text, Which for native apps just works, but engines don't expose anything, their output is just a lumpl of pixels. People have been asking Unity to address that for ten years, but they haven't. As a result developers have to meet the cost of making their own bespoke solutions.

 

This thread has some useful context on that principle:

https://mobile.twitter.com/rhia29/status/1083551289093640194

You're in the UK, right? If positive reinforcement was enough the Equality Act wouldn't need to exist.

 

Bingo, this 100% hit the nail on the head. This is exactly what the disability orgs were talking about in response to the ESA's initial blanket exemption request (the records of all this are on the CVAA website).

The "Ian and co" bit is not accurate though. I am not a legislator and had no involvement in the law being put in place, I don't even live in the USA and I'm not here to give an opinion on whether CVAA is good or bad, it simply is, I'm just here to make sure people have accurate info.

Instead of "Ian and co" a more accurate replacement would be "the US government and the various disability organisations involved".

 

I'm not sure what the "assumes the USA is the world leader" thing means, but it doesn't assume that. CVAA literally does not care at all about communication services provided outside the USA, it's remit is solely services provided to people in the USA.

It can't be entirely addressed at platform level. Requirements for things like colourblindness and epilepsy can only be handled at game level.

Some aspects can be handled at platform level, and already are, for example iOS' outstanding support for blind accessibility, both blind friendly interaction methods and full text to speech.

It can't just be done automatically, some work is needed from the developer; mainly just making sure that your interface elements have sensible names so there's something useful for the external text to speech software to read out.

At least that's how it works if you're developing a native app. If you're using Unity instead, no dice. Unity doesn't expose anything for the external software to work with, as far as the external software can see a unity game consists of one single UI element that has no label and just contains a bunch of pixels.

So the effort is shunted on to the developer instead.

If you're looking for a weak link in the chain that's causing developers unnecessary work, that's where it is. People have been asking for that weak link to be addressed for a decade. Maybe if more people asked it would be.

"CVAA should go after platforms" - CVAA applies to all communication, including at platform level. Platforms initially had a waiver too, theirs expired in 2015.

But the obligations on platforms only apply to platform level communication. If developers want platforms to help them out it's on the developers to make sure the platforms do.

That's what the 2010 to 2018 waiver period was explicitly for, for the industry to get that kind of stuff figured out. If everyone on these forums had spent those 8 years bugging platforms and engines about accessibility support we would be in a very different position today.

 

I didnt even know CVAA existed before the recent posts.

 

OK so the FCC cannot get a solution done where it would be most effective (why??), so they are taking the lazy route and squeezing small time developers until they make enough noise to get the attention of the platform companies?

That's a hell of a way to get people to do something for you.

 

I may be misunderstanding what you are saying here but the FCC do not make products for people. Laws don't work like that. If ADA says buildings must have ramps that doesn't mean the government travels around the country building ramps for people, it means if you want to build a building you have to consider things like ramps.

Or do you mean FCC should be pressuring platforms? Laws don't work like that either, you cantd delegateyour liability. If you're choosing to put comms in your game that's your choice, and if you choose to do it in an inaccessible way that's also your choice. Doing those things means it's inaccessible through your actions.

Platforms have no responsibility for your game. Sure platforms and engines could help, but they don't have to. Your game = your problem.

 

Perhaps the whole idea of a law is ill-conceived to begin with? Since it cannot be implemented in an effective way (effective meaning getting disability access happening without driving people away from making certain kinds of games altogether).

Frankly I don't buy the whole idea of 'we tried the nice way but it didn't work, EA laughed at us and devs didn't care'. I bet for all of the money spent on wasted PR someone could have paid a dev to make a Unity integration that solved everybody's problem. But I suppose that would actually need the problem to be specified precisely, which somehow never got done.

 

Guys, gals, I've perfected it.

 

I have no idea what this is trying to say, sorry

 

FCC is simply not at all knowledgeable in this field, obviously. Throwing blanket laws around expecting 'everyone' to be on the same level.

Anyone who threatens artists and hobbyist with a $1,000,000.00 fine should have their Temporoparietal junction checked for damage.

Don't forget, this actually happened:


----

Maybe voting for grown-ups next time and these kind's of oversights might be avoidable (or at least mitigated).

Someone like John Delaney (politician and businessman, now presidential candidate 2020), who openly criticizes the FCC.

 

FCC has no ability to put laws in place. The law was signed in by congress, through broad bipartisan agreement. It is an update to a law that was signed in in 1990 by broad bipartisan agreement.

Games are no more art than TV shows are, both TV shows and games have plenty of legal obligations and legal obligations come with penalties for non compliance; if they didn't, they would not be obligations. As soon as your game is published it is no longer just art. As a businessperson manufacturing and selling products and services you have legal obligations.

E.g. try launching a game with lootboxes in in Belgium or launching a game in Europe that handles player's data in a way that doesn't comply with GDPR law.

GDPR has an accommodation for small businesses. If your annual turnover is less than €0.5billion, fines for non-compliance are capped at a mere €20million. Companies above that size, i.e. the bigger publishers, have no upper limit, the limit is instead a percentage of your turnover. For Tencent the maximum GDPR fine possible is €720million.

For what it's worth, CVAA does not require everyone to be on the same level. It allows for flexibility of approach, so people in different industries are free to choose the approach that best suits their products, the only same level required is the groups required to not be unnecessarily excluded. Emphasis on unnecessarily; again everyone is not required to be on the same level due to the 'achievable within reasonable effort and expense' aspect.

Again, not here to either sell or slate CVAA, it is what it is. Just sharing the facts.

 

I'm not following this logic? if it's a law, courts get involved.

Does a TV show producers burden with subtitle data for each platform the show is displayed on? I think that's all done by platform providers like cable companies?

Also I don't see TV show producers making color blindness variants for each show.

Sorry but another disagreement with the logic, developers and games are a different breed than TV producers.

Games are cinematic in nature, true.. But they are not broadcast publicly (except by the gamers ), they have different censorship requirements as they usually have a targeted audience in mind.

Not to mention that TV shows are only one way communication systems.

 

I suspect that it's because what you call "native apps" are those built with OS-specific frameworks? These carry far more contextual information than a game engine can be expected to have, so comparing the two just sets up unrealistic expectation. I agree that Unity and other engines could provide us with some base level functionality to help out, but some level of bespoke integration or implementation is still going to be needed due to the absence of context. Same deal with the Xbox library often raised as an example.

In the GamaSutra article you say that "natively developed games are sometimes completely blind accessible by accident". I'd be interested in seeing how this came about. Any examples?

 

I think the point here might be that courts don't get involved because enforcement of this is specifically the FCCs responsibility? That said, I also don't see how that changes the potential for maliciously raised complaints / requests for dispute arbitration.

 

Yep, that's exactly it. There is no mechanism for courts be involved, you cannot bring a court case over CVAA. Enforcement is through the FCC.

A consumer making a malicious request for assistance to get an accessibility issue fixed is a bit different to a lawyer making a malicious demand for financial compensation.

 

For courts see angry penguin's reply above, that hits the nail on the head perfectly. The idea that courts are always involved in laws is incorrect.

I'm not going to reply to the rest as you completely missed the point.

 

The bespoke level of integration that would/should be required from developers extends as far as ensuring your UI has metadata that states the name of the UI element (e.g. "save"), the type of UI element (e.g. "button"), and if relevant to that type of UI element, its state (e.g. "ticked"). Then also if you're making some UI change like popping up a notification, flagging that too.

Then from the engine's side it's a case of ensuring that the metadata can be seen by each platform's APIs.

So in all hardly rocket science.

That's how it works if you're developing a UWP app for Windows or UIkit app for iOS or even making a website, but with the added bonus that for all of those things, unless you're inventing your own fancy custom types of UI element, the metadata on type and state already exists out of the box so it's only the label you need to worry about.

There are hundreds of examples of accidentally blind accessible iOS games (in amongst examples of intentionally blind accessible ones) listed on Applevis.com.

Here's one example, Hanging With Friends, which was Zynga's follow on to Words With Friends.

They had accidentally made it blind accessible simply by having sensible names for their UI elements. That meant the labels, types and states were all exposed to the screenreader. The screenreader itself handles the interaction side of blind accessibility, adjusting gestures to allow people to slide their finger over the screen and have whatevrr your finger is over read out (try it on your phone, it is built in to all android and iOS devices). And the gameplay itself of Hanging With Friends is about navigating UI rather than navigating virtual environments.

So bingo, sensible labels -> blind accessible UI -> fully blind accessible game. By accident.

That's more the level of effort that I'd like to see needed within engines. Devs should not have to be worrying about bespoke implemetations.

The first that Zynga knew about their game being blind accessible was CNN running this story on it.

Ignore the headline though, it isn't about voice controls, it is about text to speech. The journalist just got confused because iOS' built in text-to-speech is called VoiceOver.

https://edition.cnn.com/2011/11/30/tech/gaming-gadgets/blind-social-gamer/index.html

 

Your debate is becoming pointless at best.. And your defense is wildly confusing.

And I did not say "always".

I'm not here to argue with you about analogies, I am here to voice my concerns about the fact that this "law" definitely can be used maliciously against small startup studios and hobbyists who might start competing with larger companies.

You said companies could not possibly use it with the intent to do harm to their competition. While I say, what the hell is going to stop them??

--

If FCC imposes fines (erroneously) on someone, then that person (or entity) may appeal right up to Supreme Court as it is not a criminal matter, and I'm not sure but in most case the interpretation of the law may be vague enough for an appeal to be valid, so please stop saying courts will not get involved (legislation like this could lead to some very big fights).

 

• I am not debating, and am not making any defense, wildly confusing or otherwise
• Current administration is not an environment in which laws can be changed
• Right of appeal has precisely nothing to do with the ability of lawyers to file malicious rent-seeking claims, which is what we were actually talking about
• Feel free to look at the existing 7 years of compliance and zero track record of companies using malicious requests for dispute assistance as a way to get one over on competition

I am not here to attack or defend CVAA, therefore have no interest in the direction you're trying to take this. Putting you on ignore now, I won't see any more replies from you.

By contrast, Angrypenguin's conversation about how text to speech works in native apps is productive.

 

If you are not arguing about (a subject), especially in a formal manner, the only real Antonym for "Debating" is: "agreement" - which you definitely don't seem to be.

I was talking about dirty business tactics and sabotage, not lawyers... But again put words wherever you feel like..

Not very applicable, as there's no way to prove it.

---

BTW, I liked your post because you said you would be ignoring me

 

Your description only covers the traditional UI part of a game. I agree that'd probably be enough to cover the CVAA compliance in at least common use cases, but the example given here is one where the whole game is accessible, which is a whole other thing.

This isn't something that a game engine can be expected to make accessible in arbitrary cases just from me providing "sensible labels".

Comparing cross-platform game engines to OS-specific GUI frameworks doesn't seem helpful here. They're different tools with different purposes used in very different contexts. One is designed to be as broadly applicable and flexible as possible, while the other is designed with a comparatively narrow set of use cases and a particular set of conventions in mind.

Bespoke implementations are a significant part of the job! Otherwise whole, complex games could be built by drag-and-drop alone. If we want our custom bits to be accessible we need to design and build them that way.

For clarity, I'm not saying that accessibility shouldn't be considered. I'm saying that in most cases we can't expect our engines to do it for us.

 

CVAA only applies to chat functionality and any UI or information needed to identify, navigate to and operate that chat functonality. So engine level compatibility with external screenreaders would indeed cover it in all use cases, not just common ones.

Outside CVAA, screenreader compatibility is enough to make some games entirely accessible to people without any kind of sight at all. Games that are based on interfaces rather than environments, like hanging with friends, Hearthstone, or Football Manager. And games that already have blind accessible gameplay through audio design alone, like killer instinct or Forza.

Then on top of that all the other people who can see gameplay but still want screenreader support for UI. Like people who have difficulty reading (14% of adults in the UK and USA are at "below basic" literacy). And people who can see well enough to play, but not well enough to see text (including most blind people, legally blind means significant difficulty seeing, not no vision).

Here are two examples of that last point:

https://caneadventures.blog/2019/01/18/blind-button-masher/

https://mobile.twitter.com/JamesRath/status/1088312818326097920

What we're really talking about here is the low level process of getting content to actually render on a display. When talking about visuals the way that works differs from platform to platform. Before cross platform engines came along it required bespoke solutions for each platform. But things have changed since the 80s and 90s, now engines do it all for you.

That's the comparison to make. Getting your UI to display on different platforms is exactly the kind of thing that engines are there for. Regardless of whether it is being displayed as visuals or audio.

This is not an area where bespoke solutions have value. Because they aren't actually bespoke, they're exactly the same work being done over and over by different developers. Which is an absurd waste of valuable time and money when the work could just be done once at engine level.

So while it's absolutely true that engines can't just take care of all of accessibility in general, there are examples like cross platform screenreader support where they absolutely can take care of a decent chunk of the work. A couple of other examples; remapping (another CVAA req) and subtitle presentation.

To explain slightly differently, here are two scenarios:

1. You have to do your own research into trying to figure out what kind of information is useful to expose to people who can't see, add the appropriate metadata to your UI, and then manually send it to each individual screenreader's text to speech APIs, ensure your UI can be navigated digitally on non-mobile platforms, and do a ton of complicated interaction work to make touchscreen UI navigation work for blind users.

2. The engine provides fields telling you exactly what metadata to enter, passively exposes it to screenreaders (which in turn takes care of mobile touch interaction as well as text to speech), and ensure your UI can be navigated digitally on non-mobile platforms.

I assume you aren't really saying that you prefer scenario 1 to scenario 2?

 

You're the one who told us to ask our engine providers and then referred to an example of full blind accessibility "by accident". The implication that engines should make full accessibility trivially easy is what I'm talking about here.

I'm saying that scenario 1 is necessary at times, because games often involve unique things - which would make them bespoke. When I'm making a new, unique thing then my engine can't reasonably be expected to magically know what fields to provide.

On one hand you're saying that this stuff should be trivially easy to implement. Earlier, you were saying that accessibility is often poor because it's not considered until it's too late.

As a designer yourself I'm sure you understand that the end presentation ("display") is only one part of the pipeline.

Before that, it's up to us as designers to design something that will work on all target platforms, for all audiences, with all relevant inputs and outputs, and so on. Engines can help with bits of that, but they can't do it all for us.

This is a difference in how we're talking. I'm deliberately allowing for edge cases, where you're claiming that none could possibly exist.

- - -

Separately, Unity may indeed have had their eyes on this for a while. They've just acquired a chat service provider, and acquisitions aren't usually overnight affairs.

 

There was no such implication, you read that into it yourself.

The engine does know what info are needed as it is standard across industries. Label/role/state/announcements.

"On one hand you're saying that this stuff should be trivially easy to implement. Earlier, you were saying that accessibility is often poor because it's not considered until it's too late." - I'm not sure what your point is, those two things are not mutually exclusive.

Can you think of an edge case exposing UI to external screenreaders and text to speech APIs would not cover CVAA's requirements for chat related UI to be identifyable/navigable/operable to people who can't see?

Acquiring Vivox doesn't necessarily mean they've been thinking about CVAA. The interactions that myself and others have had with them over the years have indicated pretty clearly that they haven't, with explicit responses such as "we have a big backlog, text to speech support just isn't important enough to make it onto it".

But the Vivox thing is interesting though because that will force their hand, they cannot integrate Vivox without tackling CVAA requirements. Well, they can, but they may be in for a shock if stories break about devs falling foul of CVAA explicitly due to Unity failings. Or a more positive spin on the same thing - if they can be quick to market with a decent system for taking care of a decent chunk of CVAA burden that's a pretty compelling differentiator and business opportunity.

 

Great. So, can you now investigate Steam? Or will this be too big an ask? Steam provides chat for all the games they have but do not have CVAA compliance.

 

I'm not quite following what you mean by me investigating steam or things being too big an ask.

If you mean FCC carrying out an investigation into steam, I don't investigate people, I'm not the FCC. And investigations don't happen until after mediation has failed to reach a satisfactory conclusion.

Steam are not a platform, they fall under the gameplay&distribution network category. That category and therefore Steam's compliance deadline was 2015 (exactly the time when PSN & XBL's comms functionality had a bunch of accessibility stuff added). Steam will no doubt have complaints, especially given how hated they are by the blind community. but it's looking more likely that Discord will be a recipient of a mediation request before Steam.

Steam could potentially have got away with not having met all the requirements for a while due to lack of substantial updates since 2015, but they're in the process of rebuilding their UI from scratch, which brings them within CVAA's remit.