PreTeXt and Colorado's New Accessibility Law

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Chris Creighton

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Jan 23, 2024, 4:10:20 PM1/23/24
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Hi All!

I tried searching the conversations for a potential answer to this, but only came up with a few old discussions.

I am an instructional designer at the University of Colorado Colorado Springs (and former mathematician). We have had rather intense discussions around creating accessible courses and the technology available to us in my center, so I'm reaching out to see if anyone here has any advice!

Particularly of my concern is a new law in Colorado: HB21-1110. It requires that all documents/files/pages on external and internal university webpages to meet WCAG 2.1 AA standards. Which is, yeah. I'm mostly looking for where is PreTeXt at in potentially support of this over traditional LaTeX formatting.

I took a look at Active Calculus using Wave (by WebAIM) to check for accessibility. It threw major errors on most pages which means, by the law, it does not meet the Colorado accessibility requirements.

Does any one have any guidance here or even documentation as to where we are at with accessibility?

Bonus if any of you are from Colorado also considering the ramifications of this law in effect July 1.

Thank you so much for anything!

Chris

Alex Jordan

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Jan 23, 2024, 4:17:26 PM1/23/24
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Welcome, Chris. I'm surprised to hear that Active Calculus raised lots of accessibility flags. Last we checked, PTX HTML met WCAG standards well. Can you link to a page in particular where Wave raised issues, and post or summarize what the issues are? We can look too, I just want to make sure we are looking at the same place.

> I'm mostly looking for where is PreTeXt at in potentially support of this over traditional LaTeX formatting.

It's not clear if you are also looking for accessible PDF, since it sounds like you are comparing with traditional LaTeX. PreTeXt PDF is built through LaTeX, and will not be accessible. But with source in PreTeXt, you can build output as HTML, EPUB, even Braille. Not sure what the Colorado law says, but we'd hope that having an inaccessible PDF available (for printing, in general) is OK as long as you simultaneously offer an accessible format of the same content.


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Mitch Keller

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Jan 23, 2024, 5:04:52 PM1/23/24
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I’m wondering if it balked at the lack of image descriptions, since I don’t think Active Calculus has very many of those. 

Rob Beezer

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Jan 23, 2024, 5:04:54 PM1/23/24
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Dear Chris,

Section 3.29: Accessibility
https://pretextbook.org/doc/guide/html/overview-accessibility.html#overview-accessibility

Section 4.38: Accessibility
https://pretextbook.org/doc/guide/html/topic-accessibility.html#topic-accessibility

Rob

On 1/23/24 12:48, Chris Creighton wrote:
> Hi All!
>
> I tried searching the conversations for a potential answer to this, but only
> came up with a few old discussions.
>
> I am an instructional designer at the University of Colorado Colorado Springs
> (and former mathematician). We have had rather intense discussions around
> creating accessible courses and the technology available to us in my center, so
> I'm reaching out to see if anyone here has any advice!
>
> Particularly of my concern is a new law in Colorado: HB21-1110
> <https://oit.colorado.gov/accessibility-law>. It requires that all
> documents/files/pages on external and internal university webpages to meet WCAG
> 2.1 AA standards. Which is, yeah. I'm mostly looking for where is PreTeXt at in
> potentially support of this over traditional LaTeX formatting.
>
> I took a look at Active Calculus using Wave (by WebAIM) to check for
> accessibility. It threw major errors on most pages which means, by the law, it
> does not meet the Colorado accessibility requirements.
>
> Does any one have any guidance here or even documentation as to where we are at
> with accessibility?
>
> Bonus if any of you are from Colorado also considering the ramifications of this
> law in effect July 1.
>
> Thank you so much for anything!
>
> Chris
>
> --
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> "PreTeXt support" group.
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> To view this discussion on the web visit
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Sean Fitzpatrick

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Jan 23, 2024, 8:27:44 PM1/23/24
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In case the issue is image descriptions, here is a version of APEX Calculus that has both short and long descriptions for most images:


I had a team of 7 undergrads working last semester and they managed to take the book from zero to about 70%. I think the first 9 or 10 chapters are done.

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Chris Creighton

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Jan 24, 2024, 12:16:59 PM1/24/24
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Hi All,

Thanks for sharing and the resources.

Yes, the alt text on images is the major ping back for many pages when I run my scanner for compliance. I've also caught some weird speech-to-text where 18/3 was 18 choose 3 and a lot of h sqrt (null) instead of h all over the place. I am using the Mac built-in screen reader.

This does help with a potential viable option for faculty for some portions of their course.

Best,
Chris

Rob Beezer

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Jan 24, 2024, 12:27:58 PM1/24/24
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Dear Chris,

As noted in the links I sent you, we can't write alt-text for authors. Yet.
But we don't think AI is going to do a very good job either. Yet.

But you can lead a horse to water. We make it as easy, and as natural, as
possible for authors to provide these descriptions and then we know how to
communicate them. And Oscar Levin has provided an extensive tutorial to help
authors do this right. Some authors have motivated by possible use/adoption to
go back and add the descriptions.

We've had a motivated, older, student who is blind, using "Active Prelude to
Calculus" and now "Active Calculus" with very good results. He's found Nemeth
braille in a BRF file a good companion to the online experience.

Verbal versions of the math are the responsibility of MathJax, a project we work
closely with. We are aware of some places that need work, but overall it does a
great job.

Whatever the state of Colorado dictates in the law is not a huge concern to us.
We do feel a moral obligation to do as good a job as possible on this, making a
*practical* difference for all readers.

Rob


On 1/24/24 09:12, Chris Creighton wrote:
> Hi All,
>
> Thanks for sharing and the resources.
>
> Yes, the alt text on images is the major ping back for many pages when I run my
> scanner for compliance. I've also caught some weird speech-to-text where 18/3
> was 18 choose 3 and a lot of h sqrt (null) instead of h all over the place. I am
> using the Mac built-in screen reader.
>
> This does help with a potential viable option for faculty for some portions of
> their course.
>
> Best,
> Chris
>
> On Tuesday, January 23, 2024 at 6:27:44 PM UTC-7 dsfitz...@gmail.com wrote:
>
> In case the issue is image descriptions, here is a version of APEX Calculus
> that has both short and long descriptions for most images:
>
> https://opentext.uleth.ca/image-test/apex-calculus.html
> <https://opentext.uleth.ca/image-test/apex-calculus.html>
>
> I had a team of 7 undergrads working last semester and they managed to take
> the book from zero to about 70%. I think the first 9 or 10 chapters are done.
>
> On Tue, Jan 23, 2024, 3:04 p.m. Rob Beezer <bee...@privacyport.com> wrote:
>
> Dear Chris,
>
> Section 3.29: Accessibility
> https://pretextbook.org/doc/guide/html/overview-accessibility.html#overview-accessibility <https://pretextbook.org/doc/guide/html/overview-accessibility.html#overview-accessibility>
>
> Section 4.38: Accessibility
> https://pretextbook.org/doc/guide/html/topic-accessibility.html#topic-accessibility <https://pretextbook.org/doc/guide/html/topic-accessibility.html#topic-accessibility>
> https://groups.google.com/d/msgid/pretext-support/7a7a88d4-89c6-47e8-9976-113e926e0674n%40googlegroups.com <https://groups.google.com/d/msgid/pretext-support/7a7a88d4-89c6-47e8-9976-113e926e0674n%40googlegroups.com> <https://groups.google.com/d/msgid/pretext-support/7a7a88d4-89c6-47e8-9976-113e926e0674n%40googlegroups.com?utm_medium=email&utm_source=footer <https://groups.google.com/d/msgid/pretext-support/7a7a88d4-89c6-47e8-9976-113e926e0674n%40googlegroups.com?utm_medium=email&utm_source=footer>>.
>
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Chris Creighton

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Jan 24, 2024, 12:51:07 PM1/24/24
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I do understand that the Colorado law isn't of concern to those not in Colorado. I'm just working on resources for faculty who are at a complete loss as to accessibility in mathematics and to document where we can reasonably get folks, particularly for our online math courses. For instance, Desmos is WCAG 2.1 AA certified so is perfect to use under our law but I'm finding the Canvas math editor uses LaTeX on the back so is throwing some errors. We've even run into issues with professional captioning of math videos being completely wrong because the captioner doesn't know the right math term to use.

Overall, to me it does seem PreTeXt can support what we need in terms of some digital documents with the right level of training and accessibility verification of their products. Thanks so much!

Rob Beezer

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Jan 24, 2024, 1:30:22 PM1/24/24
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Dear Chris,

Wasn't trying to be snarky. ;-) Just making the point that we are more
concerned about practical improvements for readers, rather than (well-meaning)
laws and standards. Nor taking a poke at the beautiful state of Colorado. And
we recognize that lots of folks don't have that luxury.

A lot of mathematicians have gotten started with PreTeXt by meeting requirements
that their course syllabi be accessible. I'm sure you have solutions for that,
but for a STEM course/instructor that can be a good place to begin.

Rob
> https://pretextbook.org/doc/guide/html/overview-accessibility.html#overview-accessibility <https://pretextbook.org/doc/guide/html/overview-accessibility.html#overview-accessibility> <https://pretextbook.org/doc/guide/html/overview-accessibility.html#overview-accessibility <https://pretextbook.org/doc/guide/html/overview-accessibility.html#overview-accessibility>>
> >
> > Section 4.38: Accessibility
> >
> https://pretextbook.org/doc/guide/html/topic-accessibility.html#topic-accessibility <https://pretextbook.org/doc/guide/html/topic-accessibility.html#topic-accessibility> <https://pretextbook.org/doc/guide/html/topic-accessibility.html#topic-accessibility <https://pretextbook.org/doc/guide/html/topic-accessibility.html#topic-accessibility>>
> https://groups.google.com/d/msgid/pretext-support/7a7a88d4-89c6-47e8-9976-113e926e0674n%40googlegroups.com <https://groups.google.com/d/msgid/pretext-support/7a7a88d4-89c6-47e8-9976-113e926e0674n%40googlegroups.com> <https://groups.google.com/d/msgid/pretext-support/7a7a88d4-89c6-47e8-9976-113e926e0674n%40googlegroups.com <https://groups.google.com/d/msgid/pretext-support/7a7a88d4-89c6-47e8-9976-113e926e0674n%40googlegroups.com>> <https://groups.google.com/d/msgid/pretext-support/7a7a88d4-89c6-47e8-9976-113e926e0674n%40googlegroups.com?utm_medium=email&utm_source=footer <https://groups.google.com/d/msgid/pretext-support/7a7a88d4-89c6-47e8-9976-113e926e0674n%40googlegroups.com?utm_medium=email&utm_source=footer> <https://groups.google.com/d/msgid/pretext-support/7a7a88d4-89c6-47e8-9976-113e926e0674n%40googlegroups.com?utm_medium=email&utm_source=footer <https://groups.google.com/d/msgid/pretext-support/7a7a88d4-89c6-47e8-9976-113e926e0674n%40googlegroups.com?utm_medium=email&utm_source=footer>>>.
> >
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Chris Creighton

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Jan 24, 2024, 2:39:57 PM1/24/24
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Oh yes, 100%! Our issue this law is so board that it applies to all course materials: worksheets, notes, handwritten documents, etc. We have faculty using OneNote for lectures online and getting those pages accessible will be a challenge without re-typing all of it. Apparently, it applies to student uploaded work as well... which... I'm not sure if creating resources for College Algebra student to typeset mathematics is the best solution. Legal and Disability Services might need to weigh in here for us...

I'm sure some other Colorado folks will be coming through as well considering it will apply to CU Boulder as well. Hopefully this will get the ground settled for those big typing documents!

Anywho, thank you for your help! I'm sure I'll be coming back through if we get folks using PreTeXt!

Oscar Levin

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Jan 24, 2024, 6:17:06 PM1/24/24
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I too have been hearing about this law (I'm in Colorado too) and think that PreTeXt is an excellent option for accessible math documents.  We have an opportunity to increase the reach of PreTeXt as this law gets more faculty to worry about these things which they should have been worrying about anyway.  

I have a proposal in to the CDHE (Colorado Department of Higher Ed) to run a PreTeXt workshop here over the summer.  If that get's funded, I will be sure to reach out to see if you would like to attend.

Chris Creighton

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Jan 24, 2024, 7:45:35 PM1/24/24
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Oscar, that would be amazing! Feel free to reach out at this email or at ccre...@uccs.edu. I might know some other folks interested if you have space (we have a Technical Communications and Instructional Design program who I've talked to about using PreTeXt for OER STEM courses). Let me know if you'd like me to leverage some of my connections through the state's teaching centers to spread the word too.

Sean Fitzpatrick

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Jan 25, 2024, 10:03:36 AM1/25/24
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Did I just read correctly that the accessibility law applies to student work as well? Would that mean that math students are no longer allowed to submit hand-written work electronically?

That would be... interesting

Chris Creighton

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Jan 25, 2024, 11:25:06 AM1/25/24
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That is in line our center's interpretation.  The FAQ makes it fairly clear: https://oit.colorado.gov/hb21-1110-faq

We are making documentation of our good faith effort as if we require students to also create accessible document, that is a very high standard to meet by July 1. Take a look at the compliance portion too.

Key text:

"Under the Colorado Anti-discrimination Act (CADA), it is unlawful for any person to discriminate against an individual with a disability. House Bill 21-1110 expands this prohibition by defining discrimination to include two standards:

  1. It is discrimination to exclude an individual with a disability from participation in or being denied the benefits of services, programs, or activities provided by any Colorado government entity. 
  2. It is discrimination for any Colorado government entity to fail to develop an accessibility plan by July 1, 2022, and to fail to fully comply with accessibility standards developed by OIT by July 1, 2024. 

The new language specifically applies to accessibility of government information technology and expands the state's accessibility standard"

"It relates to all technology, hardware, and software, that is both public-facing and internal-facing. This includes any technology provided by or procured by a government entity that is used by the public or used by a government entity employee. This technology includes but is not limited to websites, applications, kiosks, digital signage, documents, video, audio, and third-party tools."

"There are no exemptions. All Colorado government entities are required to comply with OIT’s technology accessibility standards. Every person who contributes content to a website or application; develops or manages IT products and services; and every government entity employee who creates and shares emails, documents or presentations is responsible for making it accessible to everyone."

"The accessibility requirements of House Bill 21-1110 are specific to digital content, which is any content that exists in digital form. Accessibility is defined as “perceivable, operable, understandable and robust digital content that enables an individual with a disability to access the same information, engage in the same interactions, and enjoy the same services offered to other individuals, with the same privacy, independence, and ease of use as exists for individuals without a disability.” Given this definition, the statute applies to more than web-based content."

Honestly, I'm just trying to get faculty up to speed before addressing students and pedagogy.

Anyway, this is a bit out of scope for PreTeXt support, so definitely reach out to your OIT department for guidance!

Sean Fitzpatrick

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Jan 25, 2024, 11:37:24 AM1/25/24
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Wowza. I'm not affected by this, but depending on how you read it, the law could effectively ban online grading tools (Crowdmark, Gradescope, etc)

I bet some people will react by just eliminating digital content from their courses...

Oscar Levin

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Mar 10, 2024, 9:58:13 PM3/10/24
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For anyone in Colorado interested in the OER/PreTeXt workshop, we just opened registration: https://openmathbooks.org/comat

Oscar.

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