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Description
The working draft lists the following:
Foundational requirement: Media alternatives in all spoken languages Developing
Media alternatives are provided in all spoken languages used in audio content.
I do not believe this is properly scoped.
First, in many movies, there may be incidental occurrences of people speaking foreign languages that are not intended to be understood by the movie's target audience. If the main character cannot understand a foreign language, it is a fairly established convention that the audience for the movie is not expected to either (i.e., in an English-speaking movie, the main character cannot understand what the people are saying when visiting a foreign-language country). The established convention for captioning is not to translate what the protagonist cannot understand, but instead put in something like "[Speaking Japanese]" The current wording would seem to require that any incidental foreign language used in a film would force the full translation of all alternatives into those languages. I am assuming that is not the intent.
Second, I do not believe the language spoken in the movie should be the determinant on the accessible requirement. There is language in a video that is not spoken (such as onscreen text).
Third, many movies that are released internationally use subtitles, not dubbing. In such a case, none of the language spoken in the movie matches the intended audience. I think it should be the existence of a version of a movie intended for a language-specific audience. If there is a French-speaking movie, its alternatives should be available in French, but if there exists an English-language subtitled version, then all the text alternatives should be available in English for that version.
For commercial film releases, the requirement simply needs to have the alternative match the language-indicated version of the release.
For amateur videos, there is no arbiter to help determine the language, so there is going to have to be reliance on the video's content. I would suggest:
Media alternatives in matching language
Media alternatives are provided that match the human language used in audio and visual content, including in subtitles, except when the human language is not intended to be meaningful to the audience.
Subtitles would need to be defined, and clearly differentiated from captions (which they are not, currently). There may be an easier way of phrasing that doesn't involved subtitles.
We have previously used the term "ambiguous" in SCs like Link Purpose. The exception I'm proposing involves the same basic concept.