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SC 1.3.1 - Leaving aside that I've no idea how this SC would be applied to kiosk applications, it's worth pointing out that SC 1.3.1 already bears a very heavy load. Attempting to cram the world of document-specific or workflow-specific information to this one SC won't generate clarity. Here's an illustration. Take the case of a scanned page added as the last page of an electronic document. Let's assume all the text on this page has been made accessible; the page image's content is adequately represented via text and tags. - What of the underlying scanned page-image itself? Does it still need to be represented in the logical structure? Does the simple fact that the page's source was a scan (as is evident to a sighted user) constitute "information" that must also be programmatically determinable to conform with 1.3.1? - If so, is the fact of a page-sized image made available to AT (in addition to the text) adequate information? If so, then should be OK to write out the image as an artifact (not in the logical structure) because we've already represented the contents in an accessible manner? - Maybe we have to tag the image if the page has been signed, but not if the page hasn't been signed? - Does conformance require that each of the signatures be represented individually? Perhaps segmentation of the source-image is required in order to have a image (and thus alt. text) associated with each signature? The line between "incidental information", and "data critical to understanding the document" isn't always apparent; this is all the more so with formats that are more internally complex than HTML, or present situations that just don't occur with markup-langugage-style technologies. The WCAG2ICT draft shows zero sensitivity to such complexities.