From the following UK organisations:
Contact: David Sloan, Digital Media Access Group (DMAG), School of Computing, University of Dundee, Dundee, DD1 4HN; dsloan @ computing.dundee.ac.uk
The above organisations, all active in the UK education/technology/disability field, broadly support the principles of inclusive Web design as set out by WCAG 2.0. We also have some reservations, many of which have been expressed elsewhere, over the practical application of WCAG 2.0 in its present form. We offer some general recommendations which, if followed, we believe will better serve Web content providers in the community in which we work.
The 'Last Call' draft of version 2.0 of the Web Content Accessibility Guidelines (WCAG) has, since publication in April, attracted a significant amount of public comment, much of it of a negative nature. The authors of this response are all organisations heavily involved in promoting the appropriate use of technology to make access to education in the UK by disabled people as easy and effective as possible. We realise the importance of what will be the successor to the current de facto global standard for web accessibility in influencing commissioners and developers of Web content and applications, and all believe that WCAG 2.0 must build on WCAG 1.0 to improve, rather than inhibit levels of accessibility online.
We do not wish to repeat other detailed responses by providing a line by line critique of the current draft. Instead we present a higher-level view, outlining our concerns and our support where appropriate.
We note the many other responses that have been submitted to WAI in response to WCAG, and while we share the concerns expressed over the likely difficulty many developers will have in applying WCAG to HTML development, we strongly support the need to present Web accessibility as something more than "just following guidelines".
We are also conscious of the difficulty of developing accessibility guidelines, while also emphasising that readers must also be familiar with the ways in which disabled people access and use the Web; and the role of authoring and browsing tools - and their limitations - in ensuring an optimally accessible Web.
Our involvement in education has influenced our belief that Web accessibility should be considered on two levels:
This requires a holistic approach to Web accessibility - where development is driven by enabling the target audience to access and use the site for the intended purpose in the intended environment, whatever that may be [1, 2, 3]. In the UK, the recent emergence of PAS 78  has highlighted the importance of other factors in optimising Web accessibility beyond technical conformance.
We believe that the principles and guidelines set out in the WCAG 2.0 Last Call draft offer a solid platform on which to build on the two levels above. In particular, the technology-neutral approach adopted by WCAG supports authors in providing the best solution for the resource and audience in mind, whatever that may be. We further believe that the Baseline concept is an important step to enabling a more audience-focused approach to development, by allowing WCAG conformance to be specified in the context of a defined user environment that accurately represents reality.
We also note the tensions that appear to have emerged between the Web Standards movement and the Web Accessibility movement. We support the principle of open standards adoption, we know of the accessibility benefits that standards-conformance can bring; but we also realise that standards-compliance is not always equivalent to optimal accessibility of experiences, services and information for disabled people. Therefore we appreciate the difficulty that WAI has faced in deciding where and how to include designing to HTML (and other) standards within WCAG 2.0. Standards-conformance should be strongly encouraged; at the same time, considering the relationship between WCAG and disability legislation around the world, the potential situation of a Web site being declared unlawful (or being removed for fear of being unlawful) because it fails to validate to a particular technical standard, despite no evidence to indicate that a specific group of disabled people face undue discrimination, must be avoided.
As noted, we are concerned at the level of negative reaction to WCAG, much of which has come from prominent individuals in the field of web accessibility, notably . We echo these concerns:
The amount of documentation supporting the guidelines is immense; increasing complexity of navigation between guidelines and supporting documentation. We have welcomed the appearance in recent months of high-quality supporting material that has appeared on the redesigned WAI web site. However, we fear that the split between general guidelines and non-normative direction for specific technology development may lead to inappropriate solutions being applied. Given that, initially, most users of WCAG 2.0 will be HTML authors, this complexity, and in particular the relationship between WCAG and HTML Techniques needs to be revisited.
We reject the arguments expressed elsewhere that the Baseline concept promotes a return to browser-specific development. However we recognise that there is scope for authors to abuse the Baseline concept, which therefore needs to be defined more coherently. We would anticipate that in the UK, were a case of alleged discrimination under the DDA to come to court, any court decision should look at the baseline (if specified) and its appropriateness to the target audience, and therefore baseline definition becomes a critical task.
We share concerns expressed by others over the lack of focus on supporting people with varying cognitive impairments. We would like to see more encouragement given to supporting people who have difficulty reading on-screen text, through for example encouraging appropriate use of multimedia alternatives if they exist or can easily be created, but we also realise that there remains much work to do in this area. Nevertheless we have lent our support to the sentiments expressed in the Formal Objection co-ordinated by Lisa Seeman and Jonathan Chetwynd.
We feel that the way in which WCAG conformance has been addressed is excessively complex. In the UK, our legal obligations are to ensure that facilities and services are made accessible, and thus concentration should be on making tasks optimally accessible, and reporting on that success. The WCAG however deals with conformance at an artificial level - i.e. "Web unit", introducing as it does a new set of terminology that may confuse many people. We would prefer to see a more task-oriented approach to conformance, whereby lack of conformance requires a responsibility to document alternative routes to achieving task completion - this should be stated explicitly in the guidelines.
We see the most critical task as redefining the relationship between WCAG 2.0 and the WCAG 2.0 HTML Techniques. There is a need to support the most common WCAG 2.0 use case (those seeking support for HTML/XHTML development) by making it clear to developers what is and is not permitted in WCAG-conformant design. Clarification on the WCAG position on validation of HTML/CSS is also necessary, given the nature of many comments on the current draft and worries that WCAG conformance may promote increased use of invalid HTML.
NB We note strong support amongst Web developers for focus to move to amending WCAG 1.0 as a matter of urgency; and that development of WCAG 2.0 be continued longer-term in parallel with a redefinition of the role of second-generation Web Content Accessibility Guidelines in a world where there is increasing diversity in the nature and source of Web content (for example podcasts, collaborative online publishing areas, email discussion list archives, to name but a few), but where UAAG support by widely-used user agents is likely to remain disappointing. While we have indicated our support for the 'principles' approach that WCAG 2.0 has taken, we would support the WAI should it decide to refocus efforts in producing a revised WCAG 1.0 as an interim measure.
There is a need to reduce the perceived amount of reading required. We assume that the errors and logical absurdities pointed out by other commentators will be addressed; however we would also like to see a reduction in the amount of new concepts that must be learned by a reader. Some examples illustrating key concepts within the guidelines would be a very useful aid in this area.
NB We note the recent appearance of the WCAG 2.0 Quick Reference - which is a major step in this area.
To ensure a practically useful conformance system, there is a need to shift focus from 'Web units' to user tasks. Defining what can be done in a Web site, and which groups may find these tasks difficult or impossible, is we argue of more relevance that a report of an artificial entity's conformance against a set of checkpoints. WCAG conformance should be seen as a means to achieving accessible experiences, and not an end in its own right.
Clarification of the concept is necessary so as to limit misinterpretations and potential abuses. If not already happening, there is an urgent need for WAI to work with influential agencies across the globe to ensure that appropriate and reasonable baselines are defined and published for specific sectors.
The balance between Web Standards and Web Accessibility is altogether more difficult to address. We realise that external developments will be difficult for WAI to control, but we strongly urge WAI to re-establish links with those involved in any rival developments so that we have harmony in the way we all seek to achieve the common goal of an optimally accessible Web.