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[Bug 14107] Non-conformance of the summary attribute for the table element makes WCAG 1.0 compliance impossible

From: <bugzilla@jessica.w3.org>
Date: Sat, 28 Jan 2012 21:56:18 +0000
To: public-html-a11y@w3.org
Message-Id: <E1RrGFu-0005Am-Ig@jessica.w3.org>
https://www.w3.org/Bugs/Public/show_bug.cgi?id=14107

--- Comment #10 from theimp@iinet.net.au 2012-01-28 21:56:14 UTC ---
> Can you point to an example of legislation that forces this interpretation of
WCAG1's own requirements?

In 1997, the Australian Human Rights Commission (at the time, the Australian
Human Rights and Equal Opportunity Commission) endorsed WCAG 1.0 as being
consistent with the requirements of the Disability Discrimination Act 1992.

The first case law in the world, on this matter, McGuire vs SOCOG, affirmed
that position, in 2000.

The Council of Australian Governments, including the federal government, all of
the state governments, and the Australian Local Government Association, agreed
that all respective state legislation also implied a requirement of compliance
with WCAG 1.0; all produced policy documents asserting this, and mandated
compliance by their own agencies.

An example of this interpretation is found in the latest version of the
Victorian Government Accessibility Toolkit - the manual provided for explaining
requirements to various agencies in that state. The authors consider that
"Checkpoint 5.5 [of WCAG 1.0] requires that tables use the SUMMARY attribute."

http://www.egov.vic.gov.au/pdfs/accessibility-toolkit-v3.1.1-mar2011.pdf
(p.122)

(See also the introduction for some examples of the rationale, from a
compliance point-of-view, for not using WCAG 2.0 at this time)

> I'm not sure how W3C can guard itself against such secondary interpretations.

It could:

* Retire superseded specifications.
* Update the specifications (say, WCAG 1.01).
* Publish Errata.
* Not publish contradictory Recommendations.

The first option is not viable, as explained below. But either of the other
three would suffice.

Keep in mind that, because WCAG 1.0 is not re-implemented in legislation (such
as is the case with the US Section 508 of the Americans with Disabilities Act),
but merely referenced by legislation, formal errata would automatically
supersede interpretations unless affirmed by the High Court, in the case of
Australia at least.

> I'm not sure what you mean. In addition to WCAG's own text on the matter, WCAG2 states:
> "WCAG 2.0 succeeds Web Content Accessibility Guidelines 1.0 [WCAG10], which was published as a W3C Recommendation May 1999. Although it is possible to conform either to WCAG 1.0 or to WCAG 2.0 (or both), the W3C recommends that new and updated content use WCAG 2.0. The W3C also recommends that Web accessibility policies reference WCAG 2.0."

That is non-normative, and in fact reinforces that WCAG 2.0 does not supersede
WCAG 1.0, but is rather simply a superior choice for the kinds of web content
being generated in 2008, than for the state of the web in 1999.

Remaining consistent with WCAG 1.0 - at least where it does not cause any
problems for anybody - should therefore be a priority for the W3C, I believe.

In late 2010, the Australian Human Rights Commission did actually endorse WCAG
2.0. However, it has not yet been implemented in policy: implementation has
just been delayed again, until the end of 2013, and unofficially at this stage,
it will soon be delayed yet again until the end of 2014 as a minimum. After
that, who knows? It is very possible that HTML5 will be completed while WCAG
1.0 is still being required. And that's speaking just for Australia, and not
other countries who's implementation schedules I know rather less about.

> Can you explain what "retiring" WCAG1 would mean in terms of the W3C process?

I do not actually know how Recommendations could be made obsolete within the
W3C; in fact, I suspect they currently can't be, under ordinary circumstances.

But WCAG 1.0 has not been superseded and should not be retired, I think.

> Are there any W3C specifications that are "retired"?

"Specifications"? Yes, a large number of Working Drafts and Group Notes which
never made it to Candidate Recommendation (and typically were never supposed
to) have been obsoleted with the status "Retired". Usually, when they are
subsumed wholly withing other specifications, but sometimes it is just because
they are not, strategically, useful any longer.

> Or, failing that, can you point to any examples from other specification-recommending organisations?

I could; in light of the above comments, would if still be helpful for me to
research that and post it in this bug?

> i.e. What can W3C do to retire WCAG 1?

I don't know. I don't think that they have to. All instances of interpretation
of W3 specifications, that I know of, (by governments, as opposed to vendors,
who can be rather creative) are simply practical clarifications in an area
where the W3 has not made such clarifications, yet. That is, they have read the
specification as it makes sense to read it, and asserted a reasonable meaning.
If something different is intended, it must be clarified.

I believe that this interpretation will evaporate if appropriate Errata is
published - assuming that this is in fact what the editors of WCAG 1.0
intended, or at least what the stakeholders understood their intention to be.

Would you like for me to take this to the Web Content Accessibility Guidelines
Working Group?


In any case, in respect of this bug, if the Editor is prepared to assert that
his interpretation is that there is no inconsistency, then that will solve the
bug itself. But that will not change the WCAG specifications, nor the
interpretations made in the absence of such changes. And I have raised this
issue because I think that potentially forcing a schism between governments and
the W3C is a very dangerous thing to do, in light of the years of work the W3C
has done to encourage government involvement, for the sake of an attribute that
seems to have been removed for not much better reason that "it looks neater
this way".

I should be clear, again, that the implementability of the W3C specifications
is my goal, and not the preservation of any particular feature. I will
absolutely withdraw my protest here, if the consensus (from stakeholders within
and without the W3C) is that there is no inconsistency between the standards
mentioned here.

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Received on Saturday, 28 January 2012 21:56:21 GMT

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