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Response to the WCAG-EM 1.0 Working Draft

From: Brian Kelly <b.kelly@ukoln.ac.uk>
Date: Fri, 19 Oct 2012 10:30:43 +0100
Message-ID: <50811DC3.9020704@ukoln.ac.uk>
To: public-wai-evaltf@w3.org
The Web Accessibility Initiative’s work in providing guidelines which 
can help enhance the accessibility of Web resources for people with 
disabilities since WAI’s launch in 1997[1] 
<http://ukwebfocus.wordpress.com/#ref-01>is to be valued.

However, as might be expected (and is the case with many of the 
standards which have been developed over the years by W3C), the various 
guidelines which have been produced by WAI have shown to have 
limitations or proven inappropriate for use in a real-world context. 
Accessibility researchers and practitioners based primarily in the UK 
have been pro-active in identifying limitations of the WAI model and 
proposing ways in which the guidelines can be contexualised and used 
where appropriate. This work dates back to 2005 when a paper entitled 
“/Forcing Standardization or Accommodating Diversity? A Framework for 
Applying the WCAG in the Real World 
<http://www.ukoln.ac.uk/web-focus/papers/w4a-2005/>/” was presented at 
the W4A 2005 conference [2] <http://ukwebfocus.wordpress.com/#ref-02>. 
Further work included papers on /Contextual Web Accessibility – 
Maximizing the Benefit of Accessibility Guidelines 
<http://www.ukoln.ac.uk/web-focus/papers/w4a-2006/>/ [3], A/ccessibility 
2.0: People, Policies and Processes/ 
<http://www.ukoln.ac.uk/web-focus/papers/w4a-2007/> [4], /One World, One 
Web … But Great Diversity/ 
<http://www.ukoln.ac.uk/web-focus/papers/w4a-2008/> [5], /From Web 
Accessibility to Web Adaptability <http://opus.bath.ac.uk/14902/>/ 
[6],/Developing Countries; Developing Experiences: Approaches to 
Accessibility for the Real World/ <http://opus.bath.ac.uk/18724/> [7] 
and/A Challenge to Web Accessibility Metrics and Guidelines: Putting 
People and Processes First/ <http://opus.bath.ac.uk/29190/> [8].

The abstract for our most recent paper [8] summarised the concerns we 
have regarding the WAI model (which is based on three sets of guidelines 
– WCAG, UAAG and ATAG):

“/This paper argues that web accessibility is not an intrinsic 
characteristic of a digital resource but is determined by complex 
political, social and other contextual factors, as well as technical 
aspects which are the focus of WAI standardisation activities. It can 
therefore be inappropriate to develop legislation or focus on metrics 
only associated with properties of the resource./

/The authors describe the value of standards such as BS 8878 which focus 
on best practices for the process of developing web products and include 
a user focus./“

I have concerns that the WAI’s Website Accessibility Conformance 
Evaluation Methodology 1.0 working draft 
<http://www.w3.org/TR/2012/WD-WCAG-EM-20120920/> [9] could be 
counter-productive if it is used by policy-makers to mandate conformance 
with WCAG, rather than treating WCAG as a valuable set of guidelines 
whose use should be considered in context.

The WAI model itself provides one example of such contextual issues. 
WAI’s view of what it refers to as ‘/universal accessibility/‘ is that 
this requires conformance with WCAG, UAAG and ATAG guidelines. Since 
browsers which do not conform with ATAG are not ubiquitous it is clear 
that the values of WCAG conformance will be limited. In addition the 
ways in Web content is created has changed drastically since WAI was 
launched and the WAI model developed. Email messages sent to WAI mailing 
lists, for example, will be Web content hosted on the WAI’s mailing list 
archive on the W3C Web site. It is unlikely that such content will 
conform with WCAG guidelines.

A recent post entitled “John hit the ball”: Should Simple Language Be 
Mandatory for Web Accessibility? 
<http://ukwebfocus.wordpress.com/2012/09/18/john-hit-the-ball-simple-language-mandatory-for-web-accessibility/> 
[10] highlighted that WAI have acknowledged that conformance with the 
current WCAG guidelines will n0t, as some people mistakenly think, 
address all disabilities. However, as described in the post, providing 
additional guidelines for incorporation in a future version of WCAG 
would be inappropriate as guidelines which mandate use of simple 
language would not be welcomed by everybody, for reasons described in 
the post and a more in-depth post onThe complexities of simple: What 
simple language proponents should know about linguistics 
<http://metaphorhacker.net/2012/09/the-complexities-of-simple-what-simple-language-proponents-should-know-about-linguistics/>[11] 
by Dominik Lukes.

Beyond the limitations of the WAI model there are the contextual factors 
regarding the purposes of Web resources (which the WAI document 
highlights). The WAI model was developed at a time when the Web was 
being used primarily as an informational resource, although we were also 
seeing examples of commercial transactions being developed. But beyond 
the provision of information and the purchasing of products which are 
mentioned in the WAI document, there are also more complex areas such as 
learning and cultural appreciation for which there is a need to develop 
a better understanding of what is meant by such areas in a Web context.

It should also be noted that clarity provided on the scope of Web 
resources provided in the WAI document may ironically lead to 
organisations failing to provide Web resources which may provide 
accessibility benefits to some if they fail to conform fully with WCAG 
guidelines. This is likely to be particularly the case in the public 
sector, who may be required to provide Web sites which conform fully to 
WCAG guidelines.

In addition to dangers that this may lead to online resources failing to 
be deployed, there is also a need to consider the costs of providing 
resources which conform fully with WCAG guidelines, particularly at a 
time of economic constraints. To give a particular example a paper 
entitled Supporting PDF accessibility evaluation: early results from the 
FixRep project <http://opus.bath.ac.uk/24958/> [12] analysed the 
provision of metadata in PDFs of (typically) peer-reviewed papers hosted 
in a university’s institutional repository and concluded:

/“This means that only 10% of all PDFs processed have any likelihood of 
conforming to accessibility guidelines, and even then we would require 
further content level analysis to evaluate the extent to which they do 
indeed conform.”/

It is felt (although further research is needed) that these findings are 
likely to be the case across institutional repositories more widely. 
Should we require that peer-reviewed papers should not be hosted on 
institutional repositories unless they conform with WCAG guidelines? If 
such a decision is made, what will the financial implications be and 
will “just-in-case accessibility” be an appropriate investment of scarce 
financial resources?

In light of such issues (which are discussed in more detail in the 
peer-reviewed papers which have been mentioned) what actions are 
appropriate for the Website Accessibility Conformance Evaluation 
Methodology 1.0 working draft 
<http://www.w3.org/TR/2012/WD-WCAG-EM-20120920/>? I would suggest that 
the document should explicitly mention the limitations of the WAI model 
(i.e. its dependencies of ATAG and UAAG) ; the need to address contexual 
factors and the need to address accessibility issues in a broader 
context including the context of use and purpose of the Web resource and 
the financial implications of conforming with the guidelines.

Finally I would suggest that document makes it clear that it would be 
inappropriate for policy-makers and legislators to enact legislation 
based solely on WCAG conformance. I would hasten to add that this is not 
to suggest that no interventions need to be made. Rather I would propose 
that it would be more appropriate to develop policies and legislation 
based on the processes surrounding the development of Web products as 
suggested in A/ccessibility 2.0: People, Policies and Processes/ 
<http://www.ukoln.ac.uk/web-focus/papers/w4a-2007/> [4]. In the UK, such 
approaches have been described in the British Standard Institute’s BS 
8878 Web Accessibility Code of Practice which is described at [13].


    References

1. WAI Launch Agenda, WAI, http://www.w3.org/WAI/References/agenda

2./Forcing Standardization or Accommodating Diversity? A Framework for 
Applying the WCAG in the Real World/ <http://opus.bath.ac.uk/438/>, 
Kelly, B., Sloan, D., Phipps, L., Petrie, H. and Hamilton, F. 
Proceedings of the 2005 International Cross-Disciplinary Workshop on Web 
Accessibility (W4A). ISBN: 1-59593-036-1. http://opus.bath.ac.uk/438/

3. /Contextual Web Accessibility – Maximizing the Benefit of 
Accessibility Guidelines 
<http://www.ukoln.ac.uk/web-focus/papers/w4a-2006/>/, Sloan, D., Kelly, 
B., Heath, A., Petrie, H. Fraser, H. and Phipps, L. WWW 2006 Edinburgh, 
Scotland 22-26 May 2006. Conference Proceedings, http://opus.bath.ac.uk/402/

4./Accessibility 2.0: People, Policies and Processes 
<http://www.ukoln.ac.uk/web-focus/papers/w4a-2007/>/, Kelly, B., Sloan, 
D., Brown, S., Seale, J, Petrie, H., Lauke, P. and Ball, S. WWW 2007 
Banff, Canada, 7-11 May 2007. http://opus.bath.ac.uk/398/

5. /One World, One Web … But Great Diversity 
<http://www.ukoln.ac.uk/web-focus/papers/w4a-2008/>/, Kelly, B., Nevile, 
L., Draffan, EA. and Fanou, S. WWW 2008 Beijing, China, 21-22 April 
2008. Proceedings of the 2008 international cross-disciplinary 
conference on Web accessibility (W4A), Beijing, China. Pages 141-147, 
Year of Publication: 2008. ISBN:978-1-60558-153-8 DOI: 
http://doi.acm.org/10.1145/1368044.1368078

6. /From Web Accessibility to Web Adaptability/ 
<http://opus.bath.ac.uk/14902/>, Kelly, B., Nevile, L., Sloan, D., 
Fanou, S., Ellison, R. and Herrod, L.
Disability and Rehability: Assistive Technology, Volume 4, Issue 4, July 
2009, pages 212 – 226. DOI: 10.1080/17483100902903408

7. /Developing Countries; Developing Experiences: Approaches to 
Accessibility for the Real World/ <http://opus.bath.ac.uk/18724/>, 
Kelly, B., Lewthwaite, S. and Sloan, D. W4A2010, April 26-27, 2010, 
Raleigh, USA. Co-Located with the 19th International World Wide Web 
Conference. Copyright 2010 ACM ISBN: 978-1-4503-0045-2
DOI: 10.1145/1805986.1805992 <http://doi.acm.org/10.1145/1805986.1805992>

8./A Challenge to Web Accessibility Metrics and Guidelines: Putting 
People and Processes First/ <http://opus.bath.ac.uk/29190/>, Cooper, M., 
Sloan, D., Kelly, B. and Lewthwaite, S. W4A 2012, April 16-17, 2012, 
Lyon, France. Co-Located with the 21st International World Wide Web 
Conference. Copyright 2012 ACM ISBN 978-1-4503-1019-2

9. Website Accessibility Conformance Evaluation Methodology 1.0 working 
draft <http://www.w3.org/TR/2012/WD-WCAG-EM-20120920/>, WAI, 20 
September 2012. http://www.w3.org/TR/2012/WD-WCAG-EM-20120920/

10. /“John hit the ball”: Should Simple Language Be Mandatory for Web 
Accessibility/? 
<http://ukwebfocus.wordpress.com/2012/09/18/john-hit-the-ball-simple-language-mandatory-for-web-accessibility/>, 
Kelly, B., UK Web Focus blog, 19 Sept 2012, 
http://ukwebfocus.wordpress.com/2012/09/18/john-hit-the-ball-simple-language-mandatory-for-web-accessibility/

11.The complexities of simple: What simple language proponents should 
know about linguistics 
<http://metaphorhacker.net/2012/09/the-complexities-of-simple-what-simple-language-proponents-should-know-about-linguistics/>, 
Lukes, D. Metaphor Hacker blog, 28 September 2012, 
http://metaphorhacker.net/2012/09/the-complexities-of-simple-what-simple-language-proponents-should-know-about-linguistics/

12. Supporting PDF accessibility evaluation: early results from the 
FixRep project <http://opus.bath.ac.uk/24958/>. In: /2nd Qualitative and 
Quantitative Methods in Libraries International Conference (QQML2010)/, 
2010-05-25 – 2010-05-28, Chania. http://opus.bath.ac.uk/24958/

13. BS 8878 web accessibility standards (supersedes PAS 78) – all you 
need to know <http://www.hassellinclusion.com/bs8878/> , Jonathan 
Hassell, http://www.hassellinclusion.com/bs8878/

-- 
--------------------------------------------------------
Brian Kelly
Innovation Support Centre, UKOLN, University of Bath, Bath, UK, BA2 7AY
Phone: 01225 383943
Email: b.kelly@ukoln.ac.uk
Blog: http://ukwebfocus.wordpress.com/
Twitter: http://twitter.com/briankelly
Web: http://isc.ukoln.ac.uk/
Received on Friday, 19 October 2012 09:31:05 GMT

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