Fwd: Public Comment on ATAG 2.0

We received a public comment today.  Forwarded below. Here is the link 
to the comment in the archives.

http://lists.w3.org/Archives/Public/public-atag2-comments/2013Sep/0001.html

jeanne

-------- Original Message --------
Subject: ATAG 2.0
Resent-Date: Fri, 27 Sep 2013 13:48:53 +0000
Resent-From: public-atag2-comments@w3.org
Date: Thu, 26 Sep 2013 15:52:04 +0000
From: Rooij, R.P.L.A. de (Raph) - Logius <raph.de.rooij@logius.nl>
To: public-atag2-comments@w3.org <public-atag2-comments@w3.org>
CC: Rooij, R.P.L.A. de (Raph) - Logius <raph.de.rooij@logius.nl>

Dear ATAG working group,

First of all, thank you for making the ATAG 2.0 last call working draft 
available. I have read the document on 
http://www.w3.org/TR/2013/WD-ATAG20-20130910/ and I really liked it.

However, I do have one comment.
Currently, ATAG 2.0 does not address the subject that is related to 
transparency, compliance management and accountability. The importance 
of accountability in online information and service delivery is growing. 
Authoring tools can play a key role here, since checking assistance - 
and helping authors decide on potential web content accessibility 
problems – is not only valuable on an operational level, but also on the 
managerial level.
Technically, it is easy to offer a mechanism to capture and store the 
results of checks performed by authors[1]. By doing so, authoring tools 
become key instruments in providing input for compliance management 
systems. Such systems help website owners to better organise their 
accountability, resulting is more transparency. Not only regarding the 
level of conformance to the web accessibility specification, but also 
regarding the performance of website owners on the issue of web 
accessibility.

[1]: The Evaluation and Report Language (EARL) is W3C's specification to 
capture and store evaluation results

The following success criteria in ATAG 2.0 are related:
•  Part B: Support the production of accessible content
     •  Principle B.3. Authors are supported in improving the 
accessibility of existing content
         •  Guideline B.3.1. Assist authors in checking for 
accessibility problems
             •  B.3.1.1 Checking Assistance (WCAG)
             •  B.3.1.2 Help Authors Decide
             •  B.3.1.4 Status Report

I am not sure whether the subject can be successfully addressed in the 
context of above success criteria.
Therefore, I have not tried to fit my proposal into Part A or Part B.
I a aware that adding a Part C to ATAG 2.0 is an unlikely suggestion; 
please consider it just a placeholder for the concretization of what is 
described in above paragraphs.

--------------------------

Part C: Enhance transparency, compliance management and accountability

Principle C.1: Authoring tools offer capturing of evaluation results

Guideline C.1.1: Authors are able to re-use the results of evaluations 
against WCAG 2.0

Rationale: The results of accessibility testing are not only valuable 
during the process of  creating and editing content, but also for 
accountability purposes. Especially in situations where web 
accessibility is required by law, website owners are expected to be able 
to show proof that their content is successfully checked against W3C's 
web content accessibility guidelines.

Capturing the results of accessibility evaluation performed by authors 
has several advantages, including:
     • enabling the re-use of self-evaluation results to substantiate 
WCAG 2.0 conformance claims;
     • enabling auditing as a credible alternative to product inspections;
     • enabling aggregation of evaluation results (for research 
purposes, monitoring and ranking);
     • enhancement of the scope of large-scale monitoring of web 
accessibility, which at present often is limited to a subset of WCAG 2.0 
(i.e. what can be reliably programmatically determined);
     • supporting the transition of web content accessibility management 
from a product-based approach to a process-based approach. This will 
especially help integrating the subject of web accessibility into 
complex and/or multi-stakeholder environments.

C.1.1.1 Capture of checking assistance results:
If the authoring tool provides authors with the ability to check against 
success criteria, the author can export the evaluation results, 
including the decisions that were made by the author during checking.

[...etc...]

--------------------------

Please let me know if there is a need for clarification.


With kind regards,

Raph de Rooij
Logius, the Netherlands

raph.de.rooij@logius.nl



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Received on Friday, 27 September 2013 14:55:25 UTC