1. Replace "investment" with "cost" in this section. Also avoid the term "capital".

We are talking of costs that might be of a "capital nature" that need to be incurred less often whose usefulness lasts for more than one accounting period, as well as costs that might be more repetitive. So it is inappropriate to use the term "investment". Besides it is not for us to decide what is capital and what is not- some orgs may treat an expense as of capital nature and some orgs might treat the same expenditure differently. This is an accounting term and an accounting decision for an org. So let us keep it simple and just use "costs".

NL 1. I am in full agreement with Sailesh regarding renaming the section. The best way to talk about the costs is in association with the benefits. We need to present a cost-benefit analysis that clearly demonstrates that the costs are the long-term investment and, in the long run, will be offset by the benefits.

2. Consider following introduction for this section of the doc:

"It is important for an organization to recognize that making Web content accessible is not a one time effort and expense but needs long term commitment as Web content and Web applications undergo changes and revisions over time. Besides monetary costs, an organization needs to be prepared to invest the extra time needed for the effort especially during the initial stages, and also overcome any resistance to changing content development and deployment processes. "

NL 2. I would mention long-term commitment in relationship to the ongoing costs but would not emphasize it in this section. I would not also talk about other challenges associated with the accessibility introduction (resistance etc.). Though, I think it is a valid point that should be mentioned somewhere else.

3. "The cost of including accessibility is usually a small percentage of the overall Web site development cost."

Need to be careful here. (Natasha too sounded a warning on Oct 24 meeting) This might be true when a new website is being built with accessibility in mind. Retrofitting can be expensive, might need workflow / process changes / training etc and often fails to be prioritized as it may involve re-doing content and may be resisted. Also, what is "small"... can we indicate a range more objectively? Consider words like insignificant or negligible too. Argument can be stronger by relating incremental cost of accessibility not only to total Web content dev costs but to total expenses of running the org.

NL 3. Fully agree that we should be very careful claiming that accessibility is a small percentage of the overall development and that “Most of the costs are early investments at an organization level”. For large web sites, the initial investment can be really significant but for small and static web sites the cost can be minimal. I do not think that we can break it even by the size of the company because the size of the company does not imply that their web site is large and complex. Though we also need to take the size of the company into consideration. Maybe we can break it by two categories: one-time retrofitting costs (list all costs) and costs associated with the accessibility integration into the web development cycle.

I would suggest to follow Sailesh advice and just list all the costs that the company can potentially incur as a result of their accessibility efforts (either one-time or long-term commitment)

4. Strongly feel that repeating "leads to cost savings later on" is not necessary in this section.

The argument about someone going straight to this section can be made about any other section, so do they warrant similar inclusion of content from other sections?

NL. 4. I feel that it would be beneficial to present the costs and benefits together. We need to think about the appropriate format

5. Consider replacing "costs are early investments at an organization level..."

by saying : "Very little or nothing needs to be done to make an individual project accessible once the process of authoring(or building) accessible content has been internalized at the organizational level."

NL 5. I would be happy if the above statement was true but with the current status of web technology it is not a true statement. Even with integration of accessibility into the web development process, the cost associated with the testing and selecting the right alt text or other alternatives is pretty high.

6. Consider listing costs (non exhaustive):

The costs most likely to be incurred for making Web content accessible might be attributable to the following:

• Audit or evaluation of the state of accessibility of website and Web applications
• Tools that allow authoring accessible content
• Content management software that integrate accessibility design and development practices (The above two can be substituted with: Adopting processes / CMS that allow authoring accessible content; some might even integrate evaluation and repair capabilities)
• Training staff to design and develop accessible Web content
• Obtaining transcriptions, translations and captioning for multi media content
• Automated tools for Web accessibility evaluation and repair
• Quality assurance / testing processes to ensure Web accessibility
• Assistive technologies normally used for computer access by people with disabilities. Web content can be tested with assistive technologies. ( I put this one here because Shawn has it in the doc. But I cannot vouch for its effectiveness unless content is tested by knowledgeable and experienced PWD actually using the AT. WCAG 1.0 also recommendsthat PWDs using AT should test).
• Obtaining certification that Web content is accessible

NL 6. I fully support an idea of listing the costs. We can look at the implementation suite and list all the costs related to implementation starting from awareness campaign. But, again, there should be, at least two case-scenarios. One for a one-time web development and another one for integration accessibility into the development process

7. The following content also needs to be introduced into this section

- preferably after listing the above cost elements.

"Some of these costs might be incurred more frequently than others. An organization might choose to outsource some or all of the processes which will then require retaining consultants well versed in accessibility design and testing or firms that provide such services. Another organization might choose to build the capability inhouse by equipping itself with the necessary tools, software and staff. The costs also depend on the approach adopted for implementing Web accessibility. some organizations prefer to assign priorities to various types of Web content. One possible classification of Web content is:

• Content that is important from the organization's perspective. For example, a business might like to make its products and service offering pages accessible before working on pages that contains content of interest to investors or job seekers. Another organization might reverse the order. An organization running a passenger bus / rail network might consider making its schedules accessible first.
• Web applications- secure and non-secure
• multi-media Web content that might need extra effort for providing text alternative content / transcriptions / captions.
• static versus dynamic Web content

The level of accessibility sought to be attained may also influence the process and therefore the costs. It is possible for instance, that the efforts and time required for an organization to attain a mandated accessibility level (if any), that is lower than the one recommended as the most desirable by the Web Content Accessibility Guidelines, might be lower.

Just like itt is more economical and easier to plan and incorporate accessibility into a physical structure like a new building than an existing one, it is more easier on all counts to make a new Website accessible than retrofitting an existing website for accessibility features. In other words, it costs less to designed and develop a website with accessibility in mind. "

NL 7. I agree that you need to account for the costs associated with development of applications, multi-meida etc but I would not mention the business priorities assigned for addressing accessibility. But I would certainly reiterate it many times that accessibility should be an integral part of the web-development which is much more cost effective.

In the nutshell, I suggest to revamp the section. Make it very simple and concise that would allow people to build their own cost-benefit analysis.

Thanks a lot for listening,

Best regards,

Natasha Lipkina

HP/Ebusiness

Accessibility Program Manager