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Re: Fw: Checkpoint 3.3

From: Judy Brewer <jbrewer@w3.org>
Date: Tue, 20 Jul 1999 20:54:40 -0400
Message-Id: <3.0.5.32.19990720205440.00f96cb0@localhost>
To: w3c-wai-eo@w3.org, w3c-wai-gl@w3.org, w3c-wai-ig@w3.org
Several points on the Checkpoint 3.3 discussion.

First, a potentially simple solution to much of the recent discussion,
centering on the extent to which it is practical to rely on style sheets
right now, would be to clarify that there is a dependency between
checkpoint 3.3 and checkpoint 11.1, which reads "Use W3C technologies when
they are available and appropriate for a task and use the latest versions
when supported." Checkpoint 11.1 was, I believe, intended to apply as an
umbrella statement to the guidelines, but that is not clear from the
current text. The Web Content Guidelines Working Group has several options
for when and how to address that kind of unclarity, ranging possibly from
immediate errata to incorporating it in a revised WCAG when that happens,
assuming my interpretation is shared by others in the working group and
that people feel that this would be a constructive clarification.

Next, I am concerned by a few statements that have been made on these lists
claiming that WAI has "moved into policy-making"; that W3C is going
"legal"; that maybe WAI really meant to title the guidelines "standards" or
"rules" etc. I believe these statements promote a number of
misunderstandings. These guidelines were deliberately and precisely named
"guidelines." They are a W3C specification and have completed exactly the
process specified for W3C specifications. They have not gone through, nor
do they presume to have gone through, a legislative process -- nor has W3C
or WAI ever implied this. They can, as can any voluntary industry consensus
standard or specification, and as frequently happens, be referenced by any
organization that chooses to do so. Any organization referencing such a
document is responsible for doing so in a responsible manner. In the case
of the U.S. federal advisory committee, EITAAC, which Robert Neff, Jim
Thatcher, and Dave Poehlman have referred to, any references to WAI
guidelines in the EITAAC report (which provides recommendations for a U.S.
federal rule on electronic & information technology accessibility) would be
covered by the provision for "equivalent facilitation" which provides
(roughly, I'm not a lawyer) that if there's a reasonable or better way of
providing the same level of access intended by a referenced specification,
then the covered entity has met their obligation. Without such an ability
to reference voluntary industry consensus standards or specifications,
policy-makers would often be at a loss to develop essential policy for
areas concerning technology.

Regarding responsibility for training, there appears to be an undercurrent
in some of the comments earlier on this thread that if W3C publishes a
guideline explaining how to make Web sites accessible, as a reference for
those who would chose to make them accessible or to be referenced by
organizations setting requirements on particular entities to make their
sites accessible, then somehow W3C/WAI must assume responsibility to train
any entities that have obligations to make accessible sites. While I think
WAI has some useful support materials available and many more on the way,
and many people involved in WAI do many presentations and trainings, I hope
I'm misreading the intent of those earlier comments. WAI can help --
hopefully greatly -- with creation of re-usable training resources, but
training activities can and should be shared among many organizations,
including, in the case of US federal agencies, by (US) FedWeb which has
already been conducting trainings for federal agencies on this topic for
the past two years to prepare them for their obligations under US Section
508. And yes, WAI must be prepared to deal with potential backlash from
individuals or organizations that react in any of many possible ways to
these guidelines; however, the responsibility for responding in a
clarifying and constructive way is also, I hope, something to be shared by
the many organizations involved in trying to make the Web more accessible
for people with disabilities.

Regards,

Judy


_________________________________________________________________________
Judy Brewer    jbrewer@w3.org    +1.617.258.9741    http://www.w3.org/WAI
Director,Web Accessibility Initiative(WAI), World Wide Web Consortium(W3C)

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Received on Tuesday, 20 July 1999 20:55:36 GMT

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