Re: Is it 2 or 3 years that WCAG will be updated? - I thought it was approx. 3


Hi, everyone:

As a long-time reader of this list, and a former contributor to WCAG, I wanted to say that I agree fully with John's summary below.  He hits the nail solidly on the head with a sledgehammer.  All of the training and reporting that we do at NCAM is WCAG-based.  That's what our clients ask for, and it's also what we tell them they need.  And I can guarantee that as WCAG 2.x versions are issued we'll be updating NCAM's materials to reflect new guidance, techniques, etc.

Not to pile on, but I would disagree with this statement from Katie Haritos-Shea:

===
Believing that new SC will be taken-up by most organizations, public and private, without them being required to do so by law, is pretty much wishful thinking. As much as some  would like to believe that they live in a society that is enlightened, above accessibility needing to be mandated by law, I wish them the best – I do not live in that world.
===

This is definitely the world in which I work.  The majority of our clients don't ask us what they *must* do; they ask us what they can or should do.  True, a few will do only what is required of them, but the standard answer there is that they will have to do SOMEthing at some point, and probably soon. So why wait for a specific regulation when we know it's coming?  Don't get me wrong:  I love regulations.   But dragging regulations directly into standards/recommendation development is the best way to slow the process, constrain innovation and force authors and developers to wander off and go their own ways.

Geoff Freed
Director, Technology Projects and Web Media Standards
National Center for Accessible Media (NCAM)
WGBH Educational Foundation



From: John Foliot <john.foliot@deque.com>
Date: Tuesday, November 8, 2016 at 10:41 AM
To: Katie Haritos-Shea GMAIL <ryladog@gmail.com>
Cc: Andrew Kirkpatrick <akirkpat@adobe.com>, WCAG <w3c-wai-gl@w3.org>, Joshue O Connor <josh@interaccess.ie>
Subject: Re: Is it 2 or 3 years that WCAG will be updated? - I thought it was approx. 3
Resent-From: <w3c-wai-gl@w3.org>
Resent-Date: Tuesday, November 8, 2016 at 10:41 AM

> The crux though, is, that if those new SC aren’t adopted and required by government in their regulations – than few users will benefit from those important new SC – because they won’t be implemented other than by a few accessibility companies, disability groups and other well-meaning organizations building mobile apps.

This is your assertion.
​But where is your proof?​

I guess
​you​
've just been speaking to different clients than I have, as most developers I speak with not only want to do the right thing, but they are thirsting for guidance and specifics on *how* to do the right thing.
​They aren't going to wait for a government to mandate what they should do, they'll do what they believe is best, and my fear is that larger organizations will start to write their own "guidelines and standards" (
​​
BBC's Mobile Accessibility Guidelines<http://www.bbc.co.uk/guidelines/futuremedia/accessibility/mobile_access.shtml>
​)​
that will be hard to align with a W3C version if we take the slow, painful process that the US Government currently exhibits in their excruciating crawl to catching up to the 21st century.​

We have examples of countries being quick to adopt and adapt (the UK
​ w/
BS 8878
​
), and equally we have examples of countries that drag their feet (the USA - Section 508, which by today's standards is an actual antique).
​ We also have regulators that have​ adopted the ISO variant of WCAG 2.0 (Japan), or adapted and modified WCAG 2.0 to meet their territorial needs (AODA,
Quebec's SGQRI 008-01)
​. By my observation, regulators are as much informed by WCAG as they "adopt" WCAG whole-cloth - it's not a monolithic landscape in the real world, and even today some countries still use WCAG 1.0 (http://www.lflegal.com/2013/05/gaad-legal/). Finally, there are more than a few accessibility experts who are looking at WCAG as writ today with regard to use as a legal vehicle, and find it coming up short (http://www.funka.com/en/about-funka/ceos-corner/why-wcag-isnt-enough/), and even in the US, legal settlements today are reaching beyond WCAG to other 'standards' because WCAG 2.0 is starting to show its age:

"However, the (Netflix) agreement does not use WCAG 2.0 AA as the accessibility standard for mobile applications.  Instead, the agreement adopts the British Broadcasting Corporation’s Mobile Accessibility Standards and Guidelines version 1.0<http://www.bbc.co.uk/guidelines/futuremedia/accessibility/mobile_access.shtml> (“BBC Standard”) as the accessible standard for the mobile application.

The use of the BBC Standard is unusual and departs from the Department of Justice’s practice of using the WCAG 2.0 AA as the accessibility standard for mobile applications."
(
http://www.adatitleiii.com/2016/04/netflix-agrees-to-add-audio-description-to-many-of-its-shows-and-dvd-rentals/

​)​

More importantly however, we have companies and organizations adopting WCAG 2.0 whether or not they are mandated to do so (Penn. State, US Dept. of Justice), and at the W3C we have companies that are not only adopting our current standards, they are helping to make new accessibility standards (ARIA, a11y & SVG, Project Silver) which they will bring back to their organizations to use (IBM, Oracle, Adobe, Apple, Google, Facebook, Pearson, and more). We have absolutely no reason to believe they won't keep up with WCAG 2.x, or at least start to integrate any new Success Criteria we advance at a pace that is faster than the legislative process today, and in fact organizations like the dPub IG at the W3C are coming to the WCAG WG looking to ensure that Digital Publications can be made accessible, and have articulated gaps they see and want to fix *today*, and not when legislated to do so (https://w3c.github.io/dpub-accessibility/).

Focusing on the USA for just a minute, the advancement and adoption of WCAG 2.0 in the private sector has not happened because of a legislated requirement, but rather that the DOJ is simply referencing WCAG (as an industry standard) in their *enforcement* of ADA (the spirit of that legislation, and not the letter of the law), and while that has its drawbacks, it is also a telling indication that needing specific legislation to achieve our goals is neither necessary nor required: helpful yes for clarity, but the evidence before us (going all the way back to the Target.com case<https://www.w3.org/WAI/bcase/target-case-study>) is that it's not the legislation that matters so much, it's the enforcement.

>
to
​​
allow them to be more easily included in design specifications, purchasing agreements (procurement), regulations (government), and contractual agreements.

Sure, but that isn't the same as "becoming the next new
​legal requirement
"
​. The plan for WCAG 2.x (2.1) is to use exactly the same framework and 'methodology' as WCAG 2.0 - in fact it is mandated to be 100% backwards compatible - but the goal is not to re-write external legislation(s), it's to advance new technologies and practices that benefit PwD and inform and instruct developers on what and how to achieve that, while at the same time "...
​
allow them to be more easily included
​..." into existing or future legislation​ - not *ENSURE* they get added, but rather to allow them to be more easily included...

It is for this reason that I cringe when I hear of legislative needs acting as an drag-anchor to our efforts. We have a real need and gap in our requirements today, and just because some actors will hem and haw, and find every trick in the book to try and avoid doing the right thing, is not a reason for us to slow down or wait for them to catch up: for that, I'll leave it to the lawyers and legislators to enforce the laws they have on their books on a territory by territory basis today: the W3C informs, the governments enforce. This is the real reality today, and it is the one we should work with, not try to change through slowing down our progress.

JF

On Mon, Nov 7, 2016 at 6:39 PM, Katie Haritos-Shea GMAIL <ryladog@gmail.com<mailto:ryladog@gmail.com>> wrote:
JF: If the priority of constituents has changed since the publishing of WCAG 2.0, and the current information posted on the Intro page is now inaccurate, I'd like to know when that happened (Meeting minutes, CfC, etc.), or, conversely, do we need to review that point as part of our going forward?

John,

The question raised in today’s meeting as I recall wasn’t ‘who is WCAG for’, but was not a question at all, but rather a response to you saying that WCAG wasn’t written for governments – to which I responded……

My memory is very clear on this, and certainly much of the meeting minutes from early on in WCAG 2 development should confirm, and perhaps my colleagues from that time, that since WCAG 1 was (surprisingly to many) adopted by laws around the world, the WG decided for WCAG 2 to specifically frame the SC language to be testable and articulated so as to allow them to be more easily included in design specifications, purchasing agreements (procurement), regulations (government), and contractual agreements.

If you look at WCAG 2 itself, under the WCAG 2.0 Layers of Guidance heading:

​​​​​“Success Criteria - For each guideline, testable success criteria are provided to allow WCAG 2.0 to be used where requirements and conformance testing are necessary such as in design specification, purchasing, regulation, and contractual agreements.”

Of course WCAG 2 guidance was made for developers, designers and others - for the benefit of the true constituents, *users with disabilities*. The crux though, is, that if those new SC aren’t adopted and required by governement in their regulations – than few users will benefit from those important new SC – because they won’t be implmented other than by a few accessibility companies, disability groups and other well-meaning organizations building mobile apps.

Beleiveing that new SC will be taken-up by most organizations, public and private, without them being required to do so by law, is pretty much wishful thinking. As much as some would like to believe that they live in a society that is enlightened, above accessibility needing to be mandated by law, I wish them the best – I do not live in that world.

In my experience, with almost all clients, as I sit across the table from them after an assessment or requirements meeting, what I hear from them is “What do I *have* to do”? The shoulds and the coulds rarely get the go-ahead.

* katie *

Katie Haritos-Shea
Principal ICT Accessibility Architect (WCAG/Section 508/ADA/AODA)

Cell: 703-371-5545<tel:703-371-5545> | ryladog@gmail.com<mailto:ryladog@gmail.com> | Oakton, VA | LinkedIn Profile<http://www.linkedin.com/in/katieharitosshea/> | Office: 703-371-5545<tel:703-371-5545> | @ryladog<https://twitter.com/Ryladog>

From: John Foliot [mailto:john.foliot@deque.com<mailto:john.foliot@deque.com>]
Sent: Monday, November 7, 2016 5:41 PM
To: Katie Haritos-Shea GMAIL <ryladog@gmail.com<mailto:ryladog@gmail.com>>
Cc: Andrew Kirkpatrick <akirkpat@adobe.com<mailto:akirkpat@adobe.com>>; WCAG <w3c-wai-gl@w3.org<mailto:w3c-wai-gl@w3.org>>; Joshue O Connor <josh@interaccess.ie<mailto:josh@interaccess.ie>>

Subject: Re: Is it 2 or 3 years that WCAG will be updated? - I thought it was approx. 3

​​+1 to Andrew.

The deck I used for the internal Deque presentation today was dated September 30th and was first presented at Paris-Web on that day, and was based on thoughts & discussions that emerged from TPAC 2016 the week previous. Some aspects of that have changed since then, however the goal of getting WCAG 2.1 completed in a 2-year time frame (closer to 15-18 months), and that a FPWD of Silver (AG/3.0) is targeted for 3 years is now part of our Draft Charter out for review to the AC. Additionally, all dates in the PPT deck were also clearly marked TBC.

The current Draft Charter for this Working Group now has an indicated release date of Q2 (June) 2018 for WCAG 2.1 (https://www.w3.org/2016/11/proposed-ag-charter#milestones), and personally I have a high-level expectation that this date will not slip FOR ANY REASON. (I suspect that will also be an expectation from W3C management and AC representatives.)

Because of that, I also suspect that not all of the currently proposed 50+ new Success Criteria emerging from the various task forces will make that date. Despite my continued reservations that this scenario is currently not explicitly addressed in the proposed new WG charter, I agreed (or rather "agreed to live with") to let the charter move forward for AC review, with the understanding that we may need a WCAG 2.2, likely to ship during the *next* charter (after the currently proposed new 3 year charter expires) to address current proposed SC that did not make the cut-off date for WCAG 2.1. Whether that would be in a 1, 2 or 3 year time-frame after the 2016-2019 charter period expires has been left to determine during the next rechartering exercise. That decision will also likely be impacted and informed by progress made on the Silver activity (i.e. if progress on Silver is moving forward rapidly, we may not need a 2.2, and instead go straight to 3.0/Silver).


Another question that surfaced during that internal presentation today was "Who is WCAG for?", to which I referenced the following:
Who WCAG is for

WCAG is primarily intended for:

  *   Web content developers (page authors, site designers, etc.)
  *   Web authoring tool developers
  *   Web accessibility evaluation tool developers
  *   Others who want or need a standard for web accessibility

Related resources are intended to meet the needs of many different people, including policy makers, managers, researchers, and others.

WCAG is a technical standard, not an introduction to accessibility. For introductory material, see Where should I start? in the FAQ<http://www.w3.org/WAI/WCAG20/wcag2faq.html#start>.
(source: https://www.w3.org/WAI/intro/wcag.php)

While the role of governments and legislators is noted in the "constituents group" above (policy makers), I also wanted to note their secondary role, and to underscore that WCAG is primarily for the users and content creators (per our own documentation), and that we should be working to their needs over those of the regulators, including developing time-lines and delivery deadlines, especially with the 2.x work. If the priority of constituents has changed since the publishing of WCAG 2.0, and the current information posted on the Intro page is now inaccurate, I'd like to know when that happened (Meeting minutes, CfC, etc.), or, conversely, do we need to review that point as part of our going forward?

<opinion>
I do believe that a deeper consultation with all stakeholders is appropriate for the AG (aka 3.0) work, and in fact is called out explicitly in the Silver draft Work Statement, but I again reiterate that from my perspective, work on the 2.x activity should not and in fact must not be delayed by policy makers (etc.) not being actively involved in the 2.x work and slowing our progress.

We need to work at the speed of the internet, not the speed of regulators, to get accurate, useful, and standardized Success Criteria into the hands of those who *want* this content today: I already know of at least one organization that is legally mandated to meet the BBC Mobile Accessibility Guidelines, not because they didn't want to use WCAG Guidelines, but because WCAG has nothing today specific to Mobile, and they needed something now, not in 5 years time. This is another problem we must also recognize: if we take too long to update our guidance, our Recommendation will start to lose credibility and relevance to the real world, in much the same way that Section 508 today is irrelevant to most content producers "in the wild": even the US Department of Justice references WCAG 2.0 over Section 508, and through my work I note other 508-mandated stakeholders are today driving toward WCAG 2.0 instead - I heard this multiple times at Educause 2 weeks ago, with multiple publicly funded EDUs adopting WCAG 2.0 as their internal standard.

(I'll also note in passing that this could negatively impact this Working Group's very existence: during the last rechartering of the Education and Outreach Working Group, more than one AC representative noted that they felt the work of EO was being duplicated elsewhere: faster, and "better", and why should the W3C continue to fund that activity? That hurdle was cleared, and EO lives still, but there is a cautionary tale there that should not be ignored... UAAG WG was also wrapped up for similar reasons.)

Those that are going to take their time adopting our new work, and/or push back on each and every new SC as being difficult for regulators must not stop us in this goal - they can stay conformant to WCAG 2.0 from now to eternity (as WCAG 2.0 will never change), and instead make their legislative shift to 3.0 when it is ready to be published as a W3C Recommendation, and they are ready to adopt it - there is no obligation, implied or stated, that governments and legislators *MUST* keep up with all WCAG releases, whether major or minor.
</opinion>

JF

On Mon, Nov 7, 2016 at 4:00 PM, Katie Haritos-Shea GMAIL <ryladog@gmail.com<mailto:ryladog@gmail.com>> wrote:
Andrew,

Thanks. That is what I thought!

​​​​​Happy Monday.



* katie *

Katie Haritos-Shea
Principal ICT Accessibility Architect (WCAG/Section 508/ADA/AODA)

Cell: 703-371-5545<tel:703-371-5545> | ryladog@gmail.com<mailto:ryladog@gmail.com> | Oakton, VA | LinkedIn Profile<http://www.linkedin.com/in/katieharitosshea/> | Office: 703-371-5545<tel:703-371-5545> | @ryladog<https://twitter.com/Ryladog>

From: Andrew Kirkpatrick [mailto:akirkpat@adobe.com<mailto:akirkpat@adobe.com>]
Sent: Monday, November 7, 2016 3:26 PM
To: Katie Haritos-Shea GMAIL <ryladog@gmail.com<mailto:ryladog@gmail.com>>; 'WCAG' <w3c-wai-gl@w3.org<mailto:w3c-wai-gl@w3.org>>; josh@interaccess.ie<mailto:josh@interaccess.ie>
Subject: Re: Is it 2 or 3 years that WCAG will be updated? - I thought it was approx. 3

As of right now we say in the proposed charter "The Working Group intends to produce updated guidance for accessibility on a regular interval of approximately three years, starting with WCAG 2.1.”

We may determine that we can do it in 2 or we may determine that we need 4, or we may find that 2 is too soon or that 3 is too long. It is currently TBD, as there is not a consensus opinion on the group for 2 years at this point in time.

Thanks,
AWK

Andrew Kirkpatrick
Group Product Manager, Standards and Accessibility
Adobe

akirkpat@adobe.com<mailto:akirkpat@adobe.com>
http://twitter.com/awkawk


From: Katie GMAIL <ryladog@gmail.com<mailto:ryladog@gmail.com>>
Date: Monday, November 7, 2016 at 15:17
To: WCAG <w3c-wai-gl@w3.org<mailto:w3c-wai-gl@w3.org>>, Andrew Kirkpatrick <akirkpat@adobe.com<mailto:akirkpat@adobe.com>>, "josh@interaccess.ie<mailto:josh@interaccess.ie>" <josh@interaccess.ie<mailto:josh@interaccess.ie>>
Subject: Is it 2 or 3 years that WCAG will be updated? - I thought it was approx. 3

Andrew and Josh,

I was at a presentation today put on by John Foliot, where he stated that we, the WCAG Working Group, will be updating WCAG 2 every two years until Silver comes out.

Is there some background information about how often *we* plan on updating WCAG 2, as was stated in the charter, that I am missing?

​​​​​



* katie *

Katie Haritos-Shea
Principal ICT Accessibility Architect (WCAG/Section 508/ADA/AODA)

Cell: 703-371-5545<tel:703-371-5545> |ryladog@gmail.com<mailto:ryladog@gmail.com>|Oakton, VA |LinkedIn Profile<http://www.linkedin.com/in/katieharitosshea/>|Office: 703-371-5545<tel:703-371-5545> |@ryladog<https://twitter.com/Ryladog>




--
John Foliot
Principal Accessibility Strategist
Deque Systems Inc.
john.foliot@deque.com<mailto:john.foliot@deque.com>

Advancing the mission of digital accessibility and inclusion



--
John Foliot
Principal Accessibility Strategist
Deque Systems Inc.
john.foliot@deque.com<mailto:john.foliot@deque.com>

Advancing the mission of digital accessibility and inclusion

Received on Tuesday, 8 November 2016 20:05:53 UTC