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Archived comments from Sec 508 Washington DC hearing May 12, 2010

From: Judy Brewer <jbrewer@w3.org>
Date: Fri, 18 Jun 2010 17:25:49 -0400
To: www-archive@w3.org
Message-Id: <E1OPj50-0004NJ-Sp@bart.w3.org>
I am archiving this excerpt from the transcript of a US Access Board 
hearing on the "refresh" of US Section 508, 255, and the ADA that was 
held in Washington DC, USA, on May 12, 2010. The full transcript of 
the hearing is available at 
http://www.regulations.gov/search/Regs/home.html#documentDetail?R=0900006480b02403 
.
Please also note the previous set of comments from the Santa Clara 
hearing on March 25.

- Judy Brewer


JUDY BREWER:  Thank you for this opportunity to testify with regard 
to the United States Access Board's planned update of Section 508, 
Section 255, and the Americans with Disabilities Act guidelines.  My 
name is Judy Brewer, and I direct the Web Accessibility Initiative at 
the Worldwide Web Consortium.  As my colleague offered in the March 
hearing, we will make more detailed comments before the end of the 
comment period.  First, I would like to express my appreciation to 
the Access Board for its very hard work and care in preparing this 
ANPRM. I particularly appreciate the emphasis in the ANPRM on 
harmonization with international standards and web accessibility.

Before I started working in the field of web accessibility, the topic 
of standards harmonization sounded both abstract, and esoteric to 
me.  I suspect that this is the way that it may still sound to many 
people. But I believe it is one of the best strategies that we all 
have for accelerating the pace of implementing accessibility 
solutions across the web and the implementation does need 
acceleration.  Standardization is much more than a way to keep 
recreating the wheel.  It is a way to ensure that all parties 
interested in web accessibility are able to work towards a common 
target with regard to accessibility goals.  It is a way to ensure 
that technical support materials and training resources can be widely 
reusable, and expanded on, rather than redeveloped separately for 
each different standard, and that organizations can realize the 
benefits of WCAG2.0, which is a highly flexible framework for 
supporting innovation.

Standards harmonization is also a way to ensure that the US does not 
fragment accessibility standards for the web, restarting a process of 
cascading derivative versions of web accessibility standards that 
have a negative impact on accessibility efforts in other countries 
around the world.  I'm frequently asked by my colleagues in other 
countries what I think the US will do with regard to harmonization 
with WC3-WAI.  And I can now say that the intent to harmonize comes 
strongly in the ANPRM.  And I encourage it to be stronger if 
possible.  One of the questions that W3C is looking at is does this 
method of harmonization proposed in the ANPRM make it sufficiently 
clear for web developers that they can and should use web content 
accessibility guidelines, WCAG 2.0  AA, or even ways to make it even 
clearer.  The clearer the statement of harmonization, the more we 
believe that this will protect against fragmented interpretations of 
the standards in the US Federal Government, in U.S. states, and in 
other countries.

On the topic of harmonization, I would also like to note that at the 
time of completion of the TEITAC report, WCAG2.0 was not quite a 
completed W3C standard.  We commend the Access Board for keeping up 
with developments in the completion of the WCAG2.0 consensus standard 
as part of the regulatory process.  The Access Board has continued to 
ensure that this ANPRM reflects the completed WCAG2.0 standard.  This 
standard was supported by a broad and multi-stakeholder consensus of 
industry, disability, government, and research.

To look at the benefits of standards harmonization from another 
angle, it is important because it enables all parties to leverage 
what I call "multipliers," the most of important of which are 
authoring tools. Authoring tools are software applications that 
people use to create and produce all kinds of content on 
websites.  In the context of web accessibility, authoring tools can 
multiply the effort expended on accessibility by building support for 
production of accessible content into the tools themselves, taking 
this beyond a one developer, one website, one guideline approach, to 
an approach where improvements in support for production of 
accessible content in authoring tools, can be built into all 
mainstream authoring tools, helping raise the accessibility levels of 
hundreds of thousands of websites through individual authoring tools.

Though we are encouraged by recent changes in some authoring tools, 
progress in authoring tools has lagged too far behind the field and 
people with disabilities have lost out as a result.  Standards 
harmonization will help drive these improvements.  But we also 
commend the Access Board for incorporating into this ANPRM specific 
provisions regarding support for production of accessible content by 
authoring tools.  For instance, provisions regarding inclusion of 
accessible templates for production of accessible websites; since 
templates are one of the most widely used shortcuts to site creation 
you might add that help people to build accessible sites.  We want to 
bring to the Access Board's attention that there are further wording 
improvements in accessibility guidelines and updates to the W3C 
Accessibility Guidelines 2.0 drafts, which are in progress at W3C, 
and we will provide more detailed written comments on this point in 
case those can be useful to the Access Board.

Standards harmonization also helps with regard to improved evaluation 
methodologies by providing a common definition of what needs to be 
evaluated.  We are seeing great interest in this area of evaluation 
methodologies, in some countries, and expect to see growing interest 
in the US as well.

We encourage harmonization for this reason, as well as for the 
benefits that will be realized on the conformance side, and we 
encourage the development and availability of a variety of 
conformance approaches to evaluate to a common standard.

We also appreciate attention to user interface issues in 
particular.  We look forward to sharing additional progress on the 
User Agent Accessibility Guidelines 2.0, a draft which has also 
progressed at W3C during this time, particularly in areas such as 
support for keyboard accessibility.  We look forward to improvements 
in some of these areas.

Again, I would like to sincerely thank the US Access Board for this 
opportunity to make preliminary comments on the ANPRM and we will 
provide more detailed comments in writing, thank you.
Received on Friday, 18 June 2010 21:26:28 GMT

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