Fwd: Comments on WCAG3

Hello,

Please forward these revised comments to the W3C as you suggested. I am 
attaching a .docx copy as a backup.

Comments on WCAG 3 by Robert G. Martinengo
1/30/21

With all due respect to the Silver working group, please just stop for a 
moment. I have been in the accessibility field for over twenty years and 
have come to understand that after a certain point, continued emphasis 
on accessibility as a separate topic only serves to further distance 
people with disability from the mainstream. The WCAG is at that point, 
and it's time to make a decision.

I reviewed the various posted materials on WCAG 3. The amount of time, 
effort, and care that went in to them is impressive, evident, and 
admirable. But as it stands, WCAG 3 is bound to fail to live up to the 
lofty goals set for it. This is not a prediction, but an observation 
based on experience.

The most important thing that needs to happen with WCAG is removing the 
words 'accessibility' and 'guidelines'. Replace them with something like 
'building codes': "...sets of regulations governing the design, 
construction, alteration and maintenance of structures. They specify the 
minimum requirements to adequately safeguard the health, safety and 
welfare of building occupants."
https://www.fema.gov/emergency-managers/risk-management/earthquake/seismic-building-codes 
<https://www.fema.gov/emergency-managers/risk-management/earthquake/seismic-building-codes> 


Adopting the building code model for the web is not just a matter of 
semantics – it's a seismic shift in the way accessibility is 
conceptualized. Not to overstretch parallels with construction, but if 
mark-up languages, scripts, style sheets, etc are the raw materials, web 
building codes are the specifications for how these parts can be 
assembled in to web sites and applications that safeguard access for all 
users (authoring tools and user agents fit nicely in to this framework 
as well). The main levels of web building codes should be 'personal', 
'commercial', and 'government'. The main point is, accessibility is 
woven into the codes, not as a separate topic but simply as the way 
things are done.

Here's some good news: if the W3C adopts this approach, all of the great 
resources and experience generated by WCAG, and the terrific research 
and work done on v.3 will definitely not go to waste. Instead, WCAG will 
become the backbone of the new web building codes, ensuring 
accessibility becomes fundamental to the web and second-nature to those 
who design, build, use, and pay for web sites and apps. There will still 
be specific testing criteria, just as there are for building codes, but 
compliance with web building codes will be more holistic than testing 
for accessibility alone.

On the surface, it's a classic Catch-22: the only way to achieve 
sustainable accessibility is to stop talking about accessibility. Yes, 
there will be plenty of challenges transitioning from accessibility 
guidelines to web building codes, but the difference is between 
continuing to head down a dead end road, versus merging with the 
mainstream freeway of web development to ensure that people with 
disabilities will be in the front seat.

Thanks for your time, and I'm happy to respond to any comments or questions.
Robert G. Martinengo
rmartinengo@gmail.com <mailto:rmartinengo@gmail.com>

On Thu, Jan 28, 2021 at 7:30 AM Jeanne Spellman 
<jspellman@spellmanconsulting.com 
<mailto:jspellman@spellmanconsulting.com>> wrote:

    Hi Bob,

    Thank you for taking the time to write and forward your LinkedIn
    comments.  I don't follow LinkedIn (there are only so many
    information firehoses I can follow), so I appreciate you forwarding
    your comments to us.

    May we post forward them to our comments email list so there will be
    a W3C record of your comment?  It means that it will be discussed
    with other comments that come through the formal channels, but it
    does make it public and searchable. I won't forward it until I have
    your permission.

    jeanne


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