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The permissible uses of heading levels and F43

From: <noreply@w3.org>
Date: Fri, 04 May 2012 23:11:20 +0000
Message-Id: <E1SQRei-0005Lg-Rk@crusher.w3.org>
To: public-comments-wcag20@w3.org
Name: Duff Johnson
Email: djohnson@commonlook.com
Affiliation: NetCentric Technologies
Document: W2
Item Number: Success Criterion 1.3.1
Part of Item: 
Comment Type: general comment
Summary of Issue: The permissible uses of heading levels and F43
Comment (Including rationale for any proposed change):
I am trying to reconcile the fact of F43 with a common (but by not means general) impression that SC 1.3.1 does not require logical hierarchy in headings.

Success Criterion 1.3.1 requires that if headings are in the content that relationships are conveyed programmatically.

Now, illogical heading hierarchy does not, as has often been claimed, leave “equivalent information” available to everyone.

This claim rests on the incorrect assumption that every user will find a given structural anomaly disconcerting (or not) to a similar degree. This is obviously not the case as WAI is, I know, aware. Page-position alone can provide information that effectively removes an "important" but non-structural "structure" element from the sighted user's perception of the content's organization.

Instead, the reality is that users who depend on heading structure for navigation receive a substantially less effective navigation facility when the structure model is abused for presentational purposes.

The whole point of 1.3.1 is to eliminate practices that reliably botch the conveyance of “information, structure and relationships” to the user by way of normatively requiring “programmatic determinability”. Elegant! I applaud F43. It embodies 1.3.1 precisely because it fails the misuse of structure elements.

Now, there is – of course – a big variable in impact based on the nature of the content. This issue matters a lot less on short (typical web-page) content with few headings. On longer or highly structured content it is entirely fair to state that misuse of section headings for emphasis or styling kills the utility of headings as a reliable means of navigation for those who depend on structure to operate their AT.

When it doubt the reading of the normative text should err towards the side of accessibility rather than its opposite.

I’m not suggesting that headings must be used – that’s absurd. I am suggesting that IF headings are used to structure content (ie, to serve the “section heading” role), then they must make sense to pass 1.3.1. 

In any event, we are attempting to implement F43. It seems clear that F43 suggests that we fail content with illogical heading levels unless some other “programmatically determinable” means is provided to discern the “real” headings from the other “uses” of <H#> tags. Whatever that could be.

I have discussed this precise question with at least two-dozen experts in ICT accessibility over the past four months and have received almost the same number of opinions. ☹

In the use-cases of MY great interest – longer and structured documents – the significant majority of experts I consulted preferred to consider valid heading structure as normatively required, even if they were not sure whether or not WCAG 2.0 required it.

Proposed Change:
I think the Committee should rectify the (apparent) delta between F43 and the otherwise-stated view that “WCAG does not require strict hierarchy in headings”, including as 'represented' in H42, example 2.

Further, I think the Committee should consider that very significant use-cases exist in which 1.3.1 becomes substantially meaningless if it is NOT understood to require logically structured headings.

I believe it's a lot easier to write Techniques for 1.3.1 if one takes this view, and far easier to implement as well. More to the point, the quality and accessibility of content will improve at every level.
Received on Friday, 4 May 2012 23:11:24 UTC

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