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Re: Costs of testing with Silver

From: John Foliot <john.foliot@deque.com>
Date: Thu, 30 Aug 2018 11:33:12 -0500
Message-ID: <CAKdCpxwBLb6-YQP5cAT0+wp59iMc5vBuJGrA76nJs4-VceCgtQ@mail.gmail.com>
To: Alastair Campbell <acampbell@nomensa.com>
Cc: "Hall, Charles (DET-MRM)" <Charles.Hall@mrm-mccann.com>, "public-silver@w3.org" <public-silver@w3.org>
Like others, I've been lurking on this conversation. At this time, I have
to side primarily with Charles Hall and David Sloan.

Charles wrote:

I still contend that attempting to control or mitigate cost is both: not
the role, purpose or responsibility of the guideline; and not even possible
due to the extreme variability in operations, processes, scale, market,
proficiency, and thousands of other business variables.

As others have noted (and I've often repeated), at the W3C we create
technical standards and guidelines, not legislation.

While cost is a factor, and one we shouldn't completely ignore, I conclude
(along with Charles) that it should only matter in the context of us
recognizing that there is a cost, and not a factor that directs us in
establishing the new requirements (whatever they may look like). "Testing"
costs are but one cost - there is also the implementation cost (including
author lift), education cost, and ROI considerations that we all know
businesses DO track.

The bottom line is, everything costs something: making your site accessible
has a cost, and failing to do so also has a cost. Sometimes those costs are
harder for businesses to easily calculate, but they exist none-the-less. We
need only look back in history: had Target Department stores (one of the
earliest US-based accessibility lawsuits - circa 2008) remediated their
site back when they were being sued, it would have been simply the cost
(non-trivial that it was) of remediation. But they resisted, and ultimately
it cost them more when they settled the case:

   - The cost to m
   ake its website accessible to individuals with disabilities;
   - Pay
   $6 million to a "Damages Fund" which were directed to members of the
   class action suit;
   - Pay up to $15,000 of the costs of  NFB's costs per session for Target
   personnel accessibility design training.

As Silver evolves, do we need to remind people of this social and legal
aspect as well, or do we, as a technical standards organization, leave that
to others to calculate? And as Charles notes, that discussion can change
based on a number of factors, including scale, complexity and the size and
scope of the impacted business.

Additionally, Charles notes:

After re-reading the majority of this thread, it seems to be (mostly)
contingent upon and in response to the idea of levels of conformance –
particularly the model with Bronze, etc.

 This is simply an idea being prototyped – one of many.

A HUGE +1 to that. While the Bronze, Silver and Gold levels has some merit
and worthy of consideration, it has not been adopted as "the way forward"
has it? It's simply a discussion at this time AFAIK...

Finally Charles states:

I was unaware that ‘reasonable cost’ was a major factor in WCAG 2.x

As a very active participant in the 2.1 activity, I was also unaware of
this requirement, either formally or informally.

While many of us are holistically aware that cost is part of any
decision-making process, the charter by which WCAG 2.1 was developed
<https://www.w3.org/2017/01/ag-charter> is noticeably silent on cost, as
was the formal criteria for accepting new Success Criteria into WCAG 2.1
<https://www.w3.org/WAI/GL/wiki/WCAG_2.1_Success_Criteria>, and so
respectfully I am unsure where Alastair is coming up with this assertion.
As experienced professionals in this field, again, we understand that there
are costs involved, but cost was never a formal consideration during any of
our work (that I recall).

Testability was certainly a factor, and with testing also comes cost, but
again, I do not recall any conversations over the 18 months of WCAG 2.1
evolution where cost was a stand-alone discussion or adoption criteria for
any of the new 2.1 SC.


David writes:

I recognise the business logic of attaching costs to any additional
activity that Silver might introduce on top of current requirements of
WCAG, the tension between guidelines as educational tools and measurement
tools, and how this might impact on what Silver looks like. I think it’s an
important conversation to continue, but I’m concerned at the risk that this
conversation might lead to the perception that certain requirements that
would benefit specific disability groups are more likely to be rejected on
cost grounds.

This is spot on, and underscores and shares one of my other concerns:  that
certain disabilities will remain "left out", not due to our ability to
address their needs, but to do so has a "cost" that some organizations will
consider onerous.

We've heard these arguments for, quite literally, decades. The
protestations from businesses (and surprisingly religious institutions)
when the ADA was adopted in the US had all of the same characteristics: the
cost to business, the lost productivity, the levels of complexity,
etc. Wikipedia
documents the following

*The US Chamber of Commerce argued that the costs of the ADA would be
"enormous" and have "a disastrous impact on many small businesses
struggling to survive." The National Federation of Independent Businesses,
an organization that lobbies for small businesses, called the ADA "a
disaster for small business." Pro-business conservative commentators joined
in opposition, writing that the Americans with Disabilities Act was "an
expensive headache to millions" that would not necessarily improve the
lives of people with disabilities.*

Yet, 28 years later, the world is still spinning, and I will assert that
the ADA *HAS* improved the lives of people with disabilities. The cost of
ADA compliance in the physical built world is now "just part of the cost",
and through education and leadership, architectural firms are creating
blueprints and plans that meet the requirements outlined in the ADA, and
rarely is "cost" part of those discussions today. And while I suspect this
resources is in need of a dusting-off, the W3C provides examples of
businesses who saw significant increases in user engagement and overall
traffic when they adopted accessibility into their web sites:
https://www.w3.org/WAI/bcase/resources#cases - so we already have arguments
to counter the "cost" discussion when it comes up.

I'm fully in support of looking at means and methods of automating as much
of this testing as we can do - and at Deque, for us that includes automated
testing prior to content heading to QA. Keeping the idea of "ease of
testing" in mind as we go forward is important (and that ease, or lack
there-of) will certainly have a cost associated to it. But I also agree
Stein Erik Skotkjerra
, who wrote:

"...but clear and concise requirements that are testable,  - either by
qualitative or quantitative evaluation methods. For cost reduction
purposes, I personally believe that using technology for automated or
semi-automated, as well as tool assisted, evaluations should be a priority."

Bottom line: In the end, I simply want to be sure that "cost" is not the
tail that is wagging the dog.


On Thu, Aug 30, 2018 at 9:42 AM, Alastair Campbell <acampbell@nomensa.com>

> Hi Charles,
> > It has never been stated that Silver would {n} number of new or
> additional success criteria – only that it would simplify the language and
> format of the existing ones and establish a governance and contribution
> model that makes it easier to edit them, expire them and yes, add them.
> Point 2 in the design principles [1] is that it should “Support a
> measurement and conformance structure that can include guidance for a broad
> range of disabilities, including low vision *and cognitive accessibility
> needs*.”
> There is wide recognition that we struggle to include COGA requirements
> because they are difficult to fit into the WCAG 2.x structure.
> Therefore if we change that structure, partly to include those types of
> requirement, there will by definition be more requirements.
> We aren’t throwing away the current criteria, that will probably form the
> majority of Silver 1.0 in some way, but there isn’t much point in doing
> Silver unless it expands to cover more requirements.
> > there must be a model for determining cost as well as a definition of
> ‘reasonable’. If there is a majority opinion that practice should be
> continued, then perhaps that existing wording can be added to the prototype?
> Defining that sort of model could take until the heat death of the
> universe. 😉
> However, the working group (and this community I assume) includes lots of
> people who implement websites (or work closely with those who do) and would
> object to criteria that massively increase the time/cost.
> The best approach is to have well defined and available solutions to each
> requirement as historically defining a standard to solve problems hasn’t
> worked, the standard should follow the solutions.
> Cheers,
> -Alastair
> 1] https://w3c.github.io/silver/requirements/index.html#design_principles

*John Foliot* | Principal Accessibility Strategist

Deque Systems - Accessibility for Good

Received on Thursday, 30 August 2018 16:33:36 UTC

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