Re: Costs of testing with Silver

Hi Lisa,

I'm not sure where you are getting your research from, but I'm gong to
question that statement.

Perhaps Canadian provincial legislation might not reference WCAG directly
(such as AODA), but one of the key reasons for the way WCAG 2.1 was
structured and developed was to ensure it did NOT impact the Section 508
refresh (which maps directly back to WCAG), a point of significant concern
to more than one legal entity that commented early on the process.

E205 Electronic Content

E205.1 General. Electronic content shall comply with E205.

E205.2 Public Facing. Electronic content that is public facing shall
conform to the accessibility requirements specified in E205.4.


E205.4 Accessibility Standard. Electronic content shall conform to Level A
and Level AA Success Criteria and Conformance Requirements in WCAG 2.0
(incorporated by reference, see 702.10.1).

(source:
https://www.access-board.gov/guidelines-and-standards/communications-and-it/about-the-ict-refresh/final-rule/text-of-the-standards-and-guidelines#E205-content
)



Additionally, caution was also exercised to ensure our work did not
negatively impact the European Union's *EN 301 549 - Accessibility
requirements suitable for public procurement of ICT products and services
in Europe, - V1.1.2* which *normatively references WCAG*:

*Normative references*

The following referenced documents are necessary for the application of the
present document.


   1. ETSI ETS 300 381: "Telephony for hearing impaired people; Inductive
   coupling of telephone earphones to hearing aids".
   2. ETSI ES 200 381-1: "Telephony for hearing impaired people; Inductive
   coupling of telephone earphones to hearing aids Part 1: Fixed-line speech
   terminals".
   3. ETSI ES 200 381-2: "Telephony for hearing impaired people; Inductive
   coupling of telephone earphones to hearing aids; Part 2: Cellular speech
   terminals".
   4. *W3C Recommendation (11 December 2008)/ISO/IEC 40500:2012: "Web
   Content Accessibility Guidelines (WCAG) 2.0 ".*

(source: http://mandate376.standards.eu/standard/references)

This seems to contradict your assertion to some extent, for while these
recent legislations do not in fact re-publish WCAG 2.0, they both
normatively reference that Recommendation as *the* standard upon which
success or failure will be judged against (at least for web/digital
content).

A lot of time and effort has been applied towards international
harmonization of accessibility standards and laws, and I for one would be
quite surprised if that activity would be jettisoned in favor of a Tower of
Babel approach to legislated web accessibility.

JF

On Tue, Sep 4, 2018 at 2:53 PM, Lisa Snider <
lisa@accesschangeseverything.com> wrote:

> I will say again that laws are now not necessarily going to include
> specific standards in them, the trend is to take them out, and have them in
> a separate place, not in the law themselves. I can’t say any more than that
> until things are official in three laws I know about…
>
>
>
> This means that people may not use WCAG, or any other standards, or use a
> blending on them. So the cost theory may not even apply anymore, in terms
> of this discussion, because it becomes cost in general and not linked to
> any one standard
>
>
>
> Please keep that in mind when you go forward.
>
>
>
> Cheers
>
>
>
> Lisa
>
>
>
> Lisa Snider
>
> Senior Digital Accessibility Consultant & Trainer
>
> Access Changes Everything
>
> Web: www.accesschangeseverything.com
>
> Phone: (800) 208-1936
>
>
>
> *From: *Alastair Campbell <acampbell@nomensa.com>
> *Date: *Tuesday, September 4, 2018 at 8:57 AM
> *To: *"public-silver@w3.org" <public-silver@w3.org>
> *Subject: *Re: Costs of testing with Silver
> *Resent-From: *<public-silver@w3.org>
> *Resent-Date: *Tue, 04 Sep 2018 13:57:08 +0000
>
>
>
> Charles wrote
>
> > Conformance to accessibility guidelines is not a law. Accessibility is.
>
>
>
> That varies, several countries / regions use WCAG as part of their laws.
> E.g. Section 508 in the US, and Mandate 376 in the EU are both procurement
> laws that incorporate WCAG 2.
>
>
>
> The general law in the UK better fits your statement, although the
> guidelines become a reference point in cases.
>
>
>
> The upshot of that is that the guidelines should be legal-compatible. I.e.
> not driven by legal factors, but possible to use in policy / governance /
> legal cases. I don’t think they would have been as successful without that
> aspect.
>
>
>
>
>
> > Conformance criteria of WCAG 2.x are difficult according to all of the
> research conducted.
>
>
>
> I’m not sure if you mean implementing, testing or understanding here?
>
> There are things which are difficult such as covering certain
> user-requirements, and in understanding by non-technical audiences.
> However, assuming that people understand them I don’t think the research
> was saying they were difficult to implement or test, unless I missed
> something?
>
>
>
>
>
> > Silver is prototyping different methods of conformance that are less
> difficult.
>
>
>
> If “less difficult” means easier to understand and able to provide better
> coverage, yes. However, the criteria themselves may not be easier to
> implement or test.
>
>
>
>
>
> > Cost is not as important as results that support and improve those
> purposes.
>
>
>
> Indeed, but I would consider a ‘total cost of ownership’ model, i.e. what
> is the overall impact to all people with disabilities.
>
>
>
> To take extreme ends of the scale:
>
>    1. If all the criteria were easy to implement and test with minimal
>    overhead, we’d have fantastic take-up but terrible coverage. (Similar to
>    what automated testing provides now.)
>
>
>    2. If some of the criteria took a significant (>30%) proportion of
>    project budgets to implement/test, we could have good coverage and terrible
>    take-up. If it’s enough to prevent policy makers from choosing it as the
>    standard for public & private organisations, you’d have very little take-up.
>
>
>
> So I’d be very cautious about saying that any criteria would get in
> regardless of feasibility/cost.
>
>
>
> Where Silver has an opportunity to improve the situation is:
>
>    - Providing means of passing criteria that are not a simple yes/no
>    answers.
>    - Providing levels that can be applied differently by different
>    organisations.
>
>
>
> For example, some criteria might only be applicable to larger
> organisations (to be defined), or those aiming for a higher level of
> accessibility / inlusiveness. We can take the current WCAG 2.1 AA as a
> baseline and increase coverage in feasible ways with a new approach.
>
>
>
> Cheers,
>
>
>
> -Alastair
>



-- 
*John Foliot* | Principal Accessibility Strategist

Deque Systems - Accessibility for Good

deque.com