Re: Costs of testing with Silver

Supporting legislation and policy is not the purpose of accessibility
guidelines. People are.


Amen Charles, except...

No matter where we collectively "draw the line", it's going to fall
somewhere at less than 100% accessible - that's just a reality we need to
accept: accessibility is a long-tail problem that ends at the individual,
and no standard or guideline will include every user on earth. That's
simply reality colliding with pragmatism.

No matter the model, once legislations grab hold of the model there will be
a bright and shiny line between "pass" and "fail", even though collectively
we know that accessibility is far more nuanced than that.

My concern is that a "simple" accessibility test (i.e., low cost/no cost)
will be a bit of a paper dragon: checking of tick boxes in pursuit of some
kind of truncated solution just feels wrong to me, as entities that choose
that route aren't really concerned about PwD, they are instead concerned
about not being sued. *Reaching for the lowest common denominator just
feels wrong, as it positions web accessibility not for its benefits, but
rather its liabilities.*

I fully support free resources that help developers and content creators
"do better", and automated tests and other heuristic checks have their
place, but to create a "benchmark" based simply on free automated tests is
going to fail PwD as often as it benefits, with the added 'burden' of
falsely suggesting that because the "ACME Widget Web Site" passed all the
automated tests, it's "blessed" as somehow being accessible.

The problem isn't testing, its education.

I've long held that one of the problems with WCAG today is that most people
focus almost exclusively on the actual SC, and not on the Principles and
Guidelines. A renewed focus on the understanding piece, as opposed to
measuring compliance to specific checkpoints, is to me the more critical
piece. Silver should be focused on that, and it appears to be in many ways
(the desire/need for more "human readable" content is, I argue, an example
of the direct backlash we see/feel on focusing on the SC's and not the
reason behind the SC's, which results in folks struggling to decipher the
text of the SC's and the perception that this is "hard").

Can individual checkpoints be created in such a way that auto or
programmatic testing can speed progress? I would hope so, and would support
that goal.

But to establish a metric that suggested that a certain level of compliance
could be "claimed" based solely on auto-testing would be something I would
strenuously protest as being far too little, and feels very retrograde to
me: we moved off of WCAG 1.0 for solid reasons (including the very fact
that you could meet each of the WCAG 1.0 "tick-boxes" and still have a very
inaccessible web page/site). Returning to a model that repeats some of the
problems from the past is going backward IMHO, and I continue to fail to
see how it benefits anyone except entities and sites that want to appear to
be doing something, yet aren't prepared to do the hard miles required. It's
like saying "I want to see all the iconic stops along US Route 66
<https://www.theroute-66.com/state.html>, but I don't want to spend all
that time driving..." It's completely missing the bigger point.

JF

On Wed, Sep 5, 2018 at 8:27 AM, Hall, Charles (DET-MRM) <
Charles.Hall@mrm-mccann.com> wrote:

> I wonder if we can restart this conversation with a mission or goal in
> mind.
>
>
>
> Instead of discussing cost of procurement, cost of testing, cost of
> remediation or any other associated cost generally associated with a
> business, can we acknowledge the cost to people without access?
>
> Accessibility guidelines are a method to aid in ensuring people can access
> the web.
>
>
>
> The entire and only two reasons that any public policy or legislation
> (anywhere in the world) has ever specifically cited the WCAG x.x is because
> it was the most comprehensive guidance currently available at the time the
> legislation was considered AND that guidance was published by the W3C as a
> recommendation which is considered a web standard.
>
>
>
> The only reason that any said legislation cites a compliance or
> conformance requirement is because a strict and explicit conformance is
> part of WCAG.
>
>
>
> Any new guidance that is also comprehensive and a recommendation
> (standard) would supersede the previous guidance when drafting any new
> policy or legislation. The only constant is change.
>
>
>
> Supporting legislation and policy is not the purpose of accessibility
> guidelines. People are.
>
>
>
> If starting from scratch, but using everything we have collectively
> learned from research and experience:
>
>
>
> Can we create new guidelines that support (more) people and solve all (or
> most of) the problems that research revealed within the current guidelines?
>
>
>
> Can we create a conformance model that is not strict and explicit to
> technical details, but is to human factors?
>
>
>
> Can we do that while also considering the impact on (all) stakeholders?
>
>
>
>
>
> *Charles Hall* // UX Architect, Technology
>
>
>
> charles.hall@mrm-mccann.com
> <charles.hall@mrm-mccann.com?subject=Note%20From%20Signature>
>
> w 248.203.8723
>
> m 248.225.8179
>
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>
>
> mrm-mccann.com <https://www.mrm-mccann.com/>
>
>
>
> [image: MRM//McCann]
>
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>
>
>
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>
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>
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>
> *From: *Mark Tanner <mktanner@btinternet.com>
> *Date: *Wednesday, September 5, 2018 at 7:49 AM
> *To: *Silver Task Force <public-silver@w3.org>
> *Subject: *Re: [EXTERNAL] Costs of testing with Silver
> *Resent-From: *Silver Task Force <public-silver@w3.org>
> *Resent-Date: *Wednesday, September 5, 2018 at 7:48 AM
>
>
>
> I am writing to support and slightly expand upon the points made by John.
> WCAG 2.0 is currently referenced throughout the EU as a key component of
> digital accessibility legislation.
>
> As John pointed out, the EU standard EN 301 549 lays out "Accessibility
> requirements suitable for public procurement of ICT products and services
> in Europe" http://mandate376.standards.eu/standard
>
> This standard not only references WCAG 2.0 as normative, but specifically
> details all the WCAG 2.0 success criteria at reasonable length
> http://mandate376.standards.eu/standard/technical-requirements/#9
>
> However, as from 23 September, 2018, the standard has a wider application
> beyond procurement.  EU DIRECTIVE  2016/2102 on digital accessibility
> https://eur-lex.europa.eu/eli/dir/2016/2102/oj , which comes into legal
> effect in all EU countries (including the UK) requires that:
>
> ·       Public sector websites created *after *23 September 2018 need to
> comply with the accessibility requirements from 23 September 2019
>
> ·       Public sector websites created *before* 23 September 2018 need to
> comply with the accessibility requirements from 23 September 2020
>
> ·       Public sector mobile applications  need to comply with the
> accessibility  requirements from 23 June 2021.
>
> Paragraphs 36 and 37 of EU DIRECTIVE  2016/2102 are clear:
>
> “36. The accessibility requirements set out in this Directive … describe
> what must be achieved in order for the user to be able to perceive,
> operate, interpret and understand a website, a mobile application and
> related content …
>
> “37 … Those principles of accessibility are translated into testable
> success criteria, such as those forming the basis of the European standard
> EN 301 549 V1.1.2  ….Pending publication of the references to harmonised
> standards, or of parts thereof, in the Official Journal of the European
> Union, the relevant clauses of European standard EN 301 549 V1.1.2
> (2015-04) should be considered as the minimum means of putting those
> principles into practice.”
>
> As EN 301 549 currently uses WCAG 2.0 as its normative reference for all
> public sector websites this means that all public sector websites and
> applications throughout all EU countries will need to meet WCAG 2.0.
>
> It is also important to note that EN 301 549 is currently being updated to
> map to WCAG 2.1 to level AA). See *Explanatory Memorandum To The Public
> Sector Bodies (Websites And Mobile Applications) Accessibility Regulations
> 2018 No. 852 *http://www.legislation.gov.uk/uksi/2018/852/pdfs/uksiem_
> 20180852_en.pdf
>
> All this clearly has important implications for any shift in the future
> from WCAG to Silver.
>
> Mark Tanner
>
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-- 
*John Foliot* | Principal Accessibility Strategist

Deque Systems - Accessibility for Good

deque.com