- From: <thatch@us.ibm.com>
- Date: Mon, 19 Jul 1999 15:24:53 -0500
- To: Jason White <jasonw@ariel.ucs.unimelb.edu.au>
- cc: Web Content Accessibility Guidelines <w3c-wai-gl@w3.org>
Jason White asserted: "So far, no concrete evidence has been presented in this forum or the interest group, to indicate that the guidelines are being used inappropriately, or unthinkingly, by governments. All allegations to the contrary which have appeared in recent discussions have been based on unconfirmed surmise and reactionary speculation, hardly amounting to the kind of factual detail which should be taken seriously." The counter example to this sweeping statement is the Electronic and Information Technology Access Advisory Committee, EITAAC, which has been mentioned several times on these pages. EITACC, of which I was vice-chair, has recommended that the Federal Government require Double-A conformance for Federal procurement, for Web content, for User Agents, and for Authoring tools. There is a strong sense that that decision was "unthinking," since the latter two sets of checkpoints were still in early draft. This is only a recommendation today, but if history serves, it is likely to be law. At the time when we (EITAAC) made that decision, I did not realize how many of the Priority 1 and 2 checkpoints I personally have a difficult time supporting as requirements. As a simple example, I support using ABBR element as a guideline, but not as a requirement. I see this problem in IBM. We would like to be Double-A conformance but we cannot "require" of Web development, additional the work effort and time with no clear and direct benefit. There is clear and direct benefit from alt-text and from not using server-side maps. For example again, there is no significant direct benefit in not using tables for formatting. I agree with Rob; we must look at the guidelines as requirements. People will use them as requirements. EITAAC, the states and large companies will look to W3C and the Web Accessibility Initiative for the expertise in what to do to make the web accessible. Those making the laws or company rules may not have that expertise and will assume that thorough and balanced discussion would yield the best guidance. I worry as I listen to the discussion here and other lists, that the balance is lacking. The Web professionals, the tool and agent developers just do not have/take the time to participate. Jim Thatcher IBM Special Needs Systems www.ibm.com/sns thatch@us.ibm.com (512)838-0432 Jason White <jasonw@ariel.ucs.unimelb.edu.au> on 07/19/99 12:04:40 AM To: Web Content Accessibility Guidelines <w3c-wai-gl@w3.org> cc: (bcc: James Thatcher/Austin/IBM) Subject: Re: Fw: Checkpoint 3.3 The guidelines simply provide access requirements and solutions at three levels of priority. The latter are defined on the basis of impact (namely the consequences for particular groups of users if the checkpoints are not satisfied). The conformance section attempts to regulate the types of "conformance claims" that can be recognised as valid. All decisions as to whether to implement the guidelines, to which level of conformance, how quickly, etc., are left to the users of the document, subject to applicable legal requirements that will vary from one jurisdiction to another. The WAI should not become involved in the complex legal and policy issues, the questions regarding anti-discrimination law, the availability of funding and resources, etc., which are inevitably involved in any attempt to regulate the accessibility of the web. Rather, the WAI should provide the best available technical advice, and in large measure the guidelines in their present form do so (subject to certain reservations in connection with cognitive disabilities). Perhaps future versions should carry a disclaimer to the effect that the guidelines ought not to be treated as legal requirements, though they may be taken into account in policy formulation in so far as they document the relevant access problems and amelioration strategies, and offer prioritised advice as to which technical issues should be addressed first (priority 1 checkpoints) and which can be introduced through a more evolutionary process (priority 2 and 3 checkpoints). Of course, there is no guarantee that satisfaction of the checkpoints at any level of priority, or any combination of the checkpoints at different priority levels, will satisfy the requirements of anti-discrimination laws in any jurisdiction, since these are often complaint-based and highly dependent on individual cases, with their concomitant factual scenarios. If governments wish to set web access standards, then by all means the guidelines can be taken into account, but there are numerous other issues that would also need to be considered, on which the WAI as a research/development/educational project is ill-equipped to advise (though some of its staff/volunteers/supporters/experts may be in a position to do so in respect of particular jurisdictions or circumstances). For example, the tests associated with any anti-discrimination law, the availability of funding/expertise/resources, the approach to web design which is taken in particular governmental institutions, etc., would all need to be considered in determining an appropriate time-frame and set of requirements. Likewise, any regulation of public web sites would also need to take account of all relevant factors in reaching an appropriate policy decision. Usually, these determinations involve consultation with interested parties, disability organisations, etc., at a regional or national level; but the central point is that policy development involves quite distinct considerations that are not addressed, and ought not to be addressed, in the Web Content Accessibility Guidelines. So far, no concrete evidence has been presented in this forum or the interest group, to indicate that the guidelines are being used inappropriately, or unthinkingly, by governments. All allegations to the contrary which have appeared in recent discussions have been based on unconfirmed surmise and reactionary speculation, hardly amounting to the kind of factual detail which should be taken seriously. A disclaimer of some kind would probably be useful as a means of avoiding inappropriate application of the guidelines document, but in formulating its criteria and technical recommendations, this working group should not move into the realm of policy making.
Received on Monday, 19 July 1999 20:45:20 UTC