Re: UNS: RE: UNS: WCAG considering amending F65 to NOT fail missing ALT text if title or aria-label is present

Hello All,
Can anyone explain the technical basis for recognizing aria-labelledby or title as  suitable attributes for rendering short text alternative for images that are not UIE?
The accessible name  (and text alternative) computation  logic in ARIA specs [1] is meant only for user interface elements.
And to ensure this and prevent rist of over / mis-interpretation, the ARIA specs defined the term 'accessible name'  in the context of the ARIA specs [2]. So elements (including plain images) that are not UIE is out of scope of ARIA specs.
Aria-labelledby / aria-label applies to UIE only, not plain images. So  the accessible name / text alternative computation  logic in the ARIA specs is inapplicable to elements that are not UIE.
- Aria attributes do not help users who do not use AT but yet need  text labels to identify images.  
- When aria-labelledby is used to label an image and the image also has a non-empty alt (to ensure code is valid), there is a big ristk that the alt is different from aria-labelledby referenced text. This will distort how different group of users identifies the image.
So when one uses ARIA for purposes it is clearly not  intended to be used (as per the Intro to ARIA), it is a big big dis-service  to accessibility.
This impacts accessibility for real users with disabilities who depend on text identifiers for images as suggested by 
Ramón Corominas in another response. 
So I suggest 
I. there should be no change to F65  as documented currently.
ii. there should be no ARIA technique promoting the use of aria-labelledby or aria-label on non-UIE elements including images. 

Thanks,
Sailesh Panchang
Reference:
[1] Text alternative computation    at
http://www.w3.org/TR/wai-aria/roles#textalternativecomputation
[2] Definition of Accessible name:
http://www.w3.org/TR/wai-aria/terms#def_accessible_name


--------------------------------------------
On Mon, 11/25/13, Steve Faulkner <faulkner.steve@gmail.com> wrote:

 Subject: Re: UNS: RE: UNS: WCAG considering amending F65 to NOT fail missing  ALT text if title or aria-label is present
 To: "David MacDonald" <david100@sympatico.ca>, "Steve Faulkner" <faulkner.steve@gmail.com>, "HTML Accessibility Task Force" <public-html-a11y@w3.org>, "WCAG WG" <w3c-wai-gl@w3.org>, kirsten@can-adapt.com
 Date: Monday, November 25, 2013, 5:05 AM
 
 This http://www.w3.org/html/wg/wiki/ChangeProposals/ImgElement20100504
 is a useful detailed account of the various arguments for
 keeping a strict requirement on alt in HTML (for
 accessibility reasons).
 
 
 
 --
 
 Regards
 
 SteveF
 HTML
 5.1
 
 
 
 
 
 On 25 November 2013
 08:31, Steve Faulkner <faulkner.steve@gmail.com>
 wrote:
 
 
 Hi Janina,
 I accept
 there's a technicality here regarding HTML
 
 
 
 validation that
 makes no judgement whatsoever about
 accessibility.
 Accessibility advocates argued for 5+ years
 in the html wg against the loosening of the requirements on
 alt in HTML. It was all about accessibility.
 
 
 
 --
 
 Regards
 
 SteveF
 HTML
 5.1
 
 
 
 
 
 
 On 25 November 2013 01:58,
 Janina Sajka <janina@rednote.net>
 wrote:
 
 
 
 I don't believe your analysis is correct. These are not
 the opposing
 
 viewpoints. They address separate concerns. While I
 don't claim to
 
 fully understand what the HTML-WG means by "layering
 violations," or why those
 
 are a concern, I accept there's a technicality here
 regarding HTML
 
 validation that makes no judgement whatsoever about
 accessibility.
 
 
 
 Perhaps you and others may have been perplexed by James
 Craig response
 
 to your first posting on this topic this past Friday? His
 was the first
 
 response to your post, and basically says the same as I
 understand what
 
 he wrote:
 
 
 
 http://lists.w3.org/Archives/Public/public-html-a11y/2013Nov/0053.html
 
 
 
 PS: The 2009 WAI Guidance document was not a product of the
 HTML-A11Y
 
 Task Force as that TF had not yet been created. The document
 came from a
 
 special TF that was formed to address the specific question
 of what HTML
 
 should do regarding alternative text, short and long. The TF
 in which
 
 both you and I participate today was formed later in 2009.
 The TF that
 
 created the document cited disbanded once the document was
 accepted by
 
 the several WAI working groups and published.
 
 
 
 Janina
 
 
 
 David MacDonald writes:
 
 > I have no desire to open an old debate.  But unless
 I’ve missed something HTML5 A11y TF 2009 resolution and a
 2013 A11Y bug response seem to be in conflict....
 
 >
 
 >  http://www.w3.org/2009/06/Text-Alternatives-in-HTML5.html
 
 >
 
 > allows aria-labelledby as secondary...
 
 >
 
 >
 
 >
 
 > A bug against HTML5 seems to have the A11Y TF taking
 the opposite position. Unless I’ve missed something.
 
 >
 
 >  <https://www.w3.org/Bugs/Public/show_bug.cgi?id=6496>
 https://www.w3.org/Bugs/Public/show_bug.cgi?id=6496
 
 
 
 
 >
 
 >
 
 >
 
 > I am willing to go back to WCAG with either response
 ... I just want to know where the task force is ... if it is
 not important to the TF, I can go back with that also.
 
 >
 
 >
 
 >
 
 > If possible I would like WCAG and HTML5 to be
 consistent with each other.
 
 >
 
 >
 
 >
 
 > Cheers,
 
 >
 
 > David MacDonald
 
 >
 
 >
 
 >
 
 > CanAdapt Solutions Inc.
 
 >
 
 > Tel:  613.235.4902
 
 >
 
 >  <http://ca.linkedin.com/in/davidmacdonald100>
 http://ca.linkedin.com/in/davidmacdonald100
 
 
 
 
 >
 
 >  <http://www.can-adapt.com/>
 www.Can-Adapt.com
 
 >
 
 >
 
 >
 
 >   Adapting the web to all users
 
 >
 
 >             Including those with disabilities
 
 >
 
 >
 
 >
 
 > This e-mail originates from CanAdapt Solutions Inc. Any
 distribution, use or copying of this e-mail or the
 information it contains by other than the intended
 recipient(s) is unauthorized. If you are not the intended
 recipient, please notify me at the telephone number shown
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 >
 
 >
 
 > Le présent courriel a été expédié par CanAdapt
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 copies. Je vous remercie de votre collaboration.
 
 
 
 
 >
 
 >
 
 >
 
 > From: Sailesh Panchang [mailto:spanchang02@yahoo.com]
 
 > Sent: November 24, 2013 10:23 AM
 
 > To: Steve Faulkner
 
 > Cc: HTML Accessibility Task Force; WCAG WG; public-comments-wcag20@w3.org;
 Gregg Vanderheiden; Janina Sajka
 
 > Subject: Re: UNS: WCAG considering amending F65 to NOT
 fail missing ALT text if title or aria-label is present
 
 >
 
 >
 
 >
 
 > Hello Steve, I'm saying I disagree with the use of
 ARIA  for plain  images that are not user Interface
 elementsHello Steve, I'm saying I disagree with the use
 of ARIA  for plain  images that are not user Interface
 elements
 
 
 
 
 >
 
 > Sailesh---
 
 >
 
 > Sent from my iPad ... Please pardon
 "dictapos" and typos ... <grin>
 
 >
 
 >
 
 > On Nov 24, 2013, at 5:15 AM, Steve Faulkner <faulkner.steve@gmail.com>
 wrote:
 
 >
 
 > Hi sailesh,
 
 >
 
 > what are you saying here?
 
 >
 
 > that you disagree with making it OK to use aria-label
 etc in place of alt on an image?
 
 > http://lists.w3.org/Archives/Public/public-html-a11y/2013Nov/0052.html
 
 >
 
 > if so then we are in aggreement
 
 >
 
 >
 
 >
 
 >
 
 > --
 
 >
 
 > Regards
 
 >
 
 > SteveF
 
 >
 
 > HTML 5.1 <http://www.w3.org/html/wg/drafts/html/master/>
 
 >
 
 >
 
 >
 
 > On 24 November 2013 03:08, Sailesh Panchang <spanchang02@yahoo.com>
 wrote:
 
 >
 
 > Hello Steve,
 
 >
 
 > 1. Some advance the text alternative computation logic
 in the ARIA specs as the chief motivation for attributes
 other than the alt for images, specifically the
 aria-labelledby and title.
 
 > I find it difficult to accept that viewpoint for
  reasons noted  in my post:
 
 > http://lists.w3.org/Archives/Public/w3c-wai-gl/2013OctDec/0115.html
 
 >
 
 > 2. As one might expect, developers rely on automated
 validation checkers to validate pages  as suggested by
 techniques G134, H88 to ensure compliance with SC 4.1.1
 (A).
 
 > While only a subset of validation rules apply for this
 SC, most developers will not be able to or do not have
 bandwidth to do the fine tuning as required for this SC and
 will simply aim for full validation as the intent to the SC
 suggests that content which is 'created according to the
 rules defined in the formal grammar for that technology'
 is a good thing to ensure interoperability and robust
 browser/AT support.
 
 
 
 
 > So now if one says 'disregard validation errors for
 absence of alt attribute, confusion will be rife.
 
 > Usefulness of the validation checkers too will be
 questioned.
 
 > Above all, it is not good for the WG to say'it is
 fine if one introduces certain types of validation issues
 into the code'.
 
 >
 
 > Thanks and regards,
 
 >
 
 > Sailesh Panchang
 
 >
 
 > --------------------------------------------
 
 >
 
 > On Sat, 11/23/13, Steve Faulkner <faulkner.steve@gmail.com>
 wrote:
 
 >
 
 >  Subject: Re: UNS: WCAG considering amending F65 to
 NOT fail missing ALT text  if title or aria-label is
 present
 
 >
 
 >  To: "David MacDonald" <david100@sympatico.ca>,
 "HTML Accessibility Task Force" <public-html-a11y@w3.org>,
 "WCAG WG" <w3c-wai-gl@w3.org>,
 public-comments-wcag20@w3.org,
 "Gregg Vanderheiden" <gv@trace.wisc.edu>,
 kirsten@can-adapt.com
 
 
 
 
 >  Date: Saturday, November 23, 2013, 3:39 AM
 
 >
 
 >
 
 >  Hi Janina,
 
 >  Over time and due to experience and understanding,
 consensus
 
 >  positions change. This document is a useful
 historical
 
 >  reference, but does not represent the current (lack
 of)
 
 >  consensus position on the issue.
 
 >
 
 >
 
 >
 
 >  --
 
 >
 
 >  Regards
 
 >
 
 >  SteveF
 
 >  HTML
 
 >  5.1
 
 >
 
 >
 
 >
 
 >
 
 >
 
 >  On 22 November 2013
 
 >  23:54, Janina Sajka <janina@rednote.net>
 
 >  wrote:
 
 >
 
 >
 
 >  David:
 
 >
 
 >
 
 >
 
 >  As a point of information, the wider WAI community
 has
 
 >  already expressed
 
 >
 
 >  a view on this. We did so back in 2009, after almost
 a year
 
 >  of teleconferences nd
 
 >
 
 >  email discussions by way of presenting a coherent
 approach
 
 >  to the
 
 >
 
 >  HTML-WG.
 
 >
 
 >
 
 >
 
 >  The document we produced is entitled, "WAI CG
 Consensus
 
 >  Resolutions on
 
 >
 
 >  Text alternatives in HTML 5," and is available
 at:
 
 >
 
 >
 
 >
 
 >  http://www.w3.org/2009/06/Text-Alternatives-in-HTML5.html
 
 >
 
 >
 
 >
 
 >  So, while it's always good to revisit old
 thinking, it
 
 >  should not be
 
 >
 
 >  forgotten that we've already covered this ground,
 and
 
 >  that we covered it
 
 >
 
 >  quite extensively.
 
 >
 
 >
 
 >
 
 >  Janina
 
 >
 
 >
 
 >
 
 >
 
 >
 
 >  David MacDonald writes:
 
 >
 
 >  > On behalf of the WCAG working group, I have an
 action
 
 >  item to solicit
 
 >
 
 >  > responses from the wider community regarding a
 proposed
 
 >  amendment to WCAG
 
 >
 
 >  > failure technique F65 regarding missing ALT.
 Currently;
 
 >  if an <img> element
 
 >
 
 >  > is missing from an ALT attribute the page fails
 WCAG SC
 
 >  1.1.1 Level A. Some
 
 >
 
 >  > are proposing that we allow authors to use the
 
 >  aria-label, aria-labelledby,
 
 >
 
 >  > and title attributes INSTEAD of ALT.
 
 >
 
 >  >
 
 >
 
 >  > So under the amended failure technique NONE of
 the
 
 >  following would fail
 
 >
 
 >  > WCAG:
 
 >
 
 >  >
 
 >
 
 >  > <img src="../images/giraffe.jpg"
 
 >  title="Giraffe grazing on tree
 branches"/>
 
 >
 
 >  >
 
 >
 
 >  > <img src="../images/giraffe.jpg"
 
 >  aria-label="Giraffe grazing on tree
 
 >
 
 >  > branches"/>
 
 >
 
 >  >
 
 >
 
 >  > <img src="../images/giraffe.jpg"
 
 >  aria-labelledby="123"/>
 
 >
 
 >  > <p id="123"> Giraffe grazing on
 tree
 
 >  branches</p>
 
 >
 
 >  >
 
 >
 
 >  > As you can imagine there are strong opinions all
 around
 
 >  on this so I
 
 >
 
 >  > suggested we get a sense of what other groups
 such as
 
 >  the HTML5 A11y TF and
 
 >
 
 >  > PF think.
 
 >
 
 >  >
 
 >
 
 >  > Those in favour of the change provide the
 following
 
 >  rational:
 
 >
 
 >  >
 
 >
 
 >  > --These alternatives on the img element work in
 
 >  assistive technology
 
 >
 
 >  > --The aria spec says these attributes should get
 an
 
 >  accessible NAME in the
 
 >
 
 >  > API
 
 >
 
 >  > http://www.w3.org/TR/wai-aria/roles#textalternativecomputation
 
 >
 
 >  > --They say it's easy to teach beginner
 programmers
 
 >  to just always use an
 
 >
 
 >  > aria label on everything, rather than requiring
 a label
 
 >  on form fields and
 
 >
 
 >  > alt on images
 
 >
 
 >  > --They feel as a failure F65 is very strong if
 fails a
 
 >  page for missing ALT,
 
 >
 
 >  > especially if other things work, and they would
 like to
 
 >  soften it to allow
 
 >
 
 >  > other things that work.
 
 >
 
 >  > --html 5 allows a <figure><legend>
 
 >  combination instead of alt, so they feel
 
 >
 
 >  > WCAG will have to change F65 anyway to allow a
 figure
 
 >  with a legend, and
 
 >
 
 >  > that helps open the door to this discussion
 
 >
 
 >  >
 
 >
 
 >  > Those in favour of the status quo (which fails
 missing
 
 >  alt text) provide the
 
 >
 
 >  > following rational:
 
 >
 
 >  >
 
 >
 
 >  > --aria-label, labelledby and title, are not
 really
 
 >  suitable attributes for
 
 >
 
 >  > img alternative text because they implies a
 label or
 
 >  title, rather than an
 
 >
 
 >  > alternate text, so it is not a semantic
 equivalent
 
 >
 
 >  > --title is not well supported
 
 >
 
 >  > --some feel that the aria spec is not in any
 way
 
 >  suggesting these as
 
 >
 
 >  > replacements to ALT.
 
 >
 
 >  > --aria instructs authors to use native html
 where
 
 >  possible, and they could
 
 >
 
 >  > not come up with viable use cases of omitting
 alt text
 
 >
 
 >  > --there are hundreds of millions of dollars
 invested in
 
 >  current evaluation
 
 >
 
 >  > tools, and methodologies, and this would
 represent a
 
 >  major departure from
 
 >
 
 >  > one of the most basic accessibility convention,
 that is
 
 >  almost as old as the
 
 >
 
 >  > web and is the "rock star" of
 accessibility
 
 >
 
 >  > --it could cost a lot of money to change
 guidance to
 
 >  developers etc..., and
 
 >
 
 >  > muddy the waters on a very efficient current
 evaluation
 
 >  mechanism
 
 >
 
 >  > --when the figure/legend is supported by AT we
 can
 
 >  amend F65 but that is a
 
 >
 
 >  > different issue and the semantics of this
 construct are
 
 >  OK for text
 
 >
 
 >  > alternatives, rather than the
 label/labelledby/title
 
 >  options
 
 >
 
 >  > --it may cause some confidence problems to WCAG
 
 >  legislation, because it
 
 >
 
 >  > represents a strong loosening to a fundamental
 Success
 
 >  Criteria, an
 
 >
 
 >  > unnecessary change that doesn't help the
 cause of
 
 >  accessibility, but just
 
 >
 
 >  > complicates things
 
 >
 
 >  > --ALT is better supported and the text appears
 when
 
 >  images are turned off.
 
 >
 
 >  > --initial twitter feedback from the community
 is
 
 >  strongly against changing
 
 >
 
 >  > this failure
 
 >
 
 >  >
 
 >
 
 >  >
 
 >
 
 >  > There are probably other reasons on both sides
 which we
 
 >  hope to hear ... but
 
 >
 
 >  > these should start it off. Please give your
 opinions
 
 >  and reasons.
 
 >
 
 >  >
 
 >
 
 >  > Current technique here:
 
 >
 
 >  > http://www.w3.org/TR/WCAG-TECHS/F65.html
 
 >
 
 >  > Proposed failure here (see test procedure)
 
 >
 
 >  >
 
 >
 
 >  >
 
 >
 
 >  >
 
 >
 
 >  > Cheers,
 
 >
 
 >  > David MacDonald
 
 >
 
 >  >
 
 >
 
 >  > CanAdapt Solutions Inc.
 
 >
 
 >  > Tel:  613.235.4902
 
 >
 
 >  > http://ca.linkedin.com/in/davidmacdonald100
 
 >
 
 >  > www.Can-Adapt.com
 
 >
 
 >  >
 
 >
 
 >  >   Adapting the web to all users
 
 >
 
 >  >             Including those with
 
 >  disabilities
 
 >
 
 >  >
 
 >
 
 >  >
 
 >
 
 >
 
 >
 
 >  --
 
 >
 
 >
 
 >
 
 >  Janina Sajka,   Phone:  +1.443.300.2200
 <tel:%2B1.443.300.2200>
 
 >
 
 >                          sip:janina@asterisk.rednote.net
 <mailto:sip%3Ajanina@asterisk.rednote.net>
 
 
 
 
 >
 
 >                  Email:  janina@rednote.net
 
 >
 
 >
 
 >
 
 >  Linux Foundation Fellow
 
 >
 
 >  Executive Chair, Accessibility Workgroup:       http://a11y.org
 
 >
 
 >
 
 >
 
 >  The World Wide Web Consortium (W3C), Web
 Accessibility
 
 >  Initiative (WAI)
 
 >
 
 >  Chair,  Protocols & Formats     http://www.w3.org/wai/pf
 
 >
 
 >          Indie UI                      
  http://www.w3.org/WAI/IndieUI/
 
 >
 
 >
 
 >
 
 >
 
 >
 
 >
 
 >
 
 >
 
 >
 
 >
 
 >
 
 
 
 --
 
 
 
 Janina Sajka,   Phone:  +1.443.300.2200
 
                         sip:janina@asterisk.rednote.net
 
                 Email:  janina@rednote.net
 
 
 
 Linux Foundation Fellow
 
 Executive Chair, Accessibility Workgroup:       http://a11y.org
 
 
 
 The World Wide Web Consortium (W3C), Web Accessibility
 Initiative (WAI)
 
 Chair,  Protocols & Formats     http://www.w3.org/wai/pf
 
         Indie UI                        http://www.w3.org/WAI/IndieUI/
 
 
 
 
 
 
 
 

Received on Monday, 25 November 2013 17:11:46 UTC