- From: John Foliot <john.foliot@deque.com>
- Date: Fri, 7 Oct 2016 14:55:25 -0500
- To: WCAG <w3c-wai-gl@w3.org>
- Cc: Andrew Kirkpatrick <akirkpat@adobe.com>, Katie Haritos-Shea <ryladog@gmail.com>, AlastairCampbell <acampbell@nomensa.com>, Laura Carlson <laura.lee.carlson@gmail.com>
- Message-ID: <CAKdCpxzrbFPoa=Dw8sL=CHAWJSk1XVVZNf5QKa8zNax-F2TCJA@mail.gmail.com>
> "...ensure that the voluntary guidelines are consistent, to the extent feasible and appropriate, with the technical and functional performance criteria included in the national and international accessibility standards identified by the commission as relevant to student use of post-secondary electronic instructional materials and related technologies..." Thanks for this Laura, it is more fact-based evidence that US Regulators *can* adapt and work with the speed by which technology moves, without waiting long periods of time between updates. It also echoes what Regulators in other countries such as Great Britain (this is the *WORLD* Wide Web Consortium after all) have adopted. My concern is that we are allowing fear to influence our decision making, and I personally believe that fear is unfounded. Jason wrote: > I think it’s a sufficiently attractive proposal that it should be tried in version 2.1 by initiating a schedule-based release process, however, with a review thereafter to decide whether to proceed with a further 2.x release or whether the remaining proposals should go directly into the next major revision. In effect, I favor postponing any decision about “agile” until the completion of WCAG 2.1. There are a few problems with this: First, if we only adopt "agile" for one cycle, then it isn't really agile, it's just another stop along the way of a waterfall process. Second, it will continue to apply pressure to the existing Task Forces and the Working Group as a whole to get "everything" ready and out the door in the 2.1 time-frame (target date: Q1 of 2018), which means that a) either we'll miss that date, or, b) to meet that date we'll need to leave some things (*LOTS* of things) on the cutting room floor. If one of our prime directives is "Solid and Stable" new Success Criteria, we simply do not have enough time to get them all done in the next year/18 months. Third, I've already heard a personal and heart-felt plea to ensure that sufficient resources are directed to assist the COGA Group "meet the deadline", which suggest to me that if we *DON'T* have a "second deadline" (and even a "third deadline") that this group (and possibly also LV) will next end up struggling with the "who we are leaving behind" argument, which will suck up time and resources, and once again become an acrimonious debate that will take us off task. However, if we have a clear road map that suggests that any SC that aren't quite mature enough for the first (dot) release, then, as Alastair notes, we continue on those remaining items for the next time-boxed release: the daily/weekly/monthly work of this Working Group will continue on in exactly the same fashion, except the Success Criteria we collectively feel are "done" can be released into the wild sooner rather than later, and developers and toolmakers can start to take them up (not because the HAVE to, but because they want to - which *HAS* to be a positive thing). This way however we can also have a high-level of assurance that 'missed' proposed Success Criteria from groups like COGA and LV don't get shunted aside until "the next thing, whenever it finally arrives (in a 3 to 5 year time-period, which may end up being a 5 to 8 year time-period)". > If it’s successful and yields general satisfaction, then the Working Group can request a new Charter either to complete Silver or to continue to develop Silver and (in parallel) to deliver a 2.2 version. That is essentially what the Charter is proposing now, and it is based (as far as I understand it) on feedback from both W3C staffers and senior AC and even AB representatives of the W3C that I and others heard at the TPAC meetings a few weeks ago. The whole point of signalling our longer-range intent within a shorter-timeline Charter is to advise the AC of our bigger plans, which those AC/AB reps that *I* spoke with at TPAC have indicated is a positive thing. The plan is essentially what you are suggesting (with the additional inclusion of a "calendar" of regular, metered updates), but since the Charter only would last 2 or 3 years (after which we'd need to re-state or adjust our vision), we're not bound to that beyond the life of the current Charter. If at the end of the next Charter (which we are discussing now) we realize we *HAVE* made a tactical error, we can shift gears then: if, on the other hand, it turns out that this new 'agile' process is meeting our needs, then the next round of re-Chartering (in 2020 or 2021) will be easier, as we will be continuing along the same path outlined today. There is another reality as well: this WG is *already* working on a parallel project/process (Silver), and that needs to be communicated in our re-chartering as well. If we don't do that, there is a real possibility that the holders of the purse-strings at the W3C (the AC) will ask this Working Group to move the Silver Project into an unfunded Community Group, which will make it even harder for us to continue with real progress on that front. This is a very real fear and possibility: one that I know *I* heard explicitly at TPAC, and one that I believe others in this Working Group did as well. For this reason I believe it is critical that the Charter clearly outline this fact as well. Finally, it's important (I think) to clearly understand what we (I?) are advocating for in the Charter: there are specific, measurable deliverables, and then there is another more conceptual, informational aspect which is this notion that we are signalling our intent to regular updates in a two-year cycle, whether that's a 2.2, or Silver, or something else entirely again. However, because that aspirational goal is actually for dates beyond the length of the current proposed Charter (2 or 3 years), we're not actually committing to delivering them as specific deliverables - it's just "our plan", and the plan addresses (in part) the fact that we wont get all of the proposed SC coming from the TFs today processed in time for the 2018 mandated deliverable (2.1). And so, when it comes time to recharter again (in 2020, or 2021), we'll have this foundation that states that one of the deliverable for that next charter will be more updates to the "guidance", whether that's a 2.2, or Silver... (but we can't say for sure now, because we don't know. But we *do* know there will be more SC coming forward as part of that charter, in keeping with the goal of regular 2-year updates). I personally think this is as close as we can get to having our cake and eating it too. Earlier, Gregg wrote: > The one thing to keep in mind though — is that a regulatory standard is completely different than a technical one. Which raises a fundamental question: is this group working on a regulatory standard or a technical standard? While I think most of us would suggest that there is a large part of both in the WCAG Standard, we need to remember that the World Wide Web Consortium is a global technical standards body, and not a regulatory body, and that is an important fact to remember. Matching the cadence of how the W3C is working today benefits us; attempting to work against the current W3C process can only end up frustrating our efforts within the member-funded W3C. When Gregg writes of "...review by the white house office of management and budget etc..." I have to personally wonder why our colleagues in countries like New Zealand (Jason Kiss), Japan (Makoto Ukei), Great Britain (Alastair Campbell), Canada (David MacDonald) and numerous others would care about what happens in Washington? And more importantly, why would we want to hold back good, solid, ready-to-use Success Criteria which benefits real people with real issues simply because of how US regulatory groups operate? (*Especially* since the evidence in front of us is that they cannot always move quickly enough to address our core constituents, if the Section 508 refresh is our bench-mark. I say that with no offense to the good and hard working and committed folks at the US Access Board, who I suspect share the same frustrations we do, but it *is* a fact to acknowledge). That said however, I think this is an important point to contemplate: are we writing WCAG.next for the regulators, or for the end users and content creators? Yes, Section 508 is important, but I also wryly note that the US Department of Justice is applying WCAG 2.0 in their efforts today (see also: https://www.justice.gov/opa/pr/justice-department-enters- settlement-agreement-peapod-ensure-peapod-grocery-delivery-website), and most global organizations on the web today understand that the web is indeed global: Google, Microsoft, Apple, Facebook... they've all adopted WCAG 2.0 as their standard (with no comment on how well they are meeting that standard) already. And anecdotal evidence suggests that these organizations and others are already looking beyond WCAG 2.0, and adding additional accessibility requirements internally within their respective orgs. - they aren't waiting for the US government to set the bar, they are setting it themselves. (Case in point? BBC's Mobile Accessibility Guidelines - http://www.bbc.co.uk/guidelines/futuremedia/accessibility/mobile). Asking the W3C membership to wait another 5-7 years before we catch-up to what the BBC produced 3 years ago is just a reason to *STOP* funding this Working Group, and let territorial "industries" set their own markers. I don't think we're at that point yet, but continued slow-to-creeping progress doesn't help us. When I look at how US laws and policy have impacted real accessibility on the web today, it's not Section 508, it's laws like the 21st Century Communications Act (web-based video captions FTW) and the ACAA (Aircraft Carriers Accessibility Act) which pushed airline websites to WCAG 2.0 *AND* started making self-serve kiosk more accessible. My take-away there is that smaller and focused efforts (even regulatory ones) move quicker, get adopted sooner, and have real impact today - not 5, 7, 10 years down the road. No, based on those indicators, and the quote that Laura provided at the top of this email, it seems US-based regulators can and do change, and we need to help them catch up to the 21st Century, and not coddle them into believing that 5-10-15 years between updates is normal and OK. That may seem harsh, but it is also realistic - I've said it already many times: I am more concerned about addressing the needs of our users than I am the regulators, and I will continue to (personally) stand behind that ideal. My hope is that the consensus position of this group collects around that ideal, and I make no apologies for advocating for that position. Cheers! JF On Fri, Oct 7, 2016 at 8:37 AM, Laura Carlson <laura.lee.carlson@gmail.com> wrote: > Hi Andrew and all, > > On 10/7/16, Andrew Kirkpatrick <akirkpat@adobe.com> wrote: > > I have been reaching out for additional information. I’ve reached out > the > > Access Board again (and have in the past, which I mentioned in the > meeting > > on Tuesday), I’ve also reached out to contacts in Canada, Australia, and > the > > EU, and have also spoken with Lainey Feingold. I expect that we will > have > > more information to discuss soon. > > > > I do urge people to bring facts to the discussion > > One fact that I am aware of is the Accessible Instructional Materials > in Higher Education (AIM-HE) Act [1] has been introduced in the U.S > Congress. > > Among the duties of the new commission are: > > "...develop and issue voluntary guidelines for accessible > postsecondary electronic instructional materials, and related > technologies..." > > It doesn't mention WCAG but it does say: > > "...ensure that the voluntary guidelines are consistent, to the extent > feasible and appropriate, with the technical and functional > performance criteria included in the national and international > accessibility standards identified by the commission as relevant to > student use of postsecondary electronic instructional materials and > related technologies..." > > The National Federation of the Blind (NFB), the Association of > American Publishers (AAP), the Software and Information Industry > Association (SIIA), the American Council on Education (ACE), EDUCAUSE > have all been involved. If you or anyone else have contacts in those > organizations, they may be able to provide more info. > > Kindest Regards, > Laura > > References: > [1] https://www.congress.gov/bill/114th-congress/house-bill/6122/text > Also: > https://er.educause.edu/blogs/2016/9/accessible-instructiona > l-materials-bill-introduced > > > -- > Laura L. Carlson > > -- John Foliot Principal Accessibility Strategist Deque Systems Inc. john.foliot@deque.com Advancing the mission of digital accessibility and inclusion
Received on Friday, 7 October 2016 19:55:57 UTC