RE: Silver Conformance Proposal (draft)

Thank you for circulating the draft. Some preliminary comments appear below.


  1.  There are some methods that surely must be implemented to achieve a minimum degree of accessibility within a functional performance category. For example, if I create a web site containing a video collection, but no captions are provided for the videos, then, arguably, I shouldn’t be able to satisfy the requirements of the “usage with no or limited hearing” category. If we subdivide the category (as in EN 301 549) into two functional performance requirements (viz., “usage with no hearing” and “usage with limited hearing”), then I shouldn’t be able to satisfy the former without providing captions for the videos. Ensuring that I must provide captions can be achieved within the proposed point system by setting the number of points associated with the method, and the minimum required threshold, appropriately. However, this would require careful work to ensure that there are no other ways of conforming without doing what is deemed essential for a minimum level of accessibility according to Silver.
  2.  How are inapplicable methods counted in the point system? If there is no audio content on my web site, then do I receive the full allocation of points for the hearing-related methods, or only for some of them? It makes sense that I should be able to conform in this scenario, of course, but it would be misleading to make claims about user testing, for example, within the “hearing” category.
  3.  Perhaps it would be better to separate “content” requirements from “process” or “assurance” requirements, such as the conformance evaluation methods used. In that case, the level of assurance would be reported separately from the points gained in each functional performance category.
  4.  In assigning points to methods, the proposal rightly suggests that the impact of implementing and not implementing the method on accessibility for the group of users affected is of fundamental significance. I think there should be a systematic process for determining “impact” through reviewing the research literature, user studies or other relatively rigorous means, relying only on opinion where better evidence is unavailable.
  5.  A clear consequence of the proposal is that there may be multiple ways of conforming by selectively implementing different subsets of the requirements, while exceeding the minimum point threshold. Although this has the advantage of flexibility, it is also cause for concern, as it opens the door to web content that nominally conforms without actually meeting the needs of users within one or more of the functional performance dimensions. This concern can be addressed by systematically ensuring that there’s no combination of methods such that they can be satisfied jointly to exceed the threshold, and they lead to “absurd” consequences from an accessibility perspective. While the proposal claims that any system can be “gamed”, some systems are more amenable to exploitation than others, and the possibility can be mitigated by careful design of the conformance requirements.

From: Jeanne Spellman <jspellman@spellmanconsulting.com>
Sent: Friday, January 4, 2019 3:13 PM
To: AG WG <w3c-wai-gl@w3.org>
Subject: Silver Conformance Proposal (draft)


The Silver Task Force and Community Group have been working on the Silver prototype on Conformance.  This has been a challenging task with a lot of moving parts that all have to work together.  We wanted to share our ideas in the Draft document we have been putting together with AGWG to get your feedback before any of the ideas are too "baked" that they become difficult to change.

We have highlighted or commented on alternate proposals, items that need more work, and areas where we don't have consensus yet.

Your comments are welcome.  You can comment in the Google Doc document itself (public comment permissions are turned on) or in this email thread.

Silver Conformance Proposal Draft<https://na01.safelinks.protection.outlook.com/?url=https%3A%2F%2Fdocs.google.com%2Fdocument%2Fd%2F1wTJme7ZhhtzyWBxI8oMXzl7i4QHW7aDHRYTKXKELPcY%2Fedit%23heading%3Dh.6oetdyu21wzd&data=02%7C01%7Cjjwhite%40ets.org%7Ccbcf6525c2f54aec2be708d672812b49%7C0ba6e9b760b34fae92f37e6ddd9e9b65%7C0%7C0%7C636822296438766956&sdata=x%2BmZzA17371Yg3lZDVgCqEy7oF0%2FXLHaA1ll8uiO6%2FA%3D&reserved=0>

Shawn and I will be attending an upcoming AGWG meeting to answer questions and to listen to your comments and ideas.

Jeanne Spellman
Shawn Lauriat

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