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Re: [Protocols] Agenda for April 22th, 2022

From: John Foliot <john@foliot.ca>
Date: Wed, 20 Apr 2022 12:20:17 -0400
Message-ID: <CAFmg2sXQtiwGbyw+YPGttZ_J6DXSow7tiYGVAKi-aegC+Q6AwQ@mail.gmail.com>
To: Michael Gower <michael.gower@ca.ibm.com>
Cc: Jaunita George <jaunita_george@navyfederal.org>, "public-silver@w3.org" <public-silver@w3.org>, "w3c-wai-gl@w3.org" <w3c-wai-gl@w3.org>, Benjamin Feigel <Benjamin_Feigel@navyfederal.org>
Hi Mike,
[Comments inline]

‘*by using only abbreviations on this common list*’

I suspect this will run headlong into internationalization issues very
And, with multiple and various subject-matter domains, a "common"
abbreviation (or acronym) to one group or community may be a complete
mystery to another. Or there may be instances where the abbreviation or
acronym has multiple meanings - for example the IAAP is *also* the
Association of Administrative Professionals <https://www.iaap-hq.org>. I'd
be concerned if we get too prescriptive here, which this seems to suggest.

'*by always using a spelled out version of the term in the first instance
on a page or group of pages followed by the abbreviation in parentheses*’

While I agree with this recommendation in principle, you are (IMHO)
introducing a severe bottleneck with that kind of phrasing and the
'absolutist' tone of the requirement - it is presented in MUST-like
language rather than SHOULD-like language, which will result in the same
problem at evaluation time.

If the content author does not *ALWAYS* use a spelled out version, what are
the consequences? Fewer 'points'? How/why? And how is that then evaluated
or measured at scale? Absolutist language - a.k.a. MUST language - will
(logically - at least to me) always resolve to either True or False, which,
at the highest levels, is the problem that Protocols is seeking to resolve
(at least in my mental model) - what to do when the real answer is neither
True or False, but far closer to "*...it depends*"? Protocols, by design,
would be far more flexible - the goal being that they help inform
decision-making in the most positive way, but at the same time recognizing
that ".*..it depend*s" is, and always will be, part of the mix.

To my mind, Protocols seek to solve the problems you point out via (what I
think of as) formally documented "scenario recommendations" (and they could
be applicable at both the micro and macro levels), which are the
instructions that would be given - here, to content authors - at creation
time, but without the need to have their output rigorously 'policed' with
MUST-like requirements, which simply re-introduces the subjectivity
concerns that I was hoping Protocols would address.

*Where those protocols are published, the methods could help anyone
evaluate the relative success of the outcome against the protocol.*

To date, as 'examples' we've been using plainlanguage.gov as our primary
straw-man example, which is a site owned and published by the US Government
(thus the .gov domain). I had wanted to also include "Making
Content...COGA" as an example as well, but for reasons that I personally do
not agree with, COGA has requested we not use that document at this time
(because they believe there remain requirements in that document that can
be 'measured' - but I don't see it myself). Additionally, I personally do
not see a Protocol with *some* measurability for some requirements as being
problematic: that document may have some additional sub-points that could
be measured, but Outcomes like "Help Users Understand What Things are and
How to Use Them
will always be a subjective determination.

FWIW, I've also always thought of the alt-text decision tree
<https://www.w3.org/WAI/tutorials/images/decision-tree/> as a rudimentary
Protocol - again, that guidance does not drive to a "measurable" outcome,
but it has been created/authored in such a way that using that "Protocol"
will significantly contribute to a "good" (better?) text alternative, based
simply on the guidance and instruction provided by that document. That to
me is the real value of a Protocol - it is the "steady coaching hand" that
helps content creators "get it right" (to the best of their ability - which
also presumes that over time their ability will improve with experience, as
in real life). And in that model, I am proposing we reward entities for
"trying", as opposed to penalizing them when they fail to meet a MUST-like
technical requirement.

(I say this while the Conformance Model is still very much under-developed,
but in principle, with the current Gold/Silver/Bronze proposal I see
'scoring' as being mostly a subtractive process, with Gold being "100%",
and Silver and Bronze being "less than 100%" - you lose 'points' when you
fail an ACT-style test, which seems to be the intent at this time, but...
all TBD.)

However, I am proposing that with Protocols, instead of losing points,
you *gain
*points for making the commitment of adopting the Protocol "formally" -
which is the accountability piece. For example, if IBM were to "formally"
adopt Plain Language as part of IBM's authoring practices, that would also
be introducing "institutional risk" to the company if IBM then failed to
follow through on that commitment.

So the "assertions" piece that was part of my larger proposal will be key
there, although I am not sure if everyone agrees that this kind of "risk"
is or will-be sufficient in a conformance model. It certainly does
anticipate a certain level of trust that, when an entity makes the
assertion, that they will actually follow through. But, just like VPATs
today, a certain amount of trust is required when it comes to
"self-certification", which to me is the only way this will truly scale.
(Does this leave open the door for "gaming" the score? Sure, but at the end
of the day if an entity wants to cheat, they are cheating themselves first
and foremost - and the public assertion piece potentially makes that
cheating a risky proposition in any regulatory scenario. Having spent a
fair bit of time consulting private industry, I know from my experience and
perspective that corporate lawyers tend to be risk-averse at the best of
times - that's what they get paid to do.)

But questions remain:

   - What constitutes a 'valid' Protocol, and where should that 'official'
   and valid protocol 'live'?
   - Who writes Protocols?
   - Can we reference 3rd-Party protocols hosted external to the W3C if
   it/they have been vetted by our group?
   - Do we envision a mechanism where 3rd-Party entities could
   introduce/propose additional Protocols (and how would we roll that up into
   our spec)?
   - Or should all Protocols be hosted 'normatively' by the W3C?

(I see pros and cons for all of these options, and/but the group has not
really tackled those questions yet, as we are still struggling with what
constitutes a Protocol and how we will be using them.)

However I also see these as process and policy questions we can tackle once
we have agreement on what a Protocol is and does in the context of WCAG 3.


---------- Forwarded message ---------
From: Michael Gower <michael.gower@ca.ibm.com>
Date: Wed, Apr 20, 2022 at 9:26 AM
Subject: RE: [Protocols] Agenda for April 22th, 2022
To: John Foliot <john@foliot.ca>, Jaunita George <
Cc: public-silver@w3.org <public-silver@w3.org>, w3c-wai-gl@w3.org <
w3c-wai-gl@w3.org>, Benjamin Feigel <Benjamin_Feigel@navyfederal.org>

I largely agree with what John is saying, especially from this point
onwards: “Protocols will not / should not "evaluate guidance" - *Protocols
*ARE* guidance* – “

But how I’ve thought of the, protocols *can* potentially encapsulate both
the guidance (‘minimize abbreviations’) and one or more adopted methods
(‘by using only abbreviations on this common list’ and ‘by always using a
spelled out version of the term in the first instance on a page or group of
pages followed by the abbreviation in parentheses’). Where those protocols
are published, the methods could help anyone evaluate the relative success
of the outcome against the protocol.

So perhaps that is what is meant by “evaluate guidance”? Now that you’re
holding protocols meetings and a later time on alternating weeks, I hope to
attend to better understand where the group is at.



*From: *John Foliot <john@foliot.ca>
*Date: *Tuesday, April 19, 2022 at 4:15 PM
*To: *Jaunita George <jaunita_george@navyfederal.org>
*Cc: *public-silver@w3.org <public-silver@w3.org>, w3c-wai-gl@w3.org <
w3c-wai-gl@w3.org>, Benjamin Feigel <Benjamin_Feigel@navyfederal.org>
*Subject: *[EXTERNAL] Re: [Protocols] Agenda for April 22th, 2022

Hi Juanita, You state that one view is: "Protocols are above or beyond any
type of conformance, aka “extra credit”" I do not remember the group
agreeing to that at all - and in fact I was slapped down for bringing up
conformance during ZjQcmQRYFpfptBannerStart

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Hi Juanita,

You state that one view is: "Protocols are above or beyond any type of
conformance, aka “extra credit”"

I do not remember the group agreeing to that at all - and in fact I was
slapped down for bringing up conformance during that call.

*JF:* I still feel strongly that is not reasonable for us to expect much
progress on protocol until we have better clarity with the WCAG3
conformance model...
… just too hard to know how to talk about protocol without metrics of
scoring and points.

*Rachael:* I hear you John, and this is something the chairs have discussed.

*JF:* It seems like a blocker to me.

*Jeanne:* Point noted, I would ask that you let us move on. (JF agrees.)

(source: https://www.w3.org/2022/04/15-wcag3-protocols-minutes.html)

(I note that according to the minutes
<https://www.w3.org/2022/04/19-ag-minutes.html>, the topic of the need for
a workable Conformance Model came up again on today's WCAG call, as well as
in the WBS survey for Charter Extension, with more than one person
commenting on how critical it is we start to address this gap. But I

I disagree in the strongest of terms that Protocols are "extra credit"

a) we do not yet have any idea what "credit" means in the context of
conformance, and

b) making Protocols "extra" in any context will likely serve to relegate
Protocols to the WCAG AAA Success Criteria pile - lovely to look at but
never really adopted at scale. I believe that would be a horrible end-state.

I personally do agree with a point made by Jeanne over the concern that
Protocols not be "too weighted" and that using Protocols not be a means to
game the final score in whatever conformance model we ultimately come up


Continuing on the broader point, I do not agree with either of the "views"
you presented here - and did not on Friday either, at least not as
articulated here.

While I strongly disagree with the 'second' view, I also disagree with how
you are characterizing the 'first view' - "Protocols can evaluate guidance
where the outcomes cannot be measured, such as evaluating whether a process
has been followed."

Protocols will not / should not "evaluate guidance" - *Protocols *ARE*
guidance* - guidance that then allows content creators to evaluate their
final outcomes when faced with a given scenario. The outcomes arrived at
(in context) cannot be 'measured' in any consistent way, but they can
be contrasted and compared to the published examples and expected outcomes
articulated in a Protocol, with the content creation goal being "G*et as
close to this expected outcome as we can in our context*".

So for example, when Plain Language <https://plainlanguage.gov> states "Choose
your words carefully <https://www.plainlanguage.gov/guidelines/words/>" and
then provides the following recommendations:

   - Use simple words and phrases
   - Avoid hidden verbs
   - Avoid noun strings
   - Avoid jargon
   - Minimize abbreviations
   - Minimize definitions
   - Use the same terms consistently
   - Place words carefully

...we cannot accurately or consistently "measure" the outcome, but we *CAN*
evaluate content against those recommendations: Protocols help inform

Example: One of the recommendations is 'minimize abbreviations' - which
again cannot be measured or counted, but most people will be able to get a
sense of whether there are "too many" abbreviations or not. But... how many
is "too many"? Protocols cannot answer that question, because the most
truthful answer is "it depends"... 10 abbreviations in 10 sentences *may*
be too many (or not), but 10 abbreviations in 10,000 sentences is a whole
different scenario.

Perhaps another way of thinking about Protocols is when they are 'used' by
the content author(s)/creator(s).

ACT-like rules are run *after* there is some code or content to evaluate or
test, but Protocols should be used far sooner than that (Shifting Left) -
Protocols provide the appropriate guidance to avoid issues once content
starts to be created. Protocols guide 'planning' far more than as part of
the finished product (e.g. when writing content, "Choose your words
carefully" - which is guidance given *before *the content is written, and
not afterwards).

However you, as a 3rd-party evaluator can also use the Protocol to *evaluate
my content*. You may not agree with each individual decision I made
(subjectivity at play), but after us both reading the Protocol, we both
should have a broadly-shared understanding of the goal of any given
Protocol, that we can then use to guide our subjective (opinionated)
evaluation of the content.

This is how I view both the goals and application of Protocols in WCAG 3 -
which neither of your expressed perspectives seems to capture.

My $0.02


On Tue, Apr 19, 2022 at 4:33 PM Jaunita George <
jaunita_george@navyfederal.org> wrote:

Hi all,

We had a very productive meeting last week. Here are some of the decisions
from our meeting last Friday:

   - *Decision:* There are two views about how Protocols can be used:

   1. Protocols can evaluate guidance where the outcomes cannot be
      measured, such as evaluating whether a process has been followed.
      2. Protocols are above or beyond any type of conformance, aka “extra

   - *Decision:* Work will continue on both areas of consensus.
   - *Decision:* Meetings will alternate between 8am and 12pm EST.
   - *Decision:* Table discussion of splitting discussion during meetings
   until we have mechanics worked out but can split the time to both theories
   next week to keep discussion and work moving.

To continue our work, we’ll be using Zoom’s breakout group feature during
the first half of our meeting and then reporting out on what we worked on
and having a brief discussion to iron out the mechanics of our meetings
moving forward.

*Next Meeting:*

The next meeting will be on *Friday, April 22th at 12:00pm EST.*

**** Agenda****

Here’s our agenda for this week based on our discussions:

Agenda+ Breakout groups (30 minutes)

Agenda+ Report out (10 minutes)

Agenda+ How to run future meetings

*Meeting info:*

The Zoom teleconference data is provided at this link:

We will be on IRC using the W3C server at https://irc.w3.org
in channel *#wcag3-protocols*

*Where to find more information:*

These and additional details of our work, including minutes, current,
and archived draft documents are available on our subgroup wiki page here:

If you have any questions at all, please don’t hesitate to reach out.
Looking forward to our next meeting!

*Jaunita George, JD, PMP, WAS (she/her)*

*QA-ADA Analyst III, Product Engineering & Delivery Services (ISD)*

*DHS Certified Trusted Tester (TTV5)*

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Received on Wednesday, 20 April 2022 16:21:08 UTC

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