Re: Call for Consensus (CfC) - Update to WCAG 3

0 --- with some comments, *please read*.

This draft is kind of a mixed bag for Deque. It was encouraging to read
this draft as it seems for the first time we are getting a real glimpse of
what WCAG 3.0 might look like. The strong focus on filling gaps in WCAG
2.2, especially in the cognitive space feels like an important step
forward. It is also good to see some real examples of what outcomes might
look like. That said, with less than a year to go on AGWG’s charter, the
lack of progress in various areas has raised old concerns to new levels.

In this charter AGWG promised to demonstrate viable solutions to all major
components of WCAG 3.0. Looking at this draft, we feel various parts of it
have not sufficiently progressed, and are likely at risk for this charter
and quite possibly their inclusion in WCAG 3.0’s first recommendation. We
feel it is essentially the working group focus its efforts on the following
areas before the end of the charter, in order to fulfill its commitment:

1. demonstrate that WCAG 3.0 can achieve its goals of filling gaps for WCAG
2.2, and being overall a more equitable standard,
2. demonstrate that rewriting WCAG 2.2’s existing requirements are worth
the investment and the downstream costs of adoption,
3. create a viable conformance model that addresses complex conformance
questions, including third-party content, scoring, accessibility
statements, etc.
4. come up with a realistic plan on how and when WCAG 3.0 will be delivered.

Since those are a little vague, here is a breakdown of those four points:

*Conformance model*
WCAG 2’s conformance model is one of its biggest limitations. It works fine
for individual pages, but scaled up to whole sites and apps as everyone
needs to do, it often falls short. There are many complex challenges like
for SPAs, authoring tools, third-party content, fast changing content, etc.
WCAG 3.0 needs a conformance model that can work for full websites and
apps, and which accounts for the limitations that come with doing
accessibility at scale. The conformance model in this latest draft seems to
be less certain than before even, with bronze / silver / gold levels now
removed.

*Gaps & equity*
The two “developing” outcomes, Unambiguous Text and Keyboard Focus
Appearance, seem like AGWG’s attempt at demonstrating it is able to fill
gaps in WCAG 2.2, and showing how 3.0 can be more equitable. But the
solutions demonstrated in this draft do not seem viable.

If Unambiguous Text was part of WCAG 3.0’s foundation as proposed, it would
make a big difference for equity towards cognitive. But it seems no better
at making this user need reasonable and testable than WCAG 2.0’s 3.1.4
Abbreviations criterion. There are no considerations of the numerous edge
cases that make this difficult to universally require. Already the first
word of this draft fails this requirement: “W3C” is an acronym used before
it is explained. This is not likely to ever be accepted as “foundational”
to W3C members, and so not a convincing demonstration of how WCAG 3.0 can
be more equitable.

Next, Keyboard Focus Appearance doesn’t specify target size or contrast
requirements. That is the same problem WCAG 2.0 has, which AGWG tried and
failed to address in 2.2. This draft shows no progress in filling that gap.
If anything, the lack of progress shows the new structure of WCAG 3.0 isn’t
helping to address WCAG 2’s gaps and equity challenges.

*Rewrite existing requirements*
AGWG’s decision to attempt a full rewrite of WCAG 2.2 likely adding years
to WCAG 3.0’s development. Proponents of this approach have long argued
this is essential to achieve WCAG 3.0’s goals. But so far there is little
evidence of that. The way outcomes are phrased in the latest drafts looks
increasingly similar to how WCAG 2’s success criteria are written, and the
terminology used is largely the same.

Every difference between WCAG 2.2 and WCAG 3.0 raises the barrier for
adoption just a little. Before the end of its charter, AGWG needs to
demonstrate that the rewritten requirements are a worth-while improvement
over WCAG 2. They can’t just be simpler because they are incomplete either,
like is the case for the new image outcomes. AGWG needs to be mindful of
the cost of adoption of WCAG 3.0, and convincingly demonstrate it will be
worth the effort.

*Release plan*
AGWG’s current timeline for WCAG 3.0 (
https://www.w3.org/WAI/GL/wiki/WCAG_3_Timeline) does not extend beyond
2025. WCAG 3.0 has been in development for over 8 years. The world needs to
know whether WCAG 3.0 will be delivered in two, four or yet another eight
years. AGWG can’t write a new charter without an agreed on timeline for
WCAG 3.0, and there are only a few months left in which to do so..

Moreover, while AGWG has previously discussed options for breaking WCAG 3.0
up, or doing more incremental releases, so far no decision has been made
public. The charter lists all at once, in phases, or as modules as options.
AGWG needs to discuss and decide which to use. The lack of an agreement to
do something different does not mean the group has agreement to publish all
at once either. The charter explicitly requires a working group agreement
for this.

Kind regards,


On Wed, Nov 27, 2024 at 9:02 PM Bradley Montgomery, Rachael L <
rmontgomery@loc.gov> wrote:

> Call For Consensus — ends *Thursday, December 5th at 3:00 pm* Boston time.
>
>
>
> This call for consensus is to update the WCAG 3 Working Draft from the Editor’s
> Draft
> <https://urldefense.com/v3/__https:/w3c.github.io/wcag3/guidelines/__;!!ACWV5N9M2RV99hQ!KP3IXZZvX9LrLOiqCBP5vpbWs2bOn95uSNT5Z5kc6TMWeY3zkWHzZzcqmiVGvoTbmpHYPfK5gfkNhD_vfzvf8m3e$>
> including the How To
> <https://urldefense.com/v3/__https:/w3c.github.io/wcag3/how-to/__;!!ACWV5N9M2RV99hQ!KP3IXZZvX9LrLOiqCBP5vpbWs2bOn95uSNT5Z5kc6TMWeY3zkWHzZzcqmiVGvoTbmpHYPfK5gfkNhD_vf750MB21$>
> documents.
>
>
>
> Because of the reorganization work, the diffs are particularly difficult
> to read. The list below summarizes the changes:
>
>    - Added 3 Developing guideline: Clear meaning, Image Alternatives, and
>    Keyboard Focus Appearance along with How To
>    <https://urldefense.com/v3/__https:/w3c.github.io/wcag3/how-to/__;!!ACWV5N9M2RV99hQ!KP3IXZZvX9LrLOiqCBP5vpbWs2bOn95uSNT5Z5kc6TMWeY3zkWHzZzcqmiVGvoTbmpHYPfK5gfkNhD_vf750MB21$>
>    Documents
>    - Moved explanatory content out of WCAG and into the WCAG Explainer
>    <https://urldefense.com/v3/__https:/w3c.github.io/silver/explainer/__;!!ACWV5N9M2RV99hQ!KP3IXZZvX9LrLOiqCBP5vpbWs2bOn95uSNT5Z5kc6TMWeY3zkWHzZzcqmiVGvoTbmpHYPfK5gfkNhD_vf5296NAx$>
>    - Reorganized the guidelines for work by subgroups (these remain
>    Exploratory)
>    - Updated the conformance section based on group decisions
>    - Updated the glossary with terms and some definitions identified
>    during exploratory work
>    - Added User Agent Support section
>
>
>
> Call minutes:
>
>    - 19 November 2024
>    <https://urldefense.com/v3/__https:/www.w3.org/2024/11/19-ag-minutes*0088__;Iw!!ACWV5N9M2RV99hQ!KP3IXZZvX9LrLOiqCBP5vpbWs2bOn95uSNT5Z5kc6TMWeY3zkWHzZzcqmiVGvoTbmpHYPfK5gfkNhD_vf2djvV_T$>
>    - 27 November 2024
>    <https://urldefense.com/v3/__https:/www.w3.org/2024/11/26-ag-minutes*bc59__;Iw!!ACWV5N9M2RV99hQ!KP3IXZZvX9LrLOiqCBP5vpbWs2bOn95uSNT5Z5kc6TMWeY3zkWHzZzcqmiVGvoTbmpHYPfK5gfkNhD_vf9x2yeGU$>
>
>
>
> If you have concerns about this proposed consensus position that have not
> been discussed already and feel that those concerns result in you “not
> being able to accept” this decision, please let the group know before the
> CfC deadline.
>
>
>
> Kind regards,
>
>
>
> Rachael
>
>
>


-- 
*Wilco Fiers*
Axe-core & Axe-linter product owner - WCAG 3 Project Manager - Facilitator
ACT Task Force