Re: 508 Refresh and Reasonable Accommodation for Low Vision

Hey list,

I understand that a lot of good people have spent a lot of their time and
energy over the past few years trying to push the 508 Refresh to the
finish line. I also understand that a lot of good people are also
tirelessly dedicating a lot of their time and energy trying to make WCAG
2.0 the best standard they can. So, as respectfully as I can put it…

On Feb 18, 2015, at 1:04 PM, Phill Jenkins <> wrote:

> But, and this is a big but,
> now is not the time to slow down the 508 Refreesh.  The accessibility
> community has been complaining that it has taken too long already, we
> can't talk out of both sides of our mouths and make demands to slow it
> down again if we don't have even recommend techniques to offer, survey
> data, and economic benefits - all required to make a specification (or
> accessibility standard) a regulation.

Yes, the 508 refresh has been a long time coming. Yes, we’re all sick &
tired of waiting for it to finally happen. Yes, it’s easy to complain
about how long it takes for it to get adopted. Yes, the adoption has
become some kind of a running joke. But (here’s MY big but)…

If there are any doubts that the Refresh has really dropped the ball on a
user group as clearly and widely represented as the low vision users group
– and I believe it has, then it is our responsibility, as that inclusive,
caring accessibility community, to do everything we can to either slow the
process down, so we do come up with proposals/techniques/ideas to fill the
gaps or minimally, make sure the shortcomings for the low vision community
are somehow addressed. It’s not a question of talking out of both sides of
our mouths, it’s simply a matter of being coherent and doing all we can to
cater to the needs of as many people as we can, because we happen to claim
that we care about everyone.

I should not have to remind anyone that there are almost 10 times as many
people who have low vision than there are people who are blind. Issues
like the one Wayne is raising about word wrapping and the ability to read
comfortably are not new. The shortcomings of SC 1.4.4 are many: word
wrapping and lack of set font sizes are just a few of the things that come
to mind… proximity of inter-related objects in a page is another. Wayne
and many others have been fighting for this way before WCAG 2.0 as we know
it became a recommendation. December of 2015 will mark the 7th anniversary
of WCAG 2.0. And what has changed since then to improve the way the needs
of low vision users are handled on the Web?

Ironically enough, the best solution for the issues experienced by low
vision users on the Web in the last 7 years has come from the most
unexpected of places… responsive web design. Low vision users needs are
very poorly supported by accessibility standards and nothing is ever going
to change if we don’t do something about it. I’m sure people back in 2008
thought that WCAG 2.0 was “good enough”, and that it was “a good starting
point”… And while it is for many, it’s still very much flawed for others.
Anyone who’s ever thought of cognitive disabilities knows that most
requirements are on the AAA level, and are quickly dismissed by most
organizations. The same holds true for low vision users.

Asking not to slow down the adoption process for the 508 refresh sums up
to asking the very people who had to put their own needs aside 7 years ago
to do it again for the greater good of the Refresh. We just have to look
at how long current 508 has been around to know that whatever will be
adopted as the Refresh will also be around – and most likely set in stone
– for a very, very long time. If we don’t get anything in there to help
low vision users more concretely, then history will just repeat itself and
my guess is that we’re going to be stuck with those shortcomings for a
very, very long time too.

I’d much rather we wait a little more and fix those shortcomings, than
settle for something we know is already falling short for a lot of people
before it even gets started.

I urge us to learn from the lessons of WCAG 2.0 and not repeat the same
mistakes with the 508 Refresh. We see how difficult it is to even try to
open discussions about moving Success Criteria from level AAA to level AA
– I can’t even begin to imagine how complicated it would be to do this in
the Refresh with the Access Board, seeing how long it’s been just to get
to this point. If this accessibility community is really as inclusive as
we pretend it is, then let’s work at providing solutions to fix the gaps
left for low vision users, so they’re at least addressed and ideally,
fixed before the 508 Refresh hits us with its awesome goodness.

Just a thought. And just so we’re clear…

I think Phil did bring excellent points and a very reasonable approach to
addressing the problem and I want to thank him for the insights about
getting new techniques in to address the shortcomings of SC 1.4.4, or even
new ideas to improve areas that do need improving. I totally agree with
him that documentation, example techniques and general data need to be
gathered to build the case for word wrapping so low vision users’ need
might be better addressed in the future… as long as there are people who
can afford to spend the time pursuing that objective. I have a feeling
however, that some of the things Phil is asking to build the case for low
vision users can be found on Shawn Henry’s website, with links such as and Is is “good enough”? It’s at least
“a good starting point” I would say.

That being said, the point of this post was simply to remind us that
temporary solutions often end up being permanent. So let’s not rush into
anything, if it means we’ll still be leaving a lot of us behind.

Also published here (slightly different version):

Denis Boudreau
Web Accessibility - Universal Design - User Experience
» 514-730-9168

Received on Thursday, 19 February 2015 16:52:13 UTC