RE: Level AA exceptions

Ø  As Allen said and as I understand  - by the Refreshed Section 508 Standards being incorporated into the FAR -  the requirements to conform will be set in stone as FAR conformance requirements as far as the US Federal Government is concerned - W3C WCAG conformance is moot, not needed.

Can you explain then how alternative versions of pages, non-interference and accessibility support would be addressed?    Perhaps I’ve always read the WCAG note wrong but I don’t understand why you can’t separate conformance requirements from conformance claims.

The WCAG note specifically says “It is not required to make any conformance claim in order to conform”.    So I stand by my argument that conformance and conformance claims are two separate things.

Jonathan

--
Jonathan Avila
Chief Accessibility Officer
SSB BART Group
jon.avila@ssbbartgroup.com<mailto:jon.avila@ssbbartgroup.com>

703-637-8957 (o)
Follow us: Facebook<http://www.facebook.com/#%21/ssbbartgroup> | Twitter<http://twitter.com/#%21/SSBBARTGroup> | LinkedIn<http://www.linkedin.com/company/355266?trk=tyah> | Blog<http://www.ssbbartgroup.com/blog> | Newsletter<http://eepurl.com/O5DP>

From: Katie Haritos-Shea GMAIL [mailto:ryladog@gmail.com]
Sent: Friday, August 14, 2015 4:30 PM
To: Jonathan Avila; 'Phill Jenkins'; 'Wayne Dick'
Cc: 'GLWAI Guidelines WG org'; 'WAI Interest Group'
Subject: RE: Level AA exceptions

As Allen said and as I understand  - by the Refreshed Section 508 Standards being incorporated into the FAR -  the requirements to conform will be set in stone as FAR conformance requirements as far as the US Federal Government is concerned - W3C WCAG conformance is moot, not needed.

​​​​​


* katie *

Katie Haritos-Shea
Senior Accessibility SME (WCAG/Section 508/ADA/AODA)

Cell: 703-371-5545 | ryladog@gmail.com<mailto:ryladog@gmail.com> | Oakton, VA | LinkedIn Profile<http://www.linkedin.com/in/katieharitosshea/> | Office: 703-371-5545

From: Jonathan Avila [mailto:jon.avila@ssbbartgroup.com]
Sent: Friday, August 14, 2015 4:25 PM
To: Katie Haritos-Shea GMAIL <ryladog@gmail.com<mailto:ryladog@gmail.com>>; 'Phill Jenkins' <pjenkins@us.ibm.com<mailto:pjenkins@us.ibm.com>>; 'Wayne Dick' <waynedick@knowbility.org<mailto:waynedick@knowbility.org>>
Cc: 'GLWAI Guidelines WG org' <w3c-wai-gl@w3.org<mailto:w3c-wai-gl@w3.org>>; 'WAI Interest Group' <w3c-wai-ig@w3.org<mailto:w3c-wai-ig@w3.org>>
Subject: RE: Level AA exceptions


>  My understanding is that WCAG conformance claims will NOT be required under the Section 508 Refresh. This particular training was provided in conjunction with the Access Board.

From the Section 508 proposed rule
We proposed that “electronic content integral to the use of ICT” covered by the 255 Guidelines must conform to Level A and Level AA Success Criteria and Conformance Requirements specified for Web pages in WCAG 2.0, as incorporated by reference in C102 (Referenced Standards). The Board received no comments on this provision in the 2011 ANPRM. (http://www.access-board.gov/guidelines-and-standards/communications-and-it/about-the-ict-refresh/proposed-rule/single-file-version)

I take this to include requirements such as

>  Accessibility supported

>  Non-interference

>  Conforming alternative versions

If the access board chooses not to include anything about the conformance requirements then they’d be missing these specific areas except where vendors choose to take the equivalent facilitation route.

Jonathan





--
Jonathan Avila
Chief Accessibility Officer
SSB BART Group
jon.avila@ssbbartgroup.com<mailto:jon.avila@ssbbartgroup.com>

703-637-8957 (o)
Follow us: Facebook<http://www.facebook.com/#%21/ssbbartgroup> | Twitter<http://twitter.com/#%21/SSBBARTGroup> | LinkedIn<http://www.linkedin.com/company/355266?trk=tyah> | Blog<http://www.ssbbartgroup.com/blog> | Newsletter<http://eepurl.com/O5DP>

From: Katie Haritos-Shea GMAIL [mailto:ryladog@gmail.com]
Sent: Friday, August 14, 2015 3:59 PM
To: Jonathan Avila; 'Phill Jenkins'; 'Wayne Dick'
Cc: 'GLWAI Guidelines WG org'; 'WAI Interest Group'; ryladog@gmail.com<mailto:ryladog@gmail.com>
Subject: RE: Level AA exceptions

Jon,

My understanding is that WCAG conformance claims will NOT be required under the Section 508 Refresh. This particular training was provided in conjunction with the Access Board.

Also what individual agencies (HHS, etc) choose to do to add – additional requirements – is totally within their right to do so – however, if the refreshed Section 508 Standards do not specifically identify any Level AAA Success Criteria – Failures for such Level AAA issues will not be applicable in a court of law under a Section 508 violation. They could be violations of a specific agency’s policy – but not Section 508 itself.

​​​​​


* katie *

Katie Haritos-Shea
Senior Accessibility SME (WCAG/Section 508/ADA/AODA)

Cell: 703-371-5545 | ryladog@gmail.com<mailto:ryladog@gmail.com> | Oakton, VA | LinkedIn Profile<http://www.linkedin.com/in/katieharitosshea/> | Office: 703-371-5545

From: Jonathan Avila [mailto:jon.avila@ssbbartgroup.com]
Sent: Friday, August 14, 2015 3:53 PM
To: Katie Haritos-Shea GMAIL <ryladog@gmail.com<mailto:ryladog@gmail.com>>; 'Phill Jenkins' <pjenkins@us.ibm.com<mailto:pjenkins@us.ibm.com>>; 'Wayne Dick' <waynedick@knowbility.org<mailto:waynedick@knowbility.org>>
Cc: 'GLWAI Guidelines WG org' <w3c-wai-gl@w3.org<mailto:w3c-wai-gl@w3.org>>; 'WAI Interest Group' <w3c-wai-ig@w3.org<mailto:w3c-wai-ig@w3.org>>
Subject: RE: Level AA exceptions

>  Level AAA: (highest)
(Not applicable to Section 508/ADA)

As an FYI – the current Federal Baseline requirements for Section 508 which are adopted by several agencies do require that link text be unique out of context similar to WCAG SC 2.4.9.

In addition, the HHS HTML Section 508 checklist includes several AAA requirements.  For example, (16.7) Can interruptions be postponed or suppressed by the user, e.g. alerts, page updates, etcetera?<https://amp.ssbbartgroup.com/public/standards/view_ruleset.php?rule_id=1001066>


>  Conformance Claims:  Are optional, and, there are NO plans to require Conformance Claims in the New 508 Standards.
Don’t forget that the Section 508 refresh does include the WCAG conformance requirements such as accessibility supported, non-interference, etc.

Best Regards,

Jonathan


--
Jonathan Avila
Chief Accessibility Officer
SSB BART Group
jon.avila@ssbbartgroup.com<mailto:jon.avila@ssbbartgroup.com>

703-637-8957 (o)
Follow us: Facebook<http://www.facebook.com/#%21/ssbbartgroup> | Twitter<http://twitter.com/#%21/SSBBARTGroup> | LinkedIn<http://www.linkedin.com/company/355266?trk=tyah> | Blog<http://www.ssbbartgroup.com/blog> | Newsletter<http://eepurl.com/O5DP>

From: Katie Haritos-Shea GMAIL [mailto:ryladog@gmail.com]
Sent: Friday, August 14, 2015 3:26 PM
To: 'Phill Jenkins'; 'Wayne Dick'
Cc: 'GLWAI Guidelines WG org'; 'WAI Interest Group'; ryladog@gmail.com<mailto:ryladog@gmail.com>
Subject: RE: Level AA exceptions

In my trainings on WCAG 2 for both non-government and Section 508 audiences, I use this to differentiate the levels:


What Do the SC Levels and Conformance Mean?
Conformance Level: One levels of conformance is met in full.

  1.  Level A: (lowest/minimum)
•       Content satisfies all the Level A SC, or a conforming alternate version is provided.
•       Has the highest impact on the broadest array of user populations (or the highest degree of customer impact), and has the lowest impact on the presentation and business logic of the site.

  1.  Level AA: (higher)
•       Content satisfies all the Level A and Level AA SC, or a Level AA conforming alternate version is provided.
•       Higher Bar. Has a high impact for specific user populations, and may impose more changes to the presentation or business logic of the site. Requires an additional level of effort for developers.

  1.  Level AAA: (highest)
(Not applicable to Section 508/ADA)
Conformance Claims:  Are optional, and, there are NO plans to require Conformance Claims in the New 508 Standards.

I wouldn’t say that the level of effort by developers in necessarily true in all cases, but it was one of the many things that Gregg was talking about that was taken into account – at that time in history and level of technology that was available at that point in time………….​​​


* katie *

Katie Haritos-Shea
Senior Accessibility SME (WCAG/Section 508/ADA/AODA)

Cell: 703-371-5545 | ryladog@gmail.com<mailto:ryladog@gmail.com> | Oakton, VA | LinkedIn Profile<http://www.linkedin.com/in/katieharitosshea/> | Office: 703-371-5545

From: Phill Jenkins [mailto:pjenkins@us.ibm.com]
Sent: Friday, August 14, 2015 3:09 PM
To: Wayne Dick <waynedick@knowbility.org<mailto:waynedick@knowbility.org>>
Cc: GLWAI Guidelines WG org <w3c-wai-gl@w3.org<mailto:w3c-wai-gl@w3.org>>; WAI Interest Group <w3c-wai-ig@w3.org<mailto:w3c-wai-ig@w3.org>>
Subject: Re: Level AA exceptions

Wayne, my response [in Phill bold blue brackets]

____________________________________________
Regards,
Phill Jenkins,



From:        Wayne Dick <waynedick@knowbility.org<mailto:waynedick@knowbility.org>>
To:        Katie Haritos-Shea <ryladog@gmail.com<mailto:ryladog@gmail.com>>
Cc:        CAE-Vanderhe <gregg@raisingthefloor.org<mailto:gregg@raisingthefloor.org>>, WAI Interest Group <w3c-wai-ig@w3.org<mailto:w3c-wai-ig@w3.org>>, Phill Jenkins/Austin/IBM@IBMUS, GLWAI Guidelines WG org <w3c-wai-gl@w3.org<mailto:w3c-wai-gl@w3.org>>
Date:        08/14/2015 11:36 AM
Subject:        Re: Level AA exceptions
________________________________



What is normative? That really is the issue. I am less concerned informative notes because they are non-binding. Having attempted to explain Level A and Level AA many times to managers and programmers, I have found the logic of Understanding WCAG 2.0, very difficult and not compelling. Phill is correct. There is a gap that needs filling. We need clear language. I think, normative.
[Phill writes: you are using "normative' in a different way than I was.  Policies and regulations are "binding" when they say to conform with the particular Success Criteria (SC).  In guidelines and standards speak, "normative" is defined in the glossary - see http://www.w3.org/TR/WCAG20/#glossary "Content required for conformance<http://www.w3.org/TR/WCAG20/#conformancedef> is referred to as "normative<http://www.w3.org/TR/WCAG20/#normativedef>." .  Normative content is whether a SC is A or AA, Informative content is where we can  explain why it is A or AA. Informative doesn't change the SC from being A or AA, nor does it change the binding part of the organization's or country's regulation or policy, it informs but doesn't set the requirement.]

In my opinion it needs to be clear in its responsibility to stake holders, with the user with a disability being at the center.  Web content in all formats is be profoundly robust. The migration to mobile formats has proven this. There is no need that essential functionality needs cannot be met, but we need to address concepts like the American terms, undue burden and fundamental alteration, carefully and land on normative language.  Like all statements in natural language we need to allow for interpretation. Perhaps we need a formal elastic clause that permits variation.
[Phill writes: now you are using the "language" that is in the policies and regulations, not something we need to address in WCAG.   "Undue burden and "fundamental alteration" are policy terms used in 508 policy part, not found in WCAG 2.0. Another term used in policies and regulations is "scoping".  What does the technical requirement apply to? for example.  ADA is being considered by the Dept of Justice (DoJ) to be amended to apply the requirements in WCAG 2.0 to certain commercial web sites it has jurisdiction over.  ADA has scoping terms like a percentage of the parking spaces need to be "van accessible", while the technical specs for the width of a "van accessible" parking spec is separate. DoJ calls the percentage of parking spaces a "standard" in legal terms, so that is confusing when we talk about technical requirements in the WCAG standard.  Think of WCAG 2.0 as the list of technical specs for what makes a web site accessible, it is still up to a policy to scope which web sites need to conform and by when. There is also the jurisdiction or applicability part that the policy lawyers get involved in - for example, the Department of Transportation (DoT) has required all airline website to be conform to WCAG by a certain date, but DoT doesn't regulate Netflix, they are regulated by FCC, etc. WCAG doesn't regulate anyone, so there is no need for terms like "undue burden' or "fundamental alteration" to be included in WCAG..]

​I think what we can all agree on is that, level differentiation needs clarification.  Now that WCAG is beyond the crazy flurry of criticism that it faced in 2008, WCAG WG can revisit these definitions.
[Phill writes: well, changing something from a AA to an A is almost moot, because they are all required all the time anyway by the policy it seems - that is exactly my point and question.  Should all and each and every one of the Level AA Success Criteria always be applicable to all content all the time?  If not, why not, and is there any guidance from the working group specific to each SC?   Ontario Canada, for example choose not to include SC 1.2.5 Audio Descriptions<http://www.w3.org/TR/WCAG20/#media-equiv-audio-desc-only>  Level AA because of the cost and expertise needed to create video descriptions in audio format.  I am not advocating for not including Level AA Success Criteria in policy and regulations, but I am asking for more informative content to explain to practitioners and policy makers why the working group thought a particular SC should be assigned to Level AA.  Level A and AAA are easier, its the ones in the middle.  Documenting the "why" helps inform all of us equally, which helps the community and the emerging professionals, which in turns helps the individual who has a disability at the center.]

Phill has identifies a gap, that has confused many implementers.

Wayne