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RE: Level AA exceptions

From: Katie Haritos-Shea GMAIL <ryladog@gmail.com>
Date: Fri, 14 Aug 2015 17:16:48 -0400
To: "'Sailesh Panchang'" <sailesh.panchang@deque.com>, "'Jonathan Avila'" <jon.avila@ssbbartgroup.com>
Cc: "'Phill Jenkins'" <pjenkins@us.ibm.com>, "'Wayne Dick'" <waynedick@knowbility.org>, "'GLWAI Guidelines WG org'" <w3c-wai-gl@w3.org>, "'WAI Interest Group'" <w3c-wai-ig@w3.org>
Message-ID: <017d01d0d6d6$88dbdc80$9a939580$@gmail.com>
Sailesh,

The great thing about the Access Board adopting WCAG 2 Level AA is - once it become a FAR requirement it doesn’t matter if a SC is at Level A or Level AA, all 38 of those Success Criteria become required period - end of story -there will be no distinction between them - they all are required.



* katie *
 
Katie Haritos-Shea 
Senior Accessibility SME (WCAG/Section 508/ADA/AODA)
 
Cell: 703-371-5545 | ryladog@gmail.com | Oakton, VA | LinkedIn Profile | Office: 703-371-5545

-----Original Message-----
From: Sailesh Panchang [mailto:sailesh.panchang@deque.com] 
Sent: Friday, August 14, 2015 5:12 PM
To: Jonathan Avila <jon.avila@ssbbartgroup.com>
Cc: Katie Haritos-Shea GMAIL <ryladog@gmail.com>; Phill Jenkins <pjenkins@us.ibm.com>; Wayne Dick <waynedick@knowbility.org>; GLWAI Guidelines WG org <w3c-wai-gl@w3.org>; WAI Interest Group <w3c-wai-ig@w3.org>
Subject: Re: Level AA exceptions

I too have struggled with  Question: logic for classifying SC as Level A or AA" and would have liked the logic to have been documented in
WCAG2 as informative content.
Like many I feel that SC 1.4.3 and 2.4.7 should be Level A and had suggested to the DOJ in 2010  That they could start by requiring all Level A + these two SCs at least for ADA.
Here is an exchange with Greg in Jan/2014:
On Jan 28, 2014, at 7:25 PM, Sailesh Panchang < spanchang02@yahoo.com>
wrote:
block quote
Hello Greg,
Understanding Levels of Conformance on
http://www.w3.org/TR/UNDERSTANDING-WCAG20/conformance.html
"•whether the Success Criterion is essential (in other words, if the Success Criterion isn't met, then even assistive technology can't make content accessible)"
So for instance, if author does not provide alt text for image or caption for audio content of multimedia user agent / At cannot do anything.
So this is Level A.
In other words, if user agent / At can provide a work around if even if the SC is not met, such an SC will be Level AA, right?I note the other factors listed on this page for classifying SC but am wondering if the above factor is a primary one for the classification.
block quote end
No,  there are no hard and fast rules for why an SC is in one level or another.
The group considered many different factors -- and then made a decision separately for each SC.
So the ONLY thing that finally determined which level an SC was in -- was the consensus decision on which level it would go.
G
block quote
Thanks for your time.
Regards,
Sailesh Panchang
Tel 571-344-1765
block quote end


On 8/14/15, Jonathan Avila <jon.avila@ssbbartgroup.com> wrote:
>>Do you want me to say UNCLE now?.....
>
> No.  My intention was to learn more about what the Access Board had 
> said and what direction they are leaning to make sure that we don’t 
> lose something in the refresh of the standards.  For example, the 
> current Section 508 standards require that alternatives only be used 
> when the functionality cannot be achieved any other way.  This requirement is lost in the refresh.
> As I’ve said before and I think you agree there needs to be more 
> communication between WAI and the Access Board and other governing 
> bodies to make sure application of the guidelines are correctly 
> understood.  Put bluntly this isn’t about me being right or wrong but 
> about making sure Section 508 is refreshed without loopholes or loss 
> of access.  If indeed the conformance requirements are being 
> considered to be part of claims and thus dropped I was going to contact the Board immediately to share my thoughts.
> So I wanted to be clear about what we were discussing before 
> contacting them.
>
> I agree with your summation of the A, AA, AAA as minimum level, 
> higher, highest, that’s exactly how I position them as well.
>
> 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 4:46 PM
> To: Jonathan Avila; 'Phill Jenkins'; 'Wayne Dick'
> Cc: 'GLWAI Guidelines WG org'; 'WAI Interest Group'
> Subject: RE: Level AA exceptions
>
> Do you want me to say UNCLE now?.....
>
> ​​​​​
>
>
> * 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 4:42 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
>
>> 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.
>
> Yes, but given the dearth of lawsuits over Section 508 this would not 
> be my concern.  My concern would be over lost revenue from vendors 
> selling products and services into the US Federal Government and the 
> potential risk to business.  Thus the importance for identifying the 
> differences between these standards and their association to WCAG AAA 
> standards that other organizations are choosing to cherry pick and adopt.
>
> 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.p
> hp?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
>
Received on Friday, 14 August 2015 21:17:20 UTC

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