Forcing Standardization or Accommodating Diversity? A Framework for Applying the WCAG in the Real World

1. Forcing Standardization or Accommodating Diversity? A Framework for Applying the WCAG in the Real World Co-authors: David Sloan, University of Dundee Lawrie Phipps, TechDis Helen Petrie & Fraser Hamilton, City University Brian Kelly UKOLN University of Bath Bath, UK Email B.Kelly@ukoln.ac.uk UKOLN is supported by:

2. Background To The Paper • This paper: • Based on experiences of promoting & supporting best practices for Web accessibility within the UK higher & further education (HE/FE) & cultural heritage communities • Five authors from four HE organisations in the UK (including 2 national advisory services) Web developer since 1993 & adviser to UK HE/FE & cultural heritage communities Senior researcher at City University Consultant and researcher in inclusive design and accessibility, University of Dundee Senior adviser at TechDis – a national advisory service to HE/FE Professor at City University with interests in usability & accessibility

3. The WAI Model • WAI has been tremendously successful in raising awareness of Web accessibility and providing guidelines to achieve this. • WAI guidelines are based on: • WCAG (Web Content …) • ATAG (Authoring Tools ..) • UAAG (User Agents …) • The model is simple to grasp. But is this model appropriate for the future? Does the model: • Reflect the diversity of users & user environments • Reflect the diversity of Web usage • Reflect real-world technical environment and developments • Reflect real-world political and cultural environments

4. Limitations Of The Model • This model: • Requires all three components to be implemented in order for the WAI vision to be achieved • Is of limited use to end users who have no control over browser or authoring tools developments • Is confusing – as many think WCAG is WAI • How does this model address: • Delays in full conformance? (We're still waiting for "until user agents …" clause to be resolved) • Real-world reluctance to deploy new software (issues of inertia, testing, costs, …) • Real world complexities Is there a plan B in case this model fails to ever take off? Is it desirable to base legal requirements on an unproven theoretical framework?

5. WCAG Conformance • Page authors can only follow WCAG guidelines. Several surveys carried out using automated tools (which gives upper limit on accessibility) • DRC report: 19% A, 0.6% AA conformance based on 1,000 Web sites • UK Museums report: 42% A, 3% AA conformance based on 124 Web sites • UK Universities surveys (2002, 04): 43%/58% A, 2%/6% AA based on 160+ Web sites • Implications • These low conformance levels can indicate: • Organisations don't care • Guidelines are difficult to implement • Guidelines are inappropriate, misleading, wrong, … DRC – Disability Rights Commission, independent body legislated to stop discrimination and promote equality of opportunity of disabled people.

6. WCAG Difficulties • Certain Priority 2 and 3 guidelines cause concerns: • 11.1 Use W3C technologies when they are available and appropriate for a task ... • Promotes own technologies • Appears to ignore major improvements in accessibility of non-W3C formats • 11.1 … and use the latest versions when supported • Goes against project management guidelines • Logical absurdity: when XHTML 1 came out WAI AA HTML 4 compliant sites downgraded to A! • 3.2 Create documents that validate to published formal grammars • Dodgy HTML (<br />) can be rendered by browsers – this is an interoperability issue (e.g. W4A 2005 conf. home page)

7. Proprietary Formats • WCAG P2 requires use of W3C formats • Thoughts: • Reflects the idealism of the Web community in late 1990s • The conveyor belt of great W3C formats is slowing down • Software vendors are responding to WAI’s initiatives (formats, OS developments, …) • Developments in non-Web areas (mobile phones, …) & integration with real-world (e.g. blended learning, …) • Users care about the outcomes, not the way in which the outcomes are provided Thought: Could this requirement be regarded as anti-competitive if taken to, say, EU court?

8. DRC survey also carried out usability testing: • Exemplar accessible Web sites did not comply with WCAG guidelines (WCAG A) • WCAG compliant sites (according to tools) were not accessible or usable • DDA requires users to be able to access & use services The subjectivity of usability guidelines seems to be recognised "I don't claim people should do 100% of what I say" Jakob Neilson DDA – UK's Disability Discrimination Act Usability Issues (1) • "WCAG provides the highway code for accessibility on the information superhighway" • "Fine – but what if the accelerator and brake pedals differ on every car. I'll still crash!"

9. Accessibility Usability Usability Accessibility Accessibility Usability Usability Issues (2) • What is the relationship between usability & accessibility? Accessibility Usability

10. Confusion • SiteMorse’s automated accessibility survey of UK disability organisations’ Web sites generated heated debate • SiteMorse: Low WCAG conformance found: • Response: doesn’t matter, manual testing gives OK results • What do such comments say about disability organisations’ views of WCAG ? Note that the RNIB actively promote WCAG guidelines – and also promote use of accessible Flash, without flagging any inconsistencies. Organisations may publicly support WCAG whilst rejecting (parts of) it.

11. Nitpicking? • “This is just nit-picking! WCAG is valuable – don’t knock it!” • WCAG is valuable, but we need to: • Build a robust framework for the future • Ensure clarity and avoid ambiguities to avoid different interpretations • Reflect on experiences gained since 1999 • Avoid dangers of inappropriate case law being set Nightmare Scenario Case taken to court in UK. Defence lawyers point out ambiguities & inconsistencies. Case lost, resulting in WCAG’s relevance being diminished.

12. This approach reflects current UK emphasis on blended learning(rather than e-learning) Holistic Approach • Kelly, Phipps & Swift1 have argued for a holistic framework for e-learning accessibility • This framework: • Focusses on the needs of the learner • Requires accessible learning outcomes, not necessarily e-learning resources 1 Developing A Holistic Approach For E-Learning Accessibility, Canadian Journal of Learning and Technology, 2004, Vol. 30, Issue 3

13. Legal Issues • UK legislation requires organisations to take "reasonable steps" to ensure disabled people do not face unjustified discrimination. • This approach: • Is technology-neutral • Is both forwards-looking and backwards-compatible • Acknowledges differences across providers of services • Doesn’t differentiate between real-world and online accessibility (or between Web and other IT accessibility) • Avoids change-control difficulties The approach outlined in this paper appears to fit in well with UK legislation

14. Need For Engineers • The Web and the notion of universal accessibility was initially build on a great vision • But as: • The Web gets more complex • Real world complexities become apparent • Alternative approaches emerge • We learn from user experiences • we argue the need for an engineering approach rather than a visionary one: • Robust solutions • Fail-safe • Reflect user experiences rather than ideologies

15. "Though this be madness, yet there is method in it" • Addressing writing style has attractions, but: • Applies a single dimension (ease of understanding) to a much richer area (learning, culture, …) • Liable to undermine core accessibility issues • Hostage to fortune – "They're banning Shakespeare" • Makes divisions between real world and Web Similar concerns have been raised by Joe Clark, AListApart WAI, WCAG 2.0 • What about WCAG 2.0? • Modularity • Uncertainty of the broader context • Is is tolerant of non-W3C formats? • Why address writing style? (this is for real world) • Complexity and relationship with WCAG 1.0

16. External factors: Institutional issues (funds, expertise, policies, security…) Accessibility guidelines should be usable in wider context External factors: Legal issues; cultural factors; … This approach embraces relativism and contextrather than the current absolute approach Accessibility In Context • A framework is being developed which places accessibility & usability within a wider context: • The context • A range of policies • A compliance regime Digital Library Programme Context Purpose Sector Funding Resources Research … Policies Standards Accessibility/Usability Privacy Finance … Compliance External Self-assessment Penalties Learning Broken

17. Links To W3C Approaches • This approach has parallels with W3C approaches: • Providing a framework which co-exists with society’s policies rather than seeking to change them cf. content filtering (PICS), privacy (P3P), … • Evolution from grandiose standards to more realistic ones (cf. P3P, HTML+, …) • Evolution from monolithic standards to more modular ones (cf. XML, HTML, …) • Recognition that W3C shouldn’t seek to do everything Web-related • Implications: • WAI guidelines should be modular & usable in a wider context • Need to clarify what WAI does & doesn’t do

18. Conclusions • To conclude: • Importance of Web accessibility widely accepted • But: • WCAG P2 & P3 guidelines aren’t working (cf. disability organisations, W3C members, W4A, …) • Some guidelines are flawed • Usability issues are being lost • User focus on WCAG conformance rather than providing usable & accessible resources • World has moved on since 1999 • Need for: • Modularity • Engineering, not ideology

19. Questions • Questions are welcome