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

2. A centre of expertise in digital information managementwww.ukoln.ac.uk 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 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 Senior researcher at City University

3. A centre of expertise in digital information managementwww.ukoln.ac.uk 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 (not just informational sites) Reflect real-world technical environment and developments Reflect real-world political and cultural environments

4. A centre of expertise in digital information managementwww.ukoln.ac.uk 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. A centre of expertise in digital information managementwww.ukoln.ac.uk 5 DRC – Disability Rights Commission, independent body legislated to stop discrimination and promote equality of opportunity of disabled people. 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 (NB figures give numbers which comply with the metrics the tool measure) Implications These low conformance levels can indicate: Organisations don't care Guidelines are difficult to implement Guidelines are inappropriate, misleading, wrong, … Technical developments (ATs, OSs, …) overcome barriers Implications These low conformance levels can indicate: Organisations don't care Guidelines are difficult to implement Guidelines are inappropriate, misleading, wrong, … Technical developments (ATs, OSs, …) overcome barriers

6. A centre of expertise in digital information managementwww.ukoln.ac.uk 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 ( ) can be rendered by browsers – this is an interoperability issue

7. A centre of expertise in digital information managementwww.ukoln.ac.uk 7 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 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!“ (and I want to fly) The subjectivity of usability guidelines seems to be recognised "I don't claim people should do 100% of what I say" Jakob Neilson "I don't claim people should do 100% of what I say" Jakob Neilson

8. A centre of expertise in digital information managementwww.ukoln.ac.uk 8 Usability Issues (2) What is the relationship between usability & accessibility? Usability Accessibility Usability Accessibility

9. A centre of expertise in digital information managementwww.ukoln.ac.uk 9 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 (for understandable political reasons). But we want to develop an alternative approach.

10. A centre of expertise in digital information managementwww.ukoln.ac.uk 10 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. Nightmare Scenario Case taken to court in UK. Defence lawyers point out ambiguities & inconsistencies. Case lost, resulting in WCAG’s relevance being diminished.

11. A centre of expertise in digital information managementwww.ukoln.ac.uk 11 Holistic Approach 1Developing A Holistic Approach For E-Learning Accessibility, Canadian Journal of Learning and Technology, 2004, Vol. 30, Issue 3 This approach reflects current UK emphasis on blended learning (rather than e-learning) Kelly, Phipps & Swift 1 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

12. A centre of expertise in digital information managementwww.ukoln.ac.uk 12 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

13. A centre of expertise in digital information managementwww.ukoln.ac.uk 13 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 (evidence- based) approach rather than a visionary/dogmatic one: Robust solutions Fail-safe Reflect user experiences rather than ideologies

14. A centre of expertise in digital information managementwww.ukoln.ac.uk 14 WAI WCAG 2.0 What about WCAG 2.0? Modularity  Uncertainty of the broader context  It is tolerant of non-W3C formats  Long gestation period  Why address writing style? (this is for real world)  Complexity and relationship with WCAG 1.0  Horrendous migrations implications  Doesn’t address limitations of WAI model  Still closed:  Lack of extensibility  Fails to address implications of other developments e.g. models of accessibility; technical developments such as personalisation  … "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 "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

15. A centre of expertise in digital information managementwww.ukoln.ac.uk 15 Accessibility In Context External factors: Institutional issues (funds, expertise, policies, security…) External factors: Legal issues; cultural factors; … PurposeSectorFundingResources Context Accessibility/UsabilityPrivacy Policies … Finance External Self-assessmentPenaltiesLearning Compliance Digital Library Programme Broken Standards Research … This approach embraces relativism and context rather than the current absolute approach Accessibility guidelines should be usable in wider context A framework is being developed which places accessibility & usability within a wider context: The context A range of policies A compliance regime

16. A centre of expertise in digital information managementwww.ukoln.ac.uk 16 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

17. A centre of expertise in digital information managementwww.ukoln.ac.uk 17 Questions Questions are welcome