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W3C Web Accessibility Initiative Statement on Web Access Report from UK Disability Rights Commission

The World Wide Web Consortium (W3C) offers the following comments as an initial response to the Web Access Report released 14 April 2004 by the UK Disabilities Rights Commission. The DRC Report explores the state of Web site accessibility and usability in the UK, and in some sections makes recommendations regarding work done by W3C's Web Accessibility Initiative (WAI).

W3C/WAI produces a set of three accessibility guidelines recognized as international standards. The WAI Guidelines -- a complementary set comprised of the Web Content Accessibility Guidelines 1.0, the User Agent Accessibility Guidelines 1.0, and the Authoring Tool Accessibility Guidelines 1.0 -- address requirements for making Web sites, browsers, media players, assistive technologies, and Web authoring tools accessible for people with disabilities. These WAI Guidelines have been developed with the international cooperation of industry, disability organizations, accessibility researchers, and government representatives. W3C/WAI is currently developing advanced versions of the WAI Guidelines.

The DRC Report focuses on issues experienced by disabled Web users, and makes a number of recommendations with regard to policy options in the UK, recommendations which may contribute to improved Web accessibility in the UK. W3C was not involved in any of the research or in the development of findings from the Report.

While W3C/WAI finds the report informative and the policy recommendations useful for addressing practical implementation issues within organizations, we comment here on some of the DRC Report findings, in order to address potential misunderstandings about W3C's WAI Guidelines introduced by certain interpretations of the data.

The WAI Guidelines Address 95% of Barriers Reported by People with Disabilities in the Report

FINDING 5 of the DRC Report states:

Nearly half (45%) of the problems experienced by disabled users when attempting to navigate websites cannot be attributed to explicit violations of the Web Accessibility Initiative Checkpoints. Although some of these reflect shortcomings in the assistive technology used, most reflect the limitations of the Checkpoints themselves as a comprehensive interpretation of the intent of the Guidelines....

To the contrary, W3C/WAI's examination of the DRC data available as of 14 April 2004 shows that 95% of the barriers reported are indeed covered by existing checkpoints in WAI Guidelines. Of the high-frequency problems identified in Table 5 of the DRC Report, 77% are covered by checkpoints of theWeb Content Accessibility Guidelines 1.0, while 18% are covered by checkpoints of theUser Agent Accessibility Guidelines 1.0. Essentially, the interpretation of the data in the report fails to account for the role of browser and media player accessibility, and the role of interoperability with assistive technologies, in ensuring that people with disabilities can use Web sites effectively.

A more complete picture of the interaction of Web site and browser accessibility might result in additional policy recommendations -- for instance, recommending that conformance to the User Agent Accessibility Guidelines be considered when selecting browsers, media players and assistive technologies. For instance FINDING 3 notes that many people with disabilities are unaware of the accessibility features in browsers; the User Agent Accessibility Guidelines address this issue by requiring that browsers and media players provide documentation of accessibility features to help users find and learn how to use features that they need.

Likewise, authoring tools conforming to Authoring Tool Accessibility Guidelines 1.0 play a complementary role in achieving accessibility by providing built-in support for production of accessible Web sites. Selection of improved authoring tools -- in combination with the awareness and training recommended in the DRC Report -- would likely result in a rapid increase in the number of accessible Web sites in the UK.

Accessibility Guidelines Address Barriers Specific to People with Disabilities; Usability Affects All Web Users

Accessibility of Web sites cannot be evaluated via automated evaluation alone, as noted in W3C/WAI's Evaluating Web Sites for Accessibility which recommends using a combination of different evaluation tools, manual evaluation by experts, and user-testing of accessibility features.

The user-testing methodology employed in this study revealed similar usability problems for disabled and non-disabled users alike, over and above the accessibility problems which created specific barriers for people with disabilities. Given the extremely small number of Web sites conforming to the Web Content Accessibility Guidelines in this study, however, it is hard to draw clear conclusions on the relationship between accessibility and usability measures.

Regardless, some data in the report support the conclusion that increased conformance to the Web Content Accessibility Guidelines 1.0 results in barrier reduction -- and therefore increased accessibility -- for people with disabilities. For instance, when comparing task-completion, accessibility has a disproportionate impact on disabled vs non-disabled users:

On the sites with high accessibility, both groups successfully completed nearly all their tasks. However, on sites with low accessibility, non-disabled users still completed all their tasks, whilst blind users completed only 67%....

W3C/WAI Welcomes Input into Web Content Accessibility Guidelines 2.0

W3C/WAI relies on feedback from all parts of the Web community as it develops the WAI Guidelines, and will consider the suggestions in Appendix 2 of the DRC Report along with other input received while developing WCAG 2.0. All feedback is evaluated for issues such as direct relevance to accessibility; how precisely such requirements can be tested; and relative priority with other accessibility requirements.

The most recent Working Draft of the Web Content Accessibility Guidelines 2.0 is available, and information on where to send comments is available in the Status section of the document.

Information about W3C and WAI

The World Wide Web Consortium (W3C) is an international forum which develops interoperable technologies (specifications, guidelines, software, and tools) to lead the Web to its full potential.

W3C's Web Accessibility Initiative (WAI) addresses accessibility of the Web for people with disabilities, through a variety of activities, including technical and guidelines development and educational work, including the WAI-TIES Project, funded by the EC Information Society Technologies Programme to increase training and implementation support on Web accessibility in Europe.

Last modified: $Date: 2004/04/14 06:11:16 $ by Judy Brewer <jbrewer@w3.org>

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