Edit comment LC-2501 for Accessibility Guidelines Working Group

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Comment LC-2501
Commenter: Sheena McCullagh <sheena.mccullagh@blueyonder.co.uk>

Resolution status:

I had originally read this that 1 and 2 were exactly that an 'and', then someone I know who does accessibility testing for a living, pointed out to me that I was wrong. They are not 'and', ie you can do one or the other. However I see a problem with that:

Skip links are of main benefit to sighted users who navigate via the keyboard and are of only very limited benefit to screen reader users. However H69 (heading elements) is only of use to screen readers and provides no help whatsoever for sighted users navigating via the keyboard. (I don't know enough about map, frame and scripting to comment on those, but as they have been grouped with H69, I suspect that they too are of little or no benefit to sighted people who navigate with the keyboard.)

Nonetheless, if someone writes a web page to H69, they would be deemed to have passed SC 2.4.1, even though they have not provided any method for sighted keyboard users to bypass blocks of content that are repeated on multiple pages. The most number of hits of the tab key that I counted before getting to the main page content on one web site was 69 each time I went onto a new page.

Proposed Change:
Please make it 'and' so that both sighted keyboard users and screen reader users are helped. At the moment it's perfectly possible to help only one of those groups and not help the other and still pass this SC.

Response from WG:

It is only necessary to implement one of the listed sufficient techniques for this, or any other, success criterion. Authors may choose to implement more than one technique to improve usability, of course.

Skip links may not be the preferred mechanism for screen reader users, but links work for them, so skip links will permit them to skip over the repeated content.

The User Agent Notes for H69 discuss the native support for navigating by headings that is provided in Opera, and notes that for other browsers, plugins may be needed. Authors who rely on H69 must ensure that it is accessibility supported for their users.

Response from commenter:

You've completely missed my point. If H69 etc is used to pass this criterion you are only helping screen reader users.

What about those of us who navigate with the keyboard but are sighted, ie do not use assistive technology of any sort? Correct heading structure is of no benefit what-so-ever to us.

If you don't want an AND, perhaps 2.4.1 should be split into two requirements so that the first requirement is to provide a method for keyboard users to bypass blocks and the second requirement is to provide a method for AT users to bypass blocks. As we both know there is a precedent for splitting a single SC into various requirements - 1.4.8.

Comment from Sailesh Panchang:

Sheena and I are not talking usability here but accessibility. And WCAG2 addresses needs of a wider spectrum of PWDs than just screen reader users. Sighted keyboard users are an important constituency for SC 2.4.1.
Yes headings work with screen readers and Opera but skip nav works for a wider set of users as stated earlier. For the limited purpose of SC 2.4.1, the skip-nav technique is a sufficient technique. H69 is not. It enhances "usability".
Use of headings may be required to satisfy SC 1.3.1 (see H42) and as an auxiliary benefit will help navigation too. By requiring H42 for SC 1.3.1 and the skip-nav technique for SC 2.4.1, the techniques will address the needs of a larger set of PWD and the WCAG 2 will do more for accessibility. Not less.
As H69 has user-agent limitations I had suggested do away with H69 as h42 is present some 2-3 years ago. I reiterate that.
Finally, one does not go around adding heading tags simply to help keyboard navigation but to mark up section headings to expose structure. But websites can be required to add one skip nav link as has been the practice since S508 became law.
There are many many U.S. fed gov websites that do not implement headings because it was not needed by S508 but do have skip nav link.
Not sure many are aware of a plugin to make keyboard navigation work with headings for browsers like IE and FF. Maybe a links should be given as a resource for H69 if it is retained. H69 may be an advisory technique ..

[1] http://lists.w3.org/Archives/Public/public-comments-wcag20/2011Mar/0011.html
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(Please make sure the resolution is adapted for public consumption)

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