Submitted by the W3C WAI Education and Outreach Working Group (EOWG), 25 April 2009
[last updated $Date: 2009/04/25 17:43:52 $ UTC]
This review presents a summary of a discussion of the First Public Working Draft of Improving Access to Government through Better use of the Web. The discussion occurred among members of the Education and Outreach Working Group (EOWG) of the W3C's Web Accessibility Initiative (WAI). We understand the importance of this subject and appreciate the work of the eGovernment Interest Group in addressing it. The EOWG reviewed the document from the perspective of WAI and our observations grouped into the three topics that are listed in the Contents above.
Because the participation in e-government is so important, accessibility is critical and foundational to the rights of citizenship. As more communication occurs online between citizens and their governments the two-way dialogue must be fully accessible. People with disabilities and older citizens can participate much more equitably than ever before in history when technology is barrier-free. Additionally, research has shown that accessible technology tends to be more usable and understandable by an even broader constituency. The implications are huge. The EOWG observed that the issue of accessibility could therefore be justifiably emphasized far more clearly and emphatically within this document.
EOWG requests the opportunity to review the next draft before the final version is published because the issues in the First Public Working Draft are significant.
The following sections include our observations and suggestions for improvement within the specific area of accessibility and citizens with disabilities. However, we also identified other phrasing that could lead to serious misinterpretations; for example, some in EOWG understood "Provide input on how to ease standards compliance" to mean that the standards themselves should be made less stringent but others understood it differently. Thus, we suggest that the eGov IG enlist additional editing support from a skilled editor familiar with this type of writing and sensitive to possible misinterpretations.
Note that we re-used your language in our suggested alternatives as much as feasible, although in several cases we think it needs to be edited.
Some EOWG members have additional concerns that are not within the scope of these comments focusing on accessibility for people with disabilities and older citizens. We asked individuals to submit those comments separately.
(In order to submit these comments before the deadline, minor changes were made after EOWG discussion and all participants may not have reviewed them before they were submitted.)
The title of the document uses the word "access" in the broadest sense in reference to the rights of all citizens to enter and use government websites. "Access" makes sense in that context and is appropriate. However, the words "accessible" and "accessibility" are also used within the document, sometimes in the same broad sense and sometimes to refer specifically to people with disabilities and older users.
The EOWG requests that the document reserve the use of the words "accessible" and "accessibility" for the latter meaning. This is both consistent with the use in the rest of the W3C documents and a way to avoid confusing readers about the intent.
The content of this paragraph seems to conflate the accessibility needs of people with disabilities with the information access needs of other kinds of users. EOWG requests that the document make a distinction between "accessible" to people with disabilities and the "lack of access to information" that is due to other situations.
Current content: Four key trend areas must be accounted for...
Suggested alternative: Change "Four key trend areas..." in the the introductory paragraph to "Five key trend areas..." and then edit and add an additional bullet as follows:
Current content: "Unfortunately, much PSI was and is still being published using proprietary formats or in ways that make it not accessible to all the interested parties, such as a disabled person that cannot access the content on a Web page, a person using a mobile device or an old computer, or someone using a computer without a required proprietary software.
Suggested alternative: "Unfortunately, much PSI was and is still being published using proprietary formats or in ways that create barriers of use for various interested parties. Examples include device incompatibilities for those using mobile devices or older hardware, the lack of information available to those using computers without the required proprietary software, and accessibility barriers experienced by people with disabilities."
Current content: "For the purposes of this Note, Government Data is the same as PSI, while Open Government Data means the publication of PSI in open raw formats and ways that make it accessible to all and allow reuse..."
Suggested alternative: "For the purposes of this Note, Government Data is the same as PSI, while Open Government Data means the publication of PSI in open raw formats and ways that make it accessible and readily available to all and allow reuse..."
There are two assumptions within the first paragraph of the subsection "Inclusive Access to Information" that could be misunderstood. We have addressed these assumption separately and suggested a rewritten paragraph to address both.
The text seems to include people with disabilities in a group with those who are not yet online for other reasons. The fact is that many people with disabilities are on the Internet. The barriers they experience should be framed in a separate question specific to accessible design and conformance to guidelines.
(The suggested alternative for this is point is under the next section, 1.2.2.)
Lack of standards conformance by "third party social networking and community" is true, but the wording here is misleading in it's assumption that most government sites currently exhibit a high level of conformance. In fact, most government websites do not meet accessibility standards. A UN report from 2006 found that accessibility conformance among government sites was "dismal"; very few met WCAG Level A and not one met Level AA or higher. Even where accessibility is required by law, many sites are not accessible to people with disabilities.
We are uncomfortable with the wording "the high standards of accessibility that government Web sites are required to attain". With "high standards" and "required", this can be interpreted negatively. In fact, some government accessibility standards are not high at all. For example, many people think that the current US Section 508 standards are too low and do not provide sufficient accessibility for some people with disabilities.
Current content: Inclusive Access to Information
How are the interests of those not on the internet protected? What about the rights of those with physical impairments? Many third party social networking and community Web sites do not adhere to the high standards of accessibility that government Web sites are required to attain, in many countries by law.
Suggested alternative: Inclusive Access to Information
How are the interests and rights of people with disabilities and people who are not yet on the Internet protected? Many government, social networking and community websites are not accessible to people with disabilities and older people, even where required by policies or laws.
EOWG observed instances of statements or inferences that seemed out of alignment with official W3C positions regarding accessibility. The following are examples, yet we suggest thorough examination by the editor for consistency with W3C positions on accessibility.
When referring to people with disabilities, please use "people first" language, which is a form of reference in which the subject is a person first, e.g., "people with disabilities" rather than "the disabled". Particularly in section "Inclusive Access to Information" we are concerned about the implications of some of the phrasing. For some helpful references, please see the Introduction to Accessibility.
The following suggestion includes visual, hearing, and cognitive disabilities as well as the mobility issues implied in "physical impairments".
Current content: What about the rights of those with physical impairments?
Suggested alternative: What about the rights of people with disabilities?
Current content: ...disabled person that...
Suggested alternative: ...person with disabilities who...
EOWG strongly disagrees with this interpretation and believes that is probably not the intention of the eGov IG. We suggest that this should be reworded to remove doubt. If the suggestion is that government entities participate more actively in standards creation and/or that standards bodies provide additional support to ease the acceptance of standards, those points should be expressed more clearly.
Current content: "Governments have some unique requirements (e.g. enforcing certain policies about information privacy) and sometimes spend considerable effort in adapting some standards to their specific needs. Having those requirements reflected in the standards produced at W3C would be beneficial for all."
Suggested alternative: "Governments have requirements and responsibilities to provide full citizen access and protect citizen interests (e.g., privacy). Instead of waiting until after standards are completed and spending effort adapting standards, government representatives should actively participate in standards development in order to ensure that their interests are fully understood and considered in the standards produced at the W3C."
Current content: "Provide input on how to ease standards compliance: use previous successful experiences in terms of broad government use (such as the Web Accessibility Initiative work) to identify ways for standard bodies to better speak in terms of government needs; for example, additional effort to package, promote, and train on best practices and existing material and tools."
Suggested alternative: "Provide input to help governments comply with standards: for example, standards bodies could provide training and outreach materials on best practices and tools, and improve the packaging and promotion of existing material. The work of W3C's Web Accessibility Initiative (WAI) is an example of a successful education and outreach program that helps governments achieve compliance goals."
When making references to accessibility requirements and support materials, please reference the acronym of WAI and link to the WAI home page. (Example illustrated in 2.2.2, above and there may be more references as the document is revised.)
In the discussion of proprietary software and open government data, please consider a reference to accessibility supported and to assistive technologies. The following from the section "What Public Policy Outcomes are Related to Open Government Data?" is one example and there are likely to be others as the document is revised.
Current content: "Inclusion: providing data in open standard formats allows anyone to use numerous software tools to adapt it to one's needs. For example, an XML [XML] dataset or RSS [RSS] feed could be transformed and properly available to various devices and to people with various capabilities."
Suggested change: "Inclusion: providing data in open standard and accessibility supported formats allows anyone to use numerous software tools to adapt it to personal needs. For example, an XML [XML] dataset or RSS [RSS] feed could be transformed and properly available to various devices, including assistive technologies used by people with disabilities."
The needs of people with disabilities should be more clearly addressed in the document. We recommend additional sections specifically covering accessibility, as well as that is accessibility better integrated throughout the document. EOWG encourages the eGov IG to integrate and explicitly reference accessibility for people with disabilities in all aspects of successful e-government policies.
The following are some suggestions, but should not be considered a complete list. Instead the eGov IG should, in editing the document, look for relevant places where references to the specific needs of people with disabilities and older citizens should be included within the document. Judy Brewer, WAI Domain Lead, will be submitting additional suggestions.
Accessibility for people with disabilities, as well as for older people with accessibility needs due to ageing, needs to be explicitly covered. Below is suggested wording. This might fit in the "What Public Policy Outcomes are Related to Participation and Engagement?" section under a new subheading "Ensuring Equal Access", or when the document is edited, it might fit in another section.
Web accessibility is essential for equal opportunity. The Web is an important medium for receiving information as well as providing information and interacting with society. Therefore it is essential that the Web be accessible in order to provide equal access and equal opportunity to citizens with disabilities and older citizens. An accessible Web can also help citizens more effectively interact with government.
The Web is an opportunity for unprecedented access to information for people with disabilities. That is, the accessibility barriers to print, audio, and visual media can be much more easily overcome through Web technologies. The Web is also an opportunity for unprecedented interaction for people with disabilities.
For example, the act of completing a government form once required going to a government office and completing the form on paper. That act presented significant barriers for many people with disabilities, including getting to the office, reading the form, and completing it in writing. When that same form is also available on the Web in an accessible format, it is significantly easier for many people to complete. Therefore, people with disabilities can have more effective and efficient access to government interaction through accessible Web sites - in some cases, where there was essentially no access to them before.
An accessible Web expands opportunities for communication, interaction, and employment for people with disabilities throughout governments.
The empowering nature of technology provides a means for the large and growing numbers of people with disabilities and older users to contribute in unprecedented ways to society. Technology supports activities such as reading and writing documents, communicating with others, and searching for information on the Internet - tasks in which people with disabilities can now participate more readily than ever before. The fact that citizens with disabilities can access government information and services from their homes has special significance due to transportation and communication barriers that this group has historically encountered. These are critical reasons to ensure that e-government is open and accessible and should be noted in the introduction.
Suggested addition: [We encourage the eGov IG to significantly edit the introduction for brevity, clarity, and the inclusion of accessibility to people with disabilities. One of the main points to get across is: Equal access to government information and services is the right of every citizen, regardless of disability. This basic human right is recognized in the United Nations Convention on the Rights of Persons with Disabilities, which specifically mentions the Internet and other accessible information and communications technologies (ICT).]
The section on "Participation and Engagement" (P&E) should address the fact that technology facilitates people with disabilities taking active part in governmental activities. There are several sub-sections of this topic that have particular relevance to the participation of this large and growing group of citizens. The following examples can be used as a model for integrating the issue throughout the document.
This sub section is then further divided into another layer of subsections. We suggest to rethink the layers for clarity, and to add coverage of people with disabilities.
Suggested addition: [Add a new subheading "Ensuring Equal Access". The text for this section might be what is listed under 3.1 above, or other text, depending on how the document is edited.]
The paragraph needs a mention of assistive technology as an interoperability requirement.
Current content: "Interoperability can be achieved at different levels, ranging from local / departmental to the national and international levels."
Suggested alternative: "Interoperability is a goal for government systems at every level - departmental, local, national, and international. An important aspect of interoperability is enabling citizens who are using assistive technologies, mobile devices, and older software and hardware."
The paragraph "Easier for the Citizen" needs mention of the ways that technology enables participation by citizens with disabilities in unprecedented ways.
Current content "Before digital exchange of data, citizens were requested to present many documents that were issued by other governmental departments. The task of requesting the different documents from other administrations was sometimes left to the citizen. In an interoperable scenario, data exchange happens behind the scenes."
Suggested addition to this content: "Before digital exchange of data, citizens were requested to present many documents that were issued by other governmental departments. The task of requesting the different documents from other administrations was sometimes left to the citizen. This could be difficult for many and nearly impossible for those with disabilities or the elderly with transportation or communication constraints. In an interoperable scenario, data exchange happens behind the scenes."
Optional (Depending on how assistive technology is addressed in response to previous suggestion): "It is therefore critically important for government applications to ensure that information and services are offered using technology in ways that are accessibility supported.
Thanks for your consideration and we look forward to seeing the next draft.