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Results of Questionnaire WCAG2ICT - Review proposed changes to address Issue 145

The results of this questionnaire are available to anybody. In addition, answers are sent to the following email address: maryjom@us.ibm.com

This questionnaire was open from 2024-04-16 to 2024-04-24.

6 answers have been received.

Jump to results for question:

  1. (Part 1 of 3) Issue 145: Add info/content on the WCAG exemptions in regulatory work
  2. (Part 2 of 3) Issue 145: Add info/content on the WCAG exemptions in regulatory work
  3. (Part 3 of 3) Issue 145: Add info/content on the WCAG exemptions in regulatory work

1. (Part 1 of 3) Issue 145: Add info/content on the WCAG exemptions in regulatory work

The review of the changes for Issue 145: Add info/content on the WCAG exemptions in regulatory work will be split into 3 parts. One part for each source file that changed, which hopefully will make the review more manageable. The pull request that was made takes into consideration previous TF survey results and discussions on what we should (and can) include in WCAG2ICT.


For this question, review the changes to the indicated Note in the general WCAG2ICT guidance for 5 success criteria. The change is the same in all of those locations.


The file to review for this question is comments-by-guideline-and-success-criterion.md where two sentences were added to the end of the affected note for the Success Criteria interpreted to apply to "sets of software" and "sets of software programs".


You can read the changes in the context of the full document by using the following links:

Indicate whether these changes are ready to incorporate into the editor's draft.

Summary

ChoiceAll responders
Results
These changes are ready to merge, as-is. 1
These changes need some edits. (Be specific about your proposed changes either in the survey or on the PR.) 3
These changes are not ready. (Be specific about why and what your alternate proposal is.) 2

Details

Responder (Part 1 of 3) Issue 145: Add info/content on the WCAG exemptions in regulatory workComments
Laura Miller These changes are ready to merge, as-is.
Chris Loiselle These changes are not ready. (Be specific about why and what your alternate proposal is.)
Sam Ogami These changes need some edits. (Be specific about your proposed changes either in the survey or on the PR.) I agree with Bruce changes.
Mike Pluke These changes need some edits. (Be specific about your proposed changes either in the survey or on the PR.) I like Bruce's proposal on the wording - I think it better expresses what I think most of us believe.
Bruce Bailey These changes need some edits. (Be specific about your proposed changes either in the survey or on the PR.) Instead of:
> Regulators should consider the applicability of this success criterion to non-web documents and software.

How about something stronger? Perhaps:
> Regulators should consider if this success criterion is appropriate to apply to non-web documents and software.
Gregg Vanderheiden These changes are not ready. (Be specific about why and what your alternate proposal is.) maybe include this as a 4th>


Option 4: This success criterion in WCAG relates to “sets of web pages”. For software, this would mean “sets of software” that are meant to be viewed as a single unit. These are extremely rare. For non-web documents, it would similarly mean non-web (electronic) documents published together at the same time and meant to be used as a single entity. This is less rare but would still be limited to things that are essentially one ‘document’ broken up into pieces for convenience. See full definition of "set of documents" and "set of software programs" in the Key Terms section of the Introduction. (Note to WCAG2ICT team — this one is longer but I think it is important for this advice to make sense in place - rather than only kicking them up to the key words section. so I think a longer note on these should be provided.)

2. (Part 2 of 3) Issue 145: Add info/content on the WCAG exemptions in regulatory work

For this question, review the changes made in the file introduction.md where some content was split into a new section and additional guidance was added for regulators. To read the changes in-context, see Interpretation of Web Terminology in a Non-web Context where the new paragraph appear after the Note.

Indicate whether this content is ready to incorporate into the editor's draft.

Summary

ChoiceAll responders
Results
The updates proposed for the introduction are ready to incorporate, as-is. 1
The updates proposed for the introduction is ready to incorporate, with some edits. (Provide the specific changes needed.) 1
The updates are not ready. (Provide an alternate proposal either in the survey or the issue) 4

Details

Responder (Part 2 of 3) Issue 145: Add info/content on the WCAG exemptions in regulatory workComments
Laura Miller The updates proposed for the introduction are ready to incorporate, as-is.
Chris Loiselle The updates are not ready. (Provide an alternate proposal either in the survey or the issue)
Sam Ogami The updates are not ready. (Provide an alternate proposal either in the survey or the issue)
Mike Pluke The updates are not ready. (Provide an alternate proposal either in the survey or the issue)
Bruce Bailey The updates are not ready. (Provide an alternate proposal either in the survey or the issue) I am of the opinion that this section can and should be updated to be responsive to the new rule under ADA Title II for website and mobile app accessibility -- which references WCAG2ICT as the authoritative source for addressing application of WCAG to non-web documents and software.

@Laura and @Chris, statute and litigation was a key consideration for WCAG2ICT in 2013 and regulators were part of the target audience then. I would argue that SME guidance for regulators is needed now more than it was in 2013. Such considerations are reflected in the work statement. See: https://www.w3.org/WAI/GL/task-forces/wcag2ict/work-statement
Gregg Vanderheiden The updates proposed for the introduction is ready to incorporate, with some edits. (Provide the specific changes needed.) I think that all the info about what other standards have done in the past is more than we should include. They may change their mind in the future. We should leave their judgements to them and not freeze them by documenting them here. A simple comment should suffice I think. I would not hold up consensus over this however.

3. (Part 3 of 3) Issue 145: Add info/content on the WCAG exemptions in regulatory work

For this question, review the changes made in the file success-criteria-problematic-for-closed-functionality.md where a statement was added to the introductory content for this section. To read the changes in-context, see Success Criteria Problematic for Closed Functionality where the new proposed content appears in paragraph right before the bulleted list.

Indicate whether this content is ready to incorporate into the editor's draft.

Summary

ChoiceAll responders
Results
Incorporate proposed text, as-is.
Incorporate proposed text, with edits. (Specify the exact changes needed.) 2
Something else. (Make your alternate proposal either in the survey or the issue.) 4

Details

Responder (Part 3 of 3) Issue 145: Add info/content on the WCAG exemptions in regulatory workComments
Laura Miller Something else. (Make your alternate proposal either in the survey or the issue.) Do we really want to speak to regulators rather than developers/deployers of content with this note? Ultimately, the goal is for developers/deployers to make the content accessible to assistive technology. Is that what this note accomplishes? Suggested replacement:

"For non-web software on closed functionality products, the product must be fully accessible through the use of assistive technology. This should be considered in the application of individual WCAG 2 success criteria. Alternate accessibility provisions might be needed to cover the user needs addressed by the following:..."

Note this content from the DOJ in their recent statement about website accessibility and state and local government requirements:
" However, the Department is concerned that WCAG 2.1 could be interpreted to permit a segregated approach and a worse experience for individuals with disabilities. The Department also understands that, in practice, it can be difficult to maintain conforming alternate versions because it is often challenging to keep two different versions of web content up to date.
For these reasons, as discussed in the Section-by-Section Analysis of § 35.202, conforming
alternate versions are permissible only when it is not possible to make web content directly
accessible due to technical or legal limitations"
Chris Loiselle Something else. (Make your alternate proposal either in the survey or the issue.) For all three of these answers to the part 1-3 survey, instead of regulators, could we perhaps use the word "stakeholders or implementors of this note's objectives" rather than only concentrate on regulators? I feel our work is geared toward whether or not WCAG2ICT applies, not what a regulator should or shouldn't do with that we are providing to the collective whole in terms or the overall note. WAI has https://www.w3.org/WAI/policies/ . That page has "The information on this page is not legal advice. Please consult legal authorities for the appropriate jurisdiction." That is more broad and not specific to "regulators" who may or may not enforce this from a legal perspective.

Apologies if I'm misreading the intent of this issue or the topic!
Sam Ogami Something else. (Make your alternate proposal either in the survey or the issue.) Due two three comments by Laura, Chris, and Bruce needs more work before voting on.
Mike Pluke Something else. (Make your alternate proposal either in the survey or the issue.) I very much like Laura's proposal. It explains very clearly what everyone who is attempting to apply WCAG to documents and software, **including regulators**, need to consider.
Bruce Bailey Incorporate proposed text, with edits. (Specify the exact changes needed.) +1 to GV proposed text (in this survey) for the keyboard-oriented SC.

In this section, change "Requires" to "Is dependent upon" or "Cannot be met unless there is" or "Conditioned by" or "Has a prerequisite for" or similar.

Also, I suggest adding more emphasis into this phrase:
> regulators should consider the applicability of individual WCAG 2 success criteria.

Proposed:
> regulators should consider the applicability of **individual** WCAG 2 success criteria, on an SC-by-SC basis.
Gregg Vanderheiden Incorporate proposed text, with edits. (Specify the exact changes needed.) This should read :
"Alternate OR ADDITIONAL accessibility provisions might be needed to cover the user needs addressed by the following:"

and this should read:
Keyboard would apply to systems which are closed to screen readers, but have a physical keyboard, a connector for standard keyboards, OR ALLOW THE INSTALLATION OF ALTERNATE KEYBOARDS. ( <--- this latter is true for both Android and iOS devices)

More details on responses

  • Laura Miller: last responded on 17, April 2024 at 16:00 (UTC)
  • Chris Loiselle: last responded on 17, April 2024 at 16:04 (UTC)
  • Sam Ogami: last responded on 17, April 2024 at 22:09 (UTC)
  • Mike Pluke: last responded on 17, April 2024 at 22:18 (UTC)
  • Bruce Bailey: last responded on 18, April 2024 at 13:34 (UTC)
  • Gregg Vanderheiden: last responded on 18, April 2024 at 15:18 (UTC)

Non-responders

The following persons have not answered the questionnaire:

  1. Shadi Abou-Zahra
  2. Mary Jo Mueller
  3. Loïc Martínez Normand
  4. Mitchell Evan
  5. Charles Adams
  6. Daniel Montalvo
  7. Fernanda Bonnin
  8. Shawn Thompson
  9. Olivia Hogan-Stark
  10. Anastasia Lanz
  11. Devanshu Chandra
  12. Bryan Trogdon
  13. Thorsten Katzmann
  14. Tony Holland
  15. Kent Boucher
  16. Phil Day

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