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Comment (Including rationale for any proposed change): NOTE: Below is a rough summary of EOWG participants' comments, which EOWG did not have time to polish and approve. Please see the direct perspectives archived at <https://www.w3.org/WAI/EO/wiki/WCAG_Comments_February_2014#alt_issue> EOWG is glad that the WCAG WG is developing more WAI-ARIA Techniques. However, in reviewing the issues around ARIA10 and F65, we have significant concerns that misunderstandings would lead to lack of appropriate alternative text for many users. Allowing aria-labeledby and not requiring the HTML alt attribute could lead to misuse of aria-labeledby when the alt attribute is a better solution. The use cases cited and the examples in ARIA10 do not seem compelling enough balanced against the risk of misunderstandings that could lead web authors to conclude that aria-labeledby can be used interchangeably with the HTML alt attribute. Additionally, if HTML alt attributes were no longer a clear requirement, it would "muddy the water" for less careful developers and more of them would just not put any alternative text at all. Givens: 1. aria-labeledby is not supported by the tools that many people still use today. 2. Many developers don't understand accessibility-support. 3. Some developers like to use the latest hot markup just for the sake of it. Thus a likely scenario: some developers use aria-labeledby in cases where the alt attribute is a better solution, just because it's new, and not realizing its limitations. We also find compelling that alt attributes display onscreen when images are disabled and aria attributes do not, thus the outcomes are not equivalent. EOWG asks the WCAG WG to continue to consider how this issue is addressed. Perhaps allowing aria-labeledby instead of HTML alt attribute is not worth the risk? If the WCAG WG decides to leave ARIA10 and amend F65, we strongly urge you to provide very clear guidance about use and cautions, for example, advising authors that the alt attribute is the best solution for providing alternative text in almost all situations, and should be used whenever; and including the cautions about using aria-labeledby instead of the alt attribute. (Probably this goes in Understanding and linked to from the Techniques?)