Silver Substantially Conforms Subgroup

22 Oct 2020


jeanne, Wilco, Rachael, bruce_bailey, John_Northup


<sajkaj> Chair: Sajkaj

<PeterKorn> Good morning

<sajkaj> Indeed! Good Morning to you, Peter!

<jeanne> chair: Janina

<scribe> scribe: Wilco


Organizing our work: Purpose Statement; Enumerated Principles

Janina: The goal is to see if we can agree on what substantial conformance might look like in 3.0.
... There is already a conformance modal. Another model we want to look like is substantial conformance.
... The idea is for us to figure this out and propose something to Silver TF/CG.
... This would be passed to AGWG, if it gets agreement it would end up in a future draft of WCAG 3.0.
... Will not be in the FPWD, but perhaps for one in the near future. If it goes smoothly, it might be the next. My guess is early 2021.
... As a starting point, we want to consider defining our purpose and share it early with Silver TF and AG

Peter: Do other folks have other ideas. I have some early thoughts, but before I share that and take us in a direction I think it would be good to see if folks had specific things they want to see.

Rachael: No specific thoughts yet. I've heard a lot of ideas for it. I would suggest we start by listing different possibilities, talk about the tradeoffs. Different cut-offs, current cut-off, full conformance based on WCAG 2. etc.

Jeanne: We have built a lot of "substantial conformance" into the first draft. I think we have addressed as many issues as we could. Would like to see as an early step that the group decides what is missing that is essential.
... I think we have addressed the needs defined in the research.

Peter: I think it goes to a key question. Is the focus of this group about the words "substantial conformance" or is it problems that the existing conformance model doesn't address.
... These are two different things. If there are problems, the solution might not be associated with the words "substantial conformance".

Bruce: Would like direction in how much we should limit ourselves to "substantial conformance". I've seen the term used elsewhere. There is a recent bill that talks about substantial conformance to WCAG 2.0.
... The bill text charged Access board with defining what substantial conformance to WCAG 2 means.

Janina: I'm not surprised there are different ideas to what substantial conformance might mean. Heard different explanations. We may have some assumptions that are not necessarily ones we need to be bound to.

<jeanne> +1 for addressing the wider world that wants to be accessible.

Janina: We've met a lot of challenges, but I'm not sure we've addressed the wider world's wants. I know we're trying to not be web content and look at emerging tech.

Jeanne: Our charter is broader than that.

Janina: I'm a little surprised a bill was introduced, but we have some examples of the phrase in the wold. There are a number of websites say substantially conformant.

<jeanne> Charter <- https://www.w3.org/2019/12/ag-charter

<jeanne> Develop a new standard (name to be decided) to succeed WCAG 2.x based on the work of the Silver Task Force. The goal is to provide information that can be used to improve the accessibility of products when using the guidelines on a variety of platforms. As noted in the Draft Requirements, it will use a different framework to allow it to address more disability needs, address publishing

<jeanne> requirements and emerging technologies on the web such as web XR (augmented, virtual and mixed reality) and voice input. It will provide non-normative information about the ways web technologies need to work with authoring tools, user agents, and assistive technologies. This framework is intended to support better coverage across disabilities, and be easier to maintain, so that the new

<jeanne> framework will be more durable over time as technologies evolve. This will require development of a new conformance model, engaging policy makers in that process, and testing the model with policy makers from different settings.

Janina: There is a legal history to this concept in zoning laws. It is not surprising it falls into this space. We need to come up with something in WCAG 3.0.

<bruce_bailey> Proposed Online Accessibility Act in US Congress is Bad for Digital Inclusion

<Rachael> Wilco: EU uses the term in accessibilty statements that they require

<bruce_bailey> https://www.lflegal.com/2020/10/ada-backlash/

<Rachael> Janina: I'd like to add to wiki

Wilco: The EU has substantial conformance in its accessibility statement which it requires for government websites.

Peter: I would like to see us develop a problem statement. What is the problem statement, something new to address.

<Bryan> +1

Janina: Are we limited to one conformance model to WCAG 3.0? Would it be possible to have the current bronze/silver/gold approach, or could we have another way?
... I think this may draw the line differently. Are we open to the possibility of having more than one model under which to claim conformance to WCAG 3.

Jeanne: WCAG 2 has multiple conformance models. I think the president is that it is possible.
... I don't object to it, would be an interesting possibility to address the more complex issues.

Rachael: Worth exploring. I have no issue with multiple models.

Peter: At this early place I would suggest we not constrain our thinking. Whether it is a second approach, or fold into the current model.
... It seems like it starts from a collection of pages and moves upward, rather than from the site. I think it is important to look at it from the site first.

Jeanne: I agree, that is where we started. We came at this from a product-first approach. We've ended up down at a view level for testing, but our overall approach has been product first.
... The problems with that may continue, but would like to look at it again to see if we can find a different answer.

Sarah: What could be helpful is if we define what we mean when we say conformance.

Janina: There is a W3C document that tries to define conformance. It is a little old, 2005.
... That one allows different interpretation of conformance. It points to WCAG 2 levels as one possible approach.

<jeanne> W3C Conformance Definition <- Fulfillment by a product, process, systems, or service of a specified set of requirements.

<jeanne> https://www.w3.org/QA/glossary

Sarah: The conformance levels make sense. You can conform with all requirements, or not. If there are requirements you fail, you don't conform to that level. It is binary,
... I am concerned about the language that we use to talk about this. It creates wiggle room for things that are quite binary.
... What we're doing with the scoring is saying that despite the fact it does not conform with all outcomes, it achieves a conformance level. I think that is confusing.
... I like the levels a lot. The reason I'm here. The LEAD requirements are the requirements, you either pass them or you don't.
... I would like to make sure we keep the integrity of conformance as a concept and don't add squishiness to that.
... I've done a lot of audits and never seen anything fully conformant. I think certification levels are a good distinguishing factor.

<Rachael> WIlco: We talked about site and product certification. That is something that WCAG 2 tried to do for a long time and didn't succeed at. Its good to know that there are some lessons to be learned from the past. May want to hunt down the folks who worked on that.

Wilco: WCAG 2 also tried conformance from sites.

Janina: I think we need to find a way to draw the circle more widely.

Peter: What Janina and I talked about before was what term to try to use. The term conformance is loaded. It has a lot of meaning. I would like to suggest that we put off a deep-dive on what conformance means and focus early on what the problems are that drive people to some other term.
... What is the problem statement? What are the key ideas / principles of what term we use. If we're happy with the term, great, if it needs another term, cool. If bronze/silver/gold can accommodate all this, also cool.
... The fact we're seeing this term all over made sense, but I suggest we focus first on what the problems should be, rather than going down terminology ratholes early.

Jeanne: Agree with Peter

Bryan: Agree with Jeanne and Peter. Understanding who we're serving, the end user, the organisation, or the standards body, and then being able to say what our thinking on substantial conformance is, and getting feedback from those stakeholders is valuable.

Jeanne: The Silver work started by doing research and doing stakeholders. We did 18 months of research.
... Had a design sprint at TPAC 2018, with a 2 day workshop to propose solutions. We spent 2 years prototyping and coming up with a conformance model.
... It is important to understand what is in the conformance model. Primarily the needs for very large and very small organisations, the need to conform without having perfection. We did this without having bronze/silver/gold.

<Zakim> jeanne, you wanted to talk about what actually is in the WCAG3 Conformance model

Jeanne: Where we're doing substantially conformant is in the scoring, not in the levels. We put a lot of flexibility in there for organisations who are trying to get a good score, even if it is not perfect.
... I don't want to start over. A lot of work has been done. We need to identify what the problems are we're trying to solve.

Bryan: I think it aligns with what Peter has said, building on existing work is valuable.

<PeterKorn> It may be extremely challenging, if not impossible with today’s technology, for large websites to conform to either WCAG2, or the draft conformance model of WCAG3. Reasons include the need for human evaluation in both models

<PeterKorn> which doesn’t scale, situations with large amounts of 3rd party content, as well as programmatic page generation which like all software will contain bugs – including bugs impacting accessibility. To enable these sites to make a

<PeterKorn> strong statement about the accessibility of their site, we will develop the concept and define the term Substantial Conformance, and develop model for assessing whether a site Substantially Conforms to WCAG 3.

<PeterKorn> • Substantial Conformance should set a high, but achievable, accessibility bar. Substantial Conformance mustn’t be “a hole big enough to drive through”, that excuses or blesses fundamentally inaccessible websites

<PeterKorn> • Substantial Conformance should be reflective of the lived experience of website visitors with disabilities – sites that are Substantially Conformant to WCAG 3 should enable website visitors with disabilities to accomplish what they want on the site with a minimum of difficulty.

<PeterKorn> • Substantial Conformance assessments should be modeled around what the site is designed for, and leverage expected user interactions with the site (e.g. what are the P0, P1 tasks, and evaluating the accessibility of those paths through the site for those tasks)

<PeterKorn> • Substantial Conformance should leverage programmatic tests where they are able to accurately assess WCAG guideline support at scale (if a programmatic test would have found it, then it is a bug to be fixed)

Peter: A lot of what the WCAG 3 model does is here.

<PeterKorn> • Substantial Conformance should be designed with 3rd party content in mind; there shouldn’t a notion of “partial substantial conformance” that only looks at 1st party content. The language of a Substantial Conformance assessment might nonetheless call out any 3rd party distinctions.

<PeterKorn> • All software – and likewise all dynamic websites – of large enough size or complexity has bugs; this is unfortunately unavoidable. Websites that are Substantially Conformant should have no greater an

<PeterKorn> acceptance of accessibility bugs as the site has for bugs generally, nor should accessibility bugs be dispropotionately represented among the number or severity of bugs found.

Peter: This is the biggest gap from my reading of WCAG 3.

<PeterKorn> • Beyond what may arise naturally from a greater emphasis on programmatic testing vs. human evaluation, Substantial Conformance shouldn’t give preferential treatment to the needs of one disability over that of

<PeterKorn> another (e.g. a Substantially Conformant site shouldn’t be great for blind folks but horrible for folks with motor impairments)

<PeterKorn> • Substantial Conformance isn’t appropriate for sites that are largely static; we aren’t designing something intended to replace WCAG 3 Conformance in all situations

<bruce_bailey> It may be extremely challenging, if not impossible with today’s technology, for large websites to conform to either WCAG

Bruce: Agree with the middle, but not the beginning and end part. I'm seeing a lot of questions from small businesses.

<bruce_bailey> Substantial Conformance isn’t appropriate for sites that are largely static;

Bruce: I don't know if this isn't applicable to static sites.

Jeanne: Would like to see this in a Google doc to comment on

Summary of Action Items

Summary of Resolutions

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