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"4.8.1.1.14 When a text alternative is not available at the time of publication" Uneasy about the harm reduction technique of providing the file name instead of alt "when alt is not available"... Most AT speaks file name anyway. Perhaps consider stronger language discouraging it, and make it clear that it violates WCAG. For sighted folks ALT is almost always available, although it may be imprecise or in the case of a web master, because he may not know the "equivalent purpose" since he does not know the intended purpose of the author... I'm concerned about the perception that it is not a big deal that alt is missing.
The warning is: Note: Since some users cannot use images at all (e.g. because they are blind) the alt attribute is only allowed to be omitted when no text alternative is available and none can be made available, as in the above examples. "is only allowed" by who, HTML5? if so we should put that limitation.... because WCAG does not allow this, neither do any applicable laws which have adopted the WCAG, so authors may think they are off the hook, and may be subject to a breach of law for not having ALT text. Perhaps add: Note: Since some users cannot use images at all (e.g. because they are blind) the alt attribute is only allowed <add>in this specification</add>to be omitted when no text alternative is available and none can be made available, as in the above examples. <add>However, it my not be allowed under accessibility laws.</add>
The section on markup generators says it is really bad to use file name, yet in the section before we recommend it if the alt is not available. 4.8.1.1.19 Guidance for markup generators This is intended to avoid markup generators from being pressured into replacing the error of omitting the alt attribute with the even more egregious error of providing phony text alternatives, because state-of-the-art automated conformance checkers cannot distinguish phony text alternatives from correct text alternatives... Markup generators should generally avoid using the image's own file name as the text alternative..
img without an alt attribute does not violate WCAG