The slides and speakers notes from my CSUN 2010 presentation: “Ten Years of Web Content Accessibility Rules: Time for a Rethink?”

Following my talk at the CSUN conference in March 2010, several people have asked me to make available the slides. They also asked if it would be possible to get a transcript since many of the slides just contain a few words to highlight what I was saying.

SUMMARY

My presentation was primarily concerned with whether or not the way we have encouraged/required the development of accessible sites in the past has been successful, and how we might improve the accessibility of the web in the future.

Rather than complaining about the possible failings of past, I believe after a decade of accessibility rules it is time explore options for the future: We need to enhance the acceptance of accessibility guidelines; raise the overall awareness of the need for improved web content accessibility; address the cost of access to information for assistive technology users; and, improve the ability of people with disabilities to use assistive technologies and standard user agents like browsers.

In the real world, most people now accept that the needs of people with disabilities should be accommodated in public transport and building design. When it comes to the web however, I am concerned that many still view accessibility through the lens of charity and not rights. Too often the needs of people with disabilities who use the web are dismissed and web site accessibility is considered an add-on, something to be done only when time and money permit. Rules alone are not enough. Attitudes and behaviour both also need to change.

SPEAKERS NOTES

I don’t have a verbatim transcript of the presentation; however my talk kept close to the following quite extensive speaker’s notes. Sorry there are so many words, but I can say a lot in 50 minutes.

SLIDE 1:
Many thanks for coming to this presentation.

We have had rules and laws relating to the accessibility of websites for about ten years. During this session I plan to look at the role they have played in encouraging, or requiring, developers and their clients to consider accessibility when developing sites.

While I will be talking in part about WCAG 2.0, I don’t propose to go over the POUR principals. I think we are all pretty familiar with them by now. Rather, I hope to highlight a few potential areas of concern and make a few suggestions for the future.

SLIDE 2:
There is a tendency to consider website accessibility primarily from the perspective of people with impaired vision. In particular, accessibility is often equated with how well a site and the information it contains can be accessed by someone who relies on a screen reader.

But of course, as we all know there are many other forms of disability and what works well with a screen reader may not always meet the needs of people with other disabilities.

SLIDE 3:
But first, to get a snap shot of the extent of different disabilities I have turned to the Disability, Ageing and Careers survey which the Australian Bureau of Statistics undertakes every five or so years. For this survey, a disability is defined as something that restricts one or more core activities, such as self-care, mobility and communication.

This Disability Survey found that about a third of the respondents indicated their disability related to sight, this amounts to about 7% of the total population. The degree of sight impairment is very varied, and by no means do all these people rely on assistive technologies such as screen readers or magnifiers to use the web.

The next largest category is physical with about 20% of the respondents, followed by hearing with 11%.

For a variety of reasons it appears that surveys like this under report the number of people with cognitive disabilities and learning disorders.

SLIDE 4:
So how many people have a cognitive or learning disorder?

Work done in 1999 by Jaye Johnson and Edith Cowen university in Western Australia provides some answers. Johnson surveyed year 12 students (the final year before Tertiary education) and found that intellectual disabilities, which included learning disorder, were by far the highest proportion of disabilities.

9% of students with disabilities reported visual loss as their major disability. Whereas, when we combine Intellectual disability and autism we get a figure of nearly 60%.

SLIDE 5:
Also, research by the Australian Learning Disabilities Association suggests that about 10 to 12% of the population of Australia have a learning disability, with 4% being severely affected.

I have made this brief mention of cognitive and learning disorders because even though it probably comprises the largest number of people with disabilities in our community they are often overlooked.

And, in my view there are not given sufficient consideration in Version 2 of the Web Content Accessibility Guidelines.

SLIDE 6:
During the last decade or so one of the most significant shifts in terms of accessibility has been the move from what could be basically described as a charity model, where favours are dispensed to those in needs, to the notion of social inclusion.

What do I mean by social inclusion?

In short, it is about having a society where all people feel valued, their differences are respected, and their basic needs are met so they can live in dignity. In essence, the opposite of exclusion, which sees people excluded from participating fully in the social, economic and cultural life of a community as a result of their difference, be it income, race, gender or abilities.

Although we like to rejoice in the notion that all ‘men are created equal with inalienable rights’, this hasn’t always been the case.

Let us not forget, not 200 years ago there was slavery in so called “civilised” countries like the US, the UK and yes Australia; a hundred years ago women didn’t have the right to vote; and just 50 years ago the Aboriginal people of Australia were not counted in the census and basically had no rights at all, including the freedom to move around the country and live where they wished.

So what is the point of this polemic rave you might be thinking?

In the real world, most of us no longer think that it is all right to own slaves or the right to vote, own property or move to another city should depend on a person’s gender or racial origin.

Similarly, I believe most people now accept that the needs of people with disabilities should be accommodated in public transport and building design. And, there is increasing awareness of the abilities of those who were often stigmatised as disabled in the past. There is a growing recognition of the distinct cultural and linguistic identity of the Deaf community, and a far greater appreciation of the special talents of many people with cognitive disabilities.

When it comes to the web however, I am concerned that many still view accessibility through the lens of charity and not rights. Too often the needs of people with disabilities who use the web are dismissed and web site accessibility is considered an add-on, something to be done only when time and money permit. Consequently, while rules prohibiting discrimination against people with disabilities are important, what I feel we fundamentally need are changes in attitude. I go into these ideas in more detail in the article “Social Inclusion and the Web” on my Blog

SLIDE 7:
A little more than 10 years ago the W3C introduced Version 1 of the Web Content Accessibility Guidelines. Australia, along with a number of other countries, now has laws that require websites to not discriminate against people with disabilities. In many cases, these regulations use the WCAG checkpoints as the benchmark for accessibility.

At about the same time, the US Access Board released the 1194 Web Standards that relate to amendments to Section 508 of the Rehabilitation Act. These Standards, along with the American with Disabilities Act and other Federal and State laws underpin the requirement for website accessibility in the US.

There is not a whole lot of difference between the Guidelines of WCAG 1.0, and the Standards of Section 508. Both focus primarily on using W3C technologies such as HTML appropriately. Section 508 however does make provision for the use of JavaScript, applets and other non-W3C formats.

Another significant difference between the situation in the US and that in Australia is that 508 relates to the procurement and use of information technologies by Federal Agencies, while in Australia there is no requirement for agencies to consider accessibility when purchasing products like Content Management Systems or authoring tools.

SLIDE 8:
The web has moved on a lot in the last 10 years, I don’t the remember details of what we were using the web for back in 1999, but a quick look at the most visited sites by Americans and Australians today gives us a bit of an idea what we are doing now.

SLIDE 9:
It’s hard to find reliable data about web usage, but I think the information provided by a company called Alexa probably provides a pretty good indication.

This list indicates how many of the top 100 most visited sites in Australia and the US are in different categories, like social networking, search and let us not forget porn. The largest category, are those sites concerned with the I.T. and Web industry, followed by social networking and then search. The number of porn sites was far few than I would have thought, perhaps because these sites and their users are good at covering their tracks.

I guess it would come as no surprise to hear that Google is the most visited site now.

SLIDE 10:
The Nielsen company recently compiled a list of the 100 most visited sites in January this year, and the results are much the same as those from Alexa.

This Treemap of the top 100 sites prepared by the BBC represents the Nielsen data. The largest categories being: Search, Media, Retail, Software and Social Network including video, blogs etc

For me, this information about web usage today highlights a few interesting things:

• Our huge reliance on search sites and tools for locating resources on the web,
• The explosion of social networking and sharing sites like Facebook, Twitter and Youtube.
• Also, the amount of buying and selling that is going online today. Many sites now have an online payment system. And during the last 10 years ebay has grown from a small US business with a few employees and to a massive global enterprise with over 15 thousand workers.

SLIDE 11:
So, a lot more people are using the web for many more reasons than they did back at the start of the millennium. But, have than ten years of accessibility rules and regulations improved the overall accessibility of content on the web.

Anecdotally it seems that it is better, and when you look at specific sites it is often easy to seem improvement. But overall, is the content of the web more accessible? I don’t know, I still see many crummy sites.

When preparing this talk, I did a quick check of the accessibility of the most visited sites in Australia and the US.

SLIDE 12:
These are the seven most visited sites in Australia according to Alexa. No real surprises here: Google number one, followed by facebook and Youtube. Ebay comes in at 6 followed by NineMSN, a less than perfect site when it comes to accessibility.

I used the WAVE tool to test the home page and a couple of other pages from each site. I know using an automated tool to test just a few pages is a rather crude measure of accessibility, but it was quick.

As you can see, WAVE identified accessibility errors on all home pages, except for the Bing page. NineMSN was the worst, with 52 errors on the home page according to WAVE.

Also the home pages of all seven sites use JavaScript in some way or other. And at least 5 of the sites contain some non W3C content, usually Flash.

SLIDE 13:
Here are the results for the 7 most visited US sites.

Not really much different to what we saw with the Australian sites although a little more in the area of social networkings with both Facebook and Myspace making the top seven. Again, WAVE identified accessibility errors on most home pages and all the sites have JavaScript and nearly all contain some non-W3C content.

SLIDE 14:
Vegemite!

For those not familiar with this Australian delicacy: It’s a salty spread made from used brewer’s yeast that we all grew up on. According to the ads, it gave us vitality and could even solve teenage problems.

The true test of being an Australian is to be able to sing the vegemite song for “we love our vegemite, we all enjoy our vegemite, it puts a rose in every cheek.”

But even vegemite had to move with times.

SLIDE 15:
Don’t you just love the way everything is 2.0 nowadays.

As well as the “2.0” suffix, vegemite even managed to slip in the “i” prefix.

iSnack 2.0, a ‘great’ idea by Vegemite to show that “they get it”, if I might borrow an oft used phrase of the cool set.

SLIDE 16:
Even Government is going 2.0.

During the last year or so, the US and Australian governments, along with many others, have organised studies, camps and

taskforces to explore ways of using the new social networking and interactive web technologies. The aims are often noble and lofty:

• To increase openness by making government information more widely available
• And to encourage more active collaboration from people wishing to contribute to public life.

But I am sure many in this room will not be surprised, when I suggest some of the sexy web 2.0 interactive stuff is not very accessible; and some of it downright inaccessible.

SLIDE 17:
How governments around the world balance the potential of web 2.0 with the reality of making sure that these new ways of engaging with the community are available to all will be interesting.

Sadly, I don’t feel the “Government 2.0 Taskforce” in Australia really came to grips with this question, perhaps this is not surprising since it seems that no one with specialist knowledge in the area of accessibility was on the Taskforce Committee.

The Report of the Taskforce contains a number of significant and far reaching recommendations in regard to promoting transparency and greater engagement with the community. However I feel the Taskforce and its Report present a very narrow, technology-centric view of what is required when it comes to the adoption of Web 2.0. The report seems to assume all citizens who may wish to engage with the government are able-bodied, web-savvy, can read English and are both willing and able to use social networking tools.

Rather than arguing the case for social inclusion; the Report is more concerned with canvassing the various excuses for not addressing the issue of making sure all people, including those with disabilities, will be able to engage in the proposed Government 2.0 world.

The Report goes so far as to Recommend that when it comes to web 2.0, Government agencies should not need to comply with accessibility guidelines if they find complying all too difficult. For me this is a real worry.

SLIDE 18:
When it comes to social policy, the success of regulations or rules largely depends on three factors:

1. The inherent justice or fairness of the rules
2. An acceptance by the social group that there is a need for regulations
3. And finally, willingness by the majority of those directly affected to comply with the regulations.

This willingness is often stimulated by incentives or sanctions. Or a combination of both – the so-called carrot and stick approach: Comply and you gain some form of explicit or implicit benefit; Fail to comply and you get whacked!

Over the years, I and other web accessibility advocates have offered the carrots of ‘doing the right thing‘, and the benefits of making sure your content is accessible to the largest number of people. At the same time, we have held out the stick of threatened prosecution for failing to comply.

But, as with most policies that require some change in behaviour, often at emotional and/or financial cost, the stick, while perhaps a useful adjunct in some circumstances, is often not a major determinant in changing human behaviour or attitudes.

SLIDE 19:
In 1901, Teddy Roosevelt helped himself to an old West African proverb, ‘Speak softly and carry a big stick‘, when it came to the exercise of political and judicial power. As many students of history will know, Roosevelt was able to use this approach with considerable effect in both local and international affairs.

However, I don’t think we could say this accurately reflects some more recent US approaches to international issues: Think of the George & Dick show, “Loud and big all the way”

Nor do I think it could be said to apply to legal attempts to enforce web accessibility in Australia and around the world.

SLIDE 20:
As far as I know, the first recorded case concerning website accessibility was in 2000 when Bruce Maguire complained that the site of the Sydney Olympic Games Organising Committee was not accessible. The case was successfully pursued by the Human Rights and Equal Opportunities Commission and soon became a cause celebre of accessibility advocates everywhere.

During the following years, there have been a number of other complaints in different countries over the inaccessibility of websites. While the threat of legal action in some cases has resulted in negotiated positive outcomes for the complainants, very few complaints have made it to court.

Not withstanding the fact that little has been established in the way of legal precedents, I and many others have been shouting very loudly for years about disability discrimination laws and the risks of prosecution.

But sadly, it appears to me that the actual stick of legal action has turned out to be more of a twig. A twig that is very rarely wield in anger.

I don’t wish to suggest that the softly-softly approach has necessarily been inappropriate. As much as I might have liked to see the purveyors of large inaccessible sites get a whack, I suspect such an approach could well have been counter-productive and undermined our overall desire to improve the accessibility of the web.

SLIDE 21:
In Australia, and other jurisdictions, the processes for ensuring website accessibility rules are complied with are largely complaint driven. That is, someone has to feel that that have been sufficiently discriminated against to complain, and then the regulatory authorities have to agree to support their complaint.

In reality this doesn’t happen very often.

Many times when I have been evaluating the accessibility and usability of websites with people who have disabilities, the participants have commented on the inaccessibility of some site or other they recently tried to use. However, when I ask if they have complained about it to anyone, the answer is nearly always NO!

And, what happens when complaints are made? Regulators, who most often have limited financial resources, are then faced with the prospect of taking on what are often very large businesses with very deep pockets when it comes to protecting their reputation in court. And then there is the real prospect of the action failing, a catastrophic outcome that could establish precedents for inaccessibility rather than accessibility.

So what is the net result? In my opinion the process of enforcing web accessibility through regulations is very difficult because:

• First, many web developers and senior managers are not particularly sensitive to the issue of web accessibility.
• And second, since they see so many sites that are inaccessible, where the failure to comply is without consequence, they just basically don’t feel the pressure to take it seriously.

SLIDE 22:
Over the last ten years, the web has brought huge benefits to many people, including many with disabilities. However we are now in danger of having a web where the gap between the haves and the have nots could become a chasm.

A web, where increasingly all the fruits will only be available to the cool and able bodied! That is, those who can afford the latest technologies and have the physical and mental capabilities to use them.

A web where the basics will be available to all, but only some can travel first class.

SLIDE 23:
The WCAG 1.0 of 1999 is not able to meet the needs of the web today, with its enhanced interactivity, and most strikingly, greater community engagement:

• Social networking with Facebook and Youtube
• Social bookmarking with Delicious and Digg
• Tags and folksonomies, and
• How can we forget twitter

We’ve all heard and answered these clarion calls for narcissism. Nowadays, everybody feels they have something to say, and nothing is going to stop them. But not everyone can!

Is the inaccessibility of many of these fancy new tools, Web 2.0’s Nemesis, extracting vergence from a few for the interactive, narcissistic excesses of the many?

SLIDE 24:
The reality is that there are many more ways to present and interact with web content today than there was 10 years ago. And this number will only increase in the future.

WCAG 1.0 was primarily about W3C technologies, particularly HTML and its variants. This was in one sense a form of technological prohibition that confined our notions of accessibility.

While this confinement provided some certainty and encouraged the appropriate use of W3C technologies, it could not stop the development and use of other technologies and more importantly provided no incentive for people to improve the accessibility of content using these non-W3C technologies.

And, in some cases, these other technologies may be more appropriate than HTML.

SLIDE 25:
A friend of mine, Judith has cerebral palsy; some of you may have seen her in the video “Wheeling in Second Life” which we made together a few years ago. Judith is unable to use her hands to control a mouse or use the keyboard. She is however very proficient at using computers with a headwand and does so nearly everyday for work and pleasure.

When it comes to online forms, it often takes Judith a long time to assemble the information and fill in the form. As a result, she generally prefers PDF forms rather than HTML forms because she can download them from the web, complete them in her own time and then go back online to submit them. For her, a good PDF form is much more accessible than a HTML form!

In my work, I have come across other situations where non-W3C formats have the potential to deliver content that is more accessible for the intended audience.

SLIDE 26:
For example, several years ago I reviewed some web-based kiosk material prepared for people who are homeless. The commissioning government agency recognised that a large proportion of their clients were functionally illiterate. However, the agency’s fear of breaching accessibility guidelines and thereby the (Australian) Disability Discrimination Act, resulted in them making a conscious decision not to use Flash, or any other non-text media, to present the information.

The solution, this short “Quick Guide”: 17 screens of words!

Another example, recently I had reason to look at online resources prepared for the vocational education sector in Australia. Most of the resources were interactive and contained Flash material.

Now for people with learning and cognitive disorders, a well made interactive resource that makes extensive use of non-text content is likely to be both more usable and more accessible. However, nearly 50% of the Flash material I examined would have been inaccessible to most screen reader users. And in many cases, the material trapped the cursor, thereby preventing anyone who was unable to use a mouse to get to the rest of the page.

When I asked some of the developers if they tried to make the Flash accessible, the answer was, “not often, not worth the effort, only if I am explicitly asked to”. The keen ones would go on to say they provided an alternative; but often this was not really an equivalent alternative to the Flash content as required by WCAG. For example rather than allowing someone to discover the answer to a problem through exploration or trial and error the alternative merely provided the answer.

SLIDE 27:
Killing Bambi, now there’s an idea!

For some, knocking Walt Disney is akin to mugging mother Teresa, even though he was known to hate kids and it is rumoured he had a torture chamber in the basement. But, what ever you think about Walt, killing Bambi is certainly bad taste.

SLIDE 28:
I won’t let that stop me.

Here we have a screen shot of the web page for ordering a DVD of the Bambi movie: At the top there is the main navigation, and down one side lots of links, for example, under the heading Categories there are links to things like Family Feature Films, Disney Classics, Disney Vaults, and then there are links to different formats etc. In the centre is the main panel with information about Bambi: “The forest comes alive with Bambi, the critically acclaimed coming-of-age story that has entertained generations of fans. This grand adventure is full of humour, heart and the most beloved characters of all time…”

Now is that not wholesome and cute? But what happens if I turn off Flash?

SLIDE 29:
Oh dear, no navigation!

I should add at this stage, that when Flash is supported and the page is accessed with a screen reader, each of the navigation items is identified with the word “button”. For example, Categories: button, button, button, button and button. Format, button, button, button and so on.

And, what about the use of images?

SLIDE 30:
Well that’s very useful, no navigation and now no content.

But since I used a tool to only turn off inline image, we do know it is about Bambi, courtesy of a background image. Also, the content about the forest coming alive with Bambi and the most beloved characters of all time which appears to have disappeared is actually HTML and can be read by a screen reader: Just a small problem of white on white.

But wait, not all is lost…

SLIDE 31:
See, we have a text alternative for one of the images, telling us this is the official Bambi DVD site, beware those unofficial sites.

And, as you can see, the headings use H elements.

No seriously, enough of this frivolity. I am not trying to suggest we shouldn’t use images, or JavaScript or Flash, although I am NOT sure that Flash for navigation is such a great idea.

There are sites that use these technologies in a way that is accessible, and sometimes Flash or JavaScript can enhance the accessibility of a site for the intended audience. What I am trying to suggest is that perhaps trying to discourage or prohibit the use of different technologies might not be the best way to go. I mean to say, who are we to try and take on the power of Walt and Bambi?

SLIDE 32:
The introduction of WCAG 2 at the end of 2008 offered a new approach. WCAG 2.0 is not concerned with the technology used, but
how it is used. Of course, as with many things that come out of the W3C, if you can say it in a few words, why not use 100 and the bigger and more specialised the better!

I would like to make it clear however, that I am a big fan of the W3C and the WAI. Even though I sometimes criticise them and WCAG a bit, I think they are great and applaud their work, but writing in plain English is not one of their strong points.

One significant difference with WCAG 1 is that the WCAG 2.0 Guidelines and Success Criteria do not mention HTML and do not discriminate in favour or against any particular web content technologies. That is left up to others.

SLIDE 33
To help make this decision, WCAG 2 introduced the concept of “accessibility support”, and for a technology to be considered accessibility supported, it must meet two basic conditions:

1. First, the way a web content technology such Flash or HTML is used must work with assistive technologies.
2. Second, the user agents such as browsers and Readers, which are required to render the content, must also accessible and must not discriminate against people with disabilities in terms of availability and price.

SLIDE 34:
Of course, this raises the very interesting question of who decides what technologies can be considered accessibility supported. The W3C primarily hand this responsibility on to the authors of web sites, while at the same time recognising they probably don’t have the ability to make a decision:

“Individual authors will not usually be able to do all of the testing necessary to determine which ways of using which Web technologies are actually supported by which versions of assistive technologies and user agents.”

In reality, I am sure that the desire for consistency and certainty will mean that the various government agencies and other organisations, which are concerned with issues of discrimination in different countries, will be the ones who decide what technologies can be considered accessibility supported.

And, when it comes to deciding which assistive technologies should be able to support content, the WCAG Working Group handed the decision over to, well who knows who.

In my view, the failure to provide clear guidance in regard to these issues is one of the most significant failings of WCAG 2.0 and it places web accessibility at the crossroads.

SLIDE 35:
For, as countries move to endorse WCAG 2.0 they are faced with the issue of how to deal with the many different web content technologies and formats that are in use to day. Do they adopt the WCAG 1.0 approach of basically saying only W3C formats like HTML can be relied on to present content? Or, do they embrace the WCAG 2.0 notion of technological neutrality, and concentrate on how the technology is used rather then the technology itself?

This is a very complicated question, with many competing arguments. The simple solution is to stick with what you already know. This seems to be the approach adopted by New Zealand, which in March 2009 became one of the first countries to adopt WCAG 2.0.

SLIDE 36:
Apart from some of the technical changes relating to the use of HTML, as far as I can see, the New Zealand accessibility standards of today are very little different to those of 10 years ago.

If you use JavaScript and other programmatic objects, the pages or page elements must not rely on them for presentation or functionality – pretty much the same as WCAG 1.0 Checkpoint 6.3 (among others). And, if you use non-W3C formats such as Flash, PDF, Word and even RTF, you have to also provide the content in HTML; much like WCAG 1, Guideline 11 and specifically Checkpoint 11.4.

In essence, this is a prohibition model and provides little or no encouragement to improve the accessibility of non-W3C material.

SLIDE 37:
The New Zealand model is one simple solution to the problem of how to ensure the accessibility of content produced with new technologies. Another simple, or should that be simplistic, solution is to assert that it is all the fault of the regulators: If they prosecuted a few more people then the problem would be solved. In essence take out the big stick and use it to beat developers and manager into complying.

Sorry, but I don’t buy simple solutions to complex problems, particularly ones that involve human behaviour.

SLIDE 38:
In my view, web content accessibility regulations need to cater for the range of technologies that are currently being used, and those that may be used in the future. I am concerned that a continuation of the current (WCAG 1.0) practice of only considering W3C technologies accessible will:

• Provide little incentive for developers to improve the accessibility of web content that uses non-W3C formats like JavaScript and PDF.
• And, in the process, reduce the pressure on the producers of non-W3C technologies to improve the accessibility of their products.
• Furthermore, if these products are hard to make accessible and most developers don’t bother to use the few accessibility features that are available, where is the incentive for the manufacturers of assistive technologies to improve the capabilities of what they produce?
• Finally, when it comes to community acceptance of web accessibility, I am afraid that as more and more high-traffic sites use inaccessible non-W3C technologies without appropriate alternatives, web developers will increasingly question the value of making their sites accessible.

Rather than prohibiting the use of specific technologies, I think it is time to try something different. And so I would now like to sketch out a few ideas or suggestions.

SLIDE 39:
As a start, I think the New Zealand minimalist WCAG model is not appropriate. I believe Australia and other countries, that use WCAG as their reference point for accessibility, should adopt WCAG 2.0 at level AA. And, I believe they should embrace the notion of technological neutrality.

The Australian Government recently endorsed WCAG 2 and announced they would progressively move to Level AA over the next four years. But the question of which technologies will be considered acceptable is still to be decided and I desperately hope we don’t follow the approach of our Tasman cousins.

I believe the key question should be: Does the use of a web technology comply with the guiding Principles and Guidelines of WCAG 2.0?

SLIDE 40:
Very often discussion about compliance with WCAG 2.0 is solely in terms of the Success Criteria and their associated Techniques. That is: Are these specific techniques satisfied on a web page? If they are, then the page complies with the related Success Criteria. And if all the Success Criteria are complied with, then the page is considered accessible.

From my experience very few people in the industry understand the difference between ‘normative’ Success Criteria and ‘informative’ Techniques. Just the other day, a very large organisation told me that they hadn’t gone for Level AA because the developer had told them that they would have to meet over 700 W3C accessibility rules.

Of course this is not correct, but many developers are looking for hard and fast rules relating to HTML such as “use header elements”, as was the case with WCAG 1, and they see these rules in the Techniques document and so believe they must all be met.

Developers, and their clients, often appear to be mainly concerned with ticking off a few checkpoints rather than making sure something is accessible. I believe, when it comes to determining if a site is accessible, a more comprehensive and satisfactory approach is contained in the five Conformance Requirements specified in the WCAG 2.0 document, but unfortunately it seems to me that most developers are not aware of them.

SLIDE 41:
As I have indicated, much of the discussion concerning the implementation WCAG 2.0 often revolves around whether or not a particular content technology can be considered to be accessible. And, there is pressure on regulators to indicate which technologies they believe are accessibility supported.

Rather than attempting to nominate accessible web content technologies, I feel it might be more useful for regulators to identify those assistive technologies (and technology versions) that they believe need to be able to access web content. Obviously, such a list would need to be regularly up dated as assistive technologies improve and new ones are developed.

For example, lets imagine for a moment, that the only requirement is for all web content to be accessible with JAWS Versions 8 plus. Then if a particular use of PDF, or Flash, or HTML for that matter, can be successfully used with JAWS 8, 9, 10 etc it would be considered “accessibility supported”.

Now of course this is a very simplistic example and there would probably be many more nominated assistive technologies. But, such an approach would give certainty to clients, encourage developers to improve the accessibility of content technologies, and just as importantly, it would be easily testable.

SLIDE 42:
I feel it would also be useful for developers to prepare an accessibility compliance statement as suggested in WCAG 2.0. The statement doesn’t have to be anything fancy, nor should it require the use of an accessibility specialist. All the statement needs to do is:

• Indicate the pages, site or application it applies to
• The WCAG level complied with
• The technologies that are relied upon, that is the ones for which there is no alternative
• The technologies used but not relied up, that is those that are used for which an alternative is provided
• The author/owner of the site
• And, the date of Statement

I can see it might be difficult to have a requirement for Compliance Statements at a national or government level, but I think it is very possible for this to be a requirement at the industry sector level or by individual businesses.

One big benefit of compliance statements is that they provide something concrete that the site can be measured against should a complaint be made. Also, requiring an accessibility statement will help return responsibility for accessibility to the wider web community.

SLIDE 43:
The Web as we know it, is 16 years young, still to reach voting age in Australia. We all know there is a lot of inaccessible junk out there, but I feel it is better to spend time improving stuff for the future rather than worrying about the crappy junk of the past.

In my view, there should be a full exemption from complying with either WCAG 1.0 or WCAG 2.0 for all materials produced before 1 January 2009, on the condition that the owners of those materials provide a description of the materials and what they contain. I know many will disagree with this approach since it will give tacit approval to a bunch of inaccessible material, much of it old. However, I don’t think it is realistic to assume that much of this material will be improved what ever the regulators say.

If material has any ongoing value is it likely to be updated or migrated to a new or revised site at sometime in the future. And when this happens, I believe there should be a requirement for the material to comply with WCAG 2.0.

In other words, we say to content owners, if you don’t need it get rid of it and if you want to keep it, make it accessible.

SLIDE 44:
We know a well made site can be used by people with disabilities, and there is a tendency to assume everyone knows this. But this is not the case.

It is amazing how many developers and people with responsibility for websites in large organisations really have no idea. In my experience, hostility to web accessibility guidelines often stems from the fact that people just don’t see the point. They just can’t believe someone who is blind, for example, can use a computer let alone the web

A quick digression to help illustrate this point: A few years I took a client to the Royal Blind Society in Sydney so that they could see how people with different vision impairments use their site. Anyway, as it happens we couldn’t get onto the web – some problem with the proxy settings or something or other. So we rang tech support. And in due course a young man in a white shirt turned up, an experience the client was very familiar with.

But here is the difference; the tech support man was blind. Using information he got from a Braille note machine, the young man re-configured the settings and had us online in no time at all. And what about the client – well their eyes were out on stalks, just could not believe it!

For some years I have been running accessibility workshops. Now obviously these workshops are more likely to appeal to people who are sympathetic to the notion of accessibility. Five years ago, when I asked if anyone had seen a screen reader in use, I would be lucky if one in twenty had. Two years ago, it was over 30%, but none had seen Braille being used. And so I decided to make a video, utilising the skills of my pre-web life when I worked in the film and television industry for many years.

SLIDE 45:
I made “Refreshable Braille and the Web” with a friend Bruce Maguire, who I am sure some of you know. In the video he demonstrates the machine and shows how he goes about buying a book from Amazon. The video is available on YouTube and DotSub, where it has been captioned and translated by others into Italian and Spanish.

I have found videos to be a great awareness raising tool and I regularly use them in my workshops. But more importantly, I have found they are a great way to break down the resistance to accessibility by some clients. With many clients, and developers for that matter, a simple short video like this one, or “Wheeling in Second Life” which I mentioned earlier, can be more effective than many thousands of words!

The number of videos on the web showing different assistive technologies in use is growing all the time and I think this is great. I am hoping to make a few more myself in the future as time permits.

But video is only one of many possible ways we can raise awareness and provide information about accessibility. The WAI documents, such as the Business Case overview, are another great awareness raising resource which I refer people to.

SLIDE 46:
There is a growing need for more information and resources for the web community about what is required to produce accessible material using different content formats.

The W3C clearly have a very important role to play in this, but it should not be left up to them alone. Regulators and the web industry as a whole could do more in disseminating information about how to make accessible sites. I should acknowledge the considerable role many individuals and organisations have played in this regard over the last few years, but much more needs to be done.

This will be increasingly important, not only because new content technologies are appearing all the time, but also because we are constantly developing new ways of doing things, for example not so many years ago no one had ever heard of image-replacement or Ajax. The underlying technologies were always there, it’s just that now they are being combined and used in new ways.

SLIDE 47:
In the rush to explore and introduce new ways of providing online content, the cost of ensuring access to this content by all web users is often overlooked.

Although, as we all know, the price of computers falls by the minute, there are still millions of people who can’t afford to keep up with the latest and greatest in this rapidly changing environment. And, let us not forget, that within our communities, people with disabilities are often among those with the least financial resources.

There is little point in introducing a fantastic online resource for people with cognitive limitations, for example, if it doesn’t run on standard, commonly used user platforms. And, when it comes to assistive technologies like screen readers, vendors are bringing out new versions all the time in order to keep up with the changing web.

Some how we need to avoid the costs of technological advances becoming an entrenched barrier to accessibility. In this regard, I am very interested in the whole NVDA movement and in the way outside financial support have allowed them to focus on improving access to new developments like ARIA.

While NVDA might not be as comprehensive as many of the commercial screen readers, it is free and relatively easy to use, and so offers a real alternative to people around the world who rely on screen readers to access the web.

The accessibility problems associated with image CAPTCHAs are well known, and this has stimulated a third-party volunteer solution called Solana. While community engagement and social problem solving is great, should access to some areas of the web for people with disabilities be dependent on the good will of a few? Might, this not be another variant of the charity model I referred to earlier?

SLIDE 48:
When it comes to assistive technologies, we often assume that all the people who rely on them to access the web are highly skilled in their use. I am not sure why we make this assumption, because it is not one we tend to make with other web technologies.

In a recent WebAIM survey of screen reader users, about 60% of respondents described themselves as having advanced computer skills. And when it came to screen reader proficiency, 50% described their proficiency as intermediate or beginner. (We need to bear in mind that the respondents to this survey are likely to be at the more aware or geeky screen reader users.) When it came to learning how to use screen readers, nearly three quarters said they were self taught.

So finally, in addition to taking a technologically neutral approach to WCAG 2 and increasing the ability of web developers to make accessible content, in my view, assistive technology users also need to be provided with the resources to help them improve their skills in using the technologies they require to access content in a variety of formats.

SLIDE 49:
I am fearful if we don’t take a more active approach to accessibility and rely just on rules and regulations alone, the web will increasingly become a communication medium that only an able-bodied, tech-literate elite will be able to participate in.

Thank you. Here are my contact details.

Any questions or comments?