I am archiving this excerpt from the transcript of a US Access Board
hearing on the "refresh" of US Section 508, 255, and the ADA that was
held in Washington DC, USA, on May 12, 2010. The full transcript of
the hearing is available at
http://www.regulations.gov/search/Regs/home.html#documentDetail?R=0900006480b02403
.
Please also note the previous set of comments from the Santa Clara
hearing on March 25.
- Judy Brewer
JUDY BREWER: Thank you for this opportunity to testify with regard
to the United States Access Board's planned update of Section 508,
Section 255, and the Americans with Disabilities Act guidelines. My
name is Judy Brewer, and I direct the Web Accessibility Initiative at
the Worldwide Web Consortium. As my colleague offered in the March
hearing, we will make more detailed comments before the end of the
comment period. First, I would like to express my appreciation to
the Access Board for its very hard work and care in preparing this
ANPRM. I particularly appreciate the emphasis in the ANPRM on
harmonization with international standards and web accessibility.
Before I started working in the field of web accessibility, the topic
of standards harmonization sounded both abstract, and esoteric to
me. I suspect that this is the way that it may still sound to many
people. But I believe it is one of the best strategies that we all
have for accelerating the pace of implementing accessibility
solutions across the web and the implementation does need
acceleration. Standardization is much more than a way to keep
recreating the wheel. It is a way to ensure that all parties
interested in web accessibility are able to work towards a common
target with regard to accessibility goals. It is a way to ensure
that technical support materials and training resources can be widely
reusable, and expanded on, rather than redeveloped separately for
each different standard, and that organizations can realize the
benefits of WCAG2.0, which is a highly flexible framework for
supporting innovation.
Standards harmonization is also a way to ensure that the US does not
fragment accessibility standards for the web, restarting a process of
cascading derivative versions of web accessibility standards that
have a negative impact on accessibility efforts in other countries
around the world. I'm frequently asked by my colleagues in other
countries what I think the US will do with regard to harmonization
with WC3-WAI. And I can now say that the intent to harmonize comes
strongly in the ANPRM. And I encourage it to be stronger if
possible. One of the questions that W3C is looking at is does this
method of harmonization proposed in the ANPRM make it sufficiently
clear for web developers that they can and should use web content
accessibility guidelines, WCAG 2.0 AA, or even ways to make it even
clearer. The clearer the statement of harmonization, the more we
believe that this will protect against fragmented interpretations of
the standards in the US Federal Government, in U.S. states, and in
other countries.
On the topic of harmonization, I would also like to note that at the
time of completion of the TEITAC report, WCAG2.0 was not quite a
completed W3C standard. We commend the Access Board for keeping up
with developments in the completion of the WCAG2.0 consensus standard
as part of the regulatory process. The Access Board has continued to
ensure that this ANPRM reflects the completed WCAG2.0 standard. This
standard was supported by a broad and multi-stakeholder consensus of
industry, disability, government, and research.
To look at the benefits of standards harmonization from another
angle, it is important because it enables all parties to leverage
what I call "multipliers," the most of important of which are
authoring tools. Authoring tools are software applications that
people use to create and produce all kinds of content on
websites. In the context of web accessibility, authoring tools can
multiply the effort expended on accessibility by building support for
production of accessible content into the tools themselves, taking
this beyond a one developer, one website, one guideline approach, to
an approach where improvements in support for production of
accessible content in authoring tools, can be built into all
mainstream authoring tools, helping raise the accessibility levels of
hundreds of thousands of websites through individual authoring tools.
Though we are encouraged by recent changes in some authoring tools,
progress in authoring tools has lagged too far behind the field and
people with disabilities have lost out as a result. Standards
harmonization will help drive these improvements. But we also
commend the Access Board for incorporating into this ANPRM specific
provisions regarding support for production of accessible content by
authoring tools. For instance, provisions regarding inclusion of
accessible templates for production of accessible websites; since
templates are one of the most widely used shortcuts to site creation
you might add that help people to build accessible sites. We want to
bring to the Access Board's attention that there are further wording
improvements in accessibility guidelines and updates to the W3C
Accessibility Guidelines 2.0 drafts, which are in progress at W3C,
and we will provide more detailed written comments on this point in
case those can be useful to the Access Board.
Standards harmonization also helps with regard to improved evaluation
methodologies by providing a common definition of what needs to be
evaluated. We are seeing great interest in this area of evaluation
methodologies, in some countries, and expect to see growing interest
in the US as well.
We encourage harmonization for this reason, as well as for the
benefits that will be realized on the conformance side, and we
encourage the development and availability of a variety of
conformance approaches to evaluate to a common standard.
We also appreciate attention to user interface issues in
particular. We look forward to sharing additional progress on the
User Agent Accessibility Guidelines 2.0, a draft which has also
progressed at W3C during this time, particularly in areas such as
support for keyboard accessibility. We look forward to improvements
in some of these areas.
Again, I would like to sincerely thank the US Access Board for this
opportunity to make preliminary comments on the ANPRM and we will
provide more detailed comments in writing, thank you.
