Submission on Draft of Web Content Accessibility guidelines
March 9th, 2007
Introduction
What is VICS?
VICS is the visually Impaired computer society. It was formed in 1986 by a number of visually impaired people who used technology in their jobs in Ireland. It has now grown to have over 100 members in both the republic of Ireland and Northern Ireland and consists of members with all levels of technological experience and competency.
VICS undertakes training of members, runs an email list to facilitate interaction between members, produces a regular CD-based magazine and holds Open days to showcase new and emerging technologies of interest to visually impaired people. VICS researches the usability and accessibility of mainstream and specialised products and promotes these amongst producers of products and services.
VICS has consistently promoted W3C guidelines, but particularly those relating to web content accessibility and Authoring tools. VICS is strongly interested in ensuring that as these sets of guidelines develop, the needs of visually impaired people are high on the list of priorities, as has been the case heretofore.
For more details on VICS, see our web site at
http://www.vicsireland.org
History of access
From a technical point of view, access to technology increasingly improved in the first 10 years of the life of VICS. Although the cost of technology was very high and training in the use of screen reading software was almost non-existent, the text-based nature of most software that ran under DOS meant that making such applications accessible was a relatively simple task. However, with the introduction of windows, accessibility took a severe blow and it took several years to begin to catch up. Although the situation has improved from the early part of this century, it is still far from ideal and cost and lack of training facilities are still major barriers.
The pervasive presence of the Internet in everyday life presents enormous opportunities to visually impaired users and others who are print impaired (e.g. those with low literacy levels or who are Dyslexic). It offers access to information that otherwise may be only available in the printed word, but also allows access to online purchasing, education and myriad other opportunities. The independence, privacy and empowerment that this offers cannot be overstated.
Although VICS recognises that Version 1.0 of the WCAG were not globally accepted and certainly not as widely implemented as would be desirable, they presented the very best opportunity that reputable web site developers would adhere to a set of internationally recognised standards. This, in turn, allows developers of assistive, adaptive and augmentative technologies to develop tools to allow people with various disabilities access them. Now that these guidelines are being reviewed and greatly expanded to include access to other technologies, VICS is delighted to add its input.
General Principles
The following are general principles that relate to access to ICTs by visually impaired people. They are not all of a nature that can be influenced by the WCAG Guidelines, but they are crucial when determining which aspects of accessibility and usability are high on our list of priorities.
Unemployment levels
It is generally accepted that the level of unemployment amongst people with disabilities of working age are vastly higher than those that pertain in the general population. The National Disability Authority in Ireland state the following:
“From the Census of 2002, we can look at the number and share of people of working age (20-64) who give their Principle Economic Status as "in work". 70% of non-disabled people were in work compared to 26% of people with disabilities. So three out of every four people with disabilities of working age are not in employment.”
As a result, visually impaired people frequently have little disposable income. If they have technology at all, it may have come to them from a rehabilitation organisation as part of a training course or it may have come to them second hand from a friend or relative.
Affordability
Because of the lack of disposable income discussed above, visually impaired people are far less likely to upgrade either hardware or mainstream software than other members of society.
Assistive, adaptive and augmentative technologies are expensive. For the same reasons as mentioned above, visually impaired people often are not in a position to upgrade this technology either.
Because broadband is still quite expensive in Ireland, many visually impaired people still use dial-up to access the Internet. Thus, large downloads are time consuming and relatively expensive. This means that proprietary software that must be downloaded is also not likely to be upgraded.
Late Adopters
The Irish Information society described various groups of people within Ireland as Late adopters of technology. These include people with disabilities.
Part of the reason is those of affordability already discussed. Another is the lack of training facilities that are available. Yet another is down to attitudes that pertained until recently, including amongst many people with disabilities themselves, that other groups had a greater need for access and thus received better supports.
All of these issues have now been addressed, but visually impaired people still find themselves a long way behind the norm in society and have a lot of catching up to do.
Benefits to society
Visually impaired people gain disproportionately from access to ICTs, as they frequently do not have access to traditional alternatives such as the printed word. However, it is vital to note that society also gains.
Products and services that are developed with the needs of people with disabilities in mind are typically easier to use by everyone. Hence, VICS strongly promotes the use of design for all Principles, and these are reflected in the WCAG approach. The WCAG are also in line with a White Paper published by VICS named “An Information Society for All - the non-visual way”. For details on the White Paper, see
http://www.vicsireland.org/information/white_paper.php
Web sites and other technologies covered by W3C guidelines are constructed using predictable and reliable pyridines, thus facilitating search robots and other strategies that promote interaction between various types of web units. This enormously improves the effectiveness and efficiency of Internet use for all users.
Improved access to ICTs allows visually impaired people become employed. This facilitates their independence, but also transforms them into fully contributing members of society. Disposable income allows them to promote access, not only as a right, but also as a consumer.
VICS recommendations
Need for Clarity and Simplicity
Background
VICS feels that The WCAG Version 2.0 working documents are too dense and full of jargon. They are very difficult to use as practical tools to build accessibility into web sites or other technologies on a day-to-day basis.
Examples
Consider the Level 1 success criteria for Guideline 1.3:
“1.3.1 Information and relationships conveyed through presentation can be programmatically determined, and notification of changes to these is available to user agents, including assistive technologies”.
When one follows the link to investigate how to meet this guideline, one must read around 1,100 words before reaching "use semantic mark up". One must then follow a further set of links. VICS considers that this process is unnecessarily complicated and difficult to understand.
VICS is concerned that the developer would be so deterred by the mountain of information that he/she will never consider implementing the guidelines. Even if he/she is so-inclined, there appears to be no short and snappy non-technical support tools for presenting the guidelines to managers or others who must be convinced.
Recommendations
- That the language in the major documents and the summaries be reviewed to make them clearer and more usable, thus simplifying their use.
- That Success criteria documents be reviewed to be self-contained explanations of the appropriate success criteria and that “How To” documents become simply supporting information for them. Where such documents already exist, they need to be promoted.
- That all documentation, particularly “How To” documents, should contain concrete, real world examples of how the guidelines can be used.
Information grouping
Background
A visually impaired user frequently cannot discern how elements such as navigation bars, headings, headers, footers, main content, etc are grouped together. This could be because he/she uses screen reading or screen enlargement software so cannot read the entire contents of the screen at any given time. The visually impaired user requires a method of recognising how these are logically grouped together. This is in line with Guideline 1.3 already referenced above in Section 2.1.
VICS recognises that the recommendations in this section may require a change to mark-up languages that are beyond the scope of the guidelines, but contends that their inclusion is a complementary step in the process of achieving the desired aim.
Examples
When a visually impaired user uses <TAB> to move from link to link, he/she cannot tell which links are within a logical group of information or when he/she has moved out of that logical group.
Unfortunately the Menu and the Directory List tags were depreciated in latter versions of HTML. They could have been a more semantically correct way to mark-up web site navigation. An alternative is required.
Recommendations
- That the guidelines include a mechanism to programmatically indicate which links are grouped logically. This could, for instance, mean that links and Heading Levels are in some way connected in the same way as Table Headings and table Contents are connected.
- That the guidelines include a mechanism to programmatically define layout divisions on web units. This would be similar to how a frame title tells the user that a new frame is a new piece of content.
- That the Guidelines recommend that groups of navigation links be set out in an ordered/unordered list. Each group should have a heading and an access key defined. Details of navigation headings and access keys should be described in the sites baseline.
- Failing this, that the guidelines state that the baseline of a site describes the layout and structure of web units to users. This would be similar to how a sitemap condenses the structure of site content.
Data formatting
Background
Tables should be used for formatting tabular data, not for formatting sets of links or other navigational elements. The table tag should not be used simply to affect the layout of the content within it. When used in this way, the mark-up does not describe the purpose of the content, thus is not semantically correct.
Examples
Tables should not be used to visually set out a set of links, e.g. a navigation bar.
Tables should not be used to separate blocks of text that are not sets of tabular information.
Recommendations
- That the guidelines state that CSS be used to position elements such as sets of links, blocks of non-tabular text, etc.
- That the guidelines state that Tables should only be used to lay out groups of data that make up tabular information.
Headings and Other elements
Background
VICS feels that the importance of the use of Headings is not strong enough in the current draft. This is also true of simple lists, ordered lists and other elements whose visual effect could better be implemented using CSS.
Examples
Bolding and increased font size are often used to visually indicate the start of a logical block of text. Screen reading software does not have the facility to jump from one such piece of text to the next as it can if Heading Level tags are used.
The user of screen enlargement can benefit from the use of Heading Levels if CSS is used to format them and the user can override this formatting. This avoids text in a large font being further enlarged thus covering a big proportion of the screen.
Recommendations
- That the guidelines state that Headings, simple Lists, Ordered Lists, etc should be achieved by use of their specified Tags, not by simply adding visual effects.
- That the guidelines state that CSS should be used to format the colour, font, point size, etc of text when using these tags.
- That the guidelines state that the user should be easily able to override the colour, font, point size, etc specified for text in the CSS.
Proprietary software
Background
Information held on web units is often held in a format that can only be read or viewed using proprietary software that must be downloaded and installed on the user’s computer. As discussed above, this is simply not going to happen for many visually impaired users. Thus, even if improved accessibility features are included in the most up-to-date version of the proprietary software, the users will not have access to them and will remain excluded from accessing the desired content.
Examples
Information is often held on web units in PDF, Flash or other similar formats.
Content and web controls are occasionally presented by the use of JAVA applets that, in some cases, are developed to be accessible. However, the user is required to download and install appropriate JAVA toolkits, e.g. the Java Access Bridge. In VICS's experience, fully accessible Java Applets are very rare.
Recommendations
- That the guidelines state that any information that requires the user to download and install proprietary software must be accompanied by an accessible version which can be read or viewed using a standard User agent.
Baseline Opt outs
Background
VICS is concerned that the concept of a baseline allows developers so many opt-outs that it would be possible to nominate an almost totally inaccessible site as accessible by listing exceptions.
Examples
A developer could state as a baseline that access to documents that require the user to download a proprietary reader is out of scope for accessibility. He/she could then place all of the most important content into such documents and still declare the site accessible.
Recommendations
- That the guidelines state that a baseline may not allow exceptions that include the core functionality of the site or elements that constitute the major number of elements of the site.
About the authors
Natasha Miskella
Natasha is the Web master of the VICS web site and a member of the VICS executive committee. Natasha has nine years experience as a web designer and developer and works for a major bank in Dublin. Natasha has studied User Interface Design and Interaction Design with an emphasis on Human Computer Interaction and is passionate about web accessibility.
Gerry Ellis
Gerry was the founding chairperson of VICS and is currently its Honorary Secretary. Gerry has worked as a Software Engineer for over 25 years. Gerry is a fellow of the Irish computer society.
Gerry has spoken at conferences on accessibility issues, particularly those relating to ICTs, in 12 countries on 3 continents. This included both phases of the first world summit on the Information society in Geneva and Tunis.
Contact details
Natasha Miskella
Web Master
(+353-86) 829 8823
webmaster@vicsireland.org
Gerry Ellis
Hon. secretary
(+353-85) 716 8665
Gerry.ellis@vicsireland.org