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Re: Chronicle of Higher Education article "Colleges Lock Out Blind Students Online"

for

From: John Foliot
Date: Dec 13, 2010 7:21PM

Richard R. Hill wrote:
>
> Note that the FAE tool test for certain rules that are specific to that
> tool (not generally required or labelled as a best practice by other
> Web standards). For instance, the FAE tool marks folks down for have
> more than one H1 on a page. This is a Illinois rule, not a W3C or 508
> rule. SO, those who adhere to more of these will have slightly higher
> rankings.
>
> Still unclear as to the scope and depth of the pages/sites tested.
> –––––––––––––––––––––––––––––––––––––––
> Rick Hill, Web CMS Administrator
> University Communications, UC Davis

(Rick: http://webaccessibility.cita.illinois.edu/data/school/235/)


<Personal Opinion>
I have to vehemently agree, and further express my disappointment and
frustration at Jon Gunderson and his team for presuming to set
accessibility standards for all of Higher Education. Evaluating other
institutions against "rules" set by The University of Illinois is both
misleading, and nothing more than Grandstanding: should we now go about
judging their sites against other made up criteria as well?

In particular, I point to the following "Rules" that are not part of
either Section 508 nor the W3C WCAG 1 or 2 Guidelines (the 2 recognized
benchmarks used by all other accessibility evaluation software):

HEADING STRUCTURE:
"The page must contain at least one h1 element."
According to whom? While it is certainly good practice to ensure
each page has appropriate heading structure, nowhere (outside of the FAE
tool) is it *MANDATED* as such - a page that lacks an <h1> is not
intrinsically inaccessible. False data - False results!

"The page should contain no more than two h1 elements."
Please point to one national or international guideline or
recommendation that mandates this. Another false positive from a
mechanical tool, fueled by internal University of Illinois politics and
policies.

"The text content of each h1 element should match all or part of the title
content."
"Each h1 element should have text content exclusive of the alt text of any
img elements it contains."
Bull Feathers! Made up standards by a small team with an agenda to
promote their internal tool - and it should be noted that failing to do
either of these things in no way makes a page "less accessible" - it just
doesn't meet their FAE Guidelines.


DATA TABLES:
"For each data table, the first cell in each column must be a th element,
and each row must contain at least one th element."
Patently FALSE! In fact, the table of school rankings at the
Chronicle of Higher Ed that Jon points to in his earlier email
(http://chronicle.com/article/BestWorst-College-Web/125642/) does not meet
this "pass" criteria, yet is not "inaccessible" because of it - in fact
the size of the table (183 rows in length with little-to-no internal
navigation) is more of an access issue than the failure for each row to
start with a <th>.

The following table is perfectly acceptable and valid, and meets (as far
as I know) all required accessibility guidelines as established by both
the Section 508 Standard and W3C Guidelines (yet fails the FAE tool):

<table>
<tr>
<td></td>
<th scope="col">Sunday</th>
<th scope="col">Monday</th>
<th scope="col">Tuesday</th>
<th scope="col">Wednesday</th>
<th scope="col">Thursday</th>
<th scope="col">Friday</th>
<th scope="col">Saturday</th>
</tr>
<tr>
<th scope="row">Week 1</th>
<td></td>
<td></td>
<td>1</td>
<td>2</td>
<td>3</td>
<td>4</td>
<td>5</td>
</tr>

...etc.
</table>

"Each th element in a complex data table must have an id attribute whose
value is unique relative to all ids on the page."
Please explain how failing to add an ID attribute to a table
header makes it less accessible.

"Each td element in a complex data table must have a headers attribute
that references the id attributes of associated th elements."
Please explain how failing to add a HEADER attribute to a table
cell makes it less accessible.

What defines "complex"? How does a mechanical tool makes this
assessment? The table code example shown above is perfectly valid, is
extremely accessible, and would fail 3 of the 5 data-table 'rules' this
testing imposes on *your* sites. This is simply unacceptable.


IMAGES/ALT TEXT
"Each img element with width or height less than 8 pixels should be
removed; CSS techniques should be used instead."
Really? How exactly was this determined? If I have an image that
is 9 pixels X 2 pixels than it should have alt text and not be moved to
CSS? That's what the tool and this testing tells. Furthermore, if your
site has an image like this, it has now been deemed less accessible, thus
ranks lower in the scores - leaving the impression that your pages are
inaccessible.

Clearly this is a tool that has some value, but to stake a single page's
accessibility or lack of, never mind publishing public data that states
that a University's web content is inaccessible on arbitrary Rules made up
by one University and verified by mechanical means alone against 3 or 4
pages is foolhardy, damaging to the general state of web accessibility (as
it suggests that meeting a mechanical tester's results = job done), and
unconscionable. It may also leave the University of Illinois open to libel
suits and other legal remedies.

I know Jon Gunderson personally, I like Jon Gunderson, and I respect the
work that Jon has done to advance web accessibility over the years, but
here, today, I must point the finger of shame at him and cry "Foul" - this
is no more an assessment of true web accessibility than it is a rolling of
chicken bones and voodoo chest-beating, and the damage caused here falls
squarely at his feet.
</Personal Opinion>

NOTE: These are my personal opinions, and in no way reflect the opinion of
Stanford University (with whom I am under contract), T-Base Communications
(my employer), my associates or other professional affiliates with whom I
do business with.

JF
===========================John  Foliot

Co-chair - W3C HTML5 Accessibility Task Force (Media)
http://www.w3.org/WAI/PF/HTML/wiki/Main_Page

============================