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

for

From: John Foliot
Date: Dec 13, 2010 11:21PM

Gunderson, Jon R wrote:
>
> Rules Development Clarification
>
> The rules were not developed only by people at the University of
> Illinois, but were developed in an open forum of the Web Best Practices
> Working Group:
> http://collaborate.athenpro.org/group/web/
> There are members from all over the united States.
> Anyone can join the group and if people have better design rules the
> group would love to hear and consider them for inclusion.

However, what has happened is that these rules are now being imposed on a
number of Higher Education institutions that have neither participated in
that rule making, nor have they agreed that they are what are required to
ensure accessibility. With no offense to you or the other participants in
the Best Practices group it strikes me that representatives of the
majority of the institutions evaluated are notably absent from the Working
Group; as such, your current rule-set is hardly universally accepted or
agreed to. It would seem that only those members who have developed the
FAE rule set should be judged by those rules. As well, there is a
difference between not meeting Best Practices and having web content that
is inaccessible - a nuanced point notably absent from your report and the
recent Chronicle in Higher Ed article.

I have pointed out the rules that I personally have issue with, yet the
FAE tool and rule set were used to judge pages at the institution where I
work. This now places either my professional experience and judgment into
question, or your groups judgment, as clearly we are in disagreement. I
have already pointed out the evaluation criteria I disagree with, and
await your response and justification - for example can you prove that a
page that lacks an H1 is inaccessible? I know I certainly can't, and
further can offer examples where a page without an H1 would still remain
totally accessible, and in fact could actually be an accessibility
enhancement - the long text explanatory page associated to @longdesc.

Asserting that not meeting all of your Best Practice rules = poor
accessibility is simply false.


>
> The study included over 20,000 web pages were analyzed, please view the
> data details:
> http://webaccessibility.cita.illinois.edu/data/

...and not surprisingly the issues I take most offence with are also the
ones that have the lowest mean average across the pages evaluated. This
should come as little surprise to those of us who are most actively
involved in this subject matter, as they are also the most subjective and
contentious Rules in the rule-set.

However, for CIOs, Senior Management in other positions at Universities,
and the general population reading that Chronicle article, this subtle
point is easily lost: they see a bottom line score with little
understanding on how that score was reached. In today's climate of the
recent Penn State action, this will lead to senior executives making snap
judgments based on flawed data, rather than asking the right kinds of
questions or striving to ensure real on-line accessibility. Web
accessibility professionals have long known and stated that true
accessibility is not a series of tick boxes on a shopping list, yet the
recent results released by iCITA are just that. The results cause as much
harm as they do good.

>
> Grand Standing Charge Response
>
> To the charge me personally with grandstanding, maybe so, I'll let
> individuals make their own judgement.

I point not at you, but at the report you and your team at iCITA have
publicly released. While you are free to do what you think is best at your
institution, it places many of us in a position not of advancing the
larger issue, but defending and countering your evaluations - in part
because they suggest "Best Practices" that we were not party to creating
as *requirements* for real web accessibility. If you want to evaluate
against Section 508 or WCAG Guidelines that's one thing, but using nothing
but a programmatic evaluator and a rule that states that all TH's must
have an ID (or somehow it is now magically inaccessible) is one I cannot
endorse.

I totally understand the shock and awe effect of having a report that
'names and shames' higher ed institutions (after-all, I too am well known
for going 'rogue' when fighting for web accessibility), but if you are
going to do that then the rules-set must be one that the larger community
already agrees to, and we don't have that here.


> But without data on the inaccessibility of higher education websites
> being publicly available the inaccessibility will still continue to
> grow and get worse.
> I talk to to many CIOs, IT professionals and vendors that tell me their
> web sites are accessible because they have a policy or a law like
> Section 508 that says it must be so.
> Accessibility is more than policy, it requires setting design standards
> (rules) and auditing the use of the design standards.

Fair enough, but imposing *your (ATHEN Collaboration) rules* and design
standards is not what they have agreed to, have been mandated to (by law
or internal policy), or use in internal auditing - and herein is the rub.
I personally advocate and strive for WCAG2-AA, where understanding the
goals (POUR) is significantly more important than tick-box reporting. This
report now sets many of us back in that regard, as 'passing' your tool's
subjective rule-set is now being seen as more important in some circles
than achieving real accessibility. Good for your tool, not so good for the
larger goals.


>
> I hope people see this as an opportunity to raise awareness on their
> campuses of accessibility.

However exactly the opposite is the result. Rather than talking about the
larger issues and advancing successes, many of us are left explaining why
our institutions did not fare well in your report, and explaining why some
of your criteria really have little to do with true accessibility. You've
put many of us who would normally be speaking in positive tones on the
defense - hardly a position to win support.


> If you don't like the rules used in the data collection, I hope that
> you will define your own campus design rules that support functional
> accessibility by people with disabilities and also meet the design
> needs of developers.

As you were conducting your review did you bother to ask the institutions
you were judging if they had such internal rules or policies? Or did you
simply start from the premise that your rules should be the rules we all
must follow? I posit that the later is likely the case: again, judge your
Best Practices members' sites against your/their rules, but do not presume
to impose them on those who have not agreed to them.


> I also hope you will make the design rules publicly available so people
> with disabilities know what to expect when they get to your campuses
> web sites.
> Campuses need to treat accessibility like other IT issues, like
> security.
> They need to have people assigned web accessibility responsibilities
> and they need to measure the implementation of their policies.

You are hardly telling me or others reading this something that we don't
already know. I am unclear how this report helps to achieve any of that -
rather than helping foster the right kind of ecosystems at higher ed it
sends everyone scrambling to eliminate images that are less than 8 pixels
wide or high; effort, time and resources that should be better used going
after the larger issues. (And if you think that some executive somewhere
is going to insist that an audit of web-pages in search of such images is
a fanciful exaggeration then you and I are not working in the same
universe - I pity the poor soul who draws that task)

>
> I should also note that passing these rules doesn't mean you are
> accessible, it just means you have the markup for accessibility.
> There are many manual tests that must be made, but I don't need to tell
> this list that.

No, you need to tell the Chronicle of Higher Ed that. You now need to tell
all of the Provosts, Chancellors, Presidents, CIOs, University Lawyers and
other senior executives who are looking at this article and drawing their
own (flawed) conclusions that. You need to ensure that this point is
clearly underscored on all of the evaluation pages you have publicly
posted as "Accessibility Report Cards", because more than anything else
this is what is blatantly missing in all of the reporting and publishing
of this exercise: that the reports are based not on legal or even
universally agreed to criteria, but rather it is a mechanical evaluation
of Best Practices developed by a select group of participants, and is but
one indication of success or failure in the *opinion* of those
participants.

**********

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

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