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Re: Fixing WAI's writing styleDoes WCAG require ...


From: Chaals McCathie Nevile
Date: Nov 29, 2015 7:07PM

TL;DR: This isn't how things work. WAI is global, multi-stakeholder, and
intrinsically volunteer driven. That doesn't stop people improving things.

On Thu, 26 Nov 2015 05:09:52 +1000, Chagnon | PubCom.com
< <EMAIL REMOVED> > wrote:

>> But asking WAI to hire professional writers is like asking WebAIM to
>> fix the web's accessibility. There isn't a clear way for it to happen.
> No, not the same situation.
> WebAIM doesn't write the standards.

In practical terms, when someone comes here with a question like "does
this situation meet WCAG" and gets a broad consensus for an answer, webaim
is writing a part of the standard for the people who implement it and
follow webaim.

> Speaking as someone with several decades experience working with US
> Federal government agencies to edit and publish regulations and
> standards, the burden of clearly communicating the standards to the
> audience is on the entity that writes and controls the standards.

That isn't quite how things work. The burden of creating and communicating
standards *is* carried by the collective participants in the ecosystem
where the standard is used.

There is a sound argument that a major part of that burden should in
principle be carried by those who write the documents themselves, but that
doesn't make anything happen in the real world.

There is also a sound argument that *any* moderately complicated standard
needs to be reviewed by the people in the ecosystem to determine how it
relates to particular practical situations that were not envisaged, or are

> For WCAG, that's W3C/WAI.
> In the US, federal law requires ... plain-language ...
> When the US Access Board releases the 508 Refresh, WCAG and PDF/UA will
> become part of the US Federal regulations "by reference." And when that
> happens, the Sec. 508 Refresh will be violating the government's plain
> language law already in place.
> This is a major problem that will affect everyone in the accessibility
> community; 3 separate pieces of federal legislation/regulations/orders
> that conflict with each other.

Actually, this scenario is only directly relevant to the US, so (very
roughly) about 1/20th of the world.

Which is not to say that it doesn't matter. There is a lot of value in
having a global community of practice, and common standards across the
world - not least so organisation based in one country can readily
transfer skills and do business in others.

> When this has happened in the past, all legislation/regulations/orders
> were put "on hold" until the problems can be worked out or one or more
> of the pieces is knocked down, possibly determined by the Supreme Court.
> W3C/WAI write and control WCAG. The PDF/UA organization works with the
> ISO on PDF/UA standards.
> Therefore, they -- and only these organizations -- are responsible for
> providing their standards and guidelines (which act as
> pseudo-regulations) in clearly written language that anyone can
> understand.

That is not the case.

If a customer wants something, finding someone who can provide it is their
problem. They may be able to enforce a contract if they had one, but there
is no general right to have things the way you want just because you say
they should be that way.

In this situation, the US government is one (of many) customers for WCAG.
The very sound basis for using it is the global, multi-stakeholder
approach to producing it as a technical standard. This has produced both a
particular level of technical quality, and the important feature that it
is in line with standards used around the world. It isn't perfect, just
better than the available alternatives.

As a counter-example, when WCAG 1 was fairly new the US government
produced the original section 508's specification of requirements for Web
accessibility. That was rejected as a basis for regulation by more or less
the entire rest of the english-speaking world.

Don't forget, most countries that use WCAG - such as 27 of the 29 European
Union countries - don't have regulations written in english in the first

> W3C/WAI must hire the professional writers and editors to do this. It's
> their baby, not anyone else's...therefore it is their responsibility.

It is the responsibility of those who want to use WCAG to ensure it is as
good as it can be. If this were about buying cars for the family, the way
to achieve that would probably be to pay more - but that isn't how
standards work.

> They must act like a professional standards committee and do their
> job...don't ask volunteers to do this job.

But that is how most professional standards committees *do* work.

> W3C has enough information to require 3-4 full-time editors.

1. That's about an order of magnitude underestimated.
2. It still needs the couple of thousand technical experts who contribute
knowledge to its standards, and whom it doesn't, and can't, hire, instead
relying on them or their employers wanting to ensure the standards W3C
produces meet the needs of the ecosystems that use them.

> Otherwise, we'll have 2 possible outcomes:
> 1) Lots of rebuttal lawsuits and complaints about WCAG and PDF/UA not
> being understandable.

You will have that in any circumstance.

> WCAG especially provides a very good loophole for "undue burden" because
> it's so poorly written and incomprehensible.

If this were the case, lawyers really could have $150 every time someone
said "it's too hard to read, so I don't think I need to do it".

> 2) Eventual erosion of our US Sec. 508 law (and others worldwide) that
> could throw everything out the window. We could end up without any laws
> requiring accessibility anywhere...putting us back to 1995 again.

That would be a minor problem in the US, although in practice the ADA and
other US law doesn't need section 508. Many other countries get along fine
with well-written law. So I suggest there are more posible outcomes:

3) Organisations that have large budgets (by which I mean something like
$10 million per year, which dwarfs WAI's budget) will contribute more
resources specifically targeted to improving the writing quality of WCAG.

4) WAI will update WCAG, and many of the same volunteers responsible for
WCAG 1 and 2 will have learned from the experience and provide something

5) The US will follow other english-speaking common-law countries, whose
regulation depends on demonstrating a barrier to some person, rather than
solely requiring conformance to some specific statement. This will create
a demand for clear understanding of how to remove barriers - and therefore
a demand to improve the specifications like WCAG that provide that

> PDF/UA is fairly well-written and understandable.
> WCAG is not. Pure computer-techno-babble gobblygook.
> W3C/WAI, if you truly are dedicated to accessibility, fix the problem.
> It's your responsibility.

W3C/WAI is primarily "us" - or at least those of us who put our time and
money into making it happen. So if we are dedicated to having W3C
standards for accessibility, it follows that we should continue to put in
time and money to improve WCAG, and the various other bits of useful work
WAI does, to the best of our ability.

> Hire full-time, real, professional writers, editors, and communicators.

This request would have to be carried out with imaginary money.
Unfortunately, that is unlikely to have any useful real outcome.

An alternative interpretation is that you think the small WAI staff should
all be replaced with people who can do the job better. Let's assume that
is true - since there is always *someone* better somewhere out there. How
do you propose, in practice, that might happen? Sacking someone, and
hiring someone, are both processes that have a real cost, and *also*
require work. And you can't require that some particular person accept a
job any more than you can require that someone makes products to the
specifications you want - you have to find and agree with a real person to
achieve this.

> Relying on volunteers, committees, and programmers to do this is not
> helping achieve our ultimate goal: worldwide accessibility of
> information.

I don't think that conclusion is supported by the evidence. Relying on
volunteers, committees and programmers has got us surprisingly far in the
18 years WAI has existed - and continues to produce progress.

I spend a lot of time working within W3C, pointing out things I think they
are doing badly, and helping to focus the resources available in more
productive and useful ways. That includes improving the clarity of
writing. But "the resources available" largely means me, and others that
my company pays for, and many many others paid by their employer who
volunteers their time, as well as many individuals who simply volunteer
their own time and expertise.

Perhaps a better approach would be to look at how to enable those
volunteers to contribute more easily, and how to find more of them to do


Charles McCathie Nevile - web standards - CTO Office, Yandex
<EMAIL REMOVED> - - - Find more at http://yandex.com