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Re: Proper Markup on Web Pages

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From: Brooks Newton
Date: May 13, 2016 8:02PM

Hi Jonathan,

Thanks for your thoughts on why software regulation, in terms of why its absent from the most recent ADA SANPRM. Your suggestions are helpful to me and likely to others trying to sort out this mess.

I'm very happy that you agree, as I think most experts in this field would, that "frameworks, user agents, authoring tools, and software is very important" to figuring out the digital accessibility puzzle.

When thinking about how to best plan for the accessibility of Web sites, I believe it is important to understand the roles that operating systems, user agents / browsers and assistive technology play in the overall Web user experience. I'm certainly not even close to being as much as an expert in this area as others on this list are. So, let me just ask this question: Have you, or anyone else on this thread ever heard of person who absorbs page content directly from the source code without parsing it through a user agent / browser? I sure haven't.

Is it even possible to have a "user experience" without the help of a browser to parse Web page source code? It seems like an artificial exercise in futility to separate out Web content, as those who drafted the ADA Title II SANPRM have done, as the lone piece of the digital accessibility puzzle that must be regulated. After all, Web content alone does not make a user experience.

For users with certain types of disabilities, utilization of assistive technology is just as necessary in building an accessible user experience as is the use of Web browsers. In order for each and every one of us to Perceive, to Operate, and to Understand Web content, we must first pass the content through an operating system, a browser, and in many cases, assistive technology to make sense of the raw source code over which content owners have control (let's not even discuss third party content at this point). Additionally, what does it mean for Web page code to be "Robust," when none of the necessary software is required to be standards compliant? How is my specification-compliant page code robust (in other words, largely "future proof"), when in no way, shape, or form are browser manufacturers obligated to process my code in a consistent manner that pays heed to the same standard content owners are obligated to follow? Should we just count on software manufacturers to "do the right thing," when that same approach has yielding exceedingly disappointing results when it comes to measuring compliance by site content owners? Have we the experts, and the regulators who follow our advice, provided content owners with a clear path forward to make their Web pages and mobile apps accessible? What is keeping a software manufacturer from changing their browser functionality, for example, so that what works in my page code today, doesn't work for my page code tomorrow?

Again, I'd like to put forth the notion that there is no such thing as a "Web user experience" without intermediating software. If there is some sort of technical reason why the U.S. Department of Justice has specifically decided to regulate Web content, and not the software that facilitates the content to be Perceivable, Operable, Understandable and Robust (the core tenets of WCAG 2.0), I'd sure like to know that. If that is the case, I'd also like to know what the appropriate agency is that has jurisdiction over Web software, so that we could make sure that appropriate regulation is evolving at the same time as the ADA updates so that all of the appropriate parties are doing their requisite parts to make accessibility the norm, not the exception.

Is this really just a monumental oversight? Have we really gone this far down the regulatory road without holding fully accountable all of the integral parts of the accessibility puzzle?

Brooks Newton

-----Original Message-----
From: Jonathan Avila [mailto: <EMAIL REMOVED> ]
Sent: Friday, May 13, 2016 11:58 AM
To: WebAIM Discussion List < <EMAIL REMOVED> >
Subject: Re: [WebAIM] Proper Markup on Web Pages

> If there is anyone on this list that who is responsible in whole or in part for actively excluding software manufacturers from obligations under the proposed ADA update (recent ADA SANPRM), I would genuinely value an explanation for why you believe exclusion of these integral parties makes sense.

Brooks, while I was NOT involved in the process or decisions that went around the language in the SANPRM I can guess that trying to regulate makers of frameworks including open source frameworks is a jurisdictional issue that the DOJ may not have the ability to regulate. That is, goods and services are typically regulated around things such as interstate commerce (e.g. CVAA), places of public accommodation (e.g. ADA Title III), etc. Frameworks by themselves would likely not be covered until they are sold or used by organizations. A report and order from the FCC did hint that perhaps peer-to-peer communication services could be covered under the CVAA and the maker of the peer-to-peer software could be considered a service provider even though they did not host the service -- but I'd imagine this might face quite a challenge in our judicial system.

Ultimately I believe accessibility in frameworks, user agents, authoring tools, and software is very important and a critical piece of the puzzle -- but finding the right way to address the issue has and will continue to be a challenge.

Jonathan

Jonathan Avila
Chief Accessibility Officer
SSB BART Group
<EMAIL REMOVED>
703.637.8957 (Office)
Visit us online: Website | Twitter | Facebook | Linkedin | Blog Check out our Digital Accessibility Webinars!


-----Original Message-----
From: WebAIM-Forum [mailto: <EMAIL REMOVED> ] On Behalf Of Brooks Newton
Sent: Thursday, May 12, 2016 2:47 PM
To: 'WebAIM Discussion List'
Subject: Re: [WebAIM] Proper Markup on Web Pages


Hey Brandon,

I want to be clear in communicating my opinion that I do believe there is a tremendous amount of work that absolutely must be done by site and mobile app owners to support the accessibility of their content. No doubt about that, site / app owners, developers and other digital content production staff have their work cut out for them in the years ahead to uphold their ethical and legal obligations in making the Web and mobile app offerings more accessible. And in keeping with this opinion, my position is that content owners must also have a clear path to accessibility available to them, in terms of having a more complete list sufficient techniques at hand (for example, preapproved code snippets for implementing accessible Web page elements) related to making available advanced digital content for use by people with all abilities. We need to develop and publicize "approved" code constructs for design patterns we already see embedded in JavaScript libraries, development frameworks, Web site authoring tools, content management systems, etc. We should also be on a constant vigil, searching for new content constructs, page controls and information delivery systems that appear in the wild, which fall outside of the design patterns we already got in our vetted inventory of advance page components.

Oh yeah, and by the way, let's make the software manufacturers aware of and obligated to honor the vetted and approved content implementation techniques so that they can build their software, including operating systems, browsers / user agents, and assistive technology to support content owners who responsibly follow coding examples provided in the sufficient techniques. I know, I know - nobody wants to get bogged down in technology-centric standards. That's why, in my opinion, we need keep and cherish the generalized normative standards that work so well for WCAG 2.0, but also significantly expand upon the informative sufficient techniques with real world examples of how fancy Web page gizmos should be coded to spec. That way the software manufacturer programs can parse the site /app code properly, following their own regulated set of specifications, thus enabling access to end users with disabilities.

Anybody agree or disagree?

If there is anyone on this list that who is responsible in whole or in part for actively excluding software manufacturers from obligations under the proposed ADA update (recent ADA SANPRM), I would genuinely value an explanation for why you believe exclusion of these integral parties makes sense. If I don't hear back on this issue as a response on this thread, I'll ask the question again later in a separate post.

Thanks,

Brooks Newton




-----Original Message-----
From: Brandon Keith Biggs [mailto: <EMAIL REMOVED> ]
Sent: Thursday, May 12, 2016 12:18 PM
To: WebAIM Discussion List < <EMAIL REMOVED> >
Subject: Re: [WebAIM] Proper Markup on Web Pages

Hello Brooks,
As we have been saying, the problem is not websites and apps, but the underlying frameworks that they use. For example, anything using open GL is not accessible to blind users unless a whole accessibility framework is created.
So any ADA amendments should target frameworks primarily.

Also, what percentages of the frameworks are open source? It may be beneficial for a non profit or something to be created that just goes around and adds markup to frameworks...
Thanks,


Brandon Keith Biggs <http://brandonkeithbiggs.com/>;

On Thu, May 12, 2016 at 9:38 AM, Brooks Newton < <EMAIL REMOVED> >
wrote:

> Hey Brandon,
>
> Very good point!
>
> In terms of "going after" a software manufacturer, be it an open
> source or private entity, I wouldn't count on any effective remedy
> under U.S. law to right this wrong at the present. Software
> manufacturers have largely been given a "pass" on Web accessibility
> regulation by the powers that be. I'm planning on making a post to
> this discussion list in the coming days that underscores the need to
> make software manufacturers accountable as part of the recently
> announced Americans with Disability Act (ADA) Title II Supplemental
> Advanced Notice of Proposed Rulemaking (SANPRM), which proposes to
> regulate the accessibility of Web sites, and possibly Web apps, for
> U.S. state and local governments. We need to rally support for this
> issue and make our expert opinions clear to the U.S. Department of Justice as they seek input on how to regulate Web accessibility in this country.
>
> In terms of voluntary support for making development frameworks
> accessible, there have been a number of efforts. I'll defer to others
> on this list to speak to those efforts.
>
> More to come later on the recent ADA Title II SANPRM...
>
> Brooks Newton
>
>
>
> -----Original Message-----
> From: Brandon Keith Biggs [mailto: <EMAIL REMOVED> ]
> Sent: Wednesday, May 11, 2016 2:21 PM
> To: WebAIM Discussion List < <EMAIL REMOVED> >
> Subject: Re: [WebAIM] Proper Markup on Web Pages
>
> Hello,
> Is there any kind of org that goes after larger providers such as
> angular, .net or whatnot to make sure all their wigits are accessible?
> That would go miles in helping stuff be accessible.
>
>
> Brandon Keith Biggs <http://brandonkeithbiggs.com/>;
>
> On Wed, May 11, 2016 at 11:59 AM, Mike Barlow < <EMAIL REMOVED> > wrote:
>
> > I agree 100% Teresa. I've seen the same thing and have had similar
> > discussions in several of the local user groups I attend. Too many
> > developers only know how to "code" using some of the new tools and
> > IDE's out there that don't have accessibility in mind. And as far as
> > Wordpress goes there are a number of Accessible templates out there
> > that
> can be used.
> > I believe even the base Wordpress template direct from Wordpress is
> > flagged as an Accessible template, though since I don't use
> > Wordpress I haven't checked into that personally.
> >
> > But in most cases the edict needs to come down from "on high" to
> > inform developers they need to develop accessible sites/applications.
> > Unless a company requires that from developers most (especially the
> > ones who aren't familiar with developing accessible sites) won't
> > take that into consideration. They also need to ensure that the apps
> > get properly tested for accessibility. Too often I've heard people
> > say, well isn't it only that we have to have the "alt" attribute on images?
> >
> >
> > *Mike Barlow*
> > Web Application Developer
> > Web Accessibility/Section 508 SME
> >
> > Lancaster, Pa 17601
> > Office: 732.835-7557
> > Cell: 732.682.8226
> > e-mail: <EMAIL REMOVED>
> >
> > On Wed, May 11, 2016 at 1:38 PM, Teresa Haven < <EMAIL REMOVED> >
> > wrote:
> >
> > > Hi, Brandon. From my observations, a lot of developers don't
> > > actually write code any more -- or at least, they don't write HTML.
> > > They use something like .NET, or a toolkit like Bootstrap or
> > > Angular or any of a hundred others that generate the code for
> > > them, and they don't know what
> > is
> > > getting generated, but they do it because they think they are
> > > saving time and/or that "accessibility is hard". I've done
> > > extensive work with our in-house developers over the past year+ to
> > > get them to think hard about (and actually observe) how much time
> > > they are "saving", and many of them are now modifying their
> > > practices, but it has required a lot of personal
> > > relationship-building plus having an in-house edict that says they
> > > have
> > to
> > > improve the accessibility of what they are building. I believe
> > > many developers a) don't have the knowledge that they are doing
> > > anything
> > wrong,
> > > and b) don't have the direct support to show them why learning to
> > > do
> > things
> > > differently would be an advantage to them. I think one of the big
> > questions
> > > for groups like us is, "How can we get people to understand both
> > > why this is important, and how they can do it without them
> > > thinking it is overwhelmingly difficult?"
> > >
> > > Teresa
> > >
> > > Teresa Haven, Ph.D.
> > > Accessibility Analyst, Northern Arizona University
> > >
> > >
> > >
> > > -----Original Message-----
> > > From: WebAIM-Forum [mailto: <EMAIL REMOVED> ]
> > > On Behalf Of Brandon Keith Biggs
> > > Sent: Wednesday, May 11, 2016 9:46 AM
> > > To: WebAIM Discussion List < <EMAIL REMOVED> >
> > > Subject: [WebAIM] Proper Markup on Web Pages
> > >
> > > Hello,
> > > Over the last 2 years I have seen an increasing tendency for
> > > websites to just not use HTML in their websites.
> > > For example, sites such as:
> > > http://www.roommates.com/
> > > and
> > > https://sfbay.craigslist.org/search/hhh
> > >
> > > have headings on their homepages, but no headings anywhere else.
> > > Also, most websites have blank sharing buttons:
> > > https://www.indiegogo.com/#/picks_for_you
> > > or for their follow buttons, they just say "indigogo".
> > >
> > > This tendency is being exacerbated by CMSes such as WordPress
> > > which have plugins that people use without understanding that they
> > > are not
> > accessible.
> > > This should be a better thing, but when those plugin developers
> > > have no interest in making their plugin accessible, everyone is out of luck.
> > >
> > > Have other people noticed this tendency to not put headings, not
> > > label links and put extensive non labled clickable elements on
> > > their
> pages?
> > >
> > > What can be done to move more people to these standards?
> > >
> > > My first thought is to require at least one heading on an html
> > > page
> > unless
> > > an explicit tag is given.
> > > Another thing is to not show links that do not have text inside
> > > like: <a href="http://brandonkeithbiggs.com/" id="l1"> </a>
> > >
> > > Something I hear quite often from web developers is that native
> > > wigits
> > are
> > > too difficult to customize, so it is just easier to make their own.
> > > I
> > don't
> > > understand this, but this opinion is very detrimental to accessibility.
> > > Thank you,
> > >
> > > Brandon Keith Biggs <http://brandonkeithbiggs.com/>;
> > > > > > > > > archives at http://webaim.org/discussion/archives
> > > > > > > > > > > > archives at http://webaim.org/discussion/archives
> > > > > >
> > > > > > archives at http://webaim.org/discussion/archives
> > > >
>
>
> > > archives at http://webaim.org/discussion/archives
> >