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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