IITAA Standards Update Workgroup 2011

Participants

Purpose

From Public Act 095-0307 Section 25:

"The Department of Human Services shall, at a minimum, review the accessibility standards every 3 years after the date of initial publication and, as appropriate, amend the standards to reflect technological advances or changes in electronic and information technology. The Secretary of Human Services may convene a working group of appropriate State entity representatives, stakeholders, and other appropriate individuals and officials to advise and assist in the process of reviewing and amending the standards."

Initial Goal

We are considering whether the IITAA Standars should be "harmonized" with the new World Wide Web Consortium Web Content Accessibility Guidelines 2.0 and proposed Section 508 Standards. As an initial step, we we would like to make a recommendation regarding harmonization by September 30, 2010.

"Harmonization"

Harmonization is the process of aligning standards so that they are identical or as similar as possible. Currently, the Federal government is attempting to harmonize Section 508 with the W3C Web Content Accessibility Guidelines 2.0, and several other countries have already done so with their own accessibility regulations. Industry groups, such as the Information Technology Industry Council, are strong proponents of harmonization.

There are arguments both for and against harmonization:

• For - Vendors who create and sell information technology would like to have a single set of standards to follow. It makes it easier for us to find compliant products and gives us access to a wider range of testing tools and resources.
• Against - Existing standards, including WCAG 2.0 and Section 508, are very general and can be difficult for developers to understand. The current IITAA standards were written specifically to be more understandable/usable by State developers.

Current IITAA Standards

IITAA Standards cover software, web sites, telecommunication products, multimedia, and computer hardware. The Standards consist of three "layers":

1. Functional Performance Criteria - high level goals indicating that IT must be usable by people with different types of disabilities.
2. Technical Requirements - more specific requirements borrowed from the original Section 508 (except for web, which is based on the original Illinois Web Accessibility Standards).
3. Implementation Guidelines - explanations of "what," "why," and "how" for the web-related Technical Requirements.

State entities have a choice of complying with the Technical Requirements or demonstrating that the Functional Performance Criteria are met.

Web Content Accessibility Guidelines (WCAG) 2.0

WCAG 2.0 covers only web-based information/systems but is intended to be general enough to apply to a variety of web technologies (e.g., HTML, PDF, Flash, Silverlight, etc.). It is presented in four "layers":

1. Principles - four high level concepts key to accessibility: "Perceivable," "Operable," "Understandable," and "Robust."
2. Guidelines - twelve slightly more specific guidelines on how to make information accessible (e.g., "Provide text alternatives for any non-text content.").
3. Success Criteria - the equivalent of IITAA Technical Requirements, although not technology-specifi (e.g., "All non-text content that is presented to the user has a text alternative that serves the equivalent purpose").
4. Techniques - technology-specific instructions for meeting Success Criteria in different situations (e.g., "When using the img element, specify a short text alternative with the alt attribute"). Techniques can be added and updated at any time.

Developers comply with WCAG 2.0 Success Criteria by implementing applicable Techniques.

Section 508 Draft

The Section 508 draft covers software, web sites, telecommunication products, multimedia, and computer hardware, and the proposed revision includes additional telecommunications-related standards from Section 255. It includes two levels:

1. Functional Performance Criteria - the same as IITAA Functional Performance Criteria with a few additions.
2. Technical Design Criteria - the equivalent of WCAG 2.0 Success Criteria; not technology-specific.

The Federal government is trying to harmonize Section 508 with WCAG 2.0. The Section 508 draft indicates that it would consider a WCAG 2.0 Level AA compliant website to also be Section 508 compliant.

In the draft, the Level A & AA Success Criteria are included primarily in chapters 4 & 5, with a few in 3 & 6. WCAG Techniques are not specifically included.

Comments, Questions & Discussion

• The spirit of IITAA, WCAG, and 508 is the same; the differences are in how the standards are written. Harmonizing should not make Illinois' information technologies any less accessible.
• Harmonizing with WCAG and 508 may put us on firmer ground if there was ever a lawsuit regarding compliance.
• Harmonizing would allow us to use automated testing tools and similar resources that are designed for WCAG 2.
• There is some confusion about whether conformance would be measured against Success Criteria or Techniques. WCAG documents indicate that only the Success Criteria are "normative," but it appears that only the Techniques are specific enough to test in practice.
• Developers need Techniques in order to know what to implement (and to be able to justify what they have implemented to management).
• Anyone can create additional Techniques; Illinois could select/create a set of Techniques for IITAA compliance.
• WCAG 2.0 has been available since December 2008, but Section 508 may not be finalized for another year. We could take steps to harmonize with WCAG now, or wait until Section 508 is comleted.
• We are already having to deal with new technologies and more changes will occur in the next three years.
• The workgroup should also develop recommendations regarding education, outreach, monitoring, and enforcement.

On-line Comments

• Harmonizing IITAA standards with WCAG 2.0 and Section 508 will make accessibility easier for vendors, less confusing for webmasters, and easier to enforce within organizations and statewide. (Katy Whitelaw, Northern Illinois University, August 25)
• I am okay with harmonization as long as we prepare the techniques and tools to ensure compliance in a way most developers can understand. Most developers want to know as specific as possible so there is no grey areas of what accessibility is. I think if we make clear techniques, harmonization is a good idea. (Kevin Price, University of Illinois at Chicago, September 3)
• Harmonizing IITA with WCAG and 508 makes sense. It should make maintaining and teaching the standards easier. I know as a developer it will be easier to implement one set of standards as opposed to trying to make sure I cover all three. (Brandy Thatcher, Illinois Central College, September 3) 
• I think that we should harmonize with new Section 508 standards, then create our own technical guidelines based around the most common technologies like HTML. (Bill Seagle, Central Management Services, September 3)
• The general consensus of the group is to harmonize the standards at the "Success Criteria" level and then develop a set of "Sufficient Techniques" organized and written to be usable by developers, e.g., like the current IITAA Implementation Guidelines. (University of Illinois Web Best Practices Group)

Next Steps

We would like to develop a recommendation regarding if, when, and how Illinois should approach harmonizing with WCAG 2.0 and proposed Section 508 Standards by September 30, 2010.

We will use an online survey to collect and share comments, questions, and discussion.

If further discussion on the question of harmonization is needed, the next meeting/teleconference will be on Thursday, September 16, 2010 at Hay-Edwards Building, Room 325, 400 W Lawrence, Springfield from 1:30 PM to 3:30 PM.