Question: What are state and local governments doing that the federal government should follow?
The State of Illinois is currently working to revise its accessibility standards. The State recognizes the value of harmonizing with international and Federal standards, and is currently evaluating if and how harmonization can best be achieved.
At this point, we are working to harmonize Illinois' standards with the WCAG 2.0 Success Criteria, as done in the Section 508 draft. (Ultimately, we would like to harmonize directly with the Section 508 Standards, when they are finalized.) However, the stakeholders in our process have identified some issues related to harmonizing with WCAG 2.0 Success Criteria, and we are working to address these issues.
The primary concern is that the Success Criteria are, by design, too general to be useful to programmers who are not experts in accessibility, and who are frequently working under tight deadlines using new and sometimes unfamiliar technologies. These individuals, who are the ones responsible for implementing the Standards on a day-to-day basis, have indicated that they need more specific technical guidance to efficiently implement the standards and effectively test that compliance has been achieved. The most frequent comment from developers regarding existing WCAG and Section 508 standards has been, "Just tell me what I need to do."
To find a way to address this concern, Illinois has been evaluating the WCAG Techniques documents. The WAI indicates that the Techniques are intended to provide "specific authoring practices and examples" and that the Sufficient Techniques, while not normative, are considered "sufficient to meet the success criteria." However, the current Techniques documents are extremely difficult to navigate and understand, with complex conditions regarding applicability, overlap between Techniques, an apparently random numbering scheme, and an emphasis on providing examples and options rather than direction.
As an alternative, Illinois is considering the development of a separate set of Techniques designed to present the necessary information in a way that is understandable and usable by the programmers who will need to use it. (The WAI indicates that this approach is acceptable, stating "it is not necessary to use these particular techniques" and allowing for "other method[s] for establishing the techniques' ability to meet the success criteria.") Based on the feedback provided by programmers, we would strive to develop Techniques that meet the following requirements:
- There should be stand-alone sets of Techniques for separate technologies (e.g., HTML, PDF, Flash, etc.). CSS and JavaScript Techniques should be included with HTML. There should not be "general" techniques that overlap with technology-specific techniques.
- Techniques should be directive, presenting the best practice rather than multiple options.
- Techniques should be as concise as possible. A short code example may be provided. Longer and/or alternate examples should be provided in separate documents.
- Techniques should be organized based on the technology rather than by accessibility concepts, e.g., HTML techniques should be organized into sections like "images," "data tables," and "form fields" rather than "text alternatives," "adaptable," and "distinguishable."
While Illinois recognizes that its technology-specific approach to standards has drawbacks, the programmers involved in evaluating harmonization are even more concerned about the consequences of having standards that are general and technology-agnostic.
The Federal government is likely to face the same issues. Ideally, the Federal government might work with interested partners to develop Techniques that could be shared. (We have heard that the Social Security Administration may be embarking on an effort to this extent.) The State of Illinois would certainly be interested in participating in and contributing to such an effort.
