The UK Government has published a Public consultation on Delivering Inclusive Websites document (TG102). This document (available in MS Word and PDF formats) states that all government Web sites must comply with the WCAG AA guidelines by December 2008. And failure to comply will result in the withdrawal of the domain.

Great, you may think. At last the Government is doing something positive for people with disabilities.

I would disagree – I think this is a flawed approach for several reasons:

  • The WCAG 1.0 guidelines are widely acknowledged to be out-of-date and inappropriate for the technical environment and ways in which the Web is used today. And this is not just what I think. Michael Cooper, who works for WAI (who produce the WCAG guidelines) admitted this is a paper he presented at the W4A 2007 conference. As I described in my report on the conference Michael write:

However, we recognize that standards are slow, and technology evolves quickly in the commercial marketplace. Innovation brings new customers and solidifies relationships with existing customers; Web 2.0 innovations also bring new types of professionals to the field, ones who care about the new dynamic medium. As technologies prove themselves, standardizing brings in the universality of the benefit, but necessarily follows this innovation. Therefore, this paper acknowledges and respects Web 2.0, discussing the issues and real world solutions.

  • The WCAG 1.0 guidelines are flawed and ambiguous, as described in a paper on “Forcing Standardization or Accommodating Diversity? A Framework for Applying the WCAG in the Real World“. For example a strict interpretation of the priority 2 guideline which states “… use the latest versions [of W3C technologies] when supported” would mean that a WCAG AA conformant HTML 4 Web site would be degraded to WCAG A conformance overnight when XHTML 1.0 was officially released! There are similar flaws when one considers use of GIF (a widely used, but proprietary graphical format) and PNG (an open and rich, but comparatively rarely-used W3C graphical format). Use of a closed graphical format such as GIF would appear to break the WCAG priority 2 guideline which requires Web developers to “Use W3C technologies when they are available and appropriate for a task“. But is there any evidence that use of GIF rather than PNG is a significant accessibility barrier?
  • It is unclear whether proprietary file formats such as MS Word and PowerPoint and Adobe PDF can be hosted on a government Web site. The document implies they can, provided the file formats are used in an accessible way. But doesn’t this conflict with the WCAG guideline given above? And if Word, PowerPoint and PDF formats can be used, what other proprietary formats can be used? Would a Flash-only Web site be permitted, provided accessible Flash was used?
  • Although the document supports use of both automated testing tools and manual testing, I fear that time pressures will result in priority being given to automated testing, perhaps based on the EU-funded automated accessibility checking tool, the limitations of which I wrote about recently.
  • The conservatism often found in the public sector will stifle initiative and innovation, even when this could provide more accessible services to people with disabilities.
  • The difficulties of ensuring that user-generated content complies with WCAG AA guidelines purchase topamax online (e.g. ensuring the abbreviations and acronyms are marked up when first used in a page) will discourage government bodies from providing services which seek to actively engage UK citizens.
  • The requirement seems to ignore the benefits that can be provided within a particular context. A Web site featuring an anti-drugs campaign aimed at youths in the inner city may be more effective if it uses language likely to be understood by the target audience. But the danger is that such an approach would not be allowed, as the language would not be universally accessible.
  • The failure to address change control in the policy. When, for example, the WCAG 2.0 guidelines are released which, based on the current draft, are more tolerant of proprietary formats, JavaScript and invalid HTML pages, how are Web site owners supposed to respond?

I fear the underlying rationale to this approach is based on the checklist approach which the government seems over-enamoured with. Sadly the requirements to comply with benchmark targets seems inevitably to lead to a fixation with addressing the targets themselves, and a failure to address the underlying issues. As I write the broadsheets are arguing that failures in hygiene standards are due to the NHS’s requirements to satisfy (and monitor) benchmark figures rather tackling the hygiene issues.

After a series of useful government services are withdrawn because of the concerns that they may break dated guidelines, I predict a government minister will face the wrath of Jeremy Paxman – and Jeremy will be able to make use of an anti-EU argument, as the consultation document does admit that “In 2002, the European Parliament set the minimum level of accessibility for all public sector websites at Level Double-A“. A good question for Jeremy will be “Do you have any evidence that compliance with these dated guidelines brings any benefits to people with disabilities?

It seems that political expediency (a Brown government seeking to make a statement, perhaps) has failed to acknowledge the limitations of the checklist approach. And this despite participation from the COI at the “Accessibility Summit II: A User-Focussed Approach to Web Accessibility” in November 2007. As described in a report on the event Kevin Carey, Vice-Chair of the Royal National Institute of the Blind and director of digital inclusion charity HumanITy argued that “At the moment the government is following highly specific [WCAG] points. Some work, some don’t“.

Sadly it seems that the recommendations of this group have been ignored. At least we’re not the only ones concerned about this new. In a comment on a post on New UK government web accessibility consultation on the Blether blog, Karls states that:

I’ve been reading this document today and I agree with Jack – it needs to lose the checklist mentality, extend the deadline (I understand that the author probably had to put some date there) and get every website tested by our friends at RNIB / AbilityNet / Shaw Trust / Nomensa using some kind of joined-up (consistent) testing scheme. I might have missed a few other big players out there but the point I really want to make is I don’t want to see sites get sucked in by snake-oil salesmen.

Your thoughts?