This is great work, but I do have some overarching observations I thought it might be easiest just to capture.
Introduction
People with disabilities can face problems using online content and applications.
I was surprised to see the word "online" in this first statement. I thought Silver was being scoped beyond web content? If so, I think clarity around exactly what is meant by 'online' would be useful. Maybe it's still confined only to UIs that receives or transmits information through the Internet?
I was a bit surprised by the constraints in these two bullets
We need guidelines to:
identify these barriers encountered by people with disabilities.
explain how to solve the problems they pose.
It seems to me we need more than that, and it may be better to define the scope of what is needed here, before going on to define the problems.
In my mind, I had been thinking that a standard that aims to be significantly broader in scope, would likely need to invert its problem statement. For instance, with the fragmentation of UI into any number of customized modalities and restricted use cases, doesn't it make sense to define what any given delivery system can do?
- We need guidelines to indicate the capabilities of any specific user interface
- We need guidelines to indicate the totality of a device's capabilities
In example, a refrigerator or other major appliance may have a reduced-function UI mounted on the door. That UI may be output-only (with inputs coming from fridge activity and environment), or it may have a few user input mechanisms. There may also be manual controls inside the fridge that allow the operator to control some functions (such as temperature or humidity) in response to information revealed on that UI. Obviously the operator can manually add and remove things from the fridge, possibly in response to prompts (i.e., if the UI tells the operator they are out of milk). But the degree to which some such UI information is necessary to the operation of the fridge is debatable, as is whether it should be governed by Silver. Likely there will be a bunch of IoT information, some of which will be available via a web or mobile application, and some of which may be more or less important to the operation of the fridge.
There are a lot of use cases within that, based on user need, user ability, appliance features, etc. There are also considerations for the device itself, which if we are extending considerations beyond the web, likely need to come into play. If I'm in a wheelchair, I may care about door's arc, the reach height for its shelving, or the extension length of the bottom freezer door.
To what extent does the form factor of a device enter into considerations for its 'online' accessibility? In example, with WCAG we were able to more or less assume an external keyboard and screen. Can we assume screens? Input pads? Does a feature-rich app with a reduced voice-controlled interaction constitute a failure? Does an app with an enhanced voice-controlled interaction constitute a failure? (i.e., is there always a need to have equivalent facilitation in every modality for something to be considered to pass Silver?) Does the fact a kiosk's controls may not be within the reach of someone in a wheelchair need to enter into Silver's considerations?
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Without an introduction that gives the context of a more complex world beyond using-the-web-on-a-desktop-browser, the problem statements seem to have focus on 'what is wrong with WCAG 2.x?'
That's a good question to ask (and answer), but I believe it is a subset of what Silver's requirements are. I also think it is biasing Silver to focus on what any interface should do, instead of focusing on indicating what an interface can do.
Few UIs are going to be able to satisfy the needs of every individual. Many, by design, will be targetted at one modality. Rather than 'fail' that UI for all the things it cannot do, one possible way of positioning Silver is to provide simple tools for describing what a solution is intended to do, and what it is capable of doing from an accessibility perspective (i.e., by function, by modality, by sense/capability). Can someone blind use this fridge? Can someone in a wheelchair use this fridge? What different features and components of the fridge are understandable by someone who reads at an elementary level?
By leading with simple statements, potentially much of the complexity with 2.0 could be offered at lower levels where it makes sense.
This is just one riff, obviously. I'm not trying to position solutions, but trying to make the point that to define the Silver Requirements, I think a bit more background is needed, to ensure folks ask the questions necessary to get the best solution and implementation. For the Problem statements, I'll break any feedback down into discrete Issues so they can be dealt with or dismissed on a granular basis.
PS I note in the Draft Final report there are a bunch of statements which suggest the above is close to some of the thinking going on:
Create a solution that addresses the needs of people to find information by role, problem, by disability, and by platform. How can people discover what they need to know?
Develop scorecard or rubric measures for testing task accomplishment, instead of technical page conformance.
Develop a point and ranking system that will allow more nuanced measurement of the content or product:
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