Objections against CP for ISSUE-129

If there is objectionable material in the other change proposal that would be inappropriate to list in the above CP, then list it here so that it can be tracked and presented during the poll.

Process objections

• The discussion about changing the title or adding an introduction section seems out of scope for this issue, since it is already covered by issue 109, which has already gone to poll and is awaiting a chair response.
• The table added based on the arguments in the basis for addition of "WAI-ARIA and HTML5 Attributes" table section makes numerous changes that were never raised in any bug and that are not justified by any arguments in the change proposal.
• The HTML to Platform Accessibility APIs document, also referred to as the HTML to Platform Accessibility APIs Implementation Guide in this change proposal, should be considered out of scope as it was not proposed in any of the bugs resulting in this issue.
• The References subsection added by this proposal should be considered out of scope as it was not proposed in any of the bugs resulting in this issue.
• The change proposal contains phrases in the rationale section that fail to provide justification or rationale for changes, and instead appear to merely describe the changes in incomplete sentences (e.g. "An attempt to provide clear advice to developers of user agents.", and "Leaving the content of the ARIA section of the HTML5 specification as normative for author conformance and informative for user agent and conformance checkers.").
• In general, this issue seems to have been raised in a manner contrary to the spirit of the working group process. No effort has been made to actually work with the working group to resolve issues or to explain the underlying problems. Numerous arguments presented in the change proposal are novel, having never been presented before (e.g. in bugs or public-html mailing list discussion). A number of the bugs escalated and contributing to this issue have consist of an incoherent bug description followed by an immediate escalation after the editor asked for further clarifications. At least one of the bugs was even escalated after the bug was resolved, without any attempt at conflict resolution.

Objections to the rationale

Objections to the rationale's introduction

• The rationale of this CP implies that requiring authors to violate the semantics of elements should be allowed, but this would lead to serious accessibility and data analysis failures, essentially missing the entire point of HTML's design philosophy for the past 20 years, and regressing us substantially to the days of "font" elements, single-pixel GIFs, and layout tables. This would be a disaster for accessibility, a disaster for advocacy, and would lead to such confusion amongst the developer community that we might easily lose a decade of pro-accessibility advocacy progress (historically, developers have reacted quite poorly to dramatic changes in the messaging on such topics).
• This CP claims that the specification provides tools for authors to violate the semantics of an element in the form of JS and CSS, but does not provide tools in the form of ARIA. However, this is false. The specification provides ARIA tools to violate semantics to the same extent as CSS and JS tools; it makes such violations non-conforming regardless of the technology used (CSS, JS, or ARIA). Therefore this is a false dichotomy: if an author finds it acceptable to violate the specification in one place, it stands to reason that violating the specification elsewhere would be considered no worse, and if an author does not violate the semantics using CSS and/or JS, then there's no need to use ARIA for this use either.
• ARIA markup happens to be one of the few ways we can programatically verify semantic consistency, and seriously relaxing, or indeed removing, the restrictions on how ARIA can be applied to HTML would cause us to largely, or completely, miss this opportunity to educate users to improve their site's accessibility. Furthermore, the specification details care that validators need to take in the messaging in this area to encourage authors to write better, more accessible markup, rather than having them just drop the ARIA — so the risks detailed in this CP have already been mitigated by the specification's current text.
• It is important for overall platform consistency that a platform's specifications take a holistic approach, considering all of the features as a whole rather than each one individually. This CP fails to take such an approach, instead treating ARIA markup as a special case to which basic design principles somehow do not apply. For instance, it is implicitly argued in the CP that authors writing HTML without ARIA are able to update their markup, and this is contrasted to the case of an author writing HTML with ARIA where it is explicitly argued that the author cannot update any markup except ARIA markup. However, this is patently absurd: ARIA markup is just as much markup as the rest of HTML, so if one part of the document can be edited, so can the rest. Indeed, in conjunction with the aforementioned advice for validator implementors, it is more likely that authors will correct their non-ARIA markup than the ARIA annotations, since the validator is not expected to even mention ARIA in such situations.
• The rationale makes a number of false statements or implications. For instance, it refers to ARIA as an "accessibility repair method", which is inaccurate (the word "repair" indeed only appears once in the whole ARIA specification, in the context of images used for mathematics). The ARIA specification's abstract clearly delineates ARIA's role as being for describing "accessible user interface elements" that "can be used to improve the accessibility and interoperability of web content and applications": it is essentially and primarily for annotating "div" and "span" elements that are being used to create custom widgets. Another example of a false statement or implication in this CP is the assertion that the ARIA role taxonomy is designed so that children in that taxonomy can always be used in place of their parents. However, this is trivially disprovable by example: the "radio" role is a child of the "checkbox" role, yet these are not interchangeable native HTML concepts; similarly, the "listitem" role, which requires a "list" parent in the DOM, has as a child role the "treeitem" role, which requires a "group" or "tree" parent, so again these are clearly not interchangeable.

Objections to basis for addition the merging of the tables in the current spec text [sic]

• The premise that the current text does not define which roles, states, and properties can be used in which situations is flat-out incorrect. That is the bulk of the current section, and it is defined very precisely.
• No reasoning is provided for merging the list defining the strong native semantics and the list defining restrictions for elements without strong native semantics.
• Merging these tables results in confused conformance criteria; the subtlety of the current spec's requirement is lost. For example, compare the text in the current spec to the text in the proposed text when it comes to defining the requirements on an input element with a type attribute in the Number state. The current spec text is straightforward. The proposed text in this CP is incoherent. This is, IMHO, a result of this misguided attempt at merging the tables.

Objections to basis for changes to command roles

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Objections to basis for defining h1 to h6 element that does have an hgroup ancestor

The rationale begins by implying that there is ambiguity regarding the default role of elements that the specification does not mention explicitly in the accessibility tool annotations section, but there is no such ambiguity: the default for any element without strong native semantics or implied ARIA semantics is defined by the ARIA specification. The change proposal continues to state that it would be illogical for the specification to require that headings inside HGROUP elements be exposed to UAs in the same way as headings outside HGROUP elements, but this is a straw man argument, since the specification explicitly states that these two cases are not handled the same way, by excluding headings inside HGROUP elements from the normative conformance requirements that apply to headings in general.

The change proposal goes on to state that two adjacent H1 elements with no role should be handled by ARIA user agents in the same way as two adjacent SPAN elements, and says that this is bad. It would indeed be bad, were it true, because it would also imply that ARIA user agents would be unable to convey paragraph breaks! (P elements similarly have no role.) This is naturally quite absurd; indeed, if true even the proposed solution in the change proposal would be broken (consider an HGROUP with three child Hx elements). A number of arguments are predicated on this premise, and are therefore equally faulty.

This section also references the outline algorithm, but this is irrelevant to the discussion as the outline algorithm is orthogonal to the ARIA roles used on elements.

Objections to basis for changes to allowed roles on the a element

This section first argues that Web developers aren't going to be using the specs as a guide of what they can and cannot use, and promptly uses this to argue for changes to the spec. However, this is nonsensical. We should not design the spec's authoring conformance criteria for people who will ignore the spec; they cannot benefit from such changes. The people who will benefit are those who do care about the spec, and we owe it to them to provide them with the most helpful QA tools (such as validators) as we can, primarily by making the spec's conformance criteria as helpful as possible, catching as many likely mistakes and authoring contradictions as possible.

This same section claims that it would be bad if validators complained about ARIA values when detecting a mismatch between native semantics and ARIA values, but this is again an argument against a strawman: the specification in fact specifically suggests that validators not do this.

Objections to basis for addition of "WAI-ARIA and HTML5 Attributes" table

This section argues that the spec leaves this undefined, but this is flat-out incorrect. It is defined very precisely.

Furthermore, the arguments in this section are inconsistent with the arguments in the earlier section which suggested that having one table was clearer. Quite contrary to the earlier arguments that suggested that the spec was to be simplified by merging the two tables, the change proposal actually just changes the split from a coherent separation of elements with strong native semantics and elements with looser constraints, to an apparently incoherent split with attributes listed in one table and then partly repeated in another, data duplicated in multiple cells, etc.

Objections to basis for the img elements deualt role being img [sic]

★

Objections to basis for addition of "Guidance for User Agents"

The change proposal claims that the current specification is not comprehensive, which is false; it also says that this is somehow mutually exclusive with having links, which is again false, and is trivially disprovable since the HTML specification already links to a number of WAI documents in the "recommended reading" section and normatively references both the "Accessible Rich Internet Applications (WAI-ARIA)" and "WAI-ARIA 1.0 User Agent Implementation Guide" documents at the very start of the accessibility annotations section. There is nothing special about these documents that require that they be treated in a manner different than the 100+ other references in the specification.

Objections to basis for allowing roles on heading elements (H1-H6)

★‬

Objections to basis for addition of "References"

Adding a subsection for references makes no sense since the specification already has an entire section for references. There's nothing special about these specific documents that means they should get their own separate references section.

Objections to Guiding factors for decisions on ARIA Role use

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Objections to the Positive Effects section

The section claims that the specification as currently written deters authors from using ARIA, but this is not true — the specification includes text (which is even included in this change proposal's proposed replacement text!) to ensure that conformance checkers do not lay the blame with ARIA attribute usage.

The change proposal claims that the proposed changes will allow developers to use HTML validators to check ARIA conformance, but that misses the point. To check ARIA conformance, an author should use an ARIA validator. An HTML validator should check HTML conformance. The change proposal prevents that (as it in fact admits).

Finally, this section claims that the proposal will make authoring conformance requirements more closely match deployed content, implying that this is an improvement. However, it is quite the opposite. The goal of conformance requirements is not to reflect current practice, but to reflect best practice.

Objections to the proposed text

Overview

• The proposed text contains internal contradictions. For example, it suggests that the "abbr" element has no default role, but then specifies that the "abbr" element (when defining a command) has, in certain cases, the "menuitem" role; it also simultaneously allows authors to use aria-* attributes only in manners allowed in the HTML spec, allows authors to use aria-* attributes in any manner allowed in the ARIA specs, and requires authors to not use the aria-* attributes in ways that conflict with certain requirements, leaving the exact conformance situation highly unclear.

• The proposed text either abuses RFC2119 or has bogus conformance statements (it's unclear which). For example, the text explicitly allows "conflicts" to make things "difficult for assistive technology" (presumably mis-use of RFC2119, since "conflicts" are obviously not a defined conformance class); it also in another paragraph allows authors to "need" to do something.

• The proposed text has redundant conformance requirements, for example it restricts how people may use ARIA features multiple times with subtly different phrasing, without explaining why the requirements are repeated or whether the subtle differences are intended or not. Another example is how it simultaneously has a generic rule regarding state attributes matching equivalent HTML attributes, and has explicit rules for specific attributes. Another example is that it requires support for both the entire ARIA specification and then explicitly requires support for a subset of that specification.

• It contradicts the ARIA specification. For example, for "abbr" elements it says any aria-* attribute is allowed, but the ARIA spec restricts which attributes are allowed based on the role.

• It doesn't use the terms defined by ARIA for the purposes required by this section. For example, the term "strong native semantics" is not used. This means the spec breaks the normative definition chain.

• It allows ARIA attributes that are redundant with HTML native features, despite this having been demonstrated to result in cargo-cult accessibility authoring, which is harmful to accessibility, as discussed in bug 11557 (http://www.w3.org/Bugs/Public/show_bug.cgi?id=11557).

The tables

• The proposed text supposedly alphabetises the elements to which roles, states, and properties can be applied. However, this is nonsensical:
  • The list is not a list of element types, but a list of conditions that elements can find themselves in, so it makes no sense to alphabetise the list by element name (some of the rows don't have any element name at all!).
  • The list's ordering was the only mechanism for resolving conflicts, by changing the order arbitrarily, this resolution mechanism is lost (leading to some of the problems listed in the overview above).
• The second table is simply wrong. Here are some examples (there are many more errors; these is just a sample):
  • It refers to the disabled attribute rather than the disabled concept, so for example it requires aria-disabled="true" to be set on controls that are descendants of disabled FIELDSET elements.
  • It requires that draggable="" be set on elements that are marked as aria-grabbed, even though you can drag elements that don't have the attribute and setting the attribute would affect the user interface in a potentially breaking manner.
  • It requires that the aria-checked="" attribute match the default value of the checkedness of a checkbox element, rather than the current state.
  • It disallows aria-multiselectable="false" even on INPUT type="email" elements where "false" is the only sane value.
  • It uses terms like "match the state" or "match the value" without defining them.
  • It requires that aria-autocomplete be set in a way that mirrors the autocomplete="" attribute, despite this contradicting ARIA requirements (aria-autocomplete="" is about author-provided autocompletion UI, not UA-provided UI; the UA obviously is responsible for making its UI accessible, not the author!), and despite this being harmful to accessibility even if it didn't contradict ARIA (since it would mean that any UA with unusual autocompletion UI would be inaccessible on pages that followed the rules given in the proposal).

The Guidance for User Agents section

There is nothing of use in this section. All the requirements and statements are redundant statements repeating requirements or statements from elsewhere in the HTML and ARIA specifications. All it serves to do is lengthen the specification and potentially confuse readers.

The HTML to Platform Accessibility APIs Implementation Guide

The change proposal surreptitiously includes an entire extra document which it mentions in passing should possibly be an appendix to the specification. The paragraphs below summarise objections to that document.

This document contains requirements that are redundant with the HTML, ARIA, and ARIAIMPL specifications. Having specifications state redundant requirements is very poor form for specification writing, as it leads to unintended ambiguities (where different specifications unintentionally state things slightly differently), and thus interoperability failures. Implementors and advocates who are not fully engaged with the standards process are likely to try to find meaning in the unintended differences, with often quite unexpected conclusions (just look at the folklore that has sprung up around the spelling of the specification's name — is there a space between the "HTML" and the "5" or not? Entire yarns of pseudo-history have been spun around this question). These problems can be especially pernicious because to advocate that an implementor who follows one spec should instead follow the other requires more than the usual standards-compliance advocacy (and indeed, can be at odds with that advocacy, since it requires violating one spec to follow the other).

Furthermore, not only is the proposed document redundant, it is both incomplete and inaccurate. As currently written it presents a dramatically oversimplified view of the requirements on implementations, but even as currently written it does not claim to be complete, with numerous holes, an entire "To Do" section, and question marks throughout.

In fact, the proposed document is unnecessary. Vendors have not shown an inability to read the existing normative specifications, and the text does not help authors or readers of the specification. While it would be fine for the working group to publish a note of this kind (with suitable disclaimers), it is inappropriate as an addition to the specification itself.

Counter Change Proposal

See Change Proposal for ISSUE-129.