WCAG exemptions in regulatory work

[maryjom]

This PR is superceded by #367 to avoid merge conflicts and other messiness since this was open so long. Closing this PR without merging.

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[bruce-usab]

In survey, I suggested stronger phrasing.

[mraccess77]

I think it's worth talking about what US DOJ said in latest advance copy of final rule
https://www.ada.gov/assets/pdfs/web-rule.pdf

In determining how to make conventional electronic documents conform to WCAG 2.1
Level AA, public entities may find it helpful to consult W3C’s guidance on non-web information
and communications technology, which explains how the WCAG success criteria can be applied
to conventional electronic documents. The Department believes the compliance dates discussed
in § 35.200(b) will provide public entities sufficient time to understand how WCAG 2.1
Level AA applies to their conventional electronic documents.

[mitchellevan]

Suggested change

Not all success criteria have been fully adopted in all local regulations and legislation, and may not be applicable to all technologies. WCAG2ICT was also used to determine whether or not to apply certain success criteria. For example, some local standards such as Section 508 in the US, and EN 301 549 in Europe, state that non-Web documents and non-Web software do not need to comply with WCAG 2.0 Success Criteria 2.4.1 Bypass Blocks, 2.4.5 Multiple Ways, 3.2.3 Consistent Navigation, and 3.2.4 Consistent Identification. In addition, EN 301 549 also states that non-Web software does not need to comply with 2.4.2 Page titled and 3.1.2 Language of parts. Regulators should consider the applicability of individual success criteria to non-web documents and software.

Not all success criteria have been fully adopted in all local regulations and legislation, and may not be applicable to all technologies. Regulators have used WCAG2ICT to determine whether or not to apply certain success criteria. For example, some local standards such as Revised 508 Standards (2017) in the US, and EN 301 549 version 3.2.1 (2021) in Europe, have stated that non-Web documents and non-Web software do not need to comply with WCAG 2.0 Success Criteria 2.4.1 Bypass Blocks, 2.4.5 Multiple Ways, 3.2.3 Consistent Navigation, and 3.2.4 Consistent Identification. In addition, EN 301 549 has also stated that non-Web software does not need to comply with 2.4.2 Page Titled and 3.1.2 Language of Parts. Regulators should consider the applicability of individual success criteria to non-web documents and software, and where necessary consider alternate accessibility requirements to address user needs.

I agree with @GreggVan's concern that the references could become dated. To address this concern, as well as for writing style, I propose changing most of the paragraph to past tense. I also propose citing specific versions of the regulations, so our statements here will remain true regardless of future versions of those regulations.

Finally, I added a bit about "address user needs" at the end.

[bruce-usab]

+1 to @mitchellevan edits. Past tense == fact based, so that is constructive approach.