Serendipity

10 September 2008

Dear Sirs

Re: Web site accessibility and “browser standards draft”

http://www.coi.gov.uk/documents/guidance/browser-standards-draft-v0-13.pdf

I fear there is a fundamentally incorrect assumption behind your consultation document on web site accessibility in the guise of “browser compatibility”.

I agree with the premise of your consultation, that Government and other web site owners should be assured that their sites will be accessible using all commonly used browsers, and on special browsers designed for the impaired.

However I believe this aim, of correct display on the most commonly used browsers, may be better achieved by ensuring adherence to the underlying standards which all conforming browsers – the majority – implement. This as distinct from creating something which “works” on particular browsers by quirk, rather than because it is correctly designed and programmed.

However this latter “design by quirk” is a major risk of recommending that web sites just developed by testing with the majority browsers, rather than requiring that the job be done to accepted and common interoperability standards – those for HTML, XML, and ECMAscript (Javascript). These standards are clear, public, and universally accepted as defining the means of correct interoperability, and they are backed up by freely available validation software.

As a result it is a simple matter to ensure that the web site output is correct and interoperable. This can be done as a routine part of development, even automatically, thus keeping costs down. Full browser compatibility checks can of course still be done but will be less necessary; for day to day use a check with one standards compliant browser will assure compliance with them all.

Your example in Appendix A supposes that every office of Government would have to review every function of every web site some six times, not a task likely to enthuse the tester and not one which is likely to be performed to consistent standards by the time the tester gets to the fifth or sixth browser. I would agree that reviewing your work on a browser is an essential part of the development cycle, but you will appreciate that reviewing every feature of a site by a human on each of four or five browsers, to ensure that it looks right and works right, is not a task that it is efficient to do very often.

By ensuring web site output that is compliant to standards, as a regular intermediate validation step in web site production, you can be assured that as browser standards also strive towards compliance, you and the browser developers are working towards common goals of interoperability.

Another risk of just “developing to browser standards” rather than “developing to interoperable standards” is that browsers come and go and so do their quirks.

It is likely that some Government web sites may be in service for several years without any functional change being needed. It is inefficient to rewrite every site just to produce new output should vendor A, for instance, release a new version of Outernet Exploder which rewrites the rules on the quirks for “most common browser”. However even Outernet Exploder is very likely to have a “standards” mode, which can be invoked just by making the correct declaration of standards compatibility in the web site output.

A third benefit of building web sites to standards is that most if not all browsers for the impaired actually use the interoperable web standards in order to function. These standards define ways to provide alternative renderings as needed, and if you work to the standards, you are automatically as functional as possible, whether it is for Lynx or a special browser for impaired needs.

This can be as simple as providing meaningful “alt” texts on images, and destination titles and descriptions on hyperlinks, or provision of audio alternatives via standard HTML tags, or can help full cross-device compatibility by ensuring that all active (Javascript or Java) content also has HTML form-based alternatives available for those browsing on restricted devices.

Again this can all be achieved and verified by the use of public validation tools as a regular and integrated part of web site development procedures.

Use of common standards also aids in reorganisations. By means of CSS, two quite dissimilar web sites can be made to resemble one another without loss of function. I have made such a merge in my own web site between two web site production software tools, and because they both produce compliant HTML, it is simple to split the functions of my web site between them and still achieve a common look and user interface. I can also easily choose to keep formerly functional URLs in use as aliases, even when I reorganise the outer pages of my site to reflect the owner's changing priorities, as Government web sites will assuredly also have to do.

I believe this would be a major advantage in combatting “link rot” in Government web sites – something which has recently plagued my own use of the reorganised Disability Discrimination web sites, having invalidated all references from outside web sites as well as my extensive collection of Disability Discrimination bookmarks from prior to the reorganisation.

Finally, by mandating conformance to testable standards, work can safely be tendered out if desired, to strictly comparable cost bases, and still easily verified as meeting acceptance criteria.

In this way all users can be quite sure that your site will work correctly in any browser they choose, leading to user choice and empowerment, and your commitment to widest user availability is demonstrated to the widest possible audience.

In its present form I cannot agree at all with the Browser Standards Draft, and I hope you will give serious consideration to the points stated above.

Yours faithfully

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We the undersigned petition the incoming Prime Minister Gordon Brown and his new Chancellor, or their Tory opposite numbers if Prime Minister Blair clings on until an election, to roll back the boundaries of recent Governments and free the people and businesses of Britain for a busy and prosperous 21st Century, and most specifically to:

1. Cancel the expensive centralised ID Cards boondoggle immediately. Instead Government to promote and accept a range of trusted and secure third party forms and methods of identification, authentication and authorisation, each appropriate to purpose, such as online authorisation from financial or other newly-established institutions, computer identification certificates e.g. http://www.thawte.com, notarised signatures, and other existing legal forms.

   Why: Identity and authentication are big criminal and security growth areas now (I work in IT security and would really rather I had a more positive job). Solving them will be the economic boom area of the early 21st century. We have experts in this field in the UK, so Britain can lead the world in business, set standards, and host a whole spectrum of financial spin-offs - provided only that we tackle the commercial problems involved in internationally secure assured identity. We are going to have to find out for our own security how to work with legal assurances from other countries so it's really important that we actually do so - why not make money from it by selling our services ?

   The proposed insecure and centralised Government ID Card scheme, in contrast, shows a considerable lack of forethought, and will leave Britain in the economic Third World with the state security of Iron Curtain Europe.

   ["Why Cryptosystems fail", Proceedings of the 1st ACM conference on Computer and communications security 1993, Ross Anderson, University Computer Laboratory, Pembroke Street, Cambridge; "Sensible Authentication: Identification, Authentication, and Authorization", CACM Queue Feb 2004, Bruce Schneier, Counterpane Security; "Beyond Fear: Thinking Sensibly about Security in an Uncertain World", pub. Copernicus Books September 2003, Bruce Schneier]

2. Re-evaluate our duties under the UN Single Convention on Narcotic Drugs and move to a harm-reduction based approach to reducing drug use, such as the successful "British Method" ["A review of the Second Report of the Interdepartmental Committee on Addiction", United Nations Office on Drugs and Crime, UNODC 1966; "Heroin-based treatment in Germany", Journal of Drug Issues, Spring 2002, Michels, Ingo Ilja] as used in Holland, Switzerland and Portugal. Licence controlled sales to adults (possibly with doctors' certificate for the addictive ones) from authorised premises in the same way that alcohol and tobacco and even methadone are now officially controlled, to avoid the present evils of drug prohibition and criminalisation.

   Why: This will cut the legs from underneath the tabloids' Gangster Britain and convert the biggest sector of the black economy into tax-paid legal business (eat your heart out Al Capone). Save approx £8 billion per year currently wasted in promoting/policing the futile War On Some Drugs, and gain another £8 billion in licensed drug sales - instant £ 16 billion win to the exchequer and a recurring £8 Bn annual windfall. Cash to build up needy NHS mental services, cash for neighbourhood policing to prevent legalised drugs from getting out of hand, better social services and support to stop the needy falling into drug problems, cash for reducing personal taxes, cash for investing in UK business, etc etc. Above figures all come from Government statistics and think tanks.

3. Repeal the greedy and pernicious Inland Revenue regulations "IR35" and "S660A" which are designed purely to tax small one- and two- person businesses into the ground and steal the cash that should have been invested for growth and seen them through the recent recession. Restore the foundations of economic prosperity to Britain's small expert contractors, designers and retailers by legally limiting the tax definitions of "employment" as applied to a one or two man Company with self-held shareholding and a monopoly customer ["SMALL BUSINESS ISSUES - PARAGRAPH 5.95 OF THE BUDGET 2004 RED BOOK", Chartered Institute of Taxation and Tax Faculty, September 2004], to attract intellectual skills and provide Britain with a financially secure, well-paid, skilled and flexible IT workforce for the 21st Century.

   Why: The economic boom from such a windfall of tax reductions would need a sure hand not prone to panic: in the Chancellory to steady other Government economic policies and in the Bank of England on interest rates. On the other hand it would kick-start a massive re-growth in Britain's small IT sector to the point where, as before 1999, we could once again compete with Asian outsourcing and low-taxed Silicon Valley. The tax loss in question should be more than compensated by the business growth resulting as well as the foregoing two changes. The last year before IR35 in my audited accounts for 1998-9 I paid £17,000 total tax, plus VAT on turnover - now due to IR35 doubling my company's taxation and resulting flat small-business markets, this year I am paying you just £8,000 total and no VAT. Are you, Mr. incoming Chancellor, good enough to repeal IR35, treat small companies equally with big ones, and handle the resulting increase in tax take ? Your small IT businesses hope so because we are crying out to be allowed to grow and invest !

4. Significant tax revenue from road pricing, congestion charges, fuel duty, and other transport taxes to be ring fenced for any cost-effective (public or environmental return > 1%) public transport improvements at both local and national levels. Reverse year 2006/7 Department For Transport rail franchise cutbacks in SW England, NW England, Wales, Scotland etc. Invest in new and refurbished rolling stock for longer and more frequent trains, enhance future franchises to reduce overcrowding, and back extension of electrification, bus-rail interchange and re-opening of routes, tramways and stations to promote essential UK economic mobility.

   Why: We wasted our oil revenues - let's not waste this tax too. I have to travel for work from north of Derby to Keele, a journey of just over an hour in a car, but which takes 2.5 to 3.5 hours by public transport. I work at home as much as my employer permits, and I realise hypothecation is a dirty tax word, but we the public expect you the Government to invest our money in the transport sectors you expect us to use. There are some good investment ideas emerging from the lower parts of the DfT for infill electrification and rail company co-operation with private enterprise, but it seems in general the Secretaries and Ministers have missed the train which had their plans on - in fact they've probably cancelled it. Since 1995 successive Governments have been playing with their trains. Now let us have no more secretive Railroad Tycoon franchise brinkmanship from the train-set operators at the DfT as seen in 2006-7. Leave renting the stock and planning the trains to the franchised entrepreneurs, and limit Government's rôle to providing broad direction under clear long term plans, open investment in national infrastructure, and underwriting of larger TOC growth/co-operation schemes.

If you are as angry as I am at the increase in Government interference in our lives, at being ignored at the ballot box and overriden by un-elected advisors, at the money being wasted in our names on propping up long-failed policies and introducing new failures, the ever increasing taxation and the ever decreasing services, then please sign the petition at the URL below. The closing date is 20th February 2008 as I hope our lame duck PM Blair will finally have gone by then and we will have a new and more effective Prime Minister, one who listens to the people, not just to those who want to curry favour with him.

Sign at this Government website

The security checksum below is signed with my key 0x2AD08766 and dated 21st February 2007, but - the signing applies to the HTML between the cut lines, not to the text as rendered on your page which is browser dependent ! It may validly change if the embedded links change but this will be uploaded as a separate journal.

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Filth or freedom of speech ? Hugo Gurdon talks to an American group trying to clean up the Net

You are 13-years-old and your english teacher sets an essay on Little Women, the novel by Louisa May Alcott. You have heard that the Internet is the greatest advance in education since the pencil sharpener, so you tap out Little Women on your keyboard, click your mouse and find... what?

Printed version	Electronic version
Persian Kitty's jumpstation - a pornograhpy catalogue with words, pictures and a price list for those items which are not offered free. Here is a sample: Muscle Hunk Gallery - 40 pictures; Slutboys - gay video conferencing; Secrets of Speed Seduction - free "get laid" newsletters; and Cybersex toys. Oh, and finally you see Persian Kitty's purrfect pose of the week, in which two not so little women disport themselves.	Persian Kitty's Adult Links! - a pornography catalogue featuring Persian Kitty's purrfect pose of the week, in which two not so little women disport themselves.
Most of this, of course, has nothing to do with little women, let alone Little Women, but the error can eaily be understood. Access to sexual or indecent material on the Internet is often just an innocent search away.	The results of such searches vary, of course, depending on the search engine in use. Excite threw up the sex site on the second page of the search results. Alta Vista, on the other hand, listed so many genuine Alcott Little Women sites that you would have got very bored if you were searching for porn. Yahoo (UK & Ireland version) inexplicably listed 40Plus - erotic videos of mature English women - as its first site. The fact very few of the Web sites found in this way show anything more revealing than many UK daily newspapers sport on their covers or page three every day of the week, or that the images take an age to download even with a very fast connection, or even that in order to see anything remotely hardcore you have to enter credit card details and other identity verification is, for many people, not the point. Access to sexual or indecent material on the Internet is often just an innocent search away.
I was the 2,710,790th person to visit Persian Kitty's website. One of the others was Allison Evans, of Fairfax, Virginia, the 13-year-old researching that troublesome school essay. Allison described some of the things she saw when surfing the Net as "yuk". Her mother, Doris, agreed and took the case to the Enough is Enough lobby group, which is campaigning to shield children from pornography on the Internet. This group subsists on £500,000 a year from private donations and is run by seven mothers and grandmothers. Yet it is embroiled in the US Supreme Court in what may be the most important free speech trial in decades. Last year, the Communications Decency Act was passed by Congress and signed by President Clinton. The new Act made it illegal to send "indecent" or "patently offensive" material on the Net to children under 18, and imposed penalties of two years' jail or a $250,000 (£150,000) fine on anyone who did. Enough is Enough supports this Act and is fighting to have it enforced. But the law is at present suspended - because of fears that it breaches America's constitutional protection of free speech - while the Supreme Court examines the issue. Jerry Berman, executive director of the Centre for Democracy and Technology, a lobby opposing Enough is Enough, says that if this Act is enforced, it will not just control pornography but "destroy the Internet as we know it". American law does not apply globally, but since more than half of all daily Web use is inside the US, the Communications Decency Act would de facto dictate what appears on the information superhighway. However, supporters of the Act wonder how it can be democratic for the will of Congress and the majority of Americans to be set aside so that porn purveyors can practise unimpeded. And many reject the view that the First Amendment is an absolute protection against censorship. Constitutional "speech", they say, involves the exchange of ideas, not the exchange of smutty pictures, and freedom of speech is not - or should not be - the same as freedom to corrupt minors.
Printed version	Electronic version
According to Enough is Enough, Allison Evans's experience is typical. Monique Nelson, the West Coast organiser of the group, recalls many other examples, including one where a child typed in "toys" and was offered thousands of sexual aids. "It is not only children having easy access to pornography which is a problem," she adds, "but also paedophiles having easy access to children. Kids have been lured by adults through the Internet."	According to Enough is Enough, Allison Evans's experience is typical. Monique Nelson, the West Coast organiser of the group, said: "It is not only children having easy access to pornography which is a problem," she adds, "but also paedophiles having easy access to children. Kids have been lured by adults through the Internet."
The Justice Department argues that those who post information on the Internet must not be allowed to do so irresponsibly. It wants the Internet to be treated like book shops, which can retail pornography but are forbidden to sell it to minors. The case for imposing restrictions on those who post pages on the Internet has strengthened since the Act was signed last year. This is because inexpensive new technology has made it possible for electronic barriers to be put up around selected material, to prevent children having access. Thus it is feasible for a government to oblige porn providers to sell their wares only behind childproof screens, rather as local authorities use planning permission to concentrate strip joints in red light districts.
Printed version	Electronic version
If the Supreme Court rules that electronic red light districts are constitutional, fewer will wander down the wrong dark alleys - as I did with my two-year-old daughter, Molly. Her name alone sparked off 33,299 Internet offerings. It was the fourth which suggested why some controls are needed. "Up in the room," ran the teaser on the screen, "Mike figured that he had better take the lead because Molly was shy, so he began to take off his shirt ..." In the UK, police and Government are already putting pressure on Internet suppliers to clean up the Net. Meanwhile, worried parents can install programs which stop children downloading pornography. This software works by scanning for key phrases or by scanning all incoming material for offensive images. Children should be told never to give out their address or telephone on the Net.	Interestingly, if Allison Evans were to type 'Communications Decency Act' into her Internet search engine she would have found hundreds and hundres of Web pages discussing the issues raised by Internet censorship - and not a pixel of porn in sight.