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LJWatson avatar LJWatson commented on September 16, 2024

This feedback is based on a collective review by @stevefaulkner @PatrickLauke @jspellman @sarah-horton and @LJWatson

We agree with the intent of SC2.4.10, but have reservations about making it a Level AA SC.

The Understanding SC2.4.10 information states:

"This provision is included at Level AAA because it cannot be applied to all types of content and it may not always be possible to insert headings. For
example, when posting a pre-existing document to the Web, headings that an author did not include in the original document cannot be inserted. Or, a long
letter would often cover different topics, but putting headings into a letter would be very strange. However, if a document can be broken up into sections
with headings, it facilitates both understanding and navigation."

This proposal counters this with the following statement:

"The intent of this Success Criterion is to provide headings for all sections of a Web page. The current Success Criterion is included at Level AAA, however
headings can be implemented as invisible by authors or hidden by a user and included when needed using personalization and semantics."

The introduction of invisible headings would still not be possible in some circumstances. Where content is presented under a licence that prohibits alteration
or additions for example. More so if the headings could be made visible at any point through personalisation.

The following benefit is included in the Understanding SC2.4.10 information:

"People who are blind will know when they have moved from one section of a Web page to another and will know the purpose of each section."

This is certainly true for content that has logical divisions within it (reports or specifications for example), but it is not necessarily so for all content
(letters and speeches for example). It could even be argued that the introduction of headings would hinder the reading experience for screen reader users
in some circumstances.

The 1960 speech by Fidel Castro to the UN is an example (he spoke for 4.5 hours). It would be difficult to introduce headings into this content because they would be
arbitrary breaks, because the speech does not always fall into logical chunks that could be given meaningful headings, and because the presence of headings
would interupt the reading flow for screen reader users reading it from start to finish.

We suggest that this SC remain at Level AAA for these reasons.

from wcag21.

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