Public Consultation on Browser Standards for Public Sector Web Sites: Opera’s Response
19 January 2009: This post contains a formal response to a superseded consultation document. The revised browser testing guidelines are now available. The remainder of this post is for historical purposes only.
This is Opera Software's response to the Public consultation on browser standards for public sector Web sites by the United Kingdom's Central Office of Information (COI).
Opera Software ASA is a company headquartered in Norway. Noway is a signatory to the European Economic Area Agreement, which guarantees free trade with all EU states and cooperation in such matters as consumer protection, culture, education, and information services (see http://www.eu-norway.org/about/eeaforside.htm).
Many of our users are within the United Kingdom and the European Union, and we feel that the draft guidelines (“the guidelines”) potentially disadvantage them.
We support the aim of the COI to ensure inclusion by testing public authority Web sites on a range of browsers. It is also laudable that the COI requires that Web sites be made accessible to people with disabilities and across multiple operating systems.
However, we feel that there are some aspects of the browser guidelines that need re-drafting. We request that our concerns be considered and give permission for them to be quoted with attribution in any report on this consultation.
Opera believes that the current guidelines attempt to reinvent a wheel that has already been satisfactorily invented and refined over time by other large organizations, both public and private. Reusing their work reduces costs to taxpayers.
Also, Opera believes that the guidelines in their current form
are anti-competitive, as they perpetuate dominance in the browser market by giving the impression that alternative browser products are inferior, and those who choose to use them are not worthy of consideration,
inconvenience users unnecessarily by asking them to install new software,
do not promote best practice development and may lead to more expensive development and testing,
insufficiently “future-proof” Web sites, by ignoring methodologies which would ensure compatibility with mobile phones and other devices,
ignore plug-ins which have capabilities independent of browsers, and
do not sufficiently ensure accessibility by disabled users.
The guidelines should recommend using Web standards and a best-practice development methodology called “progressive enhancement”. This will help ensure compatibility across browsers, rather than aiming at different browsers as if they are completely separate targets.
For testing, the guidelines should recommend adoption of browser support matrices such as the one provided at http://www.bbc.co.uk/guidelines/futuremedia/technical/browser_support.shtml/ by the BBC, which is a well-respected Web brand with a public-service duty and a huge, diverse audience.
This would support
greater competition in the browser market
greater value for money for taxpayers
more consistency for Web visitors and developers, and
savings on Web development costs by promoting Web standards and proven methodologies.
These benefits are also noted in the BBC's Objectives of Web browser support, which gives the methodology by which their browser-support matrix was devised at Appendix 2.
Guidelines restrict choice
Guidelines confuse popularity with capability
Paragraph 15 says “There may be specific browsers that you choose not to fully support because they are either old or unpopular.”
It is legitimate to choose not to support old browsers fully that are not capable of rendering sites made with Web standards and progressive enhancement.
However, it is wrong to decide not to support a browser purely because it is “unpopular”. If it is capable of rendering the site, it should be supported.
The guidelines' introduction states, "It is important to declare which browsers your website has been tested on. This demonstrates a clear commitment to your audience. Users will want to know whether or not your website works with their browser."
We disagree. By naming the browsers on which a Web site has been tested (simply because they are more “popular”), the impression is given that browsers that were not mentioned are somehow “second class”, and its users are not worthy of attention, which demonstrates a clear lack of commitment to audience needs.
We recommend adopting a testing statement such as that used by the Solicitors Regulation Authority:
It doesn't matter how old your browser is—you can use this website. It looks different in some older browsers, and is mostly text in very old browsers (like Netscape 4, or Internet Explorer for Macintosh). But the information is the same, and so are the things you can do.
Guidelines inconvenience users
This erroneous impression of less “popular” browsers as being inferior is reinforced in the sample “browser support statement” in paragraph 12.
Webmasters are advised to list browsers they have tested in as “supported”. The example browser support policy statement includes the message "We advise you to upgrade your browser version as far as your computer allows and if possible to one of those listed above".
There are also many reasons why a user may not be able to change their browser easily – for example, they
may not be using their own computer and be on a shared computer; therefore, they are unable to change or update the browser,
may use a particular browser because of security or privacy settings,
may use a particular browser due to features that help them access and are unable to use another browser comfortably,
may not know how to change their browser.
Many users of the most “popular browser” made no conscious choice to use that browser. On the other hand, we know that many Opera users choose Opera because of features such as excellent keyboard support, the built-in voice browser, intelligent zoom, and fit-to-width display, which are very useful for people with disabilities. It is unreasonable and unfair to suggest that they upgrade because a Webmaster has elected not to test in Opera.
Not only does this inconvenience the user, but we strongly believe that this is anti-competitive.
The guidelines help perpetuate current market shares by encouraging users of “unsupported” (in reality, “untested”) browsers to replace their current browser with another.
(Disclosure: The EU Commission are opening an investigation into an anti-trust complaint filed by Opera on 12 December 2007, regarding Microsoft bundling Internet Explorer in the Operating System and not implementing Web standards.)
Guidelines do not promote best practices
The guidelines are published because it is “impractical and inefficient” to test in all browsers. Presumably this should be interpreted as the COI suggesting that it is not cost-effective to do so. However, it is unnecessary to do so if best-practice Web development is followed.
Best practices should be central to guidelines
The section “out of scope” notes, “How to code for browser compatibility [and] Development methodologies such as graceful degradation and progressive enhancement,” are out of scope.
Additionally, paragraph 40 notes “These guidelines do not advocate specific development methodologies, for example, graceful degradation or progressive enhancement. However, it is widely accepted that sites conforming to open Web standards such as XHTML and CSS are more likely to work well across a wide range of browsers. The importance of working to technical standards is highlighted in Minimum technical standards”.
Opera believes that the guidelines must recommend the development methodology known as “progressive enhancement” which, when based on Web standards, would reduce inconsistencies between browsers resulting in greater interoperability.
When this methodology is employed, users of the most capable browsers automatically receive the highest quality user experience, while users of less capable browsers will receive content and be able to access basic functionality. Therefore, no-one will be “locked out", whereas being "locked out" is much more likely if you choose consciously to test only in/support specific browsers.
Guidelines erroneously treat Web as a visual medium
The guidelines treat the Web as if it were a visual medium such as print, in which designers specify pixel-perfect layout and can rely on that being delivered to the consumer.
This is not true and is inappropriate for public-service websites, where the emphasis is on content rather than aesthetics.
Paragraph 41 says, “A browser is semi-supported if the content and navigation works but the website does not display as intended”.
It is incorrect to judge a Web site on whether it displays “as intended”. A Webmaster cannot mark a browser “down” as semi-supported because it does not have curved borders, opacity, or the same fonts as those on a designer's machine.
By emphasizing “intention”, the guidelines legitimize preservation of design as a goal. In the past, this has led many bad design decisions such as fonts being expressed in pixel sizes which cannot be resized in Internet Explorer, for example.
The Web site should be judged on whether the recipient can use it in a format that (s)he wishes. If, for example, a browser mis-renders a site built with Web standards, such that content is obscured or is illegible, then that browser is unsupported.
If a browser renders the content as legible, the navigation usable and functionality operable, then that browser is fully supported in the context of a public-service site.
Best practices lead to cost-savings
Recommending best practices whereby developers code to internationally-agreed standards rather than to circumvent the quirks of today's market leaders leads to cost savings throughout the life-cycle of a Web site:
It is more cost-effective to build right than to correct during testing, so explicitly advocating progressive enhancement results in more efficient development and Web sites being quicker to market.
Reducing inconsistencies through smarter development ensures that the “testing” phase is shorter and, in the case of static pages of content, it should be possible to reduce testing to a quicker “verification” stage that quickly checks across a range of browsers that there are no significant inconsistencies.
Once deployed, Web sites built using valid, semantic (X)HTML and CSS are more maintainable because they are in accordance with international standards.
Guidelines are too fragmented
The guidelines mention design methodology and minimum technical standards in paragraph 40, but it is a leap of faith to assume that everyone else will read the second document.
The guidelines are written “for all website managers, web developers and web testers delivering public sector websites”, so we recommend that all the guidance relevant to these groups be amalgamated —or developers will naturally assume this supersedes all other guidance and start developing to browsers.
Additionally, the “Minimum Technical Standards” document is dated May 2002 and is obsolete; it mentions CSS 2 as the latest version, allows HTML tables for layout, and does not mention Scalable Vector Graphics (SVG).
Opera recommends modernizing this document and incorporating the updated guidelines into a comprehensive document aimed at the target audiences named on the cover.
Guidelines do not address mobile and other devices
Paragraph 39 notes that Guidance on support for mobile platforms will be the subject of future guidance. Other devices are described are similarly “out of scope”. (Paragraph 37 also notes, “Guidance on support for mobile platforms will be the subject of future guidance”; we assume this is an editorial error.)
This further fragments the guidelines, as readers will have another set of guidelines to check.
Different guidelines are unnecessary. Recommending a progressive enhancement methodology ensures that Web pages work across all browsers and devices.
Guidelines ignore plug-ins which are independent of browsers
The guidelines ignore the subject of browser plug-ins, such as those that allow readers to access PDF, MP3, video, and Flash content. These plug into a browser but are independent of it. Therefore, a group of users running the same version of a browser may have different versions of plug-ins and receive markedly different experiences.
For example, a visitor running Opera 9.5 with Flash Player 6 would not be able to take advantage of any accessibility features built into a Flash movie, while a visitor running Opera 8 with Flash Player 7 would be able to use those accessibility features, because the plug-in has a higher specification, even though the browser is less capable.
The guidelines should address plug-ins, independently from browsers.
Opera also suggests that the guidelines for Web developers require the use of open standards wherever possible, while allowing content that requires plug-ins as a secondary delivery method.
Guidelines should recommend testing by disabled users
Opera welcomes the guidelines' inclusion of a requirement that Web sites be tested with assistive technologies.
However, the guidelines currently legitimize a sighted developer using a trial version of a screenreader and comparing the synthesized speech with the words on a screen, which is inadequate testing; a sighted user cannot have the same experience or knowledge of the tool as a real user.
Therefore, we believe that it should incorporate guidance from the British Standards Institution's Publicly Available Specification (PAS) 78, Guide to good practice in commissioning accessible websites:
“All organizations, regardless of size, should ensure that those testing the website are different from those developing it.”
“Website commissioners should conduct user testing with disabled participants to ensure that their websites are accessible and usable by disabled people”
User testing should include users from a range of disabilities and preferences, including a mix of beginners and experienced web users using a range of assistive technologies.
Inadequate definitions/ ambiguities
Paragraph 46 suggests testing “ability to bookmark” as part of testing a Web site. That is a browser feature, not a developer-authored feature and thus out-of-scope.
Why are Rich Internet Applications separated out? The requirement for sites to work with scripting turned off, etc., is not solely related to RIAs.
Too many trademarks used in examples
We would prefer it if more than one trademark were used as illustrative examples, or none at all, as currently the guidelines erroneously give the impression that only one browser exhibits the qualities being discussed.
For example, we would prefer it if paragraph 50 were redrafted to read, “Certain browsers (e.g., Firefox and Opera) are developed using cross-platform technology (e.g., Java) and, therefore, behave similarly on different operating systems,” or “Certain browsers are developed using cross-platform technology ...”.
These comments were written by Bruce Lawson, a Web Evangelist representing Opera Software ASA. Bruce may be contacted via email@example.com for any clarification of these comments.