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Interagency Council on Government Information
Web Content Standards Working Group
May 24, 2004

Summary of Comments on
Initial Draft Recommendations

A. Overview and General Comments

The Web Content Standards Group's initial draft recommendations were circulated to a broad list of vetting groups in early April 2004 (see Attachment C of the ICGI's Final Report to OMB). We received 120 sets of comments during the three-week informal vetting period, including comments from virtually every cabinet-level agency, many sub- and independent agencies, and several agencies of the legislative branch. Many of the comments were extensive (at least several pages), while others offered comments on just one or two recommendations.

Because we emphasized that this was an informal vetting process, most of the comments were from individuals and do not necessarily reflect the official views of a particular agency. In a few cases, agencies coordinated their comments internally and provided more formal comments.

While the vast majority of comments were neither explicitly positive or negative, the overall tone was substantially positive. Overall, respondents expressed support of the effort to establish government-wide policies for federal public websites. Many comments said the document was reasonable, well written, and based on sound industry best practices. The vast majority of comments asked for clarification or more detail about how the policies would be implemented – for example, clarification about which sites would be covered by the policies, excluded, or grand-fathered. Most of the negative comments expressed concern about the lack of resources to implement the requirements. Other respondents expressed concern that the recommendations are too restrictive and don't provide enough flexibility for agencies to manage websites according to their agency's specific needs.

Recommendations that received the most comments were:

Recommendation Number of Individuals/Agencies Providing Comments
(1c) Linking to External Sites 56
(2c1) Contact information 44
(2d) Websites must be results-oriented 41
(1d) Currency of information 38
(3i) Metadata 38
(1a) Government Domains 33

Recommendations that received the most positive comments were:

Recommendation Number of Individuals/Agencies Providing Comments
(3i) Metadata 38
(3a) Common Access 24
(3e) Documents in Different File Formats 16
(3b) Access for People with Disabilities 14
(3c) Plain Language 14
(3g) Consistent Navigation 12
(4a) Avoid Duplication 12

Recommendations that received the most negative comments were:

Recommendation Number of Individuals/Agencies Providing Comments
(1c) Linking to External Sites 28
(2d) Websites Must be Results-Oriented 17
(1d) Currency of Information 12
(1a) Government Domains 11
(2b) Homepages must be citizen-focused 10

Sample General Comments:

  • The Working Group has done an excellent job of laying out the extraordinarily wide range of issues to be addressed in carrying out the mandates of Section 207(f)1) of the E-Government Act of 2002.

  • Hooray! These standards will improve the federal government's credibility and accountability to the citizens of this country….The easier we make it for our visitors to find the information they need, the better it is for the federal government as a whole. One bad agency website makes all the rest of us look bad, too.

  • The guidance is rooted in existing and emerging best practice - which they should continue to be - and demonstrate significant research and thought has gone into their formulation for Federal Web site guidance.

  • We believe the draft document is very well written and incorporates many best practices generally accepted throughout industry.

  • Kudos on a good product. I manage a website at the Department of Energy and have trouble taking a stand on Federal best practices without having related Federal documentation to reference and backup my findings. Federal web content standards will help immensely.

  • Overall, while there are good reasons for the standards proposed, it is highly likely that many managers will elect to take currently public sites offline as they do not have people resources or funds available to implement the changes mandated by this standard.

  • There is the assumption that appropriate resources are available to implement these recommendations. You may wish to consider some statement with regards to resource allocation in order to accommodate the suggested recommendations of the Draft.

  • We are gravely concerned with any effort to mandate on a federal-wide basis the content of our Web site or our Information Architecture. We agree in general with the goal of these standards, but not the detailed, prescriptive nature of the standards and disagree with the use of the word must….

  • Generally good issues included here. Overall, however, [we] prefer a much more significant and robust policy than this movement “towards” common look and feel that provides more consistency in branding and assurance of the authoritative source. Not laying the foundation for it here will be missing the one legislatively mandated opportunity to implement more logic and management to the .Gov domain.

  • I found the recommendations to be well written and containing solid logic for design and concept.

B. Comments on Individual Recommendations

1a. Agencies Must Use Government Domains

Positive:   7
Negative:   11
Neutral:   15
No Comment:   75

Most comments asked for clarification about which sites this requirement would apply to, including questions about “partner” sites. Negative comments expressed concern about not being able to maintain sites in the .us or .edu domains, and the cost of switching to .gov or .mil. Positive comments said this would help reign in sites in other domains. Some mentioned the need for standard naming conventions for government domains.

Sample Comments:

  • I can't emphasize how important it has been for us to keep these non-dot-gov sites from proliferating.

  • I find the wording in the Rationale: “assures the public that these are official government sites and are accountable for the site's content” not to be convincing. Domain's on .edu sites or other web sites from reputable organizations are accurate and accountable for their content.

  • The policy should address these unique situations where the federal agency is part of a larger partnership.

  • This could become very problematic for agencies engaged in extensive operations overseas…where local domains are purchased.

  • NTIA strongly opposes this proposed policy. The domain .us should be included as an official U.S. government domain because this domain, in addition to .gov and .mil, is operated on behalf of the U.S. government, remains under the control of the Department of Commerce, and is now being used by many agencies.

1b. Agencies Must Note Sponsorship of Web Sites

Positive:   2
Negative:   9
Neutral:   12
No Comment:   97

Many of the negative comments reflected confusion about the extent to which web pages would need to be altered to include the sponsorship text and/or title tags. Others were confused by the title tag requirement, which many readers misinterpreted as metadata. Some wanted clarification about whether certain types of pages mainly PDFs) would be excluded.

Sample Comments:

  • Our reviewers support both aspects of this idea, i.e. putting the name of the agency organization on every page and in the metadata. However, they believe strongly that this should not be in the page title tag or in the keyword metadata…

  • Yes, sites should identify themselves to our visitors but in terms of usability, it's also important that the title contain the specific information available on a page…which is more important than the agency name, in terms of Internet searchers finding the information that they need...

1c. Agencies Must Follow Basic Common Linking Practices

Positive:   10
Negative:   28
Neutral:   18
No Comment:   64

Many comments reflected confusion about the difference between disclaiming links to external sites and merely notifying a user when they go to another site. Some objected to the prohibition on disclaiming other Federal sites, saying they couldn't endorse content from another federal agency. Many wanted to eliminate the option for using “exit pages,” noting usability studies that show users don't like them. Also, several people objected to posting linking policies on the Web, saying they are internal policies that should not be shared with the public. Several supporters also recommended a standard exit icon for all Federal web sites.

Sample Comments:

  • I like your recommendation to display an icon next to the hyperlinks of external sites.  I would recommend that you develop a standard icon maybe in a couple of small sizes) that could be adopted by all agencies as a standard for an external hyperlink.

  • There was some disagreement among our staff as to whether the entire policy needed to be on the site, as these cases are not always cut-and-dried. But we all agreed that general guidelines should certainly be posted.

  • The prohibition from having an exiting disclaimer for links to other Federal sites… how could this be justified since we have no control over the content of other Federal sites? There is no way for one agency to verify the accuracy of information on anther's website…A statement of "no need to disclaim" would be a much better way to handle this.

  • Failure to notify users that they are going to another site where the policy is different would be a disservice, e.g., suppose an agency applies for and receives the permission to use permanent cookies on their site or a portion of their site?

  • I'm grateful that there are several options available [for notifying users when linking to another site]. But have some concern about the exit page option because of the additional download requirement for visitors…

1d. Federal Public Websites Must Convey Current Information

Positive:   4
Negative:   12
Neutral:   22
No Comment:   82

Most comments were generally supportive and liked having the choice of different date designations. However, many thought the options listed didn't cover the range of possible circumstances—including what to do with historical documents that don't change. Several expressed concern about the technical resources required to implement the policy, including how to put dates on dynamically generated sites.

Sample Comments:

  • Please continue this practice.  I have an icon titled "Historical" on old content that is still applicable or of value being on the website. 

  • We recommend that the term “current” be defined. Our particular concern is how to indicate that an entire web site and all of its contents are non-current, historical records

  • We are concerned of the benefit of this requirement. The addition of a “last … date” does little to tell the user about the currency of the information. The content could be several months or years out of date and a recent update simply corrected a spelling error but might not update the content. Conversely, guidelines that were issued years ago could be as relevant today as the day they were issued, but the inclusion of a “last … date” could cause the user of the information to question its relevancy and generate unnecessary and unneeded worry on the part of the user and unneeded contact for the agency

2a. Content Must Be Organized in Ways That Make Sense to Citizens

Positive:   3
Negative:   8
Neutral:   16
No Comment:   93

Most comments requested more clarification and implementation guidance. While many people appreciated having multiple ways to organize a site, others felt it was overly prescriptive and objected to organizing content for the general public rather than for specialized, target audiences. Still others recommended a stronger requirement.

Sample Comments:

  • This guidance could be stronger, and linked to evaluation. Agencies should collect and evaluate user feedback, conduct usability testing, talk with their users, and continually assess their Web sites performance.

  • While we agree with “citizen-centered,” …this does not mean that organizational alignments should be abandoned completely; rather a hybridization; or dual paths can prove more useful. A “one-size fits all” approach will not work when you are drilled down into an agency.

  • Certainly, it is important to know the audiences). However, the recommendations should not give the impression that there is one appropriate means of organizing a site. EPA has MANY audiences, with differing needs.

  • The guidance instructs agencies to "assess its customers' needs"…yet gave no guidelines on how that is to be accomplished. 

2b. Home Pages Must Be Citizen-Focused

Positive:   3
Negative:   10
Neutral:   14
No Comment:   93

A number of those who commented thought this was redundant with the previous policy. Comments were mixed about restricting employee-focused information. Supporters were glad to see this issue addressed, though some asked for definitions of “visual clutter” and “extraneous content.”

Sample Comments:

  • We heartily agree and are pleased to see this in writing.

  • Since not all agency sites have the general public as their primary customer group. Change wording to something like ‘the agency's defined customer groups' in place of ‘general public'.

  • The policy should state that agency home pages should focus on the needs of external customers not internal customers.

2c. Federal Websites Must Use Common Content and Terminology

Positive:   5
Negative:   28
Neutral:   104
No Comment:   na
(totals include comments on all sub-recommendations)

Most comments requested clarification or additional guidance. Those who objected did not want the location and text of common links proscribed for them. Others urged usability testing of text labels and location of links. The vast majority of comments in this section were related to the “Contact Us” and “Important Notices” requirement.

Sample Overall Comments:

  • Please, please, please don't tell webmasters where to post something on a page. Just tell us to do it and leave the where to us.

  • Because these policies specify wording, the labels should undergo usability testing prior to the issuance.

  • Please don't prescribe specific wording for all sites; instead, insist on consistent wording within sites. Different words have different meanings for different communities and contexts, most notably in scientific, medical, or legal contexts.

  • At some point, agencies should be able to simply point everyone searching for anything to FirstGov, rather than having to figure out what the latest portals are and trying to give them all prominence on an agency's site.

Sample Comments on Specific Common Content Requirements:

Contact Information:

  • I loudly applaud the provision in this policy that suggests every page should have such a phone number

  • The ability to respond to requests varies greatly within EPA. There is no one willing to be the mail contact, so I don't think it should be a requirement because we don't have the resources

  • This is too strict a policy. A requirement to display local office phone numbers is burdensome and counter to our need to redirect business away from local offices [and toward our 800 number].

Important Notices:

  • Although we strongly support this concept, another term might be more meaningful to visitors.

  • We think it's a good idea to group all these links, as it frees the valuable real estate at the bottom of the home page.

  • Requiring the specific term “important notices” and having it in the footer of ever page is overkill. So long as the site has prominent and easily accessible links to this material from the home page and key navigations, it should not be necessary to do this.

  • Users are not likely to think of looking for FOIA information behind a link called “Important Notices”…Further, ‘Important Notices” means something entirely different to FERC's customers.

Other comments:

  • Site maps should not be required because it is not possible for a three million page document site to cover every major topic. Even if this was implemented, the sheer size of the site map would be unfriendly to customers.

  • Doesn't seem like a good idea to REQUIRE frequently asked questions. BUT, it is a good idea to specify the term to use when questions are posted and I think "common questions" is best.

  • The term “FAQ” is not universally understood, despite its prevalence.

2c. Federal Websites Must Be Results-oriented

Positive:   2
Negative:   27
Neutral:   24
No Comment:   77

Although most comments requested clarification or further guidance, a significant number expressed concern about the lack of resources available to implement this policy. Many hoped for OMB approval of a universal survey that all agencies could use without separately going through Paperwork Reduction Act clearance procedures. Others questioned the appropriateness of using the same survey across different sites.

Sample Comments:

  • Tools such as the American Customer Satisfaction Index (ACSI), now used by dozens of Federal departments, could be adopted as a standard.

  • Some agencies may already be using tools to track customer satisfaction and acquisition of a second tool may not be cost effective

  • The Department of Education has been using an agency-designed online customer satisfaction survey since 1996. ED has gathered a wealth of statistical information from this survey and has the ability to track progress over time. The operation and analysis of ED's survey currently requires 0.02 FTE; no additional costs are budgeted. In contrast to other agencies that would reap cost savings, ED's costs would increase.

  • We need ways to ensure that visitors who use more than one Government web site will not feel harassed by multiple requests that they take the survey.

  • This has more to do with achieving customer satisfaction and an agency's missions and objectives than to “Content Standards”. The mandate for Agency's to be “results driven” is already defined in the President's Management Agenda….restating legislatives requirement seems to have little to do with defining and publishing “Content Standards”.

  • A good deal more information about the process, criteria and expectations for measurement as well as the process and criteria for determining a single required customer satisfaction tool) would be needed in order to respond meaningfully to this proposed policy and implementation guidance.

3a. Common Access

Positive:   24
Negative:   1
Neutral:   0
No Comment:   95

There was general support, but many requests to clarify testing for “lower-end” technology. Others provided suggestions for additional guidance.

Sample Comments:

  • Suggest that agencies limit site template download size to no larger than 50KB, with caveat that ultimate page download size, depending on the page's content, will be larger than this limit.

  • AGREE in general but there are times when the greater good may be served by providing increased functionality afforded by newer technologies. This country can ill-afford the lowest-common denominator approach...

3b. Plain Language

Positive:   14
Negative:   1
Neutral:   0
No Comment: 105

There was general support, but many requests to provide more detailed implementation guidance. Also, some noted that it's necessary to use more technical language for specific audiences. Some suggested requiring a basic reading level 8th grade level).

Sample Comments:

  • This is a good goal, but is not sufficiently detailed to be good guidance. We suggest promulgating the use of one government-wide style guide for writing style, grammar, person, voice, etc.

  • Not all information is appropriate for all citizens. Part of the federal government's duty to provide information to its citizens includes providing a forum for making technical information available to scientists and engineers. The policy should be to develop information on a level of sophistication that is appropriate to the intended audience, not ALL audiences.

  • Should be a guideline and not a standard. Difficult to monitor and measure

3c. Access to Documents in Different File Formats

Positive:   16
Negative:   1
Neutral:   6
No Comment:   97

Comments on this section varied widely, although there was general support. Most requested clarification or suggested additional implementation guidance.

Sample Comments:

  • Agencies should be discouraged or even prohibited from using proprietary formats that require citizens to use a particular software application that must be purchased and licensed. Whereas Adobe PDF Readers and OpenOffice applications, for example, can be obtained free of charge, others, such as MS Word and MS Excel, cannot.

  • How about specifying that HTML native web page) is always the first choice for file format, followed by formats that can be used using free plug-ins or utilities, followed by formats that require purchased software such as Word.

  • What constitutes a burden? And is it ok to require a plug in if it is the only or best) way to deliver the content? Acrobat Reader is so ubiquitous that it might not be an issue. Visitors with low bandwidth need information and appropriate warnings about how long it might take to download large files.

3d. Access to Data

Positive:   0
Negative:   2
Neutral:   3
No Comment:   115

Of the few comments, most suggested that there are times when it is appropriate to rely on proprietary formats to access data. There were no substantive sample comments.

3e. Federal Websites Must Use Consistent Navigation

Positive:   12
Negative:   0
Neutral:   6
No Comment:   102

There was general agreement on the concept, but many specific questions or suggestions about implementation.

Sample Comments:

  • We strongly support these recommendations

  • While we agree with the need for consistency in navigation and look, we urge the Working Group to consider the problems that frames can cause for some versions of browsers and almost always cause for printing information from web sites.

  • Based on this description, it seems that there is an expectation that public sites will establish and proliferate a standard look-and-feel for all agency public web sites. For NASA that would translate to affinity with the NASA Portal. This would be very expensive to implement since many sites would need to be completely redesigned.

3f. Federal Websites Must Have a Search Engine

Positive:   1
Negative:   2
Neutral:   23
No Comment: 94

There was general support, but also many questions about exemptions to place a search on every page, whether using the FirstGov search is required, and the effectiveness of the service standards.

Sample Comments:

  • We agree that a search capability for the entire agency site is required. However, we feel that requiring a search box or link from every page does not add enough functionality to justify having to change every page in order to comply…

  • Not all pages require a search box. This is especially true of database query results and pages such as PDF files.

  • Having agencies “set minimum service level standards” is unclear. Do all agencies need to establish them, even those who use the FirstGov search? It seems that agencies who use the FirstGov search should be able to refer to the FirstGov standards rather than developing and maintaining their own.

  • Requiring agencies to establish their own standards will result in there being as many standards as there are agencies.

  • Are federal sites required to use the Firstgov search engine or is it just one option? Our IT people here are under the impression that we have to use FirstGov as our search engine.

3g. Agency Web Sites Must Use Standard Metadata.

Positive:   38
Negative:   0
Neutral:   0
No Comment:   82

There were mostly favorable comments. Most suggested adding additional elements most notably description”) or variations on the suggested elements.

Sample Comments:

  • In addition to "Publication Date" a "Date Most Recently Updated" tag should be required. Also, use of the Description tag should be required, since the content of this tag is often used by search engines in the results.

  • Agree on the need for metadata but the selection of the standard metadata elements should be under the purview of the Categorization Workgroup. While we agree that metadata elements should be streamlined we do not agree on the application of the metatags to just the home pages and second-tier pages. This solution would not improve the discovery of content that is embedded deep within a Web site.

  • We suggest a examination of today's popular search engines to determine the specific metadata they look for before we establish mandatory metadata.

  • The search engine used at NASA GRC recognizes title, description, data, keywords, url, and publisher. This does not match up with the items listed. Our search engine tags cannot be changed. Each search engine is configured differently.

3h. Notifying the Public about Major Changes

Positive:   0
Negative:   1
Neutral:   8
No Comment:   111

Of the few comments, most requested clarification about the mention of a “help” page and what is meant by “major or significant” changes.

Sample Comments:

  • Please make it clear that a "Help" page is not a requirement. Research has shown that the public hardly ever uses such pages.

  • Please be specific when defining a “major change”, and give concrete examples.

3i. Continuity of Operations During Emergencies

Positive:   1
Negative:   2
Neutral:   2
No Comment:   115

Of the few comments, a couple said this was outside of the purview of the working group; others suggested required links or processes for communicating with the public during emergencies. There were no substantive sample comments.

4a. Avoiding Duplication

Positive:   12
Negative:   7
Neutral:   4
No Comment:   97

The comments were generally mixed. Many expressed concern about the time and effort involved in esearching what content already exists. Many seemed unaware of the existence of FirstGov to assist with this research. Others were concerned about linking to cross-agency portals that aren't relevant to their website content.

Sample Comments:

  • How would one agency know what already exists in order to avoid duplication? Is there a repository or library documentation one can review prior to proceeding? If so, who maintains this?

  • It strikes me as somewhat naive to suggest that this problem [duplication] can be addressed simply by how one links. Many federal agencies have shared or overlapping responsibilities as part of their mission, which results in resources that often appear duplicative, yet still need to reside in that organization. Cases where there is genuine unproductive duplication of effort need to be resolved at a much higher level…I'm not sure it's fair to ask Web managers to play a role making these decisions.

  • Sounds like a librarian's work conducting a "literature search" to see what has been done on a topic.

  • It's not necessarily a bad thing to have multiple takes on the same topic available from different agencies. Also, it can be very confusing to jump back and forth between Agency sites when looking for information on a topic. I'd vote more for greater use of joint sites than greater linking.

  • This makes sense, but what if the site to which we link presents the information in an unclear manner, or in a way that results in a poor user experience?

  • I think we also need to suggest that agencies should avoid “stovepiping” of information or content. Federal-topical-based websites are a great example of “heading-in-the-right-direction”. Agencies need more encouragement to contribute content to these single-source information websites.

  • A responsible party needs to make the determination as to what information should or should not be on an agency's site. If there is a discrepancy as to which agency should provide particular content to the public, who makes the determination of responsibility?

  • The intent of the policy is admirable, but the burden to implement the policy is significant without specific direction or tools.

  • Without a government-wide taxonomy, it's hard to visualize how content managers are going to be able to meet this standard.

4b) Web Pages Must Link Back to the Home Page

Positive:   8
Negative:   4
Neutral:   2
No Comment:   106

The majority of comments agreed to this recommendation in concept. Most comments focused on clarification and questions about exemptions (for example, text files).

Sample Comments:

  • AGREE in general, but there are pages, such as TXT pages that cannot physically contain a link.

  • The wording should be clarified to indicate that it applies to the web site/collection's home page, not necessarily the agency's home page.

4c) Link to FirstGov.gov

Positive:   10
Negative:   5
Neutral:   2
No Comment:   103

The majority of comments were supportive of linking to Firstgov, but many said it is time to rename it to something more meaningful, like US.gov or USA.gov. Some objected altogether to linking to FirstGov and didn't feel it should warrant placement on the home page.

Sample Comments:

  • If “FirstGov.gov” is not meaningful to most visitors, perhaps it should be replaced with another more intuitive address and text link, such as “USAGov.gov – the U.S. Government's Home Page.”

  • We believe that agencies should have discretion in where to place links to other government web sites. For agencies trying to maintain a “clean and lean” front page, requiring so many links on the front page is not consistent with their approach

  • Since website real estate is scarce, a link to FirstGov should be optional.

  • This guidance gives the appearance that FirstGov is using the ICGI process as a promotional vehicle, assuming the role of the Government's official Web portal, confusing users about the official nature of other Federal sites or portals.

5. Agencies must develop an inventory and post schedules to their websites

This is a new section that was not included in the original version, so there were no comments.

6. Existing Federal Laws, Regulations and Policies

Positive:   1
Negative:   1
Neutral:   14
No Comment:   102

For most of the specific laws in this section, there were no comments. Some asked for clarification and a few offered additional regulations related to federal public websites. Some noted that section 508 was missing from this section. The Executive Order related to access for people with limited English proficiency generated the most comments, with several people raising concerns about resources to implement the guidance.

Sample Comments:

  • Other laws that should be cited: Paperwork Reduction Act, Section 508, GPEA, FISMA

  • A ccess for people with limited English proficiency: In simple English, what would have to be done to make web sites compliant with this law? I do not believe this would be practical to implement with the limited resources of our agency.

  • Will there be translation resources available to small agencies that do not have a staff available to manually translate content?

7a. Ongoing Structure and Process

Positive:   5
Negative:   4
Neutral:   6
No Comment:   105

Since these recommendations were addressed specifically to OMB rather than to agencies, there were fewer comments on this section.

Sample Comments:

  • The creation of a separate council that would complement the CIO council would be a great move.

  • Agencies already have existing bodies which are equipped to comment on web content issues. Instead of creating a new standing committee, expertise should be drawn as needed from these bodies. Another layer of oversight is not needed.

  • As a general principle, increasing reporting requirements only adds more work for the agencies and doesn't accomplish a lot.

  • This deserves a policy memorandum that all agencies buy into via the CIO Council. The Federal Government has three branches of government that must be coordinated with.

8. Definitions

There were a very small number of comments on general definitions. Several people asked to clarify “agency” website, for example which requirements apply to agency top level sites, e.g., www.treas.gov and which apply to agency sub-units, e.g., www.occ.treas.gov.

 

 

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