The WCAG further explains its approach by explaining how the recommendation is organized: "This document includes fourteen guidelines, or general principles of accessible design. Each guideline includes: * "The guideline number. * "The statement of the guideline. ... * "The rationale behind the guideline and some groups of users who benefit from it. * "A list of checkpoint definitions. "The checkpoint definitions in each guideline explain how the guideline applies in typical content development scenarios. Each checkpoint definition includes: * "The checkpoint number. * "The statement of the checkpoint. * "The priority of the checkpoint. Priority 1 checkpoints are highlighted through the use of style sheets. * Optional informative notes, clarifying examples, and cross references to related guidelines or checkpoints. * ""A link to a section of the Techniques Document where implementations and examples of the checkpoint are discussed. "Each checkpoint is intended to be specific enough so that someone reviewing a page or site may verify that the checkpoint has been satisfied." ANALYSIS This analysis of the accessibility impact that using the <PRE> element in web content imposes on various individuals who are persons with disabilities will, therefore, consider each of these 14 guidelines in turn. Does the guideline apply? What impact does it have? On who? It is worthwhile to note that by definition, <PRE> exists in tension with the basic themes underlying web accessibility as expressed in the WCAG. By definition <PRE> does not "gracefully transform" to any other presentation. It's very purpose is to lock in a particular presentation. Nor can it assist accessibility by making larger blocks of text "understandable and navigable." It allows no navigational elements within its bounds. Furthermore, people whose comprehension is challenged by larger blocks of undifferentiated text can be expected to have greater difficulty accessing content bounded by <PRE>. The <PRE> element does figure directly in the WCAG once, namely at: "Guideline 3. Use markup and style sheets and do so properly. "Mark up documents with the proper structural elements. Control presentation with style sheets rather than with presentation elements and attributes. "Using markup improperly -- not according to specification -- hinders accessibility. Misusing markup for a presentation effect (e.g., using a table for layout or a header to change the font size) makes it difficult for users with specialized software to understand the organization of the page or to navigate through it. Furthermore, using presentation markup rather than structural markup to convey structure (e.g., constructing what looks like a table of data with an HTML PRE element) makes it difficult to render a page intelligibly to other devices (refer to the description of difference between content, structure, and presentation). "Content developers may be tempted to use (or misuse) constructs that achieve a desired formatting effect on older browsers. They must be aware that these practices cause accessibility problems and must consider whether the formatting effect is so critical as to warrant making the document inaccessible to some users." Indeed, content producers may be tempted simply to dump content into the <PRE> tag, wrapping it with <html> and <body>, as we have seen recently, to my great surprise and dismay. In the instance noted on this list in previous discussion there was no mention of a need to preserve white space, or to preserve a particular look and feel. Indeed, the justification was ease under conditions of constrained time. One writer, perhaps recognizing the inconsistency, nevertheless defended the practice on the grounds that it was acceptable as a temporary expedient. Since the <PRE> tag is not being used as intended, it seems clear that this guideline is violated. But even more, it seems clear that it is being suborned for convenience sake. I would warrant that any client paying for markup might have legal grounds not to pay for such deliverables on the simple ground that no markup, as defined by W3C recommendations, is being delivered. Simply wrapping content as: <html><body><pre> [CONTENT] </pre></body></html hardly constitutes markup. Certainly, it does not constitute markup as intended even by the earliest extant HTML specifications. Guidance on appropriate use of <PRE> can be found at http://www.w3.org/TR/html401/struct/text.html, where the example is a poem whose visual appearance is considered important to its artistic purpose, i.e. the spacing of alternate lines in the poem. I wonder, frankly, that a poem by e. e. cummings might not have been used to make the case even more clearly.