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LC-1302 NOT SATISFIED Re: Your comments on WCAG 2.0 Last Call Draft of April 2006

From: Charles McCathieNevile <chaals@opera.com>
Date: Mon, 11 Jun 2007 13:06:18 +0200
To: "Loretta Guarino Reid" <lorettaguarino@google.com>
Cc: public-comments-WCAG20@w3.org
Message-ID: <op.ttq7sshjwxe0ny@widsith.local>

On Fri, 18 May 2007 01:28:47 +0200, Loretta Guarino Reid  
<lorettaguarino@google.com> wrote:

> ----------------------------------------------------------
> Comment 1:
> Source:  
> http://www.w3.org/mid/op.tbjlv1aowxe0ny@researchsft.myhome.westell.com
> (Issue ID: LC-1302)
> Technical/substantive issue
> The section currently provides no guidance to actually choosing a  
> baseline that can in fact be used accessibly.
> I propose that the availability of a user agent which meets level-A
> conformance to User Agent Accessibility Guidelines 1.0 for the relevant
> technology and language be a minimum criterion for the selection of a
> baseline.
> In this way, selection of a baseline that is not actually accessible
> automatically makes it impossible to claim conformance to the
> accessibility guidelines. This avoids the situation where it is possible
> to construct content that can meet the requirements, but that is not
> actually accessible due to the absence of any means for using the  
> baseline
> set. Otherwise there is a risk that the value of conformance will be
> significantly reduced, since it makes no reliable statement about whether
> the content is in fact accessible to real people.
> This seems a reasonable requirement given that UAAG is a W3C
> recommendation, and does not seem onerous for common web technologies.
> cheers
> Chaals
> ----------------------------
> Response from Working Group:
> ----------------------------
> For a period, WCAG made the assumption that user agents satisfied
> UAAG. This would have simplified a number of issues.
> However, in the absence of any user agent for any technology that is
> fully UAAG-compliant, the working group did not think it was practical
> to require only the use of technologies for which such user agents
> exist. The effect of such a requirement would be to make it impossible
> to claim compliance for any web content.
> The notion of baseline (now accessibility-supported web technologies)
> was introduced to make it possible to apply WCAG in environments with
> a wide range of user agent support for accessibility. It places a much
> heavier burden on the author to understand the capabilities of his
> customer's user agents. WCAG will be much easier to satisfy in an
> environment in which UAAG is satisfied by the available user agents.
> ----------------------------------------------------------

The notion of accessibility-supported technologies is defined in such  
loose terms as to be meaningless in practice. Important questions for a  
website trying to determine whether something is "accessibility-supported"  
must include at least the following:

1. Does it matter that the content I use is only available on one  
Operating System?
2. When does downloading a new browser discriminate against people with  
3. What kinds of Assistive Technology need to be supported? Is ZoomText  
enough? Or support for a screen reader, or for speech output combined with  
switch access?

Leaving this question to an informative document, which in any case says  
that the working group doesn't offer any answer, is almost useless for an  
organisation trying to determine which technologies are accessible as  
opposed to an organisation trying to meet some arbitrary requirement  
regardless of its impact on accessibility.

Therefore I feel that the original comment has not been satisfied at all,  
and if the current approach is incorporated into a new Last Call I expect  
to again make a comment (and objection if necessary).

As noted in the original, some kind of testable criteria should be  
offered. I understand that UAAG conformance (even to some given profile)  
may not be ideal, but simply leaving it to people to make up their own  
criteria doesn't show any path to interoperability except at the level of  
the least people think they can get away with, which is unlikely to assist  
accessibility in any way.



   Charles McCathieNevile, Opera Software: Standards Group
   hablo español  -  je parle français  -  jeg lærer norsk
chaals@opera.com  Catch up: Speed Dial  http://opera.com
Received on Monday, 11 June 2007 11:06:46 UTC

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