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Comments on WCAG 2.0 WD, 17 May 2007

From: Matt Morgan-May <mattmay@adobe.com>
Date: Fri, 29 Jun 2007 16:54:17 -0700
To: <public-comments-wcag20@w3.org>
Message-ID: <C2AAE9B9.F0%mattmay@adobe.com>


We have reviewed the current Working Draft, and our comments are below. We
appreciate the work undertaken by the WG since the previous draft to bring
the document to this point.


Web page
A very underpowered term when applied to formats other than HTML. Example 1
(virtual reality shopping) is a really far-fetched scenario, and itıs an
awful one to have first. Though I would like to see how this would be
applied to an environment like Second Life, where you can post just about
any kind of content imaginable, including URIs that open in an external
browser. Is Second Life a "Web page", or a collection of them, or a user
agent, or all of the above?

A PDF document, even a fairly complex one, would fit under the definition of
³Web page². But Flash is less cut and dry. Flash can be embedded as an
object in a document, but itıs also a user agent (and in the case of Adobe
AIR, formerly Apollo, it can itself be an HTML user agent). If we are
delivering a UA to a user, and the author wants to conform to WCAG 2, do we
then have to conform to UAAG instead? What about third-party authors of AIR

Programmatically determined
Does the author get to declare for which versions of UA or AT the content is
programmatically determinable? How often will that determination be made,
and by whom?

Also, ³mark-up² should be ³markup².

Accessibility supported
Releasing a standard without even an informative pointer to a reference list
of ³accessibility-supported² technologies is like coming out with a new car,
but refusing to either certify your own mechanics, or point people to a
resource where they can find one. The result in either case would be the
same: consumers would have trouble finding trustworthy resources, and when
things go wrong for them, they will begin to distrust the producer. Without
a concrete set of technologies that meet these criteria, or at a bare
minimum a set of pointers to definitions of accessibility-supported
technologies, WCAG 2 is not fully defined.

Also in this definition, GIF and MPEG are specified by name. But GIF cannot
be considered an accessible enough format to meet the ³Web page² bar, and
³MPEG² isnıt a format, itıs a JTC1 WG: MPEG-1, MPEG-2, MPEG-4, MPEG-7, and
MPEG-21 are the standards they produce.

Sign language
A sign language is included under ³human language,² but that is not in the
definition here. Also, sign language is not a visual language to people who
are deaf and blind.

1.3.3 (Level A):  ³Instructions provided for understanding and operating
content do not rely on shape, size, visual location, or orientation of
In English-language documents, at least, it is commonly understood that
³above² refers to the content previous to that point (³hereto,²
³heretofore²), and ³below² refers to the content after that point
(³hereafter,² ³hereinafter²). Provided that the content being referenced is
in the appropriate place in the document order, there should be no
restriction on statements such as ³Choose one of the links below:² or ³All
of the above².

1.4.6: ³Note: Background sound that meets this requirement will be
approximately one quarter as loud as the foreground speech content.²
As I understand it, the Decibel scale is log-10. A 20dB difference is not a
factor of 4, it is a factor of 100. If the desired difference in sound is
4:1 foreground to background, the correct figure should be -6dB.

Guideline 2.3: ³Do not create content that is known to cause seizures²
The content being evaluated cannot be ³known to cause seizures² until it
actually causes a seizure. What are known to cause seizures here are the
flashing patterns specified by the document. Therefore, the guideline should
read: ³Do not create flashing patterns that are known to cause seizures.²

Under the heading: ³When referring to WCAG 2.0 from another standard with a
Œshallı statement²
There are references to ³Level 1², ³Level 2² and ³Level 3² that should be

Matt May
Accessibility Engineer

Andrew Kirkpatrick
Corporate Product Accessibility Lead
Received on Saturday, 30 June 2007 18:52:39 UTC

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