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RE: Your comments on WCAG 2.0 Last Call Working Draft of December, 2007

From: <re-clf-nsi@tbs-sct.gc.ca>
Date: Wed, 9 Apr 2008 15:22:22 -0400
Message-ID: <A272EF43A3682E42BF30BFE1070D53470103F3B5@EXCHTBS2.intranet.local>
To: <public-comments-WCAG20@w3.org>
Cc: <lorettaguarino@google.com>

We agree that a technology (such as JavaScript) cannot be considered an accessibility supported technology if one or more of the supported environments requires that technology to be disabled. 

We also agree that a technology cannot be considered an accessibility supported technology if one or more of the supported user agents (such as cell phones, PDAs, or specialized browsers) cannot support the technology natively or through a widely-distributed plugin.

The problem is that these requirements are not clear in the "accessibility supported" definition (http://www.w3.org/TR/WCAG20/#accessibility-supporteddef). 

We recommend including the following wording in the "accessibility supported" definition and to also add "environment" to the glossary as it is used repeatedly throughout WCAG 2.0 and the meaning can be a bit unclear: 

3. The Web content technology is not restricted in any of the supported environments. This means that all of the following are true:

a) The technology is either supported natively or supported through widely distributed plugins for all of the supported user agents in the supported environments; AND
b) The technology is not restricted from being installed, enabled, or used in any of the supported environments; AND
c) The supported user agents, widely distributed plugins, and other technologies required to provide support for the technology are not restricted from being installed, enabled, or used in any of the supported environments.

Common Look and Feel Office | Bureau de la normalisation des sites Internet
Treasury Board of Canada, Secretariat | Secrétariat du Conseil du Trésor du Canada 
Government of Canada | Gouvernement du Canada

-----Original Message-----
From: Loretta Guarino Reid [mailto:lorettaguarino@google.com] 
Sent: April 3, 2008 5:42 PM
To: Common Look and Feel/Normalisation des sites Internet
Cc: public-comments-WCAG20@w3.org
Subject: Re: Your comments on WCAG 2.0 Last Call Working Draft of December, 2007

>  Quote from the Comment 3 response:
>  "The situations you describe are addressed differently in WCAG 2.0 than in 1.0. WCAG 2.0 has an improved set of conformance requirements. Refer to http://www.w3.org/TR/WCAG20/#conformance-reqs. We believe this is a more effective and thorough approach."
>  The problem is that the conformance requirements do not cover a technology being disabled or unavailable resulting in accessibility issues, it only covers whether a technology is "accessibility-supported" or not which only deals with compatibility with assistive technologies.
>  a)      What about users with cell phones and other Internet-enabled devices? The way things are worded now, you could make JavaScript rendered content that is fully accessible to assistive technologies and keyboard users yet unavailable when JavaScript is disabled and the page could still achieve full compliance.
>  b)      What if the device does not support the required plugin (such as Flash)? There could be an accessibility supported plugin that is available for normal browsers but are not available for certain devices resulting in Web pages. This would meet the conformance requirements but still result in content being unavailable to certain users.
>  Ultimately the conformance requirements as they are worded now leave many loopholes where sites can be completely inaccessible and unusable on certain user agents yet still be fully compliant (such as a fully JavaScript-rendered site that is fully accessible to assistive technologies but just an empty page on a handheld device that does not support JavaScript or secure environments where JavaScript is disabled).
>  RECOMMENDATION: Either expand "Accessibility-Supported Technologies" conformance requirement to cover the case where an accessibility-supported technology is disabled or the required accessibility-plugin is not supported by the widely distributed user agent (cell phones and Internet-enabled devices are pretty common but most do not support Flash or JavaScript).

Response from Working Group:
If a technology is not supported on the users' user agents (including
such user agents as cell phones or Internet-enabled devices), then the
technology is not accessibility supported. If an author is producing
content for a secure environment where Javascript is disabled, then
the author cannot rely on Javascript. Determining the range of user
agents used in an environment is a challenge, but one which authors
must already face. It is important that information about which user
agents and assistive technologies support different technologies be
available to authors, so they understand the environment for which
they are producing content.

Authors cannot control whether or not a user disables a technology
such as Javascript or fails to load a plug-in that is available to
users. As long as the conformance claim documents which technologies
are relied upon, and as long as the user agents can support that
technology, the author has met the accessibility-supported
requirements of WCAG 2.0

Thanks again for the interest that you have taken in these guidelines.
Could we ask you to let us know whether or not you are satisfied with
this response by Wed, April 9?

Loretta Guarino Reid, WCAG WG Co-Chair
Gregg Vanderheiden, WCAG WG Co-Chair
Michael Cooper, WCAG WG Staff Contact

On behalf of the WCAG Working Group
Received on Wednesday, 9 April 2008 19:23:42 UTC

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