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

From: Loretta Guarino Reid <lorettaguarino@google.com>
Date: Sat, 28 Jun 2008 21:18:37 -0700
Message-ID: <824e742c0806282118r145f65a8i18fc484ca1b7d6cd@mail.gmail.com>
To: re-clf-nsi@tbs-sct.gc.ca
Cc: public-comments-WCAG20@w3.org

On Tue, Jun 10, 2008 at 12:22 PM,  <re-clf-nsi@tbs-sct.gc.ca> wrote:
> We sent an email on May 1, 2008 following up on our "accessibility supported" definition concerns that we raised on April 9, 2008 (http://lists.w3.org/Archives/Public/public-comments-wcag20/2008Apr/0043.html). We have yet to receive a response regarding our concerns. Could you please let us know when you plan on responding to our concerns?
>
> Thank you,
>
> 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: Common Look and Feel/Normalisation des sites Internet
> Sent: May 1, 2008 4:19 PM
> To: 'public-comments-WCAG20@w3.org'
> Cc: 'lorettaguarino@google.com'
> Subject: FW: Your comments on WCAG 2.0 Last Call Working Draft of December, 2007
>
> We noticed that WCAG 2.0 advanced to a candidate recommendation even though we have not received a follow up response to one of the issues we raised (which remains unresolved in the candidate recommendation). The issue in question is the one that we raised on April 9 (http://lists.w3.org/Archives/Public/public-comments-wcag20/2008Apr/0043.html) regarding perceived gaps in the "accessibility supported" definition (which is a continuation of the absence of support for programmatic objects issue that we raised earlier).
>
> Are you still considering our recommendation for resolving this issue or was the issue that we raised previously accidentally overlooked?
>
> Thank you,
>
> 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: Common Look and Feel/Normalisation des sites Internet
> Sent: April 9, 2008 3:22 PM
> To: 'public-comments-WCAG20@w3.org'
> Cc: 'Loretta Guarino Reid'
> Subject: RE: Your comments on WCAG 2.0 Last Call Working Draft of December, 2007
>
> 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
>
>>  B) CONCERNS WITH COMMENT 3 RESPONSE
>>
>>  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
>
================================
Response from the Working Group
================================
Our apologies for leaving this dangling. We believed that we had
confirmed via telephone that all of your Last Call comments had been
addressed to your satisfaction.

In the WCAG 2.0 supporting document, "Understanding Conformance" there
is a discussion about the conditions for a WCAG 2.0 Success Criteria.
The text is as follows:

 "All Success Criteria must be important access issues for people with
disabilities that address problems beyond the usability problems that
might be faced by all users. In other words, the access issue must
cause a proportionately greater problem for people with disabilities
than it causes people without disabilities in order to be considered
an accessibility issue (and covered under these accessibility
guidelines)."

http://www.w3.org/WAI/GL/WCAG20/WD-UNDERSTANDING-WCAG20-20080505/intro.html

Taking the example you've provided, if the use of JavaScript is
incompatible with handheld devices (and creating a blank page), then
nobody will be able to access the content (regardless of ability) and
therefore it is a global problem affecting all users. It would not
affect people with disabilities disproportionately, and as such it
falls beyond the scope of WCAG.  This would also be true in
environments where JavaScript is prohibited in a secure government
environment. No one could access the content.

In order for content to conform, SC 2.1.1 requires it must be keyboard
accessible regardless of technology. Success Criteria 1.1.1 requires
it be available in text. We believe the current language of
Accessibility-Supported covers closed environments where conforming
content is targeted for that environment.

The definition of Accessibility Supported is already complex. We
believe that introducing policy constraints (such as those in a closed
environment) as well as technical constraints into the definition will
make it more difficult to understand.

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 Sunday, 29 June 2008 04:19:23 GMT

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