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Re: Fwd from Roger Hudson: Your comments on WCAG 2.0 Last Call Working Draft of December, 2007

From: Loretta Guarino Reid <lorettaguarino@google.com>
Date: Sat, 29 Mar 2008 07:48:23 -0700
Message-ID: <824e742c0803290748p4d5d3e6r29c2c33a699108cd@mail.gmail.com>
To: "Roger Hudson" <rhudson@usability.com.au>
Cc: public-comments-WCAG20@w3.org

>   ----------------------------------------------------------
>   Comment 2: Cognitive Support
>   Source: http://lists.w3.org/Archives/Public/public-comments-wcag20/2008Jan/0013.html
>   (Issue ID: 2389)
>   Status: VERIFIED / PARTIAL/OTHER
>   ----------------------------
>   Original Comment:
>   ----------------------------
>
>   The previous two drafts generated 1,500 comments which according to
>   the Working Group, "comprises a significant community contribution to
>   the guidelines". Much of the response by the Working Group to these
>   comments was in the form of additional clarifications and techniques
>   in two non-normative documents that do not have the status of WCAG
>   2.0.
>
>   WCAG 1.0 adopted a general position of offering guidance in the area
>   of accessibility; whereas during the development of WCAG 2.0, it
>   appears that a prime aim has been to prepare a document that is more
>   akin to a "standard". Perhaps, this is best illustrated by the Working
>   Group's determination that the value of a Success Criteria be
>   determined by its testability, and in particular machine testability.
>
>   Given this apparent move from offering guidance to providing a
>   (machine) testable standard, it would seem likely that the normative
>   components of WCAG 2.0 will be the main area of concern when
>   determining legal liability or responsibility for ensuring web
>   accessibility. It should be noted, that in regard to the definition of
>   "normative" the WCAG 2.0 Glossary states, "Content identified as
>   "informative" or "non-normative" is never required for conformance".
>
>   I am concerned that many issues relating directly to people with
>   cognitive, learning or language difficulties, which were raised in
>   response to the previous two drafts of WCAG 2.0, are still not
>   addressed in the core WCAG 2.0 document. In fact, I believe it could
>   be argued that from a legal perspective WCAG 2.0 offers less rather
>   than more protection or support than WCAG 1.0 for what is arguable the
>   largest community of disabled people in many countries.
>
>   Proposed Change:
>
>   ---------------------------------------------
>   Response from Working Group:
>   ---------------------------------------------
>
>   We do not believe WCAG 2 offers less *protection* for people with
>   cognitive disabilities. While some provisions that might benefit some
>   users are not included, WCAG 2 does not prohibit conforming Web sites
>   from following such guidance, nor does it prohibit policies from
>   adding additional guidance (where testability is not a concern). The
>   additional resources provided are intended to support this.
>
>   While it is true that WCAG 2.0 has an emphasis on testable criterion,
>   it is not true that there is any bias toward machine testing except
>   for a couple provisions like 'flash' where things happen too quickly
>   to be evaluated well by humans. In fact almost all of the provisions
>   require humans in testing.
>
>   That said, it is true that the cognitive, language and learning areas
>   are some of the most difficult to identify testable techniques for
>   direct access. In WCAG 1.0, there were provisions like "Use the
>   clearest and simplest language appropriate for a site's content," but
>   in practice we found that the provision was largely ignored. The
>   attempt in WCAG 2.0 was to create provisions that could be tested and
>   that would be included when sites were tested.
>
>   We have tried to include all of the qualitative guidance that we have
>   received in the advisory techniques.  We have also re-written the
>   introduction to emphasize the importance of going beyond the testable
>   SC and implementing as many of the sufficient and advisory techniques
>   as possible.
>
>   In addition, the WCAG WG has initiated an effort to develop an
>   "application note" under the framework of WCAG 2.0 on access to Web
>   Pages by people with cognitive, language and learning disabilities.
>   The application note would include approaches that are more general,
>   qualitative, and not bound by testability, so that all guidance can be
>   treated equally without levels or constraint due to the nature of the
>   advice. This effort will include the Cognitive Rehabilitation
>   Engineering Research Center which focuses on cognitive disabilities,
>   and we welcome additional participation.
>
>   The WAI continues to be interested and committed to developing
>   guidance to address Web accessibility needs in the broad area of
>   cognitive disabilities, and will continue to explore this area through
>   our other WAI 2.0 guidelines, research discussions, and in potential
>   future guidelines development.
>
>   It is hopeful to note that assistive technologies for people with
>   cognitive disabilities, including free open source technologies, are
>   on the horizon.  A large number of the provisions in WCAG 2.0 are
>   designed to provide the information needed by these new and emerging
>   technologies.
>
>   The group feels that WCAG 2.0 has more enforceable provisions that
>   deal with cognitive language and learning disabilities than WCAG 1.0.
>   Still, the guidelines point out clearly that WCAG 2.0 is not enough
>   for these groups and that more work is needed and that Web authors
>   need to look beyond WCAG for all disabilities but particularly for
>   users with cognitive language and learning disabilities.
>
>
>   ---------------------------------------------------
>   Comment on WG Response
>   ---------------------------------------------------
>   I agree with the WG that many people ignored the WCAG 1.0, provision
>  "Use the clearest and simplest language appropriate for a site's
>  content. (14.1)". But I for one, did take it seriously. At the risk of
>  repeating myself, I would like to briefly outline a case just last
>  year. A large government department (who recognise that over 30% of
>  their clients are functionally illiterate), recently asked me to
>  assess a site designed to provide information to their clients. The
>  information was all text based, often using quite complex language.
>  When I suggested they include a short Flash animation to communicate
>  the same basic information to those who might have a problem reading
>  all this text they responded, we have to make our sites Priority 1 and
>  Priority 2 compliant and this would be very difficult to do if we
>  include Flash. I then drew their attention to WCAG 1.0  CP 14.1 (P1)
>  and 14.3 (P3) and advised them to include the Flash so that their site
>  was both more accessible and more inline with the intentions of WCAG.
>  They agreed to do so, but I think this was only because I was able to
>  show them that there was a Priority 1 requirement to make something
>  understandable and if this was not possible provide some form of
>  alternative.
>
>   What I want to know; where in the normative part of WCAG 2.0 is there
>  anything similar?
>
>   With reference to this response: "The group feels that WCAG 2.0 has
>  more enforceable provisions that deal with cognitive language and
>  learning disabilities than WCAG 1.0." SC 3.1.5  Reading Level, which
>  is at AAA, does offer some support for people with reading
>  difficulties, but are there any other enforceable provisions that are
>  at A or AA level? I fully support the good intentions and long term
>  hopes of the WG but I wanted to see was a little more muscle in the
>  normative document.
>
>   I am intrigued by the notion that it is acceptable to remove a
>  provision because in the view of the WG, "in practice we found that
>  the provision was largely ignored". I will return to this point later.
>

------------------------------------------------------------------
Response from Working Group (28 March 2008):
------------------------------------------------------------------

Level A and AA provisions that that assist users with some cognitive,
learning, and language disabilities include:

1.1.1 Non-text Content
 - all content has a representation that could be read out loud
1.2.3 Audio Description or Full Text Alternative,
1.2.5 Audio Description, and
1.2.7 Audio Description (Extended)
 - Audio description provides secondary presentation of information
helpful to many who would miss details or significance of visual
events otherwise.
1.3.1 Info and Relationships,
1.3.2 Meaningful Sequence, and
1.3.3 Sensory Characteristics
  - the content can be rendered in a different format and still be understood
1.4.2 Audio Control
 - users can control distracting audio content
1.4.3 Contrast (Minimum)
 - Contrast is reported to positively affect reading and comprehension.
1.4.4 Resize text
 - Text size is reported to positively affect reading and comprehension.
2.2.1 Timing Adjustable
 - users who need more time to complete tasks can get more time, when possible
2.2.2 Pausing
 - users can control distracting motion
2.4.2 Page Titled
 - users are given context for understanding the web page content
2.4.3 Focus Order
 - focus moves in a consistent way through the content
2.4.5 Multiple Ways
 - added specifically to assist users who may not be able to
understand primary navigation method
2.4.6 Headings and Labels
 - Headings and Labels help orient users
3.1.1 Language of Page, and
3.1.2 Language of Parts
 - text-to-speech systems or dictionary lookup tools can help users
more effectively. Easier when having page read to have no confusing
mispronunciations.
3.2.1 On Focus,
3.2.2 On Input,
3.2.3 Consistent Navigation, and 3.2.4 Consistent Identification
 - web pages are predictable in the way they work
3.3.1 Error Identification,
3.3.2 Labels or Instructions,
3.3.3 Error Suggestion,
3.3.4 Error Prevention (Legal, Financial, Data)
 - users are given help when interacting with the web page


These are just the A and AA provisions.  There are additional
provisions for cognitive, language and learning disabilities at level
AAA as well.

The significance of removing WCAG 1.0  CP 14.1 is that "the provision
was largely ignored" *because it was untestable*. There was no way to
establish when an author had used sufficiently simple language.
Received on Saturday, 29 March 2008 14:49:01 GMT

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