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Fwd: RE: Response to your comments on Authoring Tool Accessibility Guidelines (ATAG) 2.0

From: Jeanne Spellman <jeanne@w3.org>
Date: Mon, 03 Oct 2011 11:13:51 -0400
Message-ID: <4E89D12F.8080707@w3.org>
To: AUWG <w3c-wai-au@w3.org>
Here are the Microsoft comments to the working draft of 21 July 2011.

-------- Original Message --------
Subject: RE: Response to your comments on Authoring Tool Accessibility 
Guidelines (ATAG) 2.0
Date: Mon, 3 Oct 2011 14:28:20 +0000
From: Alex Li <alli@microsoft.com>
To: Jeanne Spellman <jeanne@w3.org>
CC: Jutta Treviranus <jtreviranus@faculty.ocad.ca>, Cherie Ekholm 

Hi Jeanne,

Below is our response to AUWG's reply.  Where there is no specific 
response, please consider the AUWG response satisfactory.  Cherie and I 
will continue to assist AUWG to find appropriate solutions to the 
reminding issues.

Original comment

AUWG reply

Response to reply

MS1: Part B Application Notes #2 The examples seem contradictory because 
both examples pertains to automated content, yet they are treated 
differently. Please revise the example to reconcile the contradiction.

AUWG: We have clarified the wording as follows: "Applicability after the 
end of an authoring session: Authoring tools are responsible for the 
accessibility of web content that they automatically generate after the 
end of an author's authoring session (see Success Criterion B.1.1.1). 
For example, if the developer changes the site-wide templates of a 
content management system, these would be required to meet the 
accessibility requirements for automatically-generated content. 
Authoring tools are not responsible for changes to the accessibility of 
content that the author has specified, whether it is author-generated or 
automatically-generated by another system that the author has specified 
(e.g. a third-party feed)." [APPROVED 

The concept of "automatically generate" content does not appear well 
defined.  In the example where the developer changes the template of a 
content management system illustrates the issue.  How is a template 
changed or configured by a developer considered "automatic"?  It appears 
the example is saying the threshold of "automation" is something that is 
processed in an on-going basis by machine, regardless if it is 
configurable by human.  If that is the case, we ask the working group to 
define what is "not automatic".  We encourage deeper analysis of both 
the term "automatic" and related normative text.

MS2: The biggest concern for ATAG 2.0 is that it is never clear if ATAG 
is for a single tool or a collection of tools. It is trying to be both. 
This leads to a great deal of structural problems. If it is for a single 
tool, then the SCs are too far reaching and the conformance requirement 
does not make room for a simple specialized tool to conform. How does 
ATAG 2.0 conformance work for something like a web accessibility 
toolbar, photo editor, FTP client, or a social networking site? You need 
to allow tool makers to say their tool does not provide certain function 
and it is not intended to do so, but the tool conforms where it is 
applicable. On the other hand, how would conformance work for a 
collection of tools where some criteria are met via a portion of the 
tools? Would one have to specify which tool(s) is used to conform to any 
given criterion? If the collection of tools include tool(s) in which the 
conformance claimer has no Intellectual property ownership, would the 
claimer then be held responsible for the accuracy of the claim of such 
tool? What if is there is discrepancy between the tool manufacturer and 
claimers? What if the collection is still not applicable to ATAG in 
full-for example, only relevant to part A? Is the collection deemed 
incomplete? Additionally, where does the value chain of the authoring 
process end? Without knowing the scope, then ATAG 2.0 may require 
consideration of software such as scanner application, a database, a web 
service, or enterprise backend systems. Does a mail client become a "web 
authoring tool" only when it sends a message to somebody who access 
their email via the web? How is one supposed to know if the mail 
recipient uses a web client? These are extremely difficult questions. 
But if left unanswered, ATAG 2.0 will not be viable in practice. The 
conformance section requires fundamental revision to be viable. Please 
revise accordingly.

AUWG: We believe that we have addressed the issue in the following ways:
(a) using conditional phrasing on many of the success criteria.
(b) In addition we have added this wording in the conformance section: 
"Applicability of Success Criteria: The ATAG 2.0 definition of authoring 
tool is inclusive and, as such, it covers software with a wide range of 
capabilities and contexts of operation. In order to take into account 
authoring tools with limited feature sets (e.g., a photo editor, a CSS 
editor, a status update field in a social networking application, etc.), 
many of the ATAG 2.0 success criteria are conditional, applying only to 
authoring tools with the given features(s) (e.g., Success Criterion 
B.1.1.1 applies only to authoring tools that automatically generate web 
content after the end of authoring sessions). "[APPROVED 

Most of the questions posted in this comments are unaddressed by the 
reply of the update.  Please review and address accordingly.  Moreover, 
many of the updated success criteria are still lacking condition parameters.

MS8: A.3.1 There should be exception and consideration for authoring 
environment/OS where there is no keyboard. Either add a condition for 
environment/OS with keyboard or add an exception.

AUWG: Please see response to 

Most touch screen devices do not use the keyboard for navigation. 
Keyboard is only used for text input.  The current definition of 
keyboard interface does not work with the corresponding SC within the 
context of touch screen devices.  Also, please refresh the term PDA.  It 
is no longer in use today.

MS17: A.3.7.2 Please remove the term "third-party" from option A. It is 
not appropriate. This is saying that Microsoft cannot use IE; Google 
cannot use Chrome; and Apple cannot use Safari. Please remove the term 
"third-party" completely.

AUWG: We have replaced this term with "pre-existing" to distinguish 
"user agents" in the marketplace from something developed by the 
authoring tool developer from scratch.[APPROVED 

The term "pre"-existing is problematic as User agents may be updated to 
render newer types of content.  We suggest the term "pre" be removed.

MS19: A.4.1.1 "Undo" is normally not feasible for many scenarios for 
basic web form authoring tool or it depends on the browser to carry out 
the undo. In reality, most actions are reversible without having the 
"undo" function. If action is reversible, then why impose the specific 
function of "undo"? Change the SC to read: "Authoring actions are 
reversible or include warning to authors that the action is irreversible."

AUWG: Reworded as follows: "For authoring actions, one of the following 
are true:
(a) Reversible: The authoring action can be immediately reversed; or
(b) Warn and Confirm: The authoring tool includes a warning to authors 
that the action is irreversible and requires authors to confirm the 
action before proceeding.
- Note 1: Reversing actions (e.g. an "undo" function) are also 
considered authoring actions, meaning they must also meet this success 
criterion (e.g., a "redo" function).
- Note 2: It is acceptable to collect a series of text entry actions 
(e.g. typed words, a series of backspaces) into a single reversible 
authoring action.
- Note 3: It is acceptable to clear the authoring action history at the 
end of authoring sessions. "[APPROVED 

Please remove "immediately" from condition A.  It introduces far too 
much subjectivity into the success criterion.

OC13: -A.4.2.1 - Regarding documenting "all features" we feel this is 
too broad. This is a requirement for all users, not just people with 
disabilities so we feel it isn't applicable to ATAG. Even with narrowing 
to "all 'accessibility-related' features" this could still be very 
broad. For example, why would features that are programmatically 
determinable, such as keyboard shortcuts, need to be 'documented'?

AUWG: This has been clarified: "A.4.2.2 Document All Features: The 
authoring tool includes documentation for its author-level user 
interface features."
People with some disabilities benefit more from documentation than users 
in general. [APPROVED http://www.w3.org/2011/04/11-au-minutes#item03]

We need definition for "author-level user interface features".

WCAGWG15: B.1.2.2(a): "Option to Save: authors have the option to save 
the accessibility information in another way (e.g., as a "comment", as a 
backup copy of the input);" It would be great to add "accessible" to 
"authors have the option to save the accessibility information in 
another [accessible] way."

AUWG: We have taken a completely different approach to the preservation 
requirements in Guideline B.1.2. The requirements are now:

- B.1.2.1 Restructuring and Recoding Transformations (WCAG): If the 
authoring tool provides restructuring transformations or re-coding 
transformations, then at least one of the following is true:
Note: This success criteria only applies to transformations in which the 
output technology is an "included" technology for conformance.
(a) Preserve: Accessibility information (WCAG) is preserved in the 
output; or
(b) Warning: Authors have the default option to be warned that 
accessibility information may be lost (e.g. when saving a vector graphic 
into a raster image format); or
(c) Automatic Checking: After the transformation, accessibility checking 
is automatically performed; or
(d) Checking Suggested: After the transformation, the authoring tool 
prompts authors to perform accessibility checking.
- B.1.2.2 Optimizations Preserve Accessibility: If the authoring tool 
provides optimizing web content transformations then any accessibility 
information (WCAG) in the input is preserved in the output. (Level A)
- B.1.2.3 Text Alternatives for Non-Text Content are Preserved: If the 
authoring tool provides web content transformations that preserve 
non-text content in the output, then any text alternatives for that 
non-text content are also preserved, if equivalent mechanisms exist in 
the web content technology of the output. (Level A).
[APPROVED http://www.w3.org/2011/04/18-au-minutes.html]

What are "restructuring transformations" and "recoding transformations"? 
  We think the concept of "accessibility information" needs 
reexamination. We believe we are aiming at covering text alternative, 
audio description, captions, and content structure.  If so, there should 
be a tighter definition of "accessibility information" and that there 
may be a better term to encompass these items.  Moreover, I don't think 
these items are separated into A, AA, and AAA in WCAG 2.0.

MS22: B.1.3 "...prior to publishing." Invalidates the SC. If a tool 
generates content in real time, there is no content to meet WCAG 2.0 
prior to publishing. The concept has no meaning. Please remove "prior to 
publishing." In B.1.3.1, B.1.3.2, and B.1.3.3.

AUWG: This wording has been removed and instead a distinction has been 
drawn between autogeneration during authoring sessions (B.1.1.2) and 
auto-generation after authoring session (B.1.1.1).
- B.1.1.1 Content Auto-Generation After Authoring Sessions (WCAG): 
Authors have the default option that, when web content is automatically 
generated for publishing after the end of an authoring session, it is 
accessible web content (WCAG).
Note: This success criterion applies only to automatic processes 
specified by the authoring tool developer. It does not apply when author 
actions prevent generation of accessible web content.
- B.1.1.2 Content Auto-Generation During Authoring Sessions (WCAG): 
Authors have the default option that, when web content is automatically 
generated during an authoring session, then one of the following is 
true: [Implementing B.1.1.2] Note 1: Automatic generation includes 
automatically selecting templates for authors.
Note 2: This success criterion applies only to automatic processes 
specified by the authoring tool developer. It does not apply when author 
actions prevent generation of accessible web content.
(a) Accessible: The content is accessible web content (WCAG) without 
author input; or
(b) Prompting: During the automatic generation process, authors are 
prompted for any required accessibility information (WCAG); or
(c) Automatic Checking: After the automatic generation process, 
accessibility checking is automatically performed; or
(d) Checking Suggested: After the automatic generation process, the 
authoring tool prompts authors to perform accessibility checking.
[APPROVED http://www.w3.org/2011/04/18-au-minutes.html]

Please see above comments on the concept of "automatic".

MS25: B.2.1.2 "Accessibility-related properties" is undefined. Please 

AUWG: Please see response to 

The term is merely renamed "web content properties related to 
accessibility information" which is still undefined or at least ill defined.

MS47: B.1.2 How does this apply to something like a copy and paste 
operation from a rich text editor to a plain text editor where 
structural info will be lost? Who is supposed to tell the author that 
the structure is gone? Please explain how the SC applies to 
copy-and-paste or cut-and-paste operations?

AUWG: The preservation requirements have been reorganized. See 

WCAGWG15 does not address the question.

Additional comments:

*         We believe case sensitive search is considered an advanced 
search function.  Thus, we recommend moving the case sensitive search 
portion of A 3.5.1 should be moved to AAA.

*         We recommend removal of the note on B 2.4.1.  It appears 
contradictory to B 2.4.2 & B 2.4.3

*         We recommend renaming B 2.4.3 to "Author-created template"

*         We do not believe the question about the problem regarding 3rd 
party making claim on authoring tools that they are not responsible for 
is properly addressed in the conformance text.

-----Original Message-----
From: Jeanne Spellman [mailto:jeanne@w3.org]
Sent: Wednesday, July 27, 2011 10:32 AM
To: Alex Li
Cc: Jutta Treviranus
Subject: Response to your comments on Authoring Tool Accessibility 
Guidelines (ATAG) 2.0

Dear Alex:

Thank you for your comments on the 8 July 2010 Last Call Working Draft 
of Authoring Tool Accessibility Guidelines (ATAG) 2.0 
(http://www.w3.org/TR/2010/WD-ATAG20-20100708/). The Authoring Tool 
Accessibility Guidelines Working Group has reviewed all comments 
received on the draft. We would like to know whether we have understood 
your comments correctly and whether you are satisfied with our resolutions.

Please review our resolutions for the following comments, and reply to 
us by 26 August 2011 to say whether you accept them or to discuss 
additional concerns you have with our response. If we do not hear from 
you by that date, we will mark your comment as "no response" and close 
it. If you need more time to consider your acknowledgement, please let 
us know. You can respond by email to 
public-atag2-comments@w3.org<mailto:public-atag2-comments@w3.org>. Note 
that this list is publicly archived.

Since many of the comments were related, we have kept all the comments 
on a topic together in a spreadsheet format, so you can see your 
comments in the context of the others.  You can search for your specific 
comments by searching for your code "MS". The spreadsheet of comments is 
located at 

The AUWG has published a new working draft of ATAG 2.0 and Implementing 
ATAG 2.0, so you can see the results of your comments in the document.


Note that if you still strongly disagree with our resolution on an 
issue, you have the opportunity to file a formal objection (according to

3.3.2 of the W3C Process, at


to public-atag2-comments@w3.org<mailto:public-atag2-comments@w3.org>. 
Formal objections will be reviewed during the candidate recommendation 
transition meeting with the W3C Director, unless we can come to 
agreement with you on a resolution in advance of the meeting.

Thank you for your time reviewing and sending comments. Though we cannot 
always do exactly what each commenter requests, all of the comments are 
valuable to the development of ATAG 2.0.


Jutta Treviranus, AUWG Chair

Jeanne Spellman, AUWG Staff Contact
Received on Monday, 3 October 2011 15:14:04 UTC

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