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Summary of Bugzilla comments on checkpoint/guideline 3.3

From: John M Slatin <john_slatin@austin.utexas.edu>
Date: Tue, 20 Jan 2004 12:10:09 -0600
Message-ID: <C46A1118E0262B47BD5C202DA2490D1A798F3E@MAIL02.austin.utexas.edu>
To: "WCAG List" <w3c-wai-gl@w3.org>

Summary of public comments on Checkpoint/Guideline 3.3 as reported in


December 17, 2003


Prepared by: John Slatin


On 17 December 2003, Bugzilla found 13 bugs related to
Checkpoint/Guideline 3.3. Ten of these referred to the June or September
Working Drafts. The last three (#648-650) show the proposed plain
language wording broken into three separate items. There have been no
comments about the plain language proposal, either in Bugzilla or on the
list, and it has not yet been discussed in the weekly teleconferences.


The comments seem to fall under the following headings:

Editoraial suggestions

#381 Miscellaneous editorial suggestions

Comments on June 24 WD by Harvey Bingham re: best practices and
benefits. Suggests use of bulleted lists in place of long series in
sentence-form (best practices), notes ambiguity in use of word
"concrete" under examples. [The plain language proposals use bulleted
lists rather than comma-separated series in sentence form, so I think
this issue has been resolved. The word "concrete" is still used in
Additional Measures/Strategies, however, and I'm not sure I have a
better alternative yet.  Some candidates include: specific, real,
tangible, literal (as in the opposite of figurative), but all of these
seem to pose the same problem-they're pretty abstract <grin>.]


Difficulty of understanding what the checkpoint/guideline requires


Kynn Bartlett, Aug 2003, sarcastic comment about opacity of language;
response by Wendy Chisholm

Addressed (if not fully resolved) by plain language proposals



September 2003, Olivier Thereau: "not more than necessary" is not
testable, tentative suggestion to reword checkpoint title to focus on
"review" rather than "not more than necessary."

[This point is addressed, if not yet fully resolved, by plain language
proposals. See discussion of items 648-650 for details.]


Includes both editorial and substantive comments from Kansas Web
Accessibility Committee, October 2003. 

1.    Editorial: change "supplement" to "supplemented"; 

2.    Editorial: label "Required success criteria is missing". 

3.    Substantive: "might be useful to describe proper and effective use
of non-text content for the purpose indicated"

These items are addressed by the plain language revisions. See
discussion of #648-650 for details.


Difficulty of defining and evaluating "complexity"

#495 How to evaluate complexity of content

October 2003, Greg Gay posts substantive two-part critique of 3.3. He 

1.    argues that it's inappropriate to include language as a criterion
for accessibility. He argues that evaluating the complexity of written
content is a specialized job for copy-editors rather than accessibility
evaluators, that it would be costly and ultimately unreliable because
subjective.  Automated tools aren't adequate to the task and it's
difficult to determine what the cutoff point below which the document
fails would be.

2.    notes that we should distinguish between "alternative formats" and
simpler or less complex versions, noting that in our examples we talk
about supplementing complex text with audio and/or visual illustrations
but don't make clear that these are simplified representations.


The second point can (and should) be resolved by modifying the examples
to show how the supplemental content provides simplified representations
of complex textual content. The first issue poses a philosophical
problem about the scope of the guidelines themselves. This concern is
picked up in the Access Board's comment that 3.3 crosses what they
regard as the line between accessibility and usability (see next item).

#569 Complexity is subjective

October 2003, US Access Board argues that 3.3 belongs more properly to
usability than accessibility and adds that "writing style" is

Additionally, Joyce Tikalsky suggests that these suggestions about
writing style apply across all communications media and are too general
for accessibility; suggests that the suggestions could be moved to a set
of recommended guidelines about editing Web content.

Some of these concerns are addressed though not fully resolved in the
plain language proposals under Level 2 and Additional Measures, but
testability remains a major concern as does the question of whether 3.3
goes beyond the scope of accessibility.

What types of content should be included under 3.3 (specifically ASCII
art, illustrations, sound)

#382 (sound)

August 2003, Harvey Bingham: suggests explicitly including synthetic
speech (with variations of pitch, rate, etc.) as well as announcement of

Not yet addressed; might be incorporated in strategies and examples,
references to CSS 2.1 speech properties.

#420 (ASCII art)

August 2003, Kynn Bartlett: points out that ASCII art is text. I think
This is moot in the plain language proposals, which don't mention ASCII


#421 (Use of illustrations)

August 2003, Kynn Bartlett critiques phrasing that reads "Designers need
to be cautious" about "using illustrations." Kynn notes that this
appears to discourage use of illustrations and argues that we shouldn't
discourage that.  Urges careful phrasing to avoid misinterpretation by
others like the frequent misunderstandings of the WCAG 1.0 and 508
provisions about color. 

Resolved in plain-language proposals, which delete the cautionary note
and specifically call for use of illustrations to clarify complex


#430 Proposal 3, Checkpoint 3.3

August 2003, Lisa Seaman, on behalf of a group.

This proposal, sent to the list and available at
<http://lists.w3.org/Archives/Public/w3c-wai-gl/2003JulSep/0244.html> ,
forms the substance of Checkpoint 3.3 as it appears in the September WD,
though portions of the proposal were altered as they migrated into the
WD. Perhaps the most important concept that does not appear in the WD is
the one that calls for "markup of key information that the user
typically requires."  Lisa notes that this requirement is "similar to
1.3" but differs in the important respect that it first calls for
identifying important information and including it in structural markup,
whereas 1.3 calls for using structural markup and making structure


In my judgment, the proposal is clearer and perhaps more nearly testable
than Checkpoint 3.3 as it appears in the September WD; the first plain
language proposal (#648) took the WD as starting-point rather than this
proposal, so does not include the item about identifying key information
and incorporating it into structural markup.

#648 Proposed wording for Guideline 3.3

November 2003

Items 648-650 re-frame Slatin's proposal for rewording Checkpoint 3.3
into three separate items. Item 648 (this item) presents the current and
prposed wording for Checkpoint (now Guideline) 3.3, as follows:

Current wording for Checkpoint 3.3

3.3 [E8] Content is no more complex than is necessary and/or is
supplemented with simpler forms of the content.


Proposed wording for Guideline 3.3

3.3             [E8] Use the clearest wording that is consistent with
the purpose of the content. Provide summaries or paraphrases of complex
material, and provide visual or auditory illustrations as appropriate. 

The proposed rewording eliminates the controversial phrase "no more
complex than is necessary," but replaces it with one about consistency
which may be equally difficult to test. 

The proposed rewording encourages the use of non-text content to
supplement complex text. It does not explicitly call for simplified
representations. The reference to summaries or paraphrases could be
modified to call for these to be written in simpler language than the
primary content, and a reference to call for simplified illustrations
may be added as well. 

#649 Proposed wording for Guideline 3.3 Level 2

November 2003

Item 649 proposes rewording Success Criterion #1 for Checkpoint (now
Guideline 3.3). This was part of the plain language proposal.

The revision addresses at least some complaints about the difficulty of
understanding the checkpoint. Some of these changes also address
problems with testability raised in the comments.

1.    The original wording of "A. familiarity of terms and language
structure" would be replaced by "A. The resource uses vocabulary which
is widely used by members of the intended audience." This replaces the
vague "familiarity" with language that suggests a test. Note that Lisa
Seaman's proposal would go even farther by calling for links to a
specific lexicon or glossary.

2.    The original "B. reasonableness of length and complexity of
sentences" would be replaced by language that suggests possible tests:
sentence length and complexity should be consistent with practices
recommended by widely used textbooks about writing in the relevant

3.    The proposal replaces vague wording ("C. coherence of paragraphs
(and sensibility in length)") with more a more testable criterion:
"paragraphs develop a single topic or subtopic" (the issue of length is
not addressed here; the Seaman proposal calls for a maximum of 7
sentences per paragraph).

4.    The call for "clarity of headings and link text when read out of
context" is modified to include specific situations where headings and
link text must be understandable, e.g., in lists of links and headings
reported by screen readers

5.    The item about accuracy of page titles is now written in sentence
form and calls for page titles to be unique and informative (consistent
with Seaman proposal)

6.    The item about care in using all caps is deleted as being
categorically different from other criteria in this list. The deletion
is NOT consistent with the Seaman proposal.

7.    The criterion about the use of (unspecified) non-text content for
clarification is replaced by wording that calls for use of page design
as well as graphics, audio, video, and animation to clarify complex
material. This specifies types of non-text content but does not address
the concern about providing less complex representations of complex
content; the item could be reworded to address that concern. There is
still a testability issue: the proposal replaces "where they felt it was
appropriate" with "as necessary," but does not indicate how necessity
should be determined. This is probably decidable only through user
testing, though perhaps user testing could yield generalizable
results/guidelines for recognizing complexity.



#650 Proposed wording for Guideline 3.3 Strategies

November 2003

This item, also part of the plain language proposal for 3.3, proposes
new wording for the list of additional measures/strategies for achieving
greater clarity and simplicity. It attempted to organize the list under
several headings and to suggest specific practices that are or could be
made testable.  For example, it suggests using style manuals,
dictionaries, and other reference tools (could be strengthened by
specifying that these should be used to standardize citation formats,
spelling, punctuation, etc.; and by requiring the site to declare what
manuals, dictionaries, etc., have been used). It also suggests testing
comprehension with real users, including people with reading
disabilities (this would presumably compound Greg Gay's objection about
the cost of meeting such a requirement).  The proposal also offers
criteria for determining when or  whether to use a controlled language
and/or plain language lexicon, e.g., if the document is intended for
translation or if it presents highly technical information to a
non-technical audience or to non-native speakers. Item 6 in the list
does not satisfy Harvey Bingham's concern about the ambiguous use of the
word "concrete" as an antonym for "abstract."

Slatin suggests moving the items grouped under the heading "Instructions
and operable content" to Guideline 2.5, which has to do with reducing
the likelihood of error and making it easier to recover. Most of these
items are readily testable and come appropriately under the rubric of
operability. Moving them to 2.5 as Level 2 criteria would raise their
importance and make it more likely that sites would follow these



"Good design is accessible design." 
Please note our new name and URL!
John Slatin, Ph.D.
Director, Accessibility Institute
University of Texas at Austin
FAC 248C
1 University Station G9600
Austin, TX 78712
ph 512-495-4288, f 512-495-4524
email jslatin@mail.utexas.edu
web http://www.utexas.edu/research/accessibility/


Received on Tuesday, 20 January 2004 13:14:35 UTC

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