RE: Not described in words

> About putting all the timing issues under 2.2

I am not sure 2.2 needs additional timing related SC.  But let me repeat my other concern with the current wording of SC 2.1.1 (and 2.1.2):

<q>All functionality of the content is operable in a non-time-dependent manner through a keyboard interface</q>

>> seems to exclude *all* keyboard accessible games that have timing as [a] play element

It is possible for games like Pong or Frogger to satisfy SC 2.2.1 if:
<q>the user is allowed to adjust the time-out over a wide range that is at least ten times the length of the default setting</q>

But this does not help with SC 2.1.1 (and 2.1.2) and *recreational* games because, even if all functionality is operable via a keyboard interface, the functionality is *not* operable in a "non-time-dependent manner".