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RE: WCAG 2.1

From: Phill Jenkins <pjenkins@us.ibm.com>
Date: Thu, 22 Sep 2016 16:06:13 -0500
To: Jonathan Avila <jon.avila@ssbbartgroup.com>
Cc: "w3c-wai-ig@w3.org" <w3c-wai-ig@w3.org>
Message-Id: <OFE7D74E34.3D910057-ON86258036.006E3FAB-86258036.0073EDE0@notes.na.collabserv.com>
I wasn't responding only to you, so hopefully no offense was taken.
And thanks for your reply, you clearly got my point.  Because we used 
sentences instead of just terms, it was clear to me and you that we (you 
and I) were not intending to say a criterion was not important to some 
So, it may not be a term that I'm recommending to change, but perhaps, 
requiring everyone (not just you and me) to use more full sentences with 
the terms we choose to use. 

Levels of what?
What are the levels of the success criteria? 
Are they levels of importance to end users? 
No, not at all as we have both observed, acknowledged, and I think agreed 
But, we also agree that Level A criterion are most important to the web 
Are they levels of severity to end users?
no not at all. . . 
Are they levels of priority?
hmm, to whom?  Yes they are levels of priority to web developers!
but not levels of important to end users.
Perhaps we just need to add the "to whom" in the sentence, instead of just 
using the term "Levels".

The working group needs to ask itself: "Why is the level changing from A 
to AA?" I hope because it is changing the priority to the web developer 
(not to the end user) BECAUSE the criterion is no longer critical 
because now (but there wasn't a decade ago back in 2003) there is a way, a 
common ubiquitous way for the browser and AT to make the content 
In other words some or all of the complex considerations the working group 
dealt with back in 2003 are no longer valid. 

I believe this is exactly how the 2X criterion (1.4.4 Resize text ) got 
set (not lowered) from level A to Level AA because more of the problem was 
solved by then by the browsers including a zoom feature.  When we did WCAG 
1.0, the browsers didn't have that feature. Should the criterion be 
changed to 4X because of the aging population? 

So I'm trying to change the notion that the levels are about levels of 
importance or severity to the end users, but, that they are levels of 
importance to the web developer. 
In my opinion, I think we may have made a mistake by changing the term 
from Priority to Level, but in either case, the "to whom" was the part 
that really caused the confusion 
and group's issues. 

With this line of thinking we don't have to get rigid on statements like: 
no Level A criterion can be lowered to level AA. 
its got to be changed to level A from level AA because its so important to 
this set of users.

Don't get me wrong, level of importance and severity to end users is of 
critical importance and critical input to setting the level (or priority), 
but the working groups has to consider the level of priority to the web 
developer (all zillion of them) verses the level of priority to the AT and 
browser companies (all ~100 of them). 

Another example:
Content simplification and content summarization is of critical importance 
to some (even more) users.  Its actually a federal law that some US 
federal government content has to be "easy to read", however testable that 
is or isn't. 
When is it *simple enough*? and to whom is it simple enough, and what is 
it that has to be simple enough?
There are at least three (3) parts to that equation that the intent of the 
law was trying to solve.
        Is simple enough defined as 5th grade, 8th grade, or other 
        Is to whom all public, or all students at a university, or some 
other know group?
        Is what is include? legal agreements, university textbooks, voting 
guides, or some other know list? 
                ADA seemed to only apply to brick & mortar places, so lets 
not repeat that mistake.
Where does cognitive assistive technology play a role vs placing all the 
responsibility of the web developer/content author?
Where does narrowing the applicable content play a role?  Lawyers rarely 
regulate themselves by the way. . . 
        Do those complex consideration yield a different level of priority 
to the web developer? 

So, I do ask my self and the WCAG 2.1 working group, does UAAG need to be 
updated in parallel? 

Phill Jenkins, 
Senior Engineer & Business Development Executive
IBM Research - IBM Accessibility

From:   Jonathan Avila <jon.avila@ssbbartgroup.com>
To:     "w3c-wai-ig@w3.org" <w3c-wai-ig@w3.org>
Date:   09/21/2016 06:28 PM
Subject:        RE: WCAG 2.1

Phil, I had no intention of saying that some criteria were not important 
to some users.  I agree they are all not just usability issues. They are 
barriers to users with disabilities.  But as you acknowledge some are 
items that must be solved by the author while others can be solved through 
the browser or AT.  The Understanding Conformance document indicates that 
levels are set based on whether the Success Criterion is essential (in 
other words, if the Success Criterion isn't met, then even assistive 
technology can't make content accessible).  So to that degree they carry a 
greater weight.
So when I used the term important I was thinking more along these lines ? 
some SC are essential because they can?t be worked around by AT and thus 
having the author address these is of greater need.  The term severity or 
priority would probably also be objectionable.  But knowing which criteria 
affect multiple user groups and which ones can?t be worked around are real 
world needs that organizations must consider when there is a limited time 
to fix issues.    Most organizations do have to prioritize issues whether 
something is a barrier versus something AT can overcome is a realistic 
factor in helping them make these decisions.    While using the term 
change level would be best?it carries an ambiguity  ? but in the email I 
was responding to it appeared that there was confusion about what level 
was the minimum level of accessibility.  Also many organizations are 
confused when we speak of Level AA conformance and automatically assume 
incorrectly that excludes level A conformance.  So we do need to find a 
term that is appropriate and understandable to communicate.  What term 
would you recommend?
Jonathan Avila
Chief Accessibility Officer
703.637.8957 (Office)
Visit us online: Website | Twitter | Facebook | Linkedin | Blog
Check out our Digital Accessibility Webinars!
From: Phill Jenkins [mailto:pjenkins@us.ibm.com] 
Sent: Wednesday, September 21, 2016 1:34 PM
To: w3c-wai-ig@w3.org
Subject: RE: WCAG 2.1
I do not support of the use of phrases such as "raising" or "lowering 
importance" or making a success criterion "more" or "less important". 
There is a misunderstanding out there about the levels (or its just a 
misunderstanding in using English to describe things or me in 
understanding things).  Saying that it is important today or more 
important tomorrow to conform with the success criteria is a very 
different concept in my mind that saying that level A success criterion is 
more important to this end user than a level triple A success criterion is 
to that other user. Remember that it is the web content accessibility 
guidelines WCAG , not the end user experience guidelines.  In my opinion 
all the success criterion are important, period.  Level A and double A and 
triple A are not about importance, they are about if and when they apply 
to the web content (vs the browser or AT) and to whom do they benefit. One 
of the questions that the working group asked themselves when assigning a 
level to the success criterion was the following: Does it apply: 
        to all the content all the time?
        to all web sites all the time?
        for all audiences all the time?
Another questions that was asked was about whether it is best solved by 
the user agent (browser and/or AT) or whether it is best solved by or in 
the web content by the web designer and developers. You can read a wide 
range of interacting issues that the working group consider in 
Understanding Levels of Conformance.

Conformance with triple AAA is not better or more accessibility, it is 
more responsibility on the author more of the time because its more 
applicability.  The notion of "higher levels" (not higher importance) of 
conformance comes from that concept that meeting triple AAA requires 
passing more, all 65 success criteria, while double AA conformance means 
passing fewer only 38 success criteria. Level A is the lowest level, 
meaning it only requires meeting 25 success criteria.  Even the normative 
WCAG standards says: 
"Conformance  This section is normative. . . . Note 2: It is not 
recommended that Level AAA conformance be required as a general policy for 
entire sites because it is not possible to satisfy all Level AAA Success 
Criteria for some content."  

Also, because of conflicts I never recommend requiring many of the Level 
AAA success criterion all the time on all web content for all users.  Here 
are 3 examples: 
1.      Conforming to 1.4.6Contrast (Enhanced) Level AAA creates a very 
high contrast site that is distracting and "striking" for some (many?) 
users.  "The contrast ratio of 7:1 was chosen for level AAA because it 
compensated for the loss in contrast sensitivity [by some]...users... 
People with more than [20/80 vision] usually use assistive technologies to 
access their content (and the assistive technologies usually have contrast 
enhancing, as well as magnification capability built into them). The 7:1 
level therefore generally provides compensation for [some users] who do 
not [have their] assistive technology. . . ". Therefore, in my opinion, 
requiring 7:1 contrast level all the time on all content is akin to 
requiring a one size fits all contrast setting that is not in harmony with 
the principles of web accessibility and a one size fits one through 
transformation technologies in the browsers and AT, not provided by the 
web site owner.
2.      Conforming to 1.4.9Images of Text (No Exception) Level AAA:  would 
also require no logos, no images of text, no exceptions.  I'm sure SVG is 
making progress and being adopted in many places, but I do not think we 
are at a point yet that we can require 1.4.9 on all web sites all the 
time, hence that is at least one reason it is level AAA. From a cognitive 
disability perspective, logos help with branding recognition of which 
website the user is on.  I would never recommend an "East Berlin" look (if 
you ever visited East Berlin before the wall came down you would know what 
I mean) for all websites.  However, it could make sense to require this 
level AAA criterion in some limited cases, for a controlled set of users, 
such as a set of AT training pages, hence its level AAA.  But I do not 
believe sighted users with some cognitive disabilities or aging users 
would ever benefit.  Most of us are thinking, isn't that the role of the 
assistive technology, screen readers, etc, for most web sites and the 
answer is of course, hence level AAA.
3.      Conforming to 2.4.10Section Headings Level AAA:  would require 
section headings, "This provision is included at Level AAA because it 
cannot be applied to all types of content and it may not always be 
possible to insert headings. For example, when posting a pre-existing 
document to the Web, headings that an author did not include in the 
original document cannot be inserted. Or, a long letter would often cover 
different topics, but putting headings into a letter would change the 
letter. However, if a document can be broken up into sections with 
headings, it facilitates both understanding and navigation".  So you see, 
in my opinion, section headings are very important to some users for 
better comprehension, easier understanding, etc.  Its level AAA in my 
opinion also because of the difficulty of applying it all the time by the 
web owner.  New simplification and summarization technology is emerging, 
but we would not want to necessarily change the original content all the 
time in all cases - hence it would remain a level AAA.

So, moving a success criteria from level A to double A is not necessarily 
increasing the importance or benefit to all end users any more than moving 
it from level AA to single A is not lowering the importance or benefit to 
all end users.   However, moving a success criteria from double AA to 
single A (or adding a success criteria to level A) *is* about increasing 
the amount of responsibility and work onto the web content owner and 
increasing its applicability by requiring the criterion to be applied to 
all (or more) content, for all (or more) web sites and to all (or more) 
audiences all (or more) of the time.  Remember that it is the web content 
accessibility guidelines WCAG , not the end user experience guidelines. 
WCAG conformance is about whether the web content conforms to the standard 
by passing the testable success criteria.  Browsers, AT, and end users 
settings are all still part of the equation.  There are also
standards for the browser, called the User Agent Accessibility Guidelines 
UAAG, that  browsers should conform to.  See the discussion on essential 
components for more background. 
Please, lets stop the misunderstanding that WCAG conformance is the end 
all and that the levels are about importance. 

Essential Components of Web Accessibility:  

WCAG 2.0: Conformance Requirements 

Understanding WCAG: Understanding Levels of Conformance 

Phill Jenkins, 
IBM Research - IBM Accessibility

From:        Jonathan Avila <jon.avila@ssbbartgroup.com>
To:        "w3c-wai-ig@w3.org" <w3c-wai-ig@w3.org>
Date:        09/21/2016 08:21 AM
Subject:        RE: WCAG 2.0

  So you mean in WCAG2.1 some provisions will be raised from  AA to AAA 
or   A to AA?
It is my personal understanding that the importance of success criteria in 
WCAG 2.1 cannot be made less important.  So an A would not go to AA.  WCAG 
2.1 by its definition must ensure that if something passes WCAG 2.1 at a 
given level it would also pass WCAG 2 at the same level.
What is a possibility is that a success criteria might get more important. 
 So a level WCAG 2 AAA criteria might become WCAG 2.1 AA or a WCAG 2 level 
AA might become WCAG 2.1 level A.
Jonathan Avila
Chief Accessibility Officer
703.637.8957 (Office)
Visit us online: Website| Twitter| Facebook| Linkedin| Blog
Check out our Digital Accessibility Webinars!
From: Balusani, Shirisha [mailto:sirib@uillinois.edu] 
Sent: Wednesday, September 21, 2016 8:58 AM
To: Gregg Vanderheiden; w3c-wai-ig@w3.org
Subject: RE: WCAG 2.0
        Level A: For Level A conformance (the minimum level of 
conformance), the Web page satisfiesall the Level A Success Criteria, or a 
conforming alternate version is provided. 
        Level AA: For Level AA conformance, the Web page satisfies all 
the Level A and Level AA Success Criteria, or a Level AA conforming 
alternate version is provided. 
        Level AAA: For Level AAA conformance, the Web page satisfies all 
the Level A, Level AA and Level AAA Success Criteria, or a Level AAA 
conforming alternate version is provided. 
So you mean in WCAG2.1 some provisions will be raised from  AA to AAA   or 
  A to AA?
From: Gregg Vanderheiden [mailto:gregg@raisingthefloor.org] 
Sent: Tuesday, September 20, 2016 11:54 PM
To: Balusani, Shirisha <sirib@uillinois.edu>
Subject: Re: WCAG 2.0
You cannot change a normative part of a standard after it has been issued. 

There has been some discussion of a new  WCAG 2.1 ? and some discussion in 
that about raising some of the provisions from AA to A   or AAA to AA 
but going from AA to AAA would be lowering an SC?s level 

On Sep 20, 2016, at 10:59 PM, Balusani, Shirisha <sirib@uillinois.edu> 
Hi All,
I?m curious to know if the WCAG 2.0's  success level criteria  will be 
raised from AA to AAA in near future .
Received on Thursday, 22 September 2016 21:06:54 UTC

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