WCAG 2.1 public comment

Dear Sir, dear Madam,

Inclusion Europe, the European Association of People with Intellectual
Disabilities and their Families, is very concerned that the final draft of
the WCAG 2.1 includes again almost *no relevant accessibility measures for
people with intellectual and learning disabilitie*s. We are indeed
surprised that the Working Group shows such a disregard for the
accessibility needs of such a large group of people with disablities and
call upon you to end these discriminatory practices against people with
intellectual disabilities.

Furthermore, we draw your attention to the fact that intransparent and
unaccessible working methods exclude any person with intellectual or
learning disability from participating actively in the formulation of the
WCAG. We will take the opportunities in the discussions of the European
Accessibility Act with European policy-makers to raise this point.

In the following, we reiterate our main proposals that we had submitted to
you before:

*Insert new Criterion 2.4.13: Navigation to plain language summary*
The link to a Plain Language Summary page of a site is provided in the
upper part of the entry page of a site through a non-verbal icon (such as
the Easy-to-Read Logo at www.easy-to-read.eu)


*Amend Success Criterion 3.1.2 Language of Parts*
Add this text:
If a site contains any pages or summaries in plain language, each plain
language passage in the content can be programmatically determined except
for proper names, technical terms, words of indeterminate language, and
words or phrases that have become part of the vernacular of the immediately
surrounding text.

*Insert new Criterion 3.1.7: Plain Language Summary of site*
When a website requires for most of its pages a reading ability more
advanced than the primary education level, a summary page that does not
require reading ability more advanced than the primary education level, is
available as supplemental content. This Plain Language Summary page
includes:

   - Information about the purpose of the site
   - Summary explanations of and links to the 5 most used pages on the site
   - Contact information

The summary page is clearly identified by a non-verbal icon.

*Insert new Criterion 3.1.8 Plain Language Summary of main pages*
When the 10 mostly used pages of a website require a reading ability more
advanced than the primary education level, alternative content is provided
that does not require reading ability more advanced than the primary
education level. This content is clearly identified by a non-verbal icon.

*Insert new term in Glossary*
Plain language or easy-to-read language is a text that does not require
reading ability more advanced than the primary education level. It supports
access of people with intellectual or learning disabilities to relevant
contents, but can also enhances accessibility for non-native speakers of a
language.

We hope that it will be possible to take account of these accessibility
needs of people with intellectual disabilities.

Yours sincerely,

Geert Freyhoff

-- 

*Inclusion Europe *

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