Microsoft Comments to WCAG 3.0 FPWD

  *   Sending on behalf of Microsoft community -

Microsoft appreciates the Accessibility Guidelines Working Group's goal of expanding the guidelines to be more inclusive of different types of web and digital content, apps, and tools - as well as a broader range of people with disabilities. We are pleased to see the Working Group's recognition that content that is updated frequently presents challenges and requires flexibility, and the focus on content that is more important for task completion by users. Microsoft is also supportive of the Working Group's stated intent of making the guidelines easier to understand than WCAG 2.x. However, the First Public Working Draft falls short of that goal by making the guidelines more complex, harder to understand, and more difficult to implement. Specific details are outlined below.



Structure: The proposed structure is too complex, making it very hard to read and follow all the information needed to understand the guidelines. For example, a user needs to have four different web pages (W3C Accessibility Guidelines (WCAG) 3.0, How-Tos, Outcomes, and Methods) open simultaneously in order to consume all the relevant information for an individual guideline. For each of those pages, users need to change tabs to navigate among elements, adding another layer of complexity. The number of click-throughs and switching back and forth among pages and tabs necessary to read and digest each guideline creates a significant cognitive load on the user. The proposed structure also makes it difficult to search for information and to use the guidelines while offline. We recommend following the structure of WCAG 2.x to make the guidelines easier to understand and more efficient to navigate.



Scoring and Testing: Although the intent of the proposed scoring and rating system is to provide a more flexible conformance approach, it will make testing significantly more complex. Having five possible rating "bands" (a scale of 0 to 4) for each outcome will make all testing, and in particular manual testing, extremely complex. In addition, having different scoring methods (e.g., pass/fail, rating scales) and different percentages-as well as adjectival ratings-for the various rating scale "bands" for different criteria adds yet another layer of complexity.  We recommend that the proposed scoring and rating system be simplified to reduce the additional testing burden. For example, the scoring system should be more objective and data-driven, and avoid adjectival ratings which potentially introduce ambiguity and whose meaning may change when translated into other languages.



Guidelines: Clear Words is given as an example of a new type of guideline with a testing and scoring approach that differs from WCAG 2.x. It requires a manual tester to evaluate content and assign a score based on a subjective rating scale. Because the scoring is based on human judgment, it is subject to differences of opinion and interpretation. The scoring system needs to be less ambiguous and more robust.

For other guidelines, the Working Group is proposing to merge WCAG 2.x AA and AAA criteria into a single guideline. At present with WCAG 2.x, there is general acknowledgement that AAA is not necessarily readily implementable. This understanding seems to be lost in a merged guideline and would unfairly impose a lower score for any guideline containing AAA criteria that are not readily implementable.


Conformance Model: Microsoft appreciates and supports the Working Group's intent to make the conformance model more flexible and allow for bugs, provided their impact on users with disabilities is limited. Software is always subject to bugs and the conformance model reflecting this reality is extremely important. We are also pleased to see the introduction of "processes" to the proposed testing model as it is more closely aligned with our own test procedures and with the way users interact with content.

Thank you,

On behalf of Microsoft community