WCAG 3.0 public comment

Dear madam, sir,

Thank you for this opportunity to contribute to WCAG 3.0.
Enclosed, you'll find our first comments and questions on:

1. Requirements for WCAG 3.0 - W3C First Public Working Draft 21 January
2021

Paragraph

Text Working Draft

Comment/Question

1.1

WCAG 3.0 does not want to advance the WCAG 2.0 requirement: "Ensure that
the revision is 'backwards and forward compatible '" . The intention is to
include WCAG 2.x content, but migrate it to a different structure and
conformance model.

 Does this mean that websites that comply with WCAG 2.x have to start from
scratch in order to meet with WCAG 3.0 guidelines?

2.2

Multiple means of measurement, in addition to pass/fail statements, allow
inclusion of more accessibility guidance.

Will it still be possible to fully determine whether a website conforms to
the guidelines or only partial?

2.3

5.      Be written in plain language, as easy as possible to understand. We
need a definition of plain language that includes the ease of
translation. Ideally,
it will be a broadly accepted definition internationally .

For Europe it would be practical if the CEFR <https://www.efset.org/cefr/>,
Common European Framework of Reference for Languages, is included from the
start.

4.5

The core guidelines are understandable by a non-technical audience. Text
and presentation are usable and understandable through the use of plain
language, structure, and design .

Including instruction videos and illustrated how-to’s.

2. W3C Accessibility Guidelines (WCAG) 3.0 - W3C First Public Working Draft
21 January 2021

Paragraph

Tekst Working Draft

Comment/Question

Abstract

W3C Accessibility Guidelines 3.0 is a successor to Web Content
Accessibility Guidelines 2.2 [WCAG22] and previous versions, but does not
deprecate these versions. /  WCAG 3.0 does not supersede WCAG 2.2 and
previous versions; rather, it is an alternative set of guidelines.

Does this mean WCAG 2.x will be existing side by side to WCAG 3.0 and
continue to be updated?

1.1

Following these guidelines will make content more accessible to people with
a wide range of disabilities, including accommodations for blindness, low
vision and other vision impairments ; deafness and hearing loss; limited
movement and dexterity; speech disabilities; sensory disorders; cognitive
and learning disabilities; and combinations of these.

 Are color blindness and dyslexia included?



Since the new standard will use a different conformance model, the
Accessibility Guidelines Working Group expects that some organizations may
wish to continue using WCAG 2.X, while others may wish to migrate to the
new standard.

 Legislation (what is obligatory in (inter)national laws) will play a huge
role in this choice.

2.2

Within a guideline, outcomes have an AND relationship.

 Can you explain what an AND relationship is?

3

*This section is non-normative.*

It would be more logical to WCAG 2.x-users to put the normative section
first and change paragraphs 3 and 4.

3.3

Functional categories of disabilities group the functional needs of users
with disabilities.

Obviously, there will be a overlap in guidelines that are to be met for
multiple functional categories – what is the reason for categorizing? So
that organizations can choose to make their website accessible for a
certain category? Or pick the cherries and only address the problems that
affect the most categories? That doesn’t seem expedient.

6.2

*Excellent (4) *No critical errors, approx. 99% to 100% of related tests
pass

In manuel testing, how can a 100% percentage be scored as it is impossible
to test everything. Depending on the scope?

6.3

This approach, which allows the tester some flexibility in assigning
scores , has the advantage of simplicity and allowing a tester to take the
context into account beyond the simple percentages.

 How can unambiguity be assured?

7.1

We are interested in your feedback on this approach to testing and scoring .
Does this approach help large organizations conform even if their site is
not 100% perfect? Do you think that organizations will interpret that they
only need 95% of text alternatives for images and then stop adding
alternative text? Are the bands of numbers for the different ratings
correct? Do people with disabilities in particular feel that this approach
will meet their needs?

 This could work as long as the method is unambiguous, and every tester
comes to the same conclusion. Also there should be a drive for
organizations to make their websites as accessible as possible, by giving
them some kind of platform. And there should be a simple way built into the
report for people (with disabilities) for who the website is not accessible
to address the problem so that the owner can rectify this situation or
offer an alternative. This gives the owner an incentive to comply as fully
as possible since it reduces the costs for a helpdesk of chatbox.

7.2

While we do not know of any mainstream accessibility tool that measures
common words , there are some working prototypes of tools developed outside
the W3C.

Like the Accessibility Reading Level tool
<https://www.accessibility.nl/tools/leesniveau> (Dutch)

7.3

If we decide to not accept open captions as equivalent to closed captions,
then we will give more points to closed captions than open .

If closed captions are more generally accessible, this seems to be the best
way to realize accessibility. Essential is to raise awareness to this issue.

8.1

3.      Allow for bugs and oversight by content authors, provided the
impact of them is limited to users with disabilities .

 This seems to be a discriminating principle.



This priority is reflected in the scoring system, which does not allow for
errors along the paths needed to complete processes but allow for some
accessibility errors outside process completion

 There was room for error in WCAG 2.x in the difference between incidental
en structural problems. Will there be a larger room for error in WCAG 3.0?

We would like to be kept informed.
Please contact us if you have any further questions.

Kind regards,

Cockie Gerritsen & Marijke van Grafhorst,
Stichting drempelvrij.nl (Barrierfree Foundation)

tel. +31 646202791
gerritsenjj@drempelvrij.nl
info@drempelvrij.nl
www.drempelvrij.nl

[image: logo drempelvrij.nl.png]
accessible websites and apps for everyone