Oracle feedback on WCAG 3.0 FPWD

Oracle appreciates the opportunity to give feedback on the Accessibility Guidelines Working Group's first public working draft of the W3C Accessibility Guidelines 3.0. By creating WCAG 3.0 from the beginning with the intent that it applies to more than just web sites it in turn enables us to have more clarity on how the guidelines apply to our non-web products. We appreciate the work that has gone into writing the guidelines in a clear manner and adding the outcomes that better describe the intent and goal of the guidelines. This has resulted in the guidelines being more understandable which in turn leads to teams being better able to achieve them. There are a few areas of concern that we would like to see improved.

Scoring
While the example guidelines included a lot of detail, the information regarding scoring is throughout the document leading to a lot of confusion on how it would really work. Having an alternative to pass/fail is a requirement when it comes to applying WCAG to complex enterprise level products, but it needs to be done in a way that everyone can understand. Additionally, the methods used for scoring are complex since each outcome will have its own scoring scale. The impact to testing groups for the amount of data that must be recorded,  and tracking which scale is to be used on each outcome is going to lead to extensive time being spent on just tracking statistics of testing. We recommend a simplified scoring methodology be created to reduce this overhead.

Clear Words Guideline
The guideline for Clear Words makes use of an external tool that uses an undocumented set of rules. Instead of requiring the use of a specific tool, the guideline should be documenting the criteria to be met so people can in turn determine if they are going to buy a tool or add the functionality to tools they currently use.

Document Organization
"Outcome Ratings", "Critical Errors" and "Conformance Levels" are all new and distinct concepts that tie together but are not clearly documented. Just as with the scoring, information explaining how all these concept work needs to be located in one place and clearly explained.

We look forward to seeing the next working draft for WCAG 3.0 and appreciate the effort this is taking of the members.

Thank you,
Michele Van Doozer
Senior Accessibility Program Manager
Oracle