Additional Comments

Comments from Alex Li at Microsoft:



At a more detailed level, Part A contains inconsistencies and unnecessary duplications.  An example of inconsistency is the timing guideline.  A3.2.2 restricts that the only solution to deal with time limit is to extend the timeout by 20 second response.  Yet A1.1 & A1.2 point to WCAG 2.0 and WCAG 2..0 2.2.1 offers much wider range of options including turn off, adjust, extend, real-time exception, essential exception, and 20 hour exception.  If ATAG 2.0 A3.2.2 takes all the WCAG 2.0 2.2.1 options off the table except one, very explicit statement has to be made and rationale must be given.  Timing is just an example, this inconsistency can be found for animation and other topics.  As to duplication, I see A3.1.2, A3.7.1, and WCAG 2.0 2.1.2 as duplicative.  Such duplication creates inconsistency and confusion.



I cannot discern the rationale for the operations requiring shortcuts per A3.1.1 except that they are popular in desktop apps.  The list is largely invalid outside of the desktop application space.



Check for testability issues throughout, especially in part B.


Part B is about QA.  But QA in the development world is a system of business processes, people, and tools.  Yet, the guidelines are relying too much on the tools as the primary method to achieve accessible outcome