Re: Proposals for revision of the Plain Language SC proposals for WCAG 2.1

Hi Steve,

>From my perspective, do not be confused by low levels of discussion on any
single new SC - we are all struggling to keep up with the flurry of
correspondence at this time.

The latest PR for this new SC is simply the latest PR - it in no way means
that the SC is "finalized" - only that it is now going to the larger WCAG
WG for more review before it is "baked" into the 2.1 FPWD. (Note that the
full Working Group is not copied on this email, only the COGA TF)

I have a number of concerns with how this is emerging right now, including
some centered around internationalization (for example, my early research
shows that the use of the Passive Voice is not only common, but often
"required" in the Japanese language, and insisting on a non-passive voice
in that language may actually introduce *MORE* confusion for Japanese with
learning disabilities. Surely we don't want that!)

Additionally, I personally believe that statements such as "*It is expected
that natural language processing algorithms will be able to conform to this
automatically with reasonable accuracy.*" (Future tense) means that we do
not have this ability today - but I am not sure, do such tools exist today?
(Later, the draft suggests that IBM has "a tool" that can perform this
today, but dependency on a single tool for testing is problematic,
especially if it is a "for-profit" tool. Additionally, does that tool also
support multiple languages? My colleague Birkir Gunnarsson is Icelandic -
does the tool support his mother tongue as well?)

NOTE - I am not for an instant suggesting that the spirit of this SC, or
the Needs Statement that is driving it, are not valid, only that the
proposal as writ right now will have a hard time passing the wide review
that FPWD brings, and if we cannot answer the types of questions I am
asking now, in our more closed environment, then this SC will likely not
make the final cut, sad as that is.

So let's get it rock-solid now, ya?

JF

On Thu, Feb 9, 2017 at 3:14 PM, Steve Lee <steve@opendirective.com> wrote:

> Yes, my bad. I forgot where I was in the process of managing these 2.
>
> The reason for my reticence was the very low level of discussion. These
> were my 1st as a SC manager and I really expect more push and shove. I
> guess that means they are good.
>
> Sorry again for the confusion due to being new to the process.
>
>
>
> Steve Lee
> OpenDirective http://opendirective.com
>
> On 9 February 2017 at 21:01, lisa.seeman <lisa.seeman@zoho.com> wrote:
>
>> The pull request was done before Jeene made her suggestions so it is
>> really too late. The issue is closed.
>> My 2 cents - The Success criteria was pretty clear, measurable and
>> testable  - more then a lot of what is in WCAG 2.0
>>
>>
>> All the best
>>
>> Lisa Seeman
>>
>> LinkedIn <http://il.linkedin.com/in/lisaseeman/>, Twitter
>> <https://twitter.com/SeemanLisa>
>>
>>
>>
>>
>> ---- On Thu, 09 Feb 2017 20:46:03 +0200 *John
>> Foliot<john.foliot@deque.com <john.foliot@deque.com>>* wrote ----
>>
>> Hi EA,
>>
>> Thanks. I don't see this as "causing trouble" - I see this as having an
>> open, honest and candid discussion. We need to balance the needs of many
>> disparate groups, including content authors who are not experts (and never
>> will be). I've tried very hard to stay on top of the COGA requirements, and
>> one of the larger take-away's I've learned is that individual
>> personalization is and will be the Holy Grail for COGA issues.
>>
>> But we simply aren't there yet, not at anything that would scale, and I
>> think we do ourselves a dis-service if we don't accept that truism today.
>>
>> Re: Innovation - I fully support that 100% - YES. We have a number of
>> user-needs today, however the technology still isn't mature enough to start
>> mandating that site-owners do "X, Y, Z", and frankly I think that if we
>> ever got to the point where WCAG became that prescriptive we'd loose more
>> ground then we've gained.
>>
>> This is one of the reasons why I suggested that for the release of 2.1,
>> any User Requirement that was still unattainable at scale be none-the-less
>> published as an official W3C Note, as we did with the MAUR (
>> https://www.w3.org/TR/media-accessibility-reqs/) - not everything in
>> that list is achievable today, but the needs still exist, and what the
>> 'expectations' are have been collected and published. To my happy
>> discovery, there are now technologists out there taking these Requirements
>> and then working on Proof Of Concept solutions. This has to be a positive
>> thing!
>>
>> I sort of think of it like American Football - not every play is going to
>> score a touch-down, but if we are successful in moving the ball closer to
>> the goal line, we're still "winning". WCAG 2.0 had little-to-nothing to
>> address the needs of the core constituency of the COGA and LV Task Forces
>> when it was published in 2008, and we've done a good job collecting the
>> User Requirements (Gap Analysis), but I also think we've got plenty more
>> plays ahead of us before we score touch-downs there. But if, with 2.1, we
>> move the ball forward closer towards the goal-posts, I think we're doing
>> well - the goal now isn't "the touch-down" but rather "How many yards can
>> we advance forward with this play?"
>>
>> For me, it keeps on coming down to "Don't let Perfect be the enemy of
>> Good".
>>
>> Cheers!
>>
>> JF
>>
>> On Thu, Feb 9, 2017 at 10:47 AM, EA Draffan <ead@ecs.soton.ac.uk> wrote:
>>
>> Thank you for all the trouble you have taken John,  and I certainly did
>> not expect such an amazing reply this was just me researching it all a bit
>> more.
>>
>> Apologies for causing trouble.  Lets just see if we can find a better way
>> to test readability to suit all users.  Perhaps we can be a bit more
>> innovative as Lisa suggested, but I appreciate we will have to make it
>> robust and go through validation tests - thoughts of crowdsourcing help
>> across different languages etc.
>>
>> Best wishes
>> E.A.
>>
>> Mrs E.A. Draffan
>> WAIS, ECS , University of Southampton
>> Mobile +44 (0)7976 289103
>> http://access.ecs.soton.ac.uk<http://access.ecs.soton.ac.uk/>
>> UK AAATE rep http://www.aaate.net/
>>
>>
>> ________________________________
>> From: John Foliot [john.foliot@deque.com]
>> Sent: 09 February 2017 16:18
>> To: EA Draffan
>> Cc: Milliken, Neil; lisa.seeman; Thaddeus .; public-cognitive-a11y-tf;
>> Jeanne Spellman
>> Subject: Re: Proposals for revision of the Plain Language SC proposals
>> for WCAG 2.1
>>
>> TL;DR:
>>    WCAG Success Criteria need to be measurable, and while Reading Scores
>> have their issues, they are at least measurable and repeatable, and will be
>> significantly more palpable to the millions of content authors we will be
>> asking to meet this Need.
>>
>> ***
>>
>> Hi EA,
>>
>> Thanks for those links. After reading through them (and yes, I read all
>> 3), I am struck by one of the conclusion statements of the third reference (
>> https://www.ideals.illinois.edu/bitstream/handle/2142/15490
>> /why-rf-fail.html?sequence=3)
>>
>> "The real factors that affect readability are elements such as the
>> background knowledge of the reader relative to the knowledge presumed by
>> the writer, the purpose of the reader relative to the purpose of the
>> writer, and the purpose of the person who is presenting the text to the
>> reader. These factors cannot be captured in a simple formula and ignoring
>> them may do more harm than good."
>>
>> While we cannot discount this expert opinion
>> ​, it also leaves me wondering how we can ever hope to "standardize" and
>> quantify/measure something that is clearly not scientific​? Dissecting the
>> statement above:
>>
>>   1.  background knowledge of the reader relative to the knowledge
>> presumed by the writer - unknown and unknowable at scale (i.e. sites that
>> get hundreds of thousands of unique visits a day)
>>
>>   2.  the purpose of the reader relative to the purpose of the writer -
>> again, unknown and unknowable at scale
>>
>>   3.  the purpose of the person who is presenting the text to the reader
>> - this is the only factor apparently under the control of the content
>> author, and in scope for the Web Content Accessibility Guidelines, and thus
>> the only thing a WCAG SC can address.
>>
>> ​
>> My fear here is that there seems to be 2 opposing goals that we are
>> trying to meet: one is a "testable" and measurable *standard* that can be
>> taught and applied​ to millions of websites (the science piece), and yet
>> "writing" and writing for specific audiences is an "art" (my distillation
>> and take-away of those three articles).
>>
>> I get "art", and art is important, but art cannot be quantifiably
>> measured, it cannot be "taught" (outside of principles - the science of
>> painting with oils versus drawing with charcoals), but actual "art"
>> certainly cannot be standardized or measured (unless you are shopping at
>> Walmart, and purchase "Pastoral Scene #3 - 40" X 60"")
>>
>> What do I tell a Fortune 500 company they should do, if not try and meet
>> some kind of standardized reading level? When you are authoring content for
>> a million people, you cannot know all of your readers. I was more
>> encouraged by one of the conclusions of the Leeds paper (
>> http://www.leeds.ac.uk/educol/documents/213296.pdf
>> ​)​
>>
>>
>> "In conclusion, we want to emphasize that formulas are not invalidated
>> for the great majority of writing. On the other hand, what they cannot
>> measure should make clear that they cannot make writing a science."
>>
>>
>>
>> So... what can we do?
>>
>> In controlled environments, you may be able to ensure more attention is
>> applied to the "art" side of the problem statement, but for a company like
>> Tesco, what would you tell Tesco's editorial staff (where there is more
>> than one editorial person) to do? Tesco proudly claim to serve "...millions
>> of customers a week in our stores and online." (
>> https://www.tescoplc.com/about-us/our-businesses/), and so all they can
>> "know" about their audience is generalized data (likely determined by
>> user-logs on their website, coupled with possible surveys and focus-group
>> testing).
>>
>> Large organizations like this also generally use Style Guides (AP, The
>> Oxford Style Manual, The Chicago Manual of Style, etc. See:
>> https://en.wikipedia.org/wiki/List_of_style_guides) as well as often
>> they will have internal "Voice of the company/Voice of the client" guides
>> as well (when I worked at JPMC they had such an internal document).
>>
>> However, outside of specialized environments, getting any kind of buy-in
>> from the millions of content creators out there will necessitate some form
>> of measuring methodology, and while reading scores have their issues, they
>> seem to be better than nothing at all, and so I am concerned that COGA
>> experts are pushing back on this. I will posit that Jeanne's re-writes,
>> while not 100% "perfect", brings the authoring solution a lot closer to
>> what is required based upon the research provided.
>>
>> Add to that the increasingly litigious environment around web
>> accessibility, and ask yourself how will a judge (who is neither an
>> accessibility expert nor a language expert) going to judge whether a site
>> "fails" or not? (For this reason alone we need standardized testing of some
>> fashion or other, and if not readability scores, then what?)
>>
>> JF
>>
>> On Tue, Feb 7, 2017 at 8:31 AM, EA Draffan <ead@ecs.soton.ac.uk<mailto:ea
>> d@ecs.soton.ac.uk>> wrote:
>> I vote 3
>>
>> Holiday reading or references!
>>
>> Readability: The limitations of an approach through formulae (this paper
>> has a definition of readability)
>> http://www.leeds.ac.uk/educol/documents/213296.pdf
>>
>> Another very readable discussion about readability and the limitations of
>> scales,  but also measuring sentence length by number of words etc.
>> http://www.impact-information.com/impactinfo/Limitations.pdf
>>
>> old one
>>  https://www.ideals.illinois.edu/bitstream/handle/2142/15490
>> /why-rf-fail.html?sequence=3
>>
>>
>>
>> Best wishes
>> E.A.
>>
>> Mrs E.A. Draffan
>> WAIS, ECS , University of Southampton
>> Mobile +44 (0)7976 289103<tel:%2B44%20%280%297976%20289103>
>> http://access.ecs.soton.ac.uk<http://access.ecs.soton.ac.uk/>
>> UK AAATE rep http://www.aaate.net/
>>
>>
>> ________________________________
>> From: Milliken, Neil [neil.milliken@atos.net<mailto:
>> neil.milliken@atos.net>]
>> Sent: 06 February 2017 23:13
>> To: lisa.seeman
>> Cc: Thaddeus .; public-cognitive-a11y-tf; Jeanne Spellman
>> Subject: Re: Proposals for revision of the Plain Language SC proposals
>> for WCAG 2.1
>>
>> I vote 3
>>
>>
>> Kind regards,
>>
>> Neil Milliken
>> Head of Accessibility & Digital Inclusion
>> Atos
>> M: 07812325386 <07812%20325386><tel:07812325386 <07812%20325386>>
>> E: Neil.Milliken@atos.net<mailto:Neil.Milliken@atos.net><mailto:
>> Neil.Milliken@atos.net<mailto:Neil.Milliken@atos.net>>
>> http://atos.net/iux
>> http://atos.net/accessibilityservices
>> @neilmilliken
>>
>>
>>
>> On 6 Feb 2017, at 22:35, lisa.seeman <lisa.seeman@zoho.com<mailto:l
>> isa.seeman@zoho.com><mailto:lisa.seeman@zoho.com<mailto:lisa
>> .seeman@zoho.com>>> wrote:
>>
>> I am changing my vote to 3 as well.
>> The SC as it  is incredibly easy to write testing tools for. there are a
>> few open source  language processing tools that you can use to count cluses
>> actureltys. Testing against a word list is also something that exists
>> already in restricted language tools and is very easy to program. It cant
>> be that we need to have a worse SC and use archaic reading level tools
>> because WCAG are to set in their ways to accept any new technology.
>>
>> All the best
>>
>> Lisa Seeman
>>
>> LinkedIn<http://il.linkedin.com/in/lisaseeman/>, Twitter<
>> https://twitter.com/SeemanLisa>
>>
>>
>>
>>
>> ---- On Mon, 06 Feb 2017 21:55:36 +0200 Thaddeus .<
>> inclusivethinking@gmail.com<mailto:inclusivethinking@gmail.com><mailto:
>> inclusivethinking@gmail.com<mailto:inclusivethinking@gmail.com>>> wrote
>> ----
>>
>> I vote 3
>>
>> On Feb 6, 2017 11:08 AM, "lisa.seeman" <lisa.seeman@zoho.com<mailto:l
>> isa.seeman@zoho.com><mailto:lisa.seeman@zoho.com<mailto:lisa
>> .seeman@zoho.com>>> wrote:
>> We had issues with reading level , for example the word "mode" is a lower
>> reading level than "hot or cold" . the lower reading level is much harder
>> to understand.
>> The reason to go with Jeanne's proposal is because wcag _might_ find it
>> more testable. This would only be, in my opinion, because they have not
>> bothered read the whole proposal and testability section  (or they do not
>> want new tools) Also i am not sure it is more testable in different
>> languages and that is essential for WCAG. Wordlists requiremnts however,
>> can work easily in any language and wordlists can be automatically
>> generated by parsing a few sites.
>>
>> I agree that the "unless..."  clause is only human testable but that it
>> very typical for wcag.
>>
>>
>> I want to suggest three options
>>
>> 1 -  we retract our current pull requests and put these in instead
>>
>> 2 - we go with the current pull requests. If they fail and the comments
>> are hard to address then we go with Jeanne's
>>
>> 3 -we go with the current pull requests. we can revisit this if needed
>>
>> My vote is 3, to go with the current wording and see what happens
>>
>>
>> All the best
>>
>> Lisa Seeman
>>
>> LinkedIn<http://il.linkedin.com/in/lisaseeman/>, Twitter<
>> https://twitter.com/SeemanLisa>
>>
>>
>>
>>
>> ---- On Mon, 06 Feb 2017 20:00:24 +0200 Jeanne Spellman<
>> jspellman@spellmanconsulting.com<mailto:jspellman@spellmanconsulting.com
>> ><mailto:jspellman@spellmanconsulting.com<mailto:jspellman@
>> spellmanconsulting.com>>> wrote ----
>>
>> A group of us at The Paciello Group (TPG) have been meeting every week in
>> January to comment on the WCAG 2.1 proposals.  Because we test WCAG 2.0 all
>> day, every (business) day, we have a lot of experience with both the
>> language of WCAG and the testing of WCAG.  What we decided this week is
>> that we want to focus our efforts toward helping COGA TF draft success
>> criteria that will get into WCAG 2.1 and will accomplish most of what you
>> want -- even if it is phrased differently.
>>
>> We started with the proposals that we thought would be the least
>> controversial to the WCAG WG to include.  I looked at the Plain Language
>> proposals and did my best to look at the needs identified by COGA TF, and
>> craft language that I thought would be acceptable to the WCAG WG and be
>> included in the first draft version of WCAG 2.1.
>>
>> The wording is quite different, but in my opinion, addresses the needs
>> identified.  I chose reading level, because it is internationally
>> standardized, and there are automated tests already available.  When I look
>> at Technique  G153: Making the text easier to read
>> https://www.w3.org/TR/WCAG20-TECHS/G153.html , it covers most of the
>> items that the COGA TF identified.
>>
>> Issue 30 Proposal:
>>
>> Understandable Labels:  Navigation elements and form labels do not
>> require reading ability greater than primary education level.  (A)  [link
>> to WCAG’s definition of primary education level from UNESCO standard]
>>
>>
>> Issue 41:
>>
>> Understandable Instructions:  Headings, error messages and instructions
>> for completing tasks do not require reading ability greater than lower
>> secondary education level.  (AA)  [link to WCAG’s definition of lower
>> secondary level from UNESCO standard]
>>
>>
>> Delta 3.1.5 (rewrite of existing WCAG 3.1.5)
>>
>> Understandable Content: Blocks of text either:  (AAA)
>>
>> ·        have a reading level no more advanced than lower secondary
>> education, or
>>
>> ·        a version is provided that does not require reading ability more
>> advanced than lower secondary education. [links to WCAG’s definitions of
>> lower secondary education and blocks of text]
>>
>>
>>
>>
>>
>>
>>
>>
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>> --
>> John Foliot
>> Principal Accessibility Strategist
>> Deque Systems Inc.
>> john.foliot@deque.com<mailto:john.foliot@deque.com>
>>
>> Advancing the mission of digital accessibility and inclusion
>>
>>
>>
>>
>> --
>> John Foliot
>> Principal Accessibility Strategist
>> Deque Systems Inc.
>> <john.foliot@deque.com>john.foliot@deque.com
>>
>> Advancing the mission of digital accessibility and inclusion
>>
>>
>>
>>
>


-- 
John Foliot
Principal Accessibility Strategist
Deque Systems Inc.
john.foliot@deque.com

Advancing the mission of digital accessibility and inclusion