Draft Silver Response


Based the discussions we had, I've drafted a strawman response to send to
Silver.  I tried to draw from the minutes and emails I've seen but I've
likely missed or misstated something. I would appreciate your feedback. We
will disucss this briefly at tomorrow's meeting but please send edits to
the group.

Thank you,



To: Silver Taskforce
From: COGA Taskforce
Re: Silver Conformance Models


Thank you for the opportunity to review and comment on the proposed
conformance models. We recognize they are in an early phase at this point
and hope that we can continue to talk with you as they progress. Our
comments at this time are as follows:

   - A very complex scoring system may make it difficult for people with
   cognitive disabilities to use.  These drafts are so complex right now that
   it is difficult to review and provide feedback. Whatever solution is
   suggested, it needs to include plain text alternatives to the formulas and
   complexity to allow for inclusive review and comment.
   - Usability testing with individuals with disabilities is a key need to
   support COGA but there are risks such as difficulty in gaining legislative
   adoption and the possibility teams will intentionally create less usable
   systems to ensure "good" usability test results.  Any model should work to
   reduce these risks while still including usability as an important
   - There is a risk for COGA  in weighting issues by severity as small
   issues can lead to fatigue but individually would not be "severe."  There
   is also a risk in measuring by groups as COGA represents a very diverse set
   of users with overlapping but sometimes distinct user needs. If, for
   example, visual disabilities are broken out into subgroups such as blind,
   low vision, and color blind then COGA should also be broken out into
   distinct such groups such as Dyslexia, Aphasia, Non-verbal - Severe Speech
   and Language impairments, Aging and Dementia,  Down Syndrome, Autism,
   Dyscalculia, Anxiety, and Depression.
   - We also believe that any conformance model should begin with nad map
   to user needs.

Thank you again,

Cognitive and Learning Disabilities Accessibility Task Force

Received on Wednesday, 4 September 2019 17:13:35 UTC