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Re: Call for Review: Working Draft of Web Content Accessibility Guidelines 2.0

From: Christian Buehler <cb@ftb-volmarstein.de>
Date: Mon, 04 Aug 2003 13:07:44 +0200
Message-ID: <3F2E3E80.96BA18C6@FTB-Volmarstein.de>
To: public-comments-wcag20@w3.org
Cc: Judy Brewer <Jbrewer@w3.org>

Dear WAI WCAG members,

thank you for the work and enthusiasm you put into WCAG 2.0. After
following the development of WCAG 2.0
for some time, we want to comment on the current version (June 24 2003).
Our comments are based on the
experience with WCAG 1.0 and the German decree BITV, which basically
requires German federal public
websites to conform with AA. The experience includes advice for
designers, testing of web-sites, feedback and
discussion with disability groups, feed back and discussion with web
designers and federal agencies.

1. The most important request is that a smooth transition form WCAG 1.0
to WCAG 2.0 is possible and
supported by WAI. This is absolutely mandatory, if one does not want to
jeopardise the efforts that
Governments adopt W3C-WAI guidelines, as currently recommended in the
European Union. The current
version represents a major change, which is likely to create big
problems in this respect.

2. The advice promised for the transition of 1.0 to 2.0, needs to be
available, before the WCAG 2.0 can
become an official recommendation. The current checkpoint mapping is not
at all sufficient (contarily, it
highlights very clearly the problems of the transition). The advice
should follow a scheme. I conform with A
or AA, or AAA which are the new additional requirements? Which are the
obsolete 1.0 guidelines and

3. In WCAG it is said that priority 1 removes barriers, which can’t be
overcome, priority 2 removes significant
barriers, etc. What is the case for the types core and extended? Does
core remove all significant barriers?
Any statement planned like in 1.0?

4. Why moving from priorities to types. What is the difference? I would
stick with the concept of priorities.
That would be more consistent with WCAG 1.0.

5. Agree to have only two levels. Please avoid the core + thing. This
makes it very complicated. It is much
easier to deal with 2 clear levels. If you stay with things like core +
etc, you open up the creation of new
standards like “Core+ Germany” (which is defined somehow). If you want
more variety, please go ahead.

6. A very big concern is that WCAG 2.0 in the current format, does not
adequately consider the needs of older
people, people with less computer skills, people who have problems to
understand complex language. You
put most of the very important requirements in this respect under
extended. This is not acceptable. We have
big debates here on how to support the needs of these people, like those
who have sign language as first
language (the need a simple grammar, short sentences, etc.) or the ones
with slight mental problems, who
ask for less terminology, better layouts, clear navigation etc. If WCAG
2.0 does not consider this
appropriately, it will miss the opportunity to turn from a “blindness”
oriented scheme to a (dis)ability
oriented one.

7. Your checkpoint 1.6 is extended: Why? Many people with visual
impairment benefit form good colour
contrast. And the ordinary user, will not be able to do all settings
her- or himself to get a good colour
contrast. So this should be core.

8. Similar 2.4 needs to get on core level (see 6.) Maybe the success
criteria need to be changed then.

9. Similar 3.3  and 3.4 are clearly core requirements (see 6). (What
about the need of content, one can perceive
but never understand!)

10 If you kill 4.3, what happens to accessible scripts or alternatives
to scripts then? No recommendations on this
at all?


The WCAG 1.0 was at the time rather strict and provided many very clear
recommendations, for example old 2.1
(information conveyed with colour should be available without colour).
Now this is included in 1.3 separation of
info/ structure/ presentation. Well, it is basically there, but it needs
to be supported by success criteria, which is
not in the current version.(It is not sufficient to put it down to
technical docs. It needs to be part of WCAG 2.0)

Every WCAG 1.0 guideline and checkpoint need to be visited to make sure
that if it is still valid, it has found
appropriate entrance to WCAG 2.0.

If I go to the Mapping list, I really wonder why so many important WCAG
Priority 2 issues have put to the type
extended. Also the level of aggregation of criteria in one single
headline seems not very helpful in the end. (In
the beginning it reads much easier, but one needs to go to the details
for the practical case.)

When I read the draft WCAG 2.0 a year ago, I thought it was on a good
way. Today, I have much more
reservations. In a country, which uses WCAG 1.0 as a baseline for its
legislation, I forsee big problems, if this
WCAG 2.0 will replace 1.0. I recommend to take the time to produce a
WCAG 2.0, which considers
appropriately all disability groups and allows a smooth transition from
1.0 to the new one. If that is not done
properly, WCAG 2.0 will be not meet the target.

Maybe weI misunderstood some concepts. If so we would be glad to learn.
Otherwise, our criticism was formulated very frankly, in order to be as
clear as possible and to support the process as much as possible.

Best regards

Christian Buehler
Received on Monday, 4 August 2003 07:26:20 UTC

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