Comments - Technical, WCAG 2.0 draft of June 2003

Technical
1. Consider inserting a section on  development  process: Choice of technology and impact on accessibility.  This section  should talk about   "widely available",  time lag  before assistive tech adopts the technology,availability of AT in natural  language of site,  backword compatibility, etc.  This section may be placed before the guidelines and checkpoints are listed.
2. Rationale of what constitutes core and extended   like WCAG 1.0 has a structure of P1, P2, P3. Need to explain why   some  are core and some are extended, like 
Core checkpoints : if not complied with, one or more user groups may find  it impossible to access content
Extended: these enhance (usability)   or facilitate navigation and  provide more efficient  access to content
3. Under Required  success factors for 2.3: There is a tool that can identify flicker. RAMP from Deque Systems 
(www.deque.com) is the only automated tool that can identify unacceptable flicker   rate  (2 to 55 Hz as per Sec 508) and can  do the 3-49 Hz now proposed.
4. Checkpoint 2.4: [EXTENDED] Structure and/or alternate navigation mechanisms have been added to facilitate orientation and  movement in content. [was 3.1 and 3.2]
Comment: 
i. I believe that the minimum limit of 50000 word   per doc of 50 page site is not needed. Headings for text sections or 
groups of links  etc reveal structure and organization of content.  Absence of these struuctural markups make it inefficient  to navigate a  page with even less than  10k words. So wherever  a hierarchy can be used to reasonably structure  the page  content, this checkpoint is applicable.  The author should use judgment to do so.  I am a screen reader user and on numerous  sites sensed the need for structural markup. 
ii. While there is mention of headings and titles for text sections, I note the absence of linksthat can be grouped and given  headings. Like product links, links for services  offered, links for different contacts etc. Are markup for headings used to group links  outside the scope of this checkpoint?
4. Checkpoint 4.2: Technologies that are relied upon by the content are declared and widely available.[was 5.2]
The "are widely available" part should be dropped. That will influence the decision to adopt a particular technology and is  not under  content  developer's control after the decision is made to go with a technology.
Consequently references to "widely available" in definitions and elsewhere may be deleted.
5. Checkpoint4.3: Technologies used for presentation and user interface support accessibility or alternate versions of the  content are provided that do support accessibility.[was 5.3 and 5.4]
 Reword as:
"Alternate versions of the content that support accessibility are provided  where  technologies used for presentation and  user  interface [do not support accessibility ] or [present barriers to accessibility]
 * * *
Thanks,
Sailesh Panchang
Senior Accessibility Engineer
Deque Systems Inc
11180  Sunrise Valley Drive, 4th Floor, Reston VA 20191
Tel: 703-225-0380 Extension 105
Fax: 703-225-0387
E-mail: sailesh.panchang@deque.com
* Look up <http://www.deque.com> *