- From: Greg Lowney <gcl-0039@access-research.org>
- Date: Fri, 21 Nov 2003 07:40:36 -0800
- To: <public-comments-wcag20@w3.org>
- Message-ID: <002401c3b045$d1b2e4e0$8ccdfea9@lucky13>
Hello, Here are some comments and suggestions based on WCAG 2.0 Draft 2003-10-08. I've included them inline below, and also as attached Word and Text documents. I apologize for these being so late and so voluminous; I leave the method of whether or how you want to handle them to your discretion. I'm more than happy to clarify or discuss them. Thanks, Greg Lowney Lowney Access Research, LLC Greg Lowney's Comments on WCAG 2.0 Draft of 2003-10-08 Notes: 1. this document is structured with the first level of numbered items (numbered 1, 2, etc.) identifying the context of my specific comments/suggestions (numbered 1.a, 1.b, etc.). 2. Most of these comments are based on the draft of 2003-09-30, but later ones are based on the draft of 2003-10-08. 3. Much of this was entered using voice dictation so please excuse any errors that were caused by misrecognition. 1. Some thoughts on reorganization proposal five, dated October 8, 2003. 1.a. [COMMENT] Overall I'm very pleased with the reorganization proposal. I like the move to principles and guidelines. 1.b. [MEDIUM PRIORITY] I would like to see the guidelines phrased using prescriptive wording like that used for the principles; for example, changing "Synchronized media equivalents are provided for time-dependent presentations" to "Provide synchronized media equivalents for time-dependent presentations." I believe that wording is more in keeping with their designation as "guidelines". 1.c. [COMMENT] Personally I am not thrilled with the terms used for Single-A, Double-A, and Triple-A designations. I wish I had a better proposal. If we were just English I would consider using A, B, and C, but I doubt that type of thing would be cross culturally applicable. Another option would be core, expanded, and expanded +. I wish that the terms would sort in ascending order, which would be true of "A", "AA", and "AAA". Are Single-A, Double-A, and Triple-A cross-culturally meaningful expressions? 1.d. [MEDIUM PRIORITY] I suggest changing the numbering scheme so that all of the Criteria for a Guideline are sequentially numbered. For example, under Principle 3 is Guideline 3.3, and under that we have three separate Criteria numbered "1", one each in the subcategories of Single-A, Double-A, and Triple-A. (In fact, the first item numbered "1" isn't a Criterion at all, just a placeholder saying that there aren't any criteria in this category!) I suggest instead the first criteria (which is under the Double-A heading) be numbered 3.3.1, and the second (which is under the Triple-A heading) be numbered 3.3.2. The placeholder under the Single-A heading should not be numbered. This would make it MUCH easier to refer to a specific criteria: you could say "3.3.2" instead of "Triple-A Criterion 1 in section 3.3". Another viable approach, although more cumbersome, would be "3.3.A.1" and "3.3.AA.1", or perhaps "3.3.A1" and "3.3.AA1". 1.e. [COMMENT] There are still comments in the document that refer to "Extended Checkpoints"; is that concept gone now that we have Single-A, etc., designations? I hope that we will not move any principles or guidelines to a separate document just because they lack Single-A guidelines. 1.f. [QUESTION] What became of the section on conformance claims? 1.g. [MEDIUM PRIORITY]You should clarify for the reader whether the examples given are designed to be "recommended" solutions or whether they are just one of many possible solutions. (Note that some, such as example one under Checkpoint 2.2, is definitely a solution that I would not recommend! It reads "Client-side scripting is used to create blinking text. The user can deactivate the use of scripting in his or her browser or override the use of scripts with a user style sheet.") 1.h. [MEDIUM PRIORITY] I find the format used for examples to be somewhat confusing. A prime example would be Checkpoint 2.2 -- please see my comments there about the phrase "examples of content that requires a response within a timed interval". In addition, I think you would beat much clearer if we replace the list of examples, each of which consists of the name of the problem followed by a solution that is written in the present tense as if the solution had already been implemented, with a "scenario" followed by a list of one or more "possible solutions". Using 2.2 is an example, I would rewrite as follows: Scenario <number>: <title> Problem: <text> Possible solutions: 1. <sample solution 1> 2. <sample solution 2> Two examples of rewriting sample solutions: 1. The web site can provide a user-controlled option which causes the server to offer up web pages to use another form of emphasis rather than blinking. 2. If client-side scripting is used to create blinking text, user can deactivate the use of scripting in his or her user agent, or override the use of scripts with a user style sheet. (However, this approach is not recommend because it will also disable other scripts which may be necessary for use of content.) 2. Principle 1. "Make content perceivable by any user" 2.a. [MEDIUM PRIORITY] I suggest defining "content" here, as well as in the glossary, since it is so key to understanding the principle. For example, does it include UI elements as well as text and graphics? 2.b. [MEDIUM PRIORITY] The distinction between UI elements and other content is somewhat artificial, since in most browsers the user can interact with any text or graphics (for example, select and copy text, click on text or graphics that is also a link, etc.). 3. Guideline 1.1 "All non-text content that can be expressed in words" 3.a. [HIGH PRIORITY] I still have reservations about the concept of non-text content that cannot be expressed in words. To me, almost anything can be expressed in words, even a piece of artwork or musical piece. For example, I believe that I could describe a painting in terms that would satisfy most blind or not physically present listeners (although not art students who are looking for a level of detail beyond the superficial) and I could do it in fewer words than would be required to convey all the information found in a large work and complex table. I even her story on NPR recently about how some symphony orchestras are providing real-time, synchronized text descriptions of the music as it is being played, in order to help their patrons appreciate the subtleties of what they're hearing. Isn't that a textual description of a piece of classical music? 4. Guideline 1.1 Benefits of Checkpoint 1.1 4.a. [LOW PRIORITY] I believe there are quite a few benefits to Checkpoint 1.1 which are not currently listed. Some of these are mainstream advantages, rather than being particular to people with disabilities; I believe it is useful to list these because it strengthens our case, although it is probably good to distinguish them from the accessibility advantages. Some examples include: 4.a.1. Transcripts, and certain types of captions, allow users to absorb the information at their own pace rather than being forced to try to keep up with a synchronized presentation. 4.a.2. Textual descriptions can be translated into other natural languages for users who are not fluent in the content's original language. 4.a.3. Textual equivalents can be presented in the user's choice of visual attributes and layout, which is usually not true of non-textual content. 4.a.4. Textual equivalents facilitate reusing the information in the web content by allowing the information to be extracted and in many cases parsed, understood, and altered by automated systems. 4.a.5. Textual equivalents and facilitate navigation within content, such as when the user specifies that they want to go to a certain phrase and that phrase is found in the textual equivalent of a piece of content (such as ALT text). 4.a.6. Users can request that they are user agent will download the textual equivalents of non-text content in order to download more quickly over low bandwidth connections. 4.a.7. Textual equivalents are needed by user agents for do not support non-textual content, including those on some handheld devices. 4.a.8. Visual descriptions are often necessary to allow a person with disabilities up to communicate effectively with people who are using the default visual presentation. 5. Guideline 1.1 "Example 1: an image used as a button. (short description of function)" 5.a. [HIGH PRIORITY] I believe is important to provide a textual description of the appearance of an image used to represent a button in order to allow effective communication between a person using the textual description and a person using the visual presentation. For example, it poses a significant problem when a person who is blind tells a coworker to click on the "delete button" when the sighted user sees a picture of a garbage can-and vice versa. 6. Guideline 1.1 'The text equivalent is "Next Slide," so that what is read by a screen reader would be "link: Next Slide."' 6.a. [LOW PRIORITY] We should not imply that all screen readers read the same, so I recommend changing this slightly to say "so that a screen reader might read". 7. Guideline 1.1 "A link to a text transcript is provided immediately after the clip." 7.a. [MEDIUM PRIORITY] When supported by the content format, metadata should be provided for the non-textual content that provides a link to the textual description. This should allow a user agent to request and present to the user the textual description of the non-textual content without requiring the user to hunt around for a corresponding link, and it would also avoid having extraneous links clutter the presentation for users who do not require them. 8. Guideline 1.2 "an audio description is provided" 8.a. [MEDIUM PRIORITY] Is an audio description alone sufficient? It doesn't help a person who is deaf-blind, who would instead benefit from having a textual description of the visuals, which in turn could be reformatted into Braille or presented on a Braille display. If you decide not to require textual descriptions for any checkpoints, then I recommend at least making and explaining the explicit decision to do so. 9. Guideline 1.2 "if content is rebroadcast from another medium or resource that complies to broadcast requirements for accessibility (independent of these guidelines), the rebroadcast satisfies the checkpoint if it complies with the other guidelines" 9.a. [HIGH PRIORITY] I'm not sure I understand this exception. Take the example of a news broadcast on television which is provided with closed captions when broadcast live; if the live broadcast complies with accessibility guidelines for live broadcasts, that would seem to invoke this exception and thus mean that the web site where the broadcast is available for later viewing is not required to provide any captioning. Is that your intention? Is the implication that Checkpoint 1.1 would still be required, and be satisfied by providing static rather than synchronized transcripts? I do not understand why the requirement should be higher for a multimedia presentation which is only on the web site that it is for something that is now owned on the web site but at one time was available somewhere else. 10. Guideline 1.3 "Information, functionality, and structure are separable from presentation." 10.a. [HIGH PRIORITY] The wording of this guideline seems too vague, and it's hard even for me to see how the actual checkpoints under this guideline relate to the guideline's title. I also believe that those checkpoints fall into two distinct groups that are so different that it would make more sense to separate them into two separate guidelines: "Content, structure, and formatting are available programmatically" and "Give user control over presentation of content, structure, and formatting". 11. Guideline 1.3 "the following can be derived programmatically (i.e. through a markup or data model that is assistive technology compatible)" 11.a. [HIGH PRIORITY] I would modify this to say that structural elements must be distinguished by standard structural markup or API where such exist; non-standardized (e.g. proprietary, platform- or application-specific) markup or API may also be used and should be used when no standardized markup or API is defined for the content type. This will allow a wider range of user agents to change the presentation of the structural elements in a concerted fashion than would be the case when proprietary markup or API are used. 11.b. [MEDIUM PRIORITY] We probably need to define "assistive technology compatible" if we want this to be measurable. Note that the issue of compatibility with assistant technology is not a simple one. Markup is great if the data format, pipeline, user agent, user agents platform, and assistive technology all support it. Similar restrictions apply to the data model. 12. Guideline 1.3 "the following can be derived programmatically: .any emphasis" 12.a. [LOW PRIORITY] Do we need to define emphasis? Is emphasis any occurrence of a section of text which is formatted differently than the text around it? 12.b. [LOW PRIORITY] Might it be necessary for the user to distinguish between different types of emphasis, which are usually indicated by different fonts or formatting (as when an author uses underscoring to mean something different than bolding)? 12.c. [MEDIUM PRIORITY] Isn't it also important for the user to be able to find out about the visual formatting of the text (as distinct from its semantic formatting) in order to communicate about the text with people hoary using the normal visual formatting? 12.d. [LOW PRIORITY] Are drop caps an example of formatting or of emphasis? Offhand I think they're probably used most often in a purely decorative fashion, but they probably do convey to the visual reader the fact that they are starting a new section of the text, and in some cases they may be used with a more explicit meaning, such as introducing a section dealing with that emphasized letter. 13. Guideline 1.3 Checkpoint 3 "Text content is not presented over a background image or pattern OR the text is easily readable when the page is viewed in black and white (no grayscale)." 13.a. I think this belongs under 1.6 "Foreground content is easily differentiable from background for visual default presentations" rather than under 1.3. 14. Guideline 1.3 "The markup that creates the columns is separate from the markup that specifies the logical structure of the document." 14.a. [MEDIUM PRIORITY] I recommend clarifying the meaning of "separate from." By this phrase, do you mean to require that the two categories of markup be distinguishable, or that they actually have to be physically separate? If separate, must they be in separate files or can they be in separate sections of the same file? Personally I believe they should only be distinguishable from each other. 15. Guideline 1.3 "Example 2: a scrolling list of stock prices. Current stock quotes are scrolled horizontally across the screen. The data are separate from the methods used to scroll the text across the page." 15.a. [MEDIUM PRIORITY] So what is the recommended solution in this case? It is not obvious, given that the server probably does not have all the quotes at any one time, nor does it necessarily retain values after they are displayed. 16. Guideline 1.4 "All text can be decoded into words represented in Unicode" 16.a. [LOW PRIORITY] You should include Unicode in the glossary and provide a reference to the official specification. 17. Guideline 1.4 "Abbreviations and acronyms are clearly identified each time they occur if they collide with a word in the standard language that would also logically appear in the same case (e.g. all caps)." 17.a. [MEDIUM PRIORITY] The draft includes a pointer to an online discussion wherein Ben Caldwell suggests that abbreviations and acronyms need only be marked up as such in the first occurrence with a document. That makes some sense, but I see two problems with the proposal: first, that this would place the burden on user agents to keep track of all the acronyms and abbreviations encountered a document, which probably none of them today and which might be difficult on platforms with very small memory allocations; second, that the definition of "within a document" might be problematic in a large number of cases, particularly where multiple pieces of content are pulled from a database and assembled. Is a document a single web page or is it a section of web page for a web site? One additional danger is that marking up the term only the first occurrence will leave the term out of sections of the document that are copied for storage or pasting into another document. I recommend that all occurrences be marked up, but I'd also recommend that authoring tools automate this process as much as possible (e.g. applying acronym markup to all occurrences of the term). 18. Guideline 1.4 "Example 2: an acronym in a page title. In the following heading, "People of the W3C." the acronym 'W3C' is marked as an acronym" 18.a. [LOW PRIORITY] Actually in this document in this example the term is not marked as an acronym. I suggest you to be marked up properly in this file or else the wording be changed to "the acronym... should be marked as an acronym." 19. Guideline 1.5 "Structure has been made perceivable through presentation" 19.a. [HIGH PRIORITY] I consider user control to be more important than having the default presentation distinguish between these elements either visually or audibly. I guess that's covered by section 1.3, which requires structure to be programmatically determinable, which in turn should allow UA to adjust the presentation. However, for a document to be accessible it requires that for all content types used there be an available UA (or plug-in, etc.) that displays that content type and meets UA accessibility guidelines. Do we already say that anywhere? 19.b. [MEDIUM PRIORITY] I would move "users can control the presentation of structural elements or the emphasis on the structure can be varied through alternate presentation formats" up to requirement (Level 1 Success Criterion), with an added caveat like ", if supported by the technology". 20. Guideline 1.5 "for visual presentations, font variations, styles, size and white space can be used to emphasize structure.color and graphics can be used to emphasize structure." 20.a. [LOW PRIORITY] These two bullet items both list things that can be done to visually emphasize structure; why are they not combined into a single bullet item? 21. Guideline 1.5 "if content is targeted for a specific user group and the presentation of the structured content is not salient enough to meet the needs of your audience, additional graphics, colors, sounds, and other aspects of presentation can be used to emphasize the structure" 21.a. [LOW PRIORITY] I cannot figure out what this bullet item is supposed to convey. Why is this limited to documents targeted at specific user groups? 22. Guideline 1.5 "Subtle differences between the appearance of the chapter title and the section headings helps the user understand the hierarchy and relationship between the title and headings" 22.a. [MEDIUM PRIORITY] I disapprove of recommending subtle differences; I know from personal experience that I am often confused by standard technical publications (such as Microsoft's printed manuals) where a very slight difference in font size is all that distinguishes different levels of headings. That may be fine when you see the different styles together on the same page and so can see that one is larger than the other, but when you only see one it is very difficult to be sure whether it is a sub header or a peer to a header that occurred on an earlier page. Ideally the visual presentation should tell you what you need to know about the structure without having to get out a ruler. 23. Guideline 1.6 "Foreground content is easily distinguishable from background.default presentations" 23.a. [HIGH PRIORITY] I consider the user's ability to adjust the presentation to be much more important than the details of the default presentation. Therefore I recommend we also include a recommendation or requirement that the user be able to omit backgrounds that overlap text or information-bearing graphics. 23.b. [MEDIUM PRIORITY] I believe that the guidelines are lumping together two separate issues involving the distinction between foreground and background content: 23.b.1. First, there is the distinction between content that is important (because it carries information) and that which is purely decorative (meaning it carries no information). It would be useful to let users reduce visual clutter and distraction by choosing to hide or de-emphasize purely decorative content. 23.b.2. Second, it can be difficult to interpret a presentation where two pieces of content overlap each other, either visually or audibly. To address that, we should say that the presentation should either not overlap pieces of content or it should provide the user with the ability to forces pieces to not overlap. The latter can be accomplished either by rearranging the pieces or by hiding pieces that are purely decorative (that is, pieces which do not convey any information). 23.c. Is it possible to replace this distinction between "foreground" and "background" with one of useful vs. purely decorative content, such as saying that the user should be able to hide all purely decorative content? Or, if you're really only talking about background harming the legibility of foreground content, then maybe a more general thing about making sure that background does not overlap foreground, or can be hidden. After all, distinguishing one from another does not necessarily imply that the foreground is legible. 24. Guideline 1.6 "text that is presented over a background color or grayscale has a mechanism that allows the text to be presented in a fashion." 24.a. [MEDIUM PRIORITY] The wording of the Guideline is at odds with the wording of this Success Criterion: the Guideline says it's addressing "default presentation" but the Success Criterion discusses providing a mechanism that lets the user choose a non-default presentation option. Therefore you might want to remove the word "default" from the Guideline title. 25. Guideline 1.6 "Groups of rows or columns are labeled with headers." 25.a. [MEDIUM PRIORITY] Add that headers should be visually distinct from content cells. 26. Guideline 1.6 "[use].a different, more formal voice to read titles and headers so the listener can easily identify the words as a title and not part of the running text" 26.a. [LOW PRIORITY] You might also want to mention that can be useful to pause before voicing headers. 27. Guideline 1.6 "text that is presented over a background color or grayscale" 27.a. [HIGH PRIORITY] I would rephrase this to "text that is presented over a nonblank background" or something similar that would include background images and patterns as well as background colors and grayscale. 28. Guideline 1.7 "Example 1: a background image on a page." 28.a. [MEDIUM PRIORITY] This example is applicable to 1.6, so it should be deleted from 1.7. 29. Guideline 1.7 "Where speech is mixed or recorded so that it is at least 20 db above any background sounds people do not need to rely on captions to understand the dialog." 29.a. [LOW PRIORITY] Minor, but I'd qualify this as ".MOST people do not need." since some people clearly do still need to rely on captions to understand the dialogue. 30. Principle 2 "All functionality is operable at a minimum through a keyboard or a keyboard interface" and "Example 2: examples of Web content that would and would not be operable from a keyboard or keyboard interface" 30.a. [HIGH PRIORITY] I just want to make sure that I'm clear on this: according to my interpretation of this guideline and its checkpoints, it seems that ALL Java applets would comply with this guideline because they can be run on platforms that support the MouseKeys feature. That is, the guidelines do not seem to require that the product to be easily used with a keyboard, or in fact to take any steps that would accommodate keyboard users. Is this your intention? Can you provide any other examples of things that would fail to meet this criterion? (I noticed that an earlier draft of this document noted that the editors were going to try to create some tests that would require more than just MouseKeys to pass.) 31. Guideline 2.1 "where the functionality or its outcome can be expressed in words" 31.a. [LOW PRIORITY] The glossary defines content that can be expressed in words, but not functionality or its outcome that can be expressed in words. Since you use this unusual term, should you explain what it means? 32. Guideline 2.1 "wherever a choice between event handlers is available and supported, the more abstract event is used" 32.a. [MEDIUM PRIORITY] You might want to define "event handlers" in the glossary (and refer to the definition here), and also discuss what makes them more or less abstract. 33. Guideline 2.2 "control any time limits.unless.real time events or competition" 33.a. [LOW PRIORITY] Is competition really different from other "real time events" already mentioned? Oh well, I guess a little redundancy can't hurt and might make things clearer. 33.b. [MEDIUM PRIORITY] You might add a note (either in the glossary or in Guideline 2.2) to the effect that developers should take care to give the user as much control as possible over any interaction that will interrupt the user's task or train of thought. It is usually possible to give the user the option of delaying or suppressing most interactions that are triggered by external, real-time events, such as notice of incoming email or the availability of updated content. 34. Guideline 2.2 "content is designed so that time limits are not an essential part of interaction or at least one of the following is true for each time limit" 34.a. [HIGH PRIORITY] I suggest adding another means of complying with this criterion: an alternative method of accomplishing the same goal is provided which meets the above exceptions. 34.b. [HIGH PRIORITY] I suggest adding another means of complying with this criterion: in a supervised or moderated setting (such as a student taking a computer-based test), the person supervising or moderating the experience is able to deactivate the time limit or adjust the time limit over a wide range which is at least 10 times the average user's preference. 35. Guideline 2.2 "People with physical disabilities might not be able to move quickly or accurately enough to interact with moving objects" 35.a. [LOW PRIORITY] I would add ".or may take longer than usual to interact with the UI elements." 36. Guideline 2.2 "Examples of content that requires comprehension or a response within a timed interval" 36.a. [MEDIUM PRIORITY] I suggest rewarding this slightly to make it clear that the things listed are not things which are granted an exemption but rather are things that require modification in order to comply with Checkpoint 2.2. 37. Guideline 2.2 "Client-side scripting is used to create blinking text. The user can deactivate the use of scripting in his or her browser or override the use of scripts with a user style sheet." 37.a. [HIGH PRIORITY] I really dislike this recommended solution because it's using a sledgehammer to pound in a nail: deactivating all scripts would have a lot of and potentially very harmful effects on the user's ability to carry out their work. A far better solution would be one that is very specific to this problem: the site should provide an option that would let the user disable the blinking text while still leaving other, more benign formatting intact. 38. Guideline 2.3 "user can avoid experiencing screen flicker" 38.a. [MEDIUM PRIORITY] It seems that screen flicker could be limited by the User Agent, which would be a more reliable approach because it would protect the user from badly designed web content. 38.b. [MEDIUM PRIORITY] I seem to recall a discussion of whether a web page (or equivalent) the displays multiple items, each updating slower than three hertz but all visible simultaneously can equal the effect of having one element which updates more frequently than three hertz. Is that true? Is that something we should warn against? 39. Guideline 2.3 "content was not designed to flicker (or flash) in the range of 3 to 49 Hz" 39.a. [MEDIUM PRIORITY] I think you would be more accurate to recommend that "content was designed not to flicker..." (rather than "content was not designed to flicker."); that is, the current wording would seem to be met by any web page which flickers inadvertently rather than by design. Or were you intentionally trying to say that the requirement is merely that it not intentionally flicker, and that avoiding inadvertent flickering is only a best practice? 39.b. [MEDIUM PRIORITY] Might the actual flicker rate very depending on the hardware and software platform? It seems like a web page which does not visibly flicker when displayed on a fast PC might visibly flicker when displayed on a very slow PC. Should we address this? Should we specify something like what platforms need to be tested to verify that is not flickering unacceptably? 40. Guideline 2.3 "Individuals who are easily distracted may not be able to focus on page content with flicker occurring in the same visual field" 40.a. [HIGH PRIORITY] Isn't it also true that these individuals will probably be just as distracted by pieces of content updating within their visual field, even if the updating is not at a rate which is considered flicker? Should we address this by saying, in essence, that the user should be able to disable any animations or automatic updates? The more inclusive recommendation seems much more useful. 41. Guideline 2.4 "Mechanisms have been added to facilitate orientation and movement in content" 41.a. [LOW PRIORITY] I think the word "added" should be changed to "included", making the sentence "Mechanisms have been included that facilitate orientation and movement in content". The reason is that "added" makes it sound like something that is only done for accessibility reasons, as an afterthought or extra action. 42. Guideline 2.4 "a user is able to move through the content in an order that follows the visual layout or follows the order the page is read." (This is the proposed new wording, per the BBS posting.) 42.a. [HIGH PRIORITY] What do you mean by "move through the content"? Simply scroll? Or are you requiring the UA to have the equivalent of a cursor that the user can position within the content? What content would fail this checkpoint? If the user agent is able to figure out the spatial locations of all elements in the document as they are visually presented (e.g. a Web browser knows where it is displaying each element of the HTML) it can choose whatever order it feels is appropriate, including making a best guess at the order the user might read it in. Is that sufficient? What does the content have to do to facilitate this? It is not always advantageous to follow the visual layout: users of screen readers, for example, would usually like to skip the navigation links and get right to the page-specific content. Since the new guideline does not address this need, what exactly is its goal? Maybe what we're getting at is more like: the UA must be able to recognize structural elements identifying and naming blocks of content that are essentially the same between pages or documents within the document set, thus allowing the UA to provide the user with the option of skipping over those sections. (See my note below about the glossary entry for Structure.) Of course, we should also require that at least one UA be available that actually offers this feature, or else we leave a loophole of almost infinite size. Also, of course, we'd need to push to get such markup added to HTML and other standard document formats. 43. Guideline 2.4, under Benefits, "When the logical structure is provided in markup or a data model.the content can be presented on a variety of devices because the device software can choose only those elements of the content that it is able to display and display them in the most effective way for that device." 43.a. [LOW PRIORITY] This is clearly not related to structural markup, but rather to markup describing data types. It could be rewritten to discuss structural markup by saying ".the content can be presented on a variety of devices, including those with serial presentation (such as voice output) and those with small visual presentations, because the UA can allow the user to choose to present only selected sections or choose the order in which they are presented. 44. Guideline 2.5 "The CKW proposal suggested that this success criterion be combined with one of the (now AAA) items and that another best practice item be moved up." 44.a. [COMMENT] I like the proposed rewrite of this guideline. 45. Guideline 2.5, Benefits, "Individuals with speech disabilities might not be recognized properly in voice input applications" 45.a. [LOW PRIORITY] This is funny: anyone's speech can be misrecognized (and often is!). I suggest that, if you keep this, you rewrite it as "Individuals with disabilities affecting their speech or manual dexterity will often have a higher error rate when communicating with speech or handwriting recognition, or typing, and therefore benefit proportionately more from features that assist in recognizing and correcting input errors." 46. Guideline 2.5 "Example." 46.a. [LOW PRIORITY] I suggest adding another example, that when providing a form for submitting feedback, the form UI include an optional spell-checking feature. 47. Principle 3 "Content and controls" 47.a. [MEDIUM PRIORITY] Are "controls" the same as "Interface Elements" mentioned elsewhere? Should we use consistent terminology? 48. Guideline 3.1 "document attributes identify the natural language of the document." 48.a. [LOW PRIORITY] I agree that we need the requirements to effectively guarantee that all content can be identified by its natural language (and, if applicable, character set), but I don't like the phrasing of this nor the artificial distinction between the two Requirements. Not all formats allow the document to be categorized by language, so I propose combining the two Single-A checkpoints into something like "it must be possible to unambiguously and programmatically identify the natural language and character set of all textual content in the document." In explanation it can say that the primary language of the document can be specified as attributes of the document itself and/or using markup within the document (such as using tags to the entire body of the document), and that any passages of text within the document whose language or character set differ from that around them must be demarcated and identified. 49. Guideline 3.1 "Example 1: a French phrase in an English sentence" 49.a. [LOW PRIORITY] I don't think you should say "In the following sentence.is marked as French" when it is not actually marked that way in the guidelines document. Instead you should say "In the following sentence.should be marked as French". 50. Guideline 3.2 "The definition of abbreviations and acronyms can be unambiguously determined" 50.a. [COMMENT] This is a very interesting topic! Some questions worth thinking about include: (1) Is it that much more important to provide definitions of acronyms than, say, names, or words that are usually omitted from abridged dictionaries? (2) I agree that someday there should exist a way to link from a word in a document to an unambiguous definition-think how much easier that would make automatic cross-language translation! 50.b. [LOW PRIORITY] Does this also apply to abbreviations that use punctuation rather than letters? For example, the double-quote character (") is sometimes used for quoting, but sometimes it serves as an abbreviation for "inches" (a unit of measurement for linear distance) or "seconds" (a unit of measurement for arc). Similarly, the symbol #, commonly referred to in the U.S. as a "pound sign", may be used for "pounds" (a unit of measurement for weight) or as an abbreviation for the word "number" (ordinal counting). As far as I know, HTML allows marking up non-characters this way, but I never see sites do so. Should we recommend this? How about cases where punctuation is itself ambiguous, such as distinguishing the period in "3.4" from the identical character used to indicate the end of a sentence, or the end of an abbreviation? It would be nice to address this someday, although probably not needed right now. 50.c. [MEDIUM PRIORITY] Do we have to make exceptions for media types that don't really allow links or markup like this, such as an audio recording of a speech? 51. Guideline 3.2 "acronyms and abbreviations do not appear first in standard unabridged dictionaries" 51.a. [LOW PRIORITY] I doubt that the standard dictionaries for English are 100% consistent on the order they list possible meanings of acronyms and abbreviations. Does that matter? Probably not, but should acknowledge it? 52. Guideline 3.2 "a list is provided on the page or home page of URIs to cascading dictionaries that can or should be used to define abbreviations or acronyms" 52.a. [MEDIUM PRIORITY] Is there a standard for such "cascading dictionaries"? If so, we should reference it; if not, then is this meaningful? 52.b. [MEDIUM PRIORITY] Putting something on the home page doesn't help with documents that get copied around, or converted to another medium, etc. Therefore it is preferable to have such links in every document. 52.c. [LOW PRIORITY] The current wording seems a bit HTML-centric, talking about the page and so forth. 53. Guideline 3.2 "provide a definition or link (with the first occurrence) of phrases" 53.a. [MEDIUM PRIORITY] As mentioned in another comment, putting an annotation on the first occurrence requires defining first occurrence-is it first in a document, section, page, etc.?-and also means that copying a selection may not include the annotation. This could be addressed by providing the annotation on every occurrence, and leaving it to the UA to hide redundant occurrences if the user so chooses. 53.b. [LOW PRIORITY] Should that be first occurrence other than in headings, or first including headings? Often books indicate trademark on the first occurrence in normal text. 54. Guideline 3.2 "if contracted forms of words are used such that they are ambiguous, provide semantic markup to make words unique and interpretable" 54.a. [LOW PRIORITY] This guideline is not clear to me. What are examples of ambiguous contracted words? 54.b. [COMMENT] If we're going to require markup to disambiguate contractions, why not non-contracted words that have ambiguous meanings? Other than the fact that it'd be a lot of work to comply, that is. 55. Guideline 3.3 "the content has been reviewed, taking into account the following strategies for evaluating the complexity of the content, applying them as appropriate" 55.a. [MEDIUM PRIORITY] I don't think this should be a requirement because it is neither measurable (since you have to take their word for it that they reviewed it) nor provably beneficial (because they are not required to actually make changes based on the findings of the review). In addition, I doubt there are widely accepted measurements of complexity that cover all of these points. Therefore I think it has to be relegated to a recommendation. 55.b. [LOW PRIORITY] 1.e should be broadened to recommend "accuracy and uniqueness of page and section titles" rather than just page titles. 56. Guideline 3.3 "Example 2: a concrete concept. The primary concept on a page is concrete." 56.a. [LOW PRIORITY] This doesn't really say anything. In fact, it could be taken as saying that the document discusses concrete (the material). I hope that all examples will be concrete (specific). This describes a document that does lots of things, but the Example doesn't make clear which things are key, or why they are being done. A negative example would help, for contrast. See my suggestions elsewhere for reformatting Examples to be clearer. 57. Guideline 3.3 "Example 4: child's report of school trip" 57.a. [MEDIUM PRIORITY] This example, as several others, describes a scenario without making clear what aspects of the scenario are key. That makes the example more confusing and less helpful than it would be if it called out the things that are important. See my proposal above about reformatting all examples. 58. Guideline 3.3 "Note: Designers need to be cautious in deciding when to use illustrations." 58.a. [LOW PRIORITY] I think this note should be revised or removed, because it could be interpreted as recommending against using any illustrations, which would either lead to less usable web content or to designers deciding that the guidelines are unreasonable and discounting them altogether. I think that what you're trying to say-with complete validity-is that designers should avoid conveying any information solely by illustrations, but that illustrations can also be very helpful for many readers. I don't feel this paragraph makes clear what we are recommending. 59. Guidelines 3.4 "Key orientation and navigational elements (such as navigation bars) are generally found in one or two consistent locations." 59.a. [LOW PRIORITY] I recommend saying something like "(such as navigation bars, page numbers, and section titles)" to avoid giving the impression that we're only referring to things outside the primary content. 60. Guideline 3.4 "when inconsistent of unpredictable responses.the user is warned in advance of encountering them" 60.a. [MEDIUM PRIORITY] I'm not sure what you mean. Can you give an example showing recommended UI for this? Are you suggesting that a game present a warning that what the challenges the user will encounter will vary? Is it enough that the documentation says that every game will be different? 61. Guideline 3.4 "Whenever there are extreme changes in context, one of the following is true." 61.a. [LOW PRIORITY] In-line warnings and options to deactivate are good, but it seems like UA could also handle this in most cases, such as: letting the user adjust whether they want to allow, block, or be asked how to handle pop-ups; notifying the user when a page transition makes significant changes to the page layout; identifying links that will pop up a new window or go to a different site; etc. 62. Guideline 3.4, "pages with similar function should have similar appearance and layout" 62.a. [LOW PRIORITY] But we might note that it's also good for separate sections to be easily distinguishable, which implies not using identical appearance; distinct visual elements such as colors or graphics will help readers orient themselves, keep in mind which section they are in, and avoid mistaking similar pages. 63. Guideline 3.4 "the content has been reviewed, taking into account." 63.a. [MEDIUM PRIORITY] Isn't there some way that this criterion could be made to have some impact or benefit? I'm afraid that, as it is, criteria phrased this way will just be a checkbox that can be checked without anyone doing anything! Perhaps, to have some benefit, the web site could post a review of its usability and rationale for their decisions to avoid making improvements. Something? Anything? 64. Guideline 3.4, Example 3: "frames that do not track history making the back button behave unexpectedly" 64.a. [MEDIUM PRIORITY] This doesn't describe a recommendation; is it simply to avoid frames? (Again, it seems like UA should be able to solve this problem without changes to Web sites.) 65. Guideline 4.1 "Technologies are used according to specification." 65.a. [HIGH PRIORITY] I firmly believe the technology should only be used according to their specification when the specification leads them to be used in an accessible manner. I do not believe you should assume that all specifications when followed exactly will lead to accessible results, and when they do not, the author should follow unofficial guidelines to result in more accessible content. I'm sorry if that doesn't make for a simple, objective guideline. (On the other hand, I also admit that the consistency that comes from everyone following specifications usually has other advantages.) 65.b. [LOW PRIORITY] In the description of benefits, you could add that following specifications (especially for markup and other file formats) is that it allows reformatting, repurposing, and reuse of content, which is especially important to users who can only make full use of the content in a different format. 66. Guideline 4.2 (formerly 4.3) "programmatic user interfaces are accessible or alternative, accessible versions are provided" 66.a. [LOW PRIORITY] Terminology point: I don't think APIs are accessible, but rather APIs support accessibility and are implemented in accessible ways. That is to say, APIs are in fact specifications for the communication method between software components; different platforms (including different versions of the same operating system or operating environment) provide different implementations of the API in the form of specific code or components. An API is accessible if the definition allows or requires the caller to provide all the information and functionality needed to render the end result accessible. I would therefore suggest rephrasing this guideline. 66.b. [MEDIUM PRIORITY] I'm not familiar with the term "programmatic user interfaces"; by that do you mean API that report on the presentation (e.g. enumerate sections of content and give their screen coordinates and names), or API that control the program (e.g. change selection, move focus, activate controls), or both, or something else altogether? This should probably be clarified in the document. 67. Guideline 4.2 "the interface has been tested using a variety of assistive technologies.to determine that those assistive technologies are able to access all information on the page or hidden within the page" 67.a. [MEDIUM PRIORITY] This is very screen-reader specific; I recommend making it more general by saying ".assistive technologies are able to access all content, structure, and formatting information on the page or hidden within the document, and are able to identify and manipulate all user interface elements on the user's behalf." 68. Guideline 4.3, Double-A Checkpoint 1, "the Web resource includes a list of the technologies (other than standard HTML) users must have in order for its content to work as intended. Users who do not have one or more of these technologies can still access and use the resource, though the experience may be degraded." 68.a. [HIGH PRIORITY] I think we need to do more to explain this guideline. What constitutes sufficiently documenting the list of required technologies? For example, when a web page contains an OBJECT element that specifies the technology required, is that sufficient? Or are you saying that the page would have to list those required technologies in human-friendly text in addition to the UA-friendly tags? Does the list of required technologies have to be posted with every link to the document, so that users can view the list before downloading the document? Would you, for example, require every Web page that links to a site's online store have some text indicating that the store requires SSL? Does every link to a PDF document need to identify it as such? 68.b. [LOW PRIORITY] It seems to me that the two sentences in this checkpoint are really making two separate points, and so should be broken into two separate checkpoints. Thus: Checkpoint 1, "The Web resource includes a list of the technologies (other than standard HTML) users must have in order for its content to work as intended", and Checkpoint 2, "Users who do not have one or more of the technologies used by the document can still access and use the resource, though the experience may be degraded." This allows a document to get credit for degrading gracefully even though it might not list required technologies up-front. 68.c. [LOW PRIORITY] You might explicitly note that the first example shows listing required technologies, and the second shows degrading gracefully. 69. Guideline 4.3, Triple-A Checkpoint 1, "a list of technologies and features, support for which is required in order for the content to be operable, has been determined and is documented in metadata and / or a policy statement associated with the content." 69.a. [LOW PRIORITY] How about giving priority to using metadata (which is then computer-usable) by saying ".documented in metadata if such metadata is supported by the file format, otherwise is documented in a policy statement associated with the content." 70. Glossary definition of "Audio Descriptions" 70.a. [MEDIUM PRIORITY] The glossary entry for audio descriptions are redundant to the entry for audio description. 71. Glossary definition of "Feature" 71.a. [MEDIUM PRIORITY] I think we should clarify the word "Feature" has several meanings. The definition currently gives only one definition, but in the WCAG 2.0 document the word is used in a variety of meanings. 72. Glossary definition of "Keyboard Interface": "A keyboard interface is the point where the application accepts any input that would come from the keyboard (or optional keyboard)." 72.a. [LOW PRIORITY] I would change this to read "A keyboard interface is the point where the application accepts any input that would come from a keyboard, optional keyboard, or assistive technology simulating keyboard input." 73. Glossary definition of "Media equivalents" : "Media equivalents present essential audio information visually (captions) and essential video information auditorily (audio descriptions)." 73.a. [MEDIUM PRIORITY] I would include presenting essential audio or visual information in textual form, which would then be usable by people who are deaf-blind and by accessibility aids, as well as supporting mainstream uses such as searching and indexing. 74. Guideline 3.4, Glossary entry for "Mechanisms that cause extreme changes in context" 74.a. [LOW PRIORITY] The two examples, "in an auditory presentation, the speaker changes with no visual cue and no notation in the captions" and "captions that do not identify change in speaker" seem redundant to each other. 75. Glossary definition of "Non-Text Content" 75.a. [MEDIUM PRIORITY] The definition of "non-text content" is currently just a list of examples. A simple way to summarize the definition might be to start with something like "Non-text content is any content that is not displayed for the user as Unicode text." 76. Glossary definition of "Operable" 76.a. [MEDIUM PRIORITY] The definition of "operable" is specific to the context of "operable using a keyboard", but the word really has a broader definition. I suggest (a) keeping the definition, but changing the glossary entry to "Operable using a keyboard," or if that's not acceptable then (b) prefixing the definition with something like "In this document the term 'operable' is used in the context of content being usable through a keyboard or assistive technology that simulates keyboard input." 76.b. [MEDIUM PRIORITY] I have suggested that we might be able to come up with a metric for keyboard usability, which would be something like "The number of keystrokes required to carry out an operation should be no more than five times the number of discrete actions required when a pointing device is available." Discrete actions include keystrokes, mouse movements, and mouse button presses. Worth thinking about. 77. Glossary definition of "Real-Time Events" 77.a. [LOW PRIORITY] I would recommend against defining a phrase by referring to one of its own components, such as defining "Real-time events" as, essentially, events that happen "in real-time"; therefore I would remove the phrase "in real-time" from the definition. In addition, I would supplement "where the events are not under the control of the author" by adding "or the user". How about something like "Real-time events are those whose timing is triggered by outside events and therefore cannot be put under the control of the author or user without compromising their usefulness. For example, a stock ticker or emergency warnings could potentially lose their value if delayed significantly and are therefore real-time events, whereas any direct and immediate reaction to the user's input is not a real-time event." 78. Glossary definition of Site Navigation Mechanism 78.a. [MEDIUM PRIORITY] An additional recommended mechanism would be providing navigation links that allow the user to skip portions of the content which are consistent between documents or sections of the document. This can also be achieved by providing sufficient markup, along with names meaningful to humans, allowing the user to recognize which are recurring and instruct compatible UA over or to those sections. 79. Glossary definition of Structure: "Structure includes both hierarchical structure of the content and non-hierarchical relationships such as cross-references, or the correspondence between header and data cells in a table. The hierarchical structure of content represents changes in context." 79.a. [LOW PRIORITY] I recommend against defining a phrase by referring to one of its components, such as "structure includes both hierarchical structure." Can we phrase this to avoid using the term structure in the definition? How about "Structure includes both hierarchical relationships between elements (such as the division into sections and sub-sections) and non-hierarchical relationships." 79.b. [LOW PRIORITY] In one instance the word "hierarchical" is misspelled as "heirarchical". 79.c. [LOW PRIORITY] Missing space between "in a table." and "The hierarchical". 79.d. [MEDIUM PRIORITY] One of the most important relationships between pieces of content is that which tells the user agent in what order they should be presented. Is this structure or presentation? The most common case is where the presentation order is implied by the order in which the pieces of content are defined in the source file (e.g. HTML) and in most cases this is the default, but it is not always the only order specified. Is there a standard way to specify alternate orders? IF so, would that be in the style sheet, and if so, would it thus be presentation? 79.e. [LOW PRIORITY] Might note that structural markup serves to aid in identification (it identifies a block of content), orientation (allowing the user to tell where they are in relation to various blocks; this can happen at the user's request or automatically as the content is being presented to the user), reference/navigation (allowing the user to refer to a location for any purpose, including asking the user agent to begin acting there), and reformatting (such as allowing the user to hide or skip certain blocks, or alter their presentation). [End of Greg Lowney's Comments on WCAG 2.0 Draft of 2003-10-08]
Received on Friday, 21 November 2003 12:32:05 UTC