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SIDAR's WCAG2-espa group : Comments on Working Draft of WCAG 2.0

From: Jaustral <jaustral@yahoo.es>
Date: Thu, 11 Sep 2003 00:44:05 +0200
Message-ID: <3F5FA935.F16CDCB7@yahoo.es>
To: public-comments-wcag20@w3.org

SIDAR (Seminario Iberoamericano sobre Discapacidad y Accesibilidad en la
Red) is a permanent working group devoted to promote accesibility in new
technologies and web accesibility as its core concern. Its members are
volunteers from all over Latin America, Portugal and Spain are experts
in IT and accessibility. For an extensive introduction please visit

WCAG2-espa is a Spanish translation group focused on WCAG 2.0, formed
when the first working draft was released. We would like to thank the
opportunity the Working Group is offering the web community requesting
comments on their work.

Comments on 06/24/2003 Working Draft of WCAG 2.0:

Comments are organized as follows. First, the part of the text commented
is written, according to the hierarchy expressed in the table of
contents. Then a link to the nearest anchor in the document is given,
and finally the comment to the point is explained. Highlighting is made
placing text in asterisks. 

1)Introduction: How to read this document: Technology-specific 

URL: http://www.w3.org/TR/2003/WD-WCAG20-20030624/#how-to

We'd like to congratulate the working group for approaching the new
version of the guidelines in this way, separating the different layers
that are present in web content production processes. The first one
involves design and is the main concern of these guidelines. The
document acquires a more abstract point of view and detaches from the
final technology used by the user to access the content. However, this
more abstract approach moves the guidelines away from their final
application in web content production. This is the main reason why we
think that the second group of documents, the Technology-specific
Checklists, must strengthen the purpose of the guidelines and therefore
should be normative for each technology. 

That is to say, conformance to these guidelines and conformance to
technology-specific checklists should be bound in a clear and plain way.

2)Introduction: Conformance

URL: http://www.w3.org/TR/2003/WD-WCAG20-20030624/#conformance

With regard to the different levels of comformance, we think that
considering a "Core+" level is a good idea. But we think that the wide
spectrum and subtleties inside this qualification shouldn't be measured
by the number of checkpoints that are met. A more satisfactory way to do
it would be to create several combinations of Extended Checkpoints to
qualify the specific way in which the content cares  about
accessibility. These combinations would give different "flavours" to
"Core+" conformance claim.

As an example, verification of Extended CheckPoints 1.5, 2.4, 
3.4 could qualify "Core+" conformance claim as "usable" as it considers
perception, operability and understandability points that strengthen
usability of the content.

3)Guideline 1: Core Checkpoints: 1.1

URL: http://www.w3.org/TR/2003/WD-WCAG20-20030624/#text-equiv

We think it's a basic conceptual error to use the expression "non-text
content that can be expressed in words". What does it mean? All content
*can* be expressed in words or described in some way. With all our
respect it's like saying "oops sorry,  I remained speachless" in the ALT
attribute of an image. When one reads Required Success Criteria 2. of
this checkpoint, one thinks you are talking about "non-text content that
can not be expressed in *a few* words". So, shoudn't the Checkpoint
read: "1.1 [CORE] All non-text content that can be expressed in a few
words has a text equivalent of the function or information that the
non-text content was intended to convey. [was 1.1]". And Required
Success Criteria 2. should read: "non-text content that can not be
expressed in a few words has a descriptive label provided as its

4)Guideline 1: Core Checkpoints: 1.3: Example 4


Example 4 in this checkpoint should also include a reference to
checkpoint 4.3

5)Guideline 2: Core Checkpoints: 2.1: Definitions: Editorial Note

URL: http://www.w3.org/TR/2003/WD-WCAG20-20030624/#keyboard-operation

Proposed definition for "operable through a keyboard interface": Content
is operable when it is properly designed in a way that all the
information is reachable and all the funcionality is available through
an efficient use of a keyboard interface. An appropriate hierarchical
collection of keyboard shortcuts or a navigation bar situated after each
section strengthens operability. Intensive use of tabbing weakens
operability due to monotony and lack of a clear structure.

6)Guideline 2: Extended Checkpoints: 2.4

URL: http://www.w3.org/TR/2003/WD-WCAG20-20030624/#navigation-mechanisms

Shouldn't this checkpoint be a Core one? Besides, we think the Required
Success Criteria miss the point. We think there shouldn't exist a
trigger length below which unstructured documents are happily welcome.
Allowing structure markup to disappear is a step backwards, since even
in a single document without a table of contents, structural markup such
as lists, paragraphs, etc. give a solid base to understand the relative
weight of different content pieces. 

The way the Checkpoint is written allows for weird interpretations such
as thinking that alternate navigation mechanisms can substitute
structure. We propose an alternate redaction for Checkpoint 2.4 : "The
contents are structured and alternate navigation mechanisms have been
added to facilitate orientation and movement within"

Of course this implies a reformulation of the whole explanation of the
Required Success Criteria.

7)Guideline 4: Extended Checkpoints: 4.3


This a controversial Checkpoint becuase it involves the other layers of
web content production processes. Maybe it should be reformulated but it
shouldn't disappear. Maybe it could be the binding point with the
Technology-specific Checklists. Developers and web designers, whatever
the device they are thinking of primarily, must know that they must
produce accessible products. See our comment to "How to read this

Thanks again for this opportunity to contribute to WCAG 2.0.
Juan Luis Lara
WCAG2-espa coordinator
Received on Wednesday, 10 September 2003 18:48:58 UTC

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