Collection of Comments from AbI

This set of comments were collected during the discussions about
the WCAG 2.0 Working Draft by the AbI-Project (Aktionsbuendnis für 
barrierefreie Informationstechnik)

COMMENTS ON WCAG 2.0 OF 2004-03-11
Aktionsbündnis für barrierefreie Informationstechnik, Germany
Version 3, 2004-05-07, Gottfried Zimmermann, Christian Bühler, Frank Reins

General Comments
(1) We assume that WCAG 2.0 will not be released within the next 12 
months.  In Germany there are currently legislative efforts under way, 
to (a) revise the technical accessibility standard on the federal level, 
and (b) to issue technical accessibility standards on the state and 
municipal levels.  Given this situation we strongly encourage the WCAG 
group to release a WCAG 1.1 version that has the same structure as WCAG 
1.0 but without some deprecated requirements and (optionally) a few new 
checkpoints.  Ideally WCAG 1.1 should be released within the next 6 months.
(2) We welcome the structure of the WCAG 2.0 document with the four 
basic principles.
(3) We regret that the old priority levels of WCAG 1.0 have been 
abandoned.  We under stand, however, that there were issues regarding 
testability of checkpoints.  In general, for the sake of backward 
compatibility in the German legacy, we would like to see the WCAG 1.0 A- 
and AA-checkpoints covered by WCAG 2.0 level 1&2 criteria, and the WCAG 
1.0 AA-checkpoints covered by WCAG 2.0 level 3 criteria.
(4) We see the need a mapping document which describes the migration for 
WCAG 1.0 to WCAG 2.0 in detail this document should be available 
together with the release of WCAG 2.0:
* new additional (stronger) requirements
* deprecated (weaker) requirements based on the level of priorities / 
(5) For some success criteria in WCAG 2.0, it is not specified whether 
the responsibility is with the Web designer or the user agent developer. 
  This should be made very clear, and necessary harmonization with UAAG 
is required.  Examples:
* The user is allowed to turn off content that blinks for more 
than 3 seconds.
* The user is allowed to pause and/or permanently stop moving 
or timebased content. In the past we have seen user agents, which did 
not fulfil UAAG requirements. Hence, WCAG 2.0 shall not transfer 
responsibility to UAAG if the issue can be solved within WCAG 
requirements. The Problem is that in many countries including Germany 
only WCAG is adapted by legislation.
(6) Techniques documents will be consulted by Web developers more than 
WCAG 2.0 itself. Therefore, and because the German regulation is likely 
to adopt them in some form, they should be W3C recommendations rather 
than informal documents. Furthermore, if the techniques documents are 
informal only, a Web designer would have the choice between applying a 
specific technique proposed by the techniques document, or to come up 
with their own solution based on their interpretation of the WCAG 2.0 
document. This would impose a test problem and interoperability problem 
with AT.
(7) Tables are not adequately accommodated in WCAG 2.0.  It is our 
understanding that tables are not techniques-specific.
* Should have the explicit requirement for marking of row and 
column headers in tables, either in guideline 1.3 or guideline 2.4.  Cf. 
WCAG 1.0 checkpoint 5.1.
* No explicit mentioning of (layout) tables required to be 
linearized.  Should be added to WCAG 2.0.  Cf. WCAG 1.0 checkpoint 5.3.
* Summaries for data tables should be explicitly required.  Cf. WCAG 1.0 
checkpoint 5.5.
(8) WCAG 2.0 has no success criteria regarding the contrast in images 
(or "non-text content"), only for text (guideline 1.4).  This could be a 
problem for images containing text - the author could claim that 
contrast is no issue because it is an image (it is "non-text content" 
per definition in the glossary of WCAG 2.0).
(9) We ask for clarification for WCAG 1.0 checkpoint, which begin with 
"until user agents support ..." are those Checkpoints seen as deprecated 
now or how are they covered in WCAG 2.0. This pertains to 10.2, 10.3, 
10.4, 10.5 and also 1.5

Other Requests for Change - Details
(10) & Typo: Should say "(a) through (i)", not "(a) 
through (j)".
(11) should be level 1 or 2.
(12) Should apply to all blinking content, not only for content 
that blinks more than 3 seconds.  Could open up a backdoor, if content 
blinks for 3 seconds, then stops blinking for the next 3 seconds, then 
blinking again for 3 seconds...
(13) should be level 2.  Cf. WCAG 1.0 checkpoint 10.1 Until user 
agents allow users to turn off spawned windows, do not cause pop-ups or 
other windows to appear and do not change the current window without 
informing the user.
(14) should be "applied", not only "considered".  Should be 
level 1.
(15) should be "applied", not only "considered".  Should be 
level 2.
(16) should be promoted to level 2.  Is there any technical 
reason why this would not be possible?
(17) The concept of metadata describing resources should be included in 
WCAG 2.0.  Cf. WCAG 1.0 checkpoint 13.2 Provide metadata to add semantic 
information to pages and sites.
(18) "Navigation bar" should be added to the list of "site 
navigation mechanisms" in the glossary.  Cf. WCAG 1.0 checkpoint 13.5 
Provide navigation bars to highlight and give access to the navigation 
(19) No specific criterion about search function in WCAG 2.0.  Should be 
added.  Cf. WCAG 1.0 checkpoint 13.7 If search functions are provided, 
enable different types of searches for different skill levels and 

Questions for Clarification
(20) Why "at least one plug-in"? Shouldn't it apply to all 
plug-ins required?  Are we missing anything here?
(21) & What is meant by ". or the resource provides a 
mechanism.". Does it mean that the responsibility shifts from the author 
to the user agent?
(22) Should be dropped for clarification: ".or the resource 
provides a mechanism to allow the text to meet this criterion"?
(23) Feedback: Is this meant to apply to the "default 
presentation mode"?  How can the author make sure it looks or sounds 
different if the user uses their own style sheet?
(24) Should be harmonized with UAAG.
(25) ". can still access the resource": not clear whether it is 
the same page or could be an alternative page.
(26) What determines whether the "user is allowed to turn off 
(27) What determines whether the "user is allowed to pause."?
(28) What determines whether the "user is allowed to."?  The 
example in WCAG 2.0 implies that the user must be able to control 
automatic refresh through a mechanism provided by the author through Web 
(29) From and we conclude: On level 3, essential 
time-outs (e.g. automatic refreshs, automatic redirects) are only 
allowed if they can be controlled by the user.  Is this
correct?  If yes, what determines whether they can be 
postponed/suppressed by the user?
(30) Access keys (keyboard shortcuts) could be automatically 
assigned by the user agent, to avoid platform-specific conflicts.  Is 
this right?
(31) We are assuming that by "each page or resource that can be 
accessed inde-pendently" frames are included.  Is this correct?
(32) Is meant to apply to a "default presentation mode" 
(otherwise conflict with  If yes, this should be added to the 
wording of the criterion.
(33) We would like to have a level-2 criterion.  This is 
probably not possible because of its implications for testability.  Is 
this correct?
(34) What exactly is "and can be provided without jeopardizing 
(35) The following WCAG 1.0 checkpoint should be included in WCAG 2.0:
5.6 Provide abbreviations for header labels.
(36) We need a specific criterion for skipping over ASCII art in WCAG 
2.0.  Cf. WCAG 1.0 checkpoint 13.10 Provide a means to skip over 
multi-line ASCII art.

Expectations for the evolving HTML Techniques Document
(37) We expect that the specific operability issue of server-side image 
maps will be dealt with in the HTML techniques document.  Cf. WCAG 1.0 
checkpoint 1.2.
(38) Make sure WCAG 1.0 checkpoint 6.1 will have an equivalent in the 
WCAG 2.0 HTML Techniques document.
6.1 Organize documents so they may be read without style sheets. For 
example, when an HTML document is rendered without associated style 
sheets, it must still be possible to read the document.
(39) We expect that the requirement for frames to have unique titles and 
descriptions will be covered in the HTML techniques document.  Cf. WCAG 
1.0 checkpoints:
* 12.1 Title each frame to facilitate frame identification and navigation.
* 12.2 Describe the purpose of frames and how frames relate to each 
other if it is
not obvious by frame titles alone.

Our comments are based on our own mapping document between WCAG 1.0 AA 
and WCAG 2.0 Level 2. This document can be made available on request

Received on Tuesday, 11 May 2004 03:36:51 UTC