Re: Comments on WCAG2 Draft June 30/05

Dear Greg,

Thank you for your comments on the 30 June 2005 Working Draft of WCAG
2.0. A list of issues related to comments you have made is available at:

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Thank you for your patience while the WCAG WG responds to the variety
of comments we received on this last Working Draft.

All the best,


Ben Caldwell | <>
Trace Research and Development Center <>

Greg Gay wrote:
> July 28,05 WCAG 2.0 Comments  on Draft June 30/05
> 1. ...should WCAG 2.0 have 2 or 3 levels of conformance?
> There are many reasons why a three level conformance framework should
> be maintained.
> For a transition from WCAG 1.0 to WCAG 2.0  that will be easy to 
> comprehend for content developers, evaluators, and clients who are 
> currently accustomed to the "required, should, could" notions that
> give concrete meaning to priority levels, a three level structure
> should be used using similar or the same associated meanings. There
> are still things that "must" be done or content  will be inaccessible
> to a particular group. There are things that "should" be done, or
> some groups are going to have a difficult time accessing content, but
> where accessing content is otherwise possible. There are things that
> "could" be done to improve usability beyond what might be considered
> technically accessible.
> There are cases in the WCAG 2 draft where current level 3 success 
> criteria are relatively difficult or unnecessary to implement, and as
> a result would prevent many sites from conforming with Level 2
> guidelines should the guidelines be moved from level 3 to level 2.
> For  example, guideline 3.1 Level 3 #1 "A Mechanism is available for
> finding definitions for all words..." is not something most sites
> would implement. A glossary is more likely to be implemented for
> specific keywords, though still relatively rare, but for definitions
> for all words a full dictionary would need to be available. Very few
> site would thus be able to comply with level 2. If a person needs a
> dictionary there are many such sites available on the Internet. There
> is no reason why every site that wishes to comply with Level 2
> guidelines has to have their own dictionary. I don't think requiring
> a dictionary should be a requirement at any level.
> Likewise, if a site is specifically targeting post secondary students
> or a professional audience,  providing a summary, graphic, or spoken
>  version at a lower education level is generally unnecessary (re: 
> guideline 3.1 Level 3 #5). As a result such a level 2 requirement
> would prevent most post secondary sites from attaining Level 2
> conformance. The audience being addressed might be included in the
> baseline, and this guideline adjusted to reflect accommodations for
> that particular audience, rather than an outright requirement that
> all content needs to be readable by all, or have a summary with
> primary level language.
> I'd vote for sticking with the meanings currently associated with 
> priority levels of WCAG 1.0, and go with three levels of success 
> criteria in WCAG 2.0. Grouping all current level 2 and level 3 
> guidelines into one level is going to blur the importance of the
> current level 2 guidelines. It will discourage content developers
> from attempting to go beyond the basic accessibility of level 1, if
> level 2 is generally unattainable for average content developers.
> 2. Should a validity success criterion be addressed at Level 1 or
> Level 2 (refer to "Validity and Accessibility" for a summary of
> recent discussion)?
> While I certainly think validity is a reflection of quality, and in
> all our work validation is a key step in our development process, I
> tend to agree that it should not be the responsibility of the WCAG to
> police the validation of Web documents. Though intended as
> recommendations, as noted, WCAG does end up being the basis for
> policy, and a requirement for valid markup is going to have serious
> legal and financial consequences for those bound by policies based on
> When we evaluate Web sites virtually all fail the validity check. 
> Sometimes they might fail by simple omission or perhaps a  typo or
> two, such as  the odd broken tag on a few pages within a larger site.
> Other times sites are a mess with broken markup throughout. In the
> latter case there will likely be accessibility problems as a result
> of the invalid markup, but in the former the minor markup errors will
> likely have no affect at all. There is no clear line between validity
> that affects accessibility, and validity that does not. WCAG's
> primary concern should only be with validity issues that do affect
> accessibility, not with validity in general.
> If validity is to be a Level 1 success criteria, a distinction would
>  have to be made between markup errors that are proven to be 
> accessibility barriers (these will differ across user agents, and
> will change over time), and errors that do not affect accessibility.
> How one would go about making the distinction I do not know. Given
> individual errors may not cause accessibility problems, but
> combinations of errors often do, documenting Level 1 and Level 2
> validation errors would likely not be possible without a major
> effort. Then checking for those errors, or combinations thereof, is
> also going to be difficult to accomplish.
> If the validity requirement is made a Level 1  criteria, it will be
> the single most difficult hurdle to conformance, and given that in
> most cases where invalid markup is encountered there is no affect on
>  accessibility, making a general requirement that all markup be valid
>  would be problematic This would be particularly true for dynamic
> sites where information changes regularly or where user contributed 
> information is collected. As a Level 2 requirement, at least these
> sites could claim a consistent level 1 conformance. They may never be
> able to claim conformance if validity is listed as a level 1
> requirement.
> My vote is to leave validation a Level 2 success criteria, though
> within a three level (required, should, could) conformance framework.
> Baseline!!! Great idea! Audience needs to be added to the baseline in
>  addition to technologies. See below re: guideline 3.1 Level 3 #5, 
> particularly important if level 3 guidelines are merged with level 2.
> 1. Technology assumptions and the baseline
> I realize these two examples are informative, but they have the 
> potential to create confusion through multiple interpretations.
> Example 2 "...supported by more than one accessible and affordable
> user agent for more than one release."  The word release is a
> relative term. Release cycles vary greatly for different software.
> Does this include major and/or minor releases (e.g. feature release
> vs a bug fix release). What about where only one accessible user
> agent exists, like Internet Explorer was for the longest time. Use
> words like "readily available user agent" rather than "more than
> one."  The words "readily available" could also remove multiple
> interpretation of the word "release". A definition of the phrase
> "readily available" could be added to the glossary, with a definition
> something like "...with minimal effort  is attainable by searching
> the Internet."
> Example 3 "... to reflect the increased ability of affordable user
> agent (including assistive technology)..." I might ask "are there
> affordable assistive technologies?" thinking about the current cost
> of screen readers. The affordability of assistive technologies is
> relative to a person's income, or the availability of funding to them
> (in Canada funding is available every five years), so this leaves
> room for many different interpretations.  Perhaps replace
> "affordable" with "readily available."
> Conformance Claims Regarding #2 of the information that must be
> included with a conformance claim, "... a list of one or more URIs
> ...". In the case of a Web application, a base URI may not be
> available. For example, our Web applications claim AA conformance,
> but they do not reside at any specific URI, but rather at many URIs
> where users have installed the software, or at open source
> repositories that distribute the software. The applications exist as
> archived bundles of  software, that when unpacked  and installed on a
> user's Web site, will conform with WCAG AA specifications.
> Or, could the URI perhaps be a download location of the primary
> software distribution. Perhaps yes, but this did not seem immediately
> apparent when I read it the first time (thinking to myself aloud).
> The definition of  "delivery unit" might include mention of a
> "software package" or "software archive". A Web application
> distributed by CD may not have an associated URI at all, but may
> otherwise be conformant. The #2 requirement should also include
> something like "...or a software version identifier where a URI is
> not available."
> Also with regard to conformance claims, a date on which the claim was
>  made should also be included.  For Web sites that are continually 
> changing, the accessibility of the site may vary from day to day. For
>  the protection of human evaluators who find a site to be conformant,
>  then are brought to task a month later, for example, when the
> evolving site is found to no longer conform, a "date of conformance"
> is required. The only case where a conformance claim remains valid
> indefinitely, which would be assumed if no date were specified, is
> when the content of a web site does not change (which relatively is
> rare).
> Similarly a claim of conformance could be made on one version of a
> Web application, and be carried over to later versions of the
> software, which are perhaps not conformant if a date of conformance
> or software version identifier is not associated with the claim.
> Principle 1: Level 1 Success Criteria for Guideline 1.1 While I do
> believe all meaningless non-text elements should have a text 
> alternative, success criteria 1.1 #4 is not a critical accessibility
>  issue, and thus does not warrant a level 1 rating. If the image does
> not convey meaning, assistive technologies announcing the filename
> disrupts comprehension of the page being read, but it does not
> prevent a user from accessing the content of the page as would a
> missing text alternative  for non-text content that does contain
> meaningful information. Perhaps include this item as a level 2
> success criteria which is describe as a "should" do item to make it
> less difficult to access the content in question.
> Guideline 1.2 1.a A text transcript should be required at level 1 to
> accommodate those using technology that does not read the captions in
> a particular user agent. 1.b I agree that adding captioning is
> effortful, and may ultimately be seen as "undue hardship" in the eyes
> of the courts, and thus be ignored altogether. If the transcript is
> required at level 1, there will always be a text alternative. Given
> transcripts are fairly easy to create, undue hardship could never be
> a defense for not include a text alternative.
> There could also be reference to "readily available" for the above
> with regard to captioning software, in which case it may be more
> reasonable to leave captioning as a level 1 success criteria.
> 2. Audio descriptions may also fall under the "undue hardship"
> category if maintained as a level 1 success criteria. Also, there is
> a question of subjectivity in what requires an audio description, and
> the capacity to include audio descriptions where the video does not
> have sufficient breaks into which it can be inserted. Including a
> text version of the audio descriptions as part of a transcript as
> mentioned for 1a above as a level 1 criteria,  would assure that an
> alternative exists in some form.
> *While I think of the "undue hardship" clause as a poor defense in
> most cases, if the effort required to add synchronized captioning and
>  descriptive audio (particularly descriptive audio, and extended
> audio descriptions) approaches a significant cost within the overall
> cost of producing the video, courts are likely to favor the undue
> hardship argument. Captioning and descriptive audio as level 2 items,
> and transcripts of audio and video tracks as level 1, would remove
> the undue hardship defense.*
> Guideline 1.3 The association between guideline 1.3 and its examples
> is not immediately apparent. While each example represents some
> implementation of structure, how they represent separation from
> presentation is not clear.  Example #2 re associating table headers
> with data cells might fit better into Guideline 2.4, where structure
> is more thoroughly covered.
> Guideline 1.4 Guideline 1.4 does not seem general enough, specifying
> images or sound, but not colour (though colour is mentioned is the
> level 1 success criteria). (i.e. "Make it easy to distinguish
> foreground information from background images or sounds)." Perhaps
> the words "images or sounds" should be replaced with "information" to
> make the guideline more general.
> Level 1 success criteria for guideline 1.4 seems a little weak,
> though unless the algorithm of level 2 #1, to measure contrast
> between foreground and background colours, comes about before the
> release of WCAG 2, there's probably nothing better than
> "programmatically determined" colours so users agents can make
> adjustments as required. The problem is colours can be
> programmatically determine with relative ease in most cases, but
> there is no mention of contrast between foreground and background
> colours in level 1. Presenting bright yellow on a white background
> for example, would not violate this guideline if the colours were
> explicitly defined as an attribute or style, but the text would be
> inaccessible to most people who are not using an assistive technology
> that reads colour attributes;   essentially disabling otherwise fully
> able users.
> Perhaps it would be more effective here to "...ensure that foreground
>  and background colours can be overridden by the reader," which is 
> perhaps what "programmatically determined" means in this case.
> Perhaps include an example for Guideline 1.4 that describes the
> ability to override presentation styles would add clarity to the
> level 1 criteria, and an example of foreground background readability
> (or non-readability as the case may be).
> Principle 2 Guideline 2.4 Level 2 Success Criteria #1. Similar to the
> timed content 2.2 Level #1 guideline  "...without invalidating the
> activity" could be used here as well, with reference to providing
> alternate paths for navigating content. For example "More than one
> way is available to locate content within a set of delivery units 
> except where non-sequential navigation would change the intended
> outcome of an activity".
> 2.4 Level 2 #2  might also include reference to bypassing large
> blocks of data (i.e. data tables). Similarly, things like an
> alphabetized browse menu for a glossary can use bypass links. These
> might be better referred to in examples.
> 2.4 ... who benefits. It's not clear to me what the following means
> in the Who Benefits section of guideline 2.4: "Individuals with
> cognitive disabilities may find it easier to ask for what they want
> than to deduce its location from categorical choices." particularly
> the word "ask" as it relates to mechanisms to find, orient, and
> navigate Web content. Structures like headings for example, are more
> apt to draw users with cognitive disabilities to categorical
> information that aids in comprehension, like that described for blind
> users above "... jumping from header to header to get an overview or
> to more quickly skim...". Most people, including those with cognitive
> disabilities, can benefit from the summary information structures
> provide, for comprehension and learning.
> Principle 3
> In Who benefits from Guideline 3.2, reference to difficulty
> interpreting visual cues here, and in the Who benefits section for
> 3.1, are only remotely representative of dyslexics. Dyslexia is
> specifically associated with difficulties making letter to sound
> correspondences (i.e. phonemic awareness). With regard to having
> difficulty interpreting visual cues, WCAG should perhaps refer to
> dyspraxia, or better to non-verbal learning disability. Though not
> specifically associated with difficulties interpreting visual cues,
> these latter disabilities are more likely to include them. Dyslexics
> as a group tend to be good at interpreting visual cues, with visual
> difficulties occurring only when multiple disabilities are present.
> For guideline 3.1 a Level 2 success criteria might be added to
> suggest using meaningful link text (i.e. navigation controls), or
> provide context that allows users to infer meaning where the link
> text is otherwise meaningless. In the latter case for example, a link
> to a full article via its title, followed by a link with the link
> text "more" provides context for the otherwise meaningless word
> "more." This is likely HTML specific so it might fit as an example
> for a more general requirement the interface controls be meaningful.
> Principle 4 Guideline 4.2 Level 1 item 1 suggests that alternatives
> are preferable over making the original Web content accessible in the
> first place. Rather than "If content does not meet all level 1
> success criteria..." use "If content can not be authored to meet all
> level 1 success criteria..."
> Guideline 4.2 Who benefits, the first statement and its list items
> seem redundant. The statement might read better as "Authors who
> address accessibility during the design stage of content development,
>  will:" distinguish between designing for accessibility and 
> retrofitting for accessibility.
> Guideline 4.2 Use of relative measures should be a level 2 success 
> criteria. There might include an example that mentions relative
> measure for defining layout and font sizing. If fonts must be marked
> up in a way that allows them to be increased in size  for those with
> low vision, the layout elements must also be included in this
> requirement so as the font size increases, the surrounding containers
> also increase in size, so one does not end up with a paragraph
> displayed as a single column of words for  example. Similarly,
> relative sizing could be used to define image sizes (16px = 1 em) so
> images also increase in size relative to the fonts and their
> containers, and the symmetry of the screen is maintained.

Received on Monday, 29 August 2005 17:19:46 UTC