Num	Re	Type	Priority	Comment	Reference
1	General	EDITORIAL	LOW PRIORITY	Are you going to provide titles for criteria, or make people refer to it either by cryptic number or the full criteria text?	[Comment on "General"]
2	General	EDITORIAL	LOW PRIORITY	Each page such as "Guide to Guideline 1.1 Level 1 Success Criterion 2" has a link such as "1.1 L1 SC2" which takes you to the corresponding section of the actual guidelines document. However, the link text is cryptic and there is no surrounding information explaining it; one has to take it to find out what it is for.	[Comment on "General"]
3	General	TECHNICAL	MEDIUM PRIORITY	Several success criteria use the phrases like "when something is drawn over a background image, color, or text", but in reality ALL text is drawn over some background, even if it is just a default solid color assumed by the user agent. In some cases a background is specified by the content author, in some cases it is specified by the user agent (i.e. the application that renders and/or displays the content), and in some cases it is specified by the author but overridden by the software (which may or may not be in response to user preference settings or commands).	[Comment on "General"]
4	General	EDITORIAL	HIGH PRIORITY	The table of contents in the General Techniques document really needs to be modified so that it has entries for all success criteria, even if those are only placeholders for criteria for which no techniques have been written. Readers may assume that the table of contents in the techniques (which _seems_ to be a list of the success criteria) is an accurate list of those criteria, when it is really a subset. The General Techniques document seems to repeat everything in the main section of the Guidelines document, with elaboration, which would make it an ideal document to rely on, but in fact it leaves out many criteria without giving the reader any indication it's doing so! It fooled me, causing me significant inconvenience when I realized the problem.	[Comment on "General"]
5	General	EDITORIAL	HIGH PRIORITY	I find the current system for providing examples to be confusing and far less helpful than it could be, because it does not identify which success criteria they are illustrating. In many cases it is really unclear, or requires a lot of mental juggling to identify the author's intention. (I found the extensive examples for Guideline 2.5 illustrate this particularly well.)	[Comment on "General"]
6	General	TECHNICAL	HIGH PRIORITY	Unless I've overlooked it, we should clarify when it's acceptable for content's default presentation to not comply with certain criteria as long as the user can make it comply by adjusting options in the content or in the user agent. For example, can a Web site comply with the criterion "Change of context are initiated only by user action" if it normally automatically updates content every five minutes but lets the user disable this by checking a check box on the page? How about a single check box on a page of site-wide preference settings? Is it enough even if the user would need to adjust that setting every time they visit the site? What if the site relies on a user agent preference setting to turn off automatic refreshing?	[Comment on "General"]
7	General	EDITORIAL	MEDIUM PRIORITY	I suggest gathering into one place the 15 success criteria specifically about making things programmatically determinable (identifiable, operable, etc.). They are currently scattered throughout the document under Guidelines 1.3, 1.4, 2.4, 3.1, 3.2, and 4.2, and I think this makes it very difficult for the reader to understand what they cover and how they relate to each other...ideally complementing each other (with minimal overlap) to provide all the capabilities needed by assistive technology. My first thought was to move them all into a separate, new principle such as "Programmatically expose structure, content, and functionality", but I realize that all the success criteria relating to markup really fall into this category.	[Comment on "General"]
8	"Change of context"	TECHNICAL	MEDIUM PRIORITY	This definition should be narrowed, as the current wording makes several success criterion in the guideline prohibit commonly-used and well-regard mechanisms (such as several in 3.2 L2). For example, scrolling the viewport should not be considered a change of context unless it is done other than in response to a user action; in particular, it should be OK to scroll the viewport to keep the focus visible.	[Comment on "Change of context: A change of user agent, viewport, user interface controls, or focus; or complete change of content."]
9	"Function"	TECHNICAL	LOW PRIORITY	I can’t think of cases where we’d want to refer just to things that are “functional” according to this definition, which says things that react to user input (directly or indirectly) are “functional” but things that react to other external events are not. The strangeness comes because the definition does not limit this category to things that _take_ input directly, instead including things that change in response to input elsewhere (such as a static text field that changes to display help related to the control that has the selection). I understand that we don’t want to limit it to things that themselves take input directly, as at an implementation level a button may react to a keystroke by changing some static text elsewhere on the form, while from the user’s perspective both the button and the text seem to be reacting to the user’s input. Still, it leads to strange examples: if text on a Web page changes to show when a server goes down, that text is NOT functional, but if the same page lets you select which server the text is monitoring then the text IS functional. I’m curious whether this is used in other documents, and if so, how well it works.	[Comment on "Function: Performs or is able to perform one or more actions in response to user input. "]
10	"Function"	EDITORIAL	LOW PRIORITY	I suggestion changing "Performs or is able to perform" to "Is able to perform." The existing phrase is redundant because something that performs is necessarily able to perform, and thus "Is able to perform" is functionally the same as "Performs or is able to perform."	[Comment on "Function: Performs or is able to perform one or more actions in response to user input."]
11	"Non-text content"	TECHNICAL	MEDIUM PRIORITY	This definition could be interpreted as saying that all content on an 8-bit encoding scheme is considered non-text, which is clearly not the intention. Is Unicode so universally used now that all other systems don't occur in the real world?	[Comment on "Non-text content: Content that is not represented by a Unicode character or sequence of Unicode characters. "]
12	"Programmatically determined"	TECHNICAL	HIGH PRIORITY	I strongly agree that communicating via standard means is a key requirements for complying with this guideline. I suggest adapting the wording I proposed for HFES/ANSI 200.2, which reads "Software should use the accessibility services provided by the operating system to provide information to the operating system and other applications, especially to assistive technologies. If that is not sufficient to comply with guidelines 9.2.3, 9.3, 9.4, 9.5, and 9.6, software should use other publicly documented software services supported by assistive technology." The key aspects are (a) use OS-provided means where those exist and are sufficient, otherwise (b) use means that are documented and supported by at least SOME assistive technology products.	[Comment on "Programmatically determined means that the specific value can be determined in a standard, machine or software readable form."]
13	Conformance		EDITORIAL	LOW PRIORITY	If you maintain three levels of success criteria this might also mention that some guidelines do not contain level 3 success criteria.	[Comment on "NOTE: Some guidelines do not contain level 1 success criteria, and others do not contain level 2 success criteria. "]
14	1.1 L1 SC2	TECHNICAL	MEDIUM PRIORITY	I suggest rewording the clause "if text alternatives can not serve..." to clarify that this phrase refers only to situations where it is impossible for the author to supply a text alternative that would provide equivalent functionality, rather than cases where the supplied text alternative merely fails to provide equivalent functionality.	[Comment on "1.1 L1 SC2: For functional non-text content, text alternatives serve the same purpose as the non-text content. If text alternatives can not serve the same purpose as the functional non-text content, text alternatives identify the purpose of the functional non-text content"]
15	1.1 L1 SC5	TECHNICAL	LOW PRIORITY	Need to define "live" as in "live audio-only content." This should clarify that live content need not include live actors or speakers; real-time data from an automated weather station and an automated stock ticker would each count as "live". Would "real-time" be a clearer term to use than "live"?	[Comment on "1.1 L1 SC5: For live audio-only or live video-only content, text alternatives at least identify the purpose of the content with a descriptive label."]
16	1.2 L1 SC1	TECHNICAL	MEDIUM PRIORITY	Comments in the document say there is debate about whether captions should be L1. I think providing either transcripts AND/OR captions should satisfy L1, while providing BOTH transcripts AND captions should satisfy L2. I say this because in many if not most cases a transcript of audio and important visuals will make the content will be entirely usable without captions. (Transcripts are also often cheaper and easier to produce, and in many cases provided more benefit than captions, such as being searchable, indexable, supporting copy/paste, allow quick visual or tactile scanning, etc. For some content transcripts would be more useful to most viewers than captions.) However, I wonder if there exists content for which captions alone would be unsatisfactory.	[Comment on "1.2 L1 SC1: Captions are provided for prerecorded multimedia."]
17	1.2 L1 SC2	TECHNICAL	MEDIUM PRIORITY	As with 1.2 L1 SC1, I feel that audio descriptions should not be L1, but that either audio descriptions OR transcripts that describe the visuals should satisfy L1, while providing BOTH would satisfy L2. I say this because in many if not most cases a transcript of audio and important visuals will make the content will be entirely usable without captions. (Transcripts are also often cheaper and easier to produce, and in many cases provided more benefit than captions, such as being searchable, indexable, supporting copy/paste, allow quick visual or tactile scanning, etc. For some content transcripts would be more useful to most viewers than captions.)	[Comment on "1.2 L1 SC2: Audio descriptions of video are provided for prerecorded multimedia."]
18	1.2 L2 SC1	EDITORIAL	LOW PRIORITY	I suggest we change "Real- time captions" to just "Captions" and in the notes explain that it is accepted that captions of real-time multimedia, often referred to as "real-time captions", are generally of lesser accuracy than is expected of captions on prerecorded multimedia. This is because there is no definition of "real-time captions", and I doubt that there's a technical distinction between real- time captions and all other captions. Using two different terms actually hurts clarity by implying there's a technical difference when there isn't; I think the distinction merely serves to reassure the provider that captions of live multimedia can be of lower quality than that of prerecorded multimedia. (In fact, low- quality captions of prerecorded multimedia comply with success criteria just as well as high-quality captions due.)	[Comment on "1.2 L2 SC1: Real-time captions are provided for live multimedia."]
19	1.2	EDITORIAL	LOW PRIORITY	Example 2 for Guideline 1.2 shows captions for a tutorial being in all upper case. If that is not really _the_ recommended style I would avoid showing it that way, as people will interpret it as a recommendation. NCAM's samples use mixed case and I would follow their lead.	[Comment on "1.2: Examples"]
20		EDITORIAL	LOW PRIORITY	The title of Guideline 1.3 says it addresses “information, functionality, and structure” but the actual success criteria only address information and structure, not functionality. Therefore it would be more accurate to delete “functionality,” from the guideline text.	[Comment on "1.3: Ensure that information, functionality, and structure can be separated from presentation."]
21	1.3 L1 SC1	TECHNICAL	HIGH PRIORITY	See my comment on the definition of "programmatically determined."	[Comment on "1.3 L1 SC1: Structures within the content can be programmatically determined."]
22	1.3 L1 SC2	TECHNICAL	HIGH PRIORITY	Reword this criterion as "When information is conveyed by color, the color can be programmatically determined or the information is also conveyed through another visual means that does not depend on the user's ability to differentiate colors." This embodies two changes. First, it is especially important to delete the clause "the color can be programmatically determined, or", because allowing color to be determined programmatically is NOT an adequate substitute, especially at L1, as it does not help the vast majority of viewers who have color deficiencies or are using monochrome displays. Second, I believe the "other means" by which the information is conveyed should be limited to _visual_ means (as is made clear by the wording of 1.3 L2 SC2.)	[Comment on "1.3 L1 SC2: When information is conveyed by color, the color can be programmatically determined or the information is also conveyed through another means that does not depend on the user's ability to differentiate colors."]
23	1.3 L2 SC2	TECHNICAL	HIGH PRIORITY	The wording of this criterion is flawed and should be replaced by a an L1 reading "When information is conveyed by color, the color can be programmatically determined or the information is also conveyed through another visual means that does not depend on the user's ability to differentiate colors." Please see my comments on 1.3 L1 SC2 for more a more detailed explanation. However, also note that the current wording of this criterion ("...when color is not available") is seriously flawed because it could be interpreted as only applying when running on a non-color display, rather than also applying when the user cannot perceive the colors on the display.	[Comment on "1.3 L2 SC2: Any information that is conveyed by color is visually evident when color is not available."]
24	1.3 L3 SC1	TECHNICAL	MEDIUM PRIORITY	I recommend removing the "When..." clause, because I can't think of real-world examples where reordering the contents would not affect their meaning. I don't think you can assume reordering content is ever harmless, and including an exception like this just opens room for authors to assume order is unimportant in cases where that's probably not actually true. (For example, even with an _explicitly_ unordered list a reader will refer to "the fifth" item, etc.)	[Comment on "1.3 L3 SC1: When content is arranged in a sequence that affects its meaning, that sequence can be determined programmatically."]
25	1.3 L3 SC1	EDITORIAL	LOW PRIORITY	It's also noteworthy that using color to highlight required or missing fields helps any users who can give the document a quick visual scan (e.g. people who read slowly, even if it's not because of cognitive impairments).	[Comment on "1.3 L3 SC1: When content is arranged in a sequence that affects its meaning, that sequence can be determined programmatically."]
26	1.4 L1 SC1	TECHNICAL	HIGH PRIORITY	It is important that ALL text can be programmatically determined, not just text that is drawn over certain backgrounds. I would change this to read "Any text that can be programmatically determined" and move it out of the section on foreground/background, probably to section 1.3.	[Comment on "1.4 L1 SC1: Any text that is presented over a background image, color, or text can be programmatically determined. [I] "]
27	1.4 L2 SC1	TECHNICAL	LOW PRIORITY	See my comment above about the fact that all text is drawn over some background.	[Comment on "1.4 L2 SC1: Text and diagrams that are presented over a background image, color, or text have a contrast greater than X1 where the whiter element is at least Y1 as measured by _____. [V]"]
28	1.4 L2 SC2	TECHNICAL	LOW PRIORITY	How does one define the width of a character's serifs? I don't see this number discussed among standard font metrics, and in most fonts a serif's thickness varies along the length of the serif. How is the typical content author or graphic artist supposed to measure this to determine whether accommodation is needed?	[Comment on "1.4 L2 SC2: Text that is presented over a background pattern of lines which are within 500% +/- of the stem width of the characters or their serifs must have a contrast between the characters and the lines that is greater than X2, where the whiter element is at least Y2. [V]"]
29	1.4 L2 SC3	TECHNICAL	MEDIUM PRIORITY	If this is meant to imply that the user should be able to turn off background audio without silencing foreground audio, then the criterion needs to be reworded to reflect that. As it reads today, all multimedia would comply as long as the user can turn off their speakers or mute all audio at the operating system level.	[Comment on "1.4 L2 SC3: A mechanism is available to turn off background audio that plays automatically. [V] "]
30	1.4 L2 SC3	TECHNICAL	LOW PRIORITY	The current wording only applies this criterion to background audio that plays automatically, but if it doesn't play automatically--only in response to some user action--then one could argue that the user can effectively turn it off by declining to start it. Therefore I suggest removing the phrase "that plays automatically" as unnecessary.	[Comment on "1.4 L2 SC3: A mechanism is available to turn off background audio that plays automatically. [V] "]
31	1.4 L2 SC3	TECHNICAL	MEDIUM PRIORITY	I suggest adding a success criterion to the effect that "A mechanism is available to turn off display of background patterns and images that are displayed behind text and/or graphics and to control the color of the solid background behind such text and graphics." I would make this L2. (Or is this a UA issue?)	[Comment on "1.4 L2 SC3: A mechanism is available to turn off background audio that plays automatically. [V] "]
32	1.4 L3 SC1	TECHNICAL	LOW PRIORITY	See my comment above about the fact that all text is drawn over some background.	[Comment on "1.4 L3 SC1: Text is not presented over any background (image, text, color or pattern), or if any background is present, the contrast between the text and the background is greater than X2. [V]"]
33	1.4 L3 SC2	TECHNICAL	MEDIUM PRIORITY	I would add a third option, "..., or the user can turn off playing of the background sounds."	[Comment on "1.4 L3 SC2: Audio content does not contain background sounds or the background sounds are at least 20 decibels lower than the foreground audio content, with the exception of occasional sound effects. [V]"]
34	2.1 L1 SC1	TECHNICAL	MEDIUM PRIORITY	I remain unconvinced of the usefulness of the phase "that can be described in a sentence." I prefer the approach of saying that, to be L1 compliant, "All of the functionality of the content must be operable using only non-time dependent keyboard (or keyboard equivalent) input that does not rely on visual recognition of pointer location." This is similar to the wording we are using in HFES/ANSI 200.2, where we also add "This includes, but is not limited to, editing text and other document components, and navigation to and full operation of all controls." Note that this would effectively be promoting 2.1 L3 SC1 ("All functionality of the content is designed to be operated through a keyboard interface.") to L1, albeit with added restrictions.	[Comment on "2.1 L1 SC1: All of the functionality of the content, where the functionality or its outcome can be described in a sentence, is operable through a keyboard interface."]
35	2.1 L3 SC1	EDITORIAL	HIGH PRIORITY	This criterion ("All functionality of the content is designed to be operated through a keyboard interface") is described as L2 in Web Content Accessibility Guidelines 2.0 W3C Working Draft 30 June 2005 (http://www.w3.org/TR/2005/WD-WCAG20-20050630/) but L3 in General Techniques for WCAG 2.0 of the same date (http://www.w3.org/TR/2005/WD-WCAG20-GENERAL-20050630/).	[Comment on "2.1 L3 SC1: All functionality of the content is designed to be operated through a keyboard interface."]
36	2.1 L3 SC1	TECHNICAL	HIGH PRIORITY	I recommend folding this into 2.1 L1 SC1; see my comments on the latter for details.	[Comment on "2.1 L3 SC1: All functionality of the content is designed to be operated through a keyboard interface."]
37	2.2 L1 SC1	EDITORIAL	LOW PRIORITY	It would be clearer if each list item ended with "and/or" instead of "or", to reinforce the fact that at least one should be true (rather than exactly one).	[Comment on "2.2 L1 SC1: Content is designed so that time-outs are not an essential part of interaction, or at least one of the following is true for each time-out that is a function of the content:"]
38	2.2 L1 SC1	TECHNICAL	LOW PRIORITY	It currently says "the time- out is part of an activity where timing is essential (for example, competitive gaming or time-based testing) and time limits can not be extended further without invalidating the activity", but I think that to achieve L1 time-based testing should be designed so that administrators can extend the allowed time (e.g. for students with certain disabilities) even if the end user cannot.	[Comment on "2.2 L1 SC1: Content is designed so that time-outs are not an essential part of interaction, or at least one of the following is true for each time-out that is a function of the content:"]
39	2.2 L2 SC1	TECHNICAL	LOW PRIORITY	Change "any" to "all" because use of "any" implies that the user can be required to turn off each blinking item independently. While that level of control can be useful for many users, it would be impractical for users who need to stop large number of blinking elements, especially if new ones might continually start blinking over time.	[Comment on "2.2 L2 SC1: Content does not blink for more than 3 seconds, or a method is available to stop any blinking content in the delivery unit. [I]"]
40	2.2 L2 SC2	TECHNICAL	LOW PRIORITY	Change to "...paused by the user for at least N minutes" (with N to be filled in before publication) because allowing the user to pause the content only for a short time period should not be sufficient to comply. Alternatively you could say "...paused indefinitely..." but I don't believe that is always feasible.	[Comment on "2.2 L2 SC2: Moving or time-based content can be paused by the user. [I] "]
41	2.2 L3 SC3	TECHNICAL	LOW PRIORITY	I fear that in many cases it is not feasible to let the user resume an operation after a session has been idle for a very long time, because it would be a large burden for servers to maintain state of each session indefinitely. (However, since this is only L3 it doesn't really matter.)	[Comment on "2.2 L3 SC3: When an authenticated session has an inactivity timeout, the user can continue the activity without loss of data after re-authenticating."]
42	2.4 L1 SC1	TECHNICAL	MEDIUM PRIORITY	This criterion is entirely redundant to other criteria. Navigational features are defined as either functional elements or structural (grouping) constructs, each of which are already required to be programmatically identifiable by criteria 4.2 L1 SC3 and 1.3 L1 SC 1, respectively.	[Comment on "2.4 L1 SC1: Navigational features can be programmatically identified."]
43	2.4 L2 SC1	TECHNICAL	MEDIUM PRIORITY	Currently there are no criteria that recommend providing ways for locating content within the current delivery unit, such as providing a table of contents or search function within a very long page. The current wording only addresses locating content within a set of delivery units, which could be interpreted as merely identifying which delivery unit contains a phrase, for example, of even just providing the titles of each unit. (Overall this criterion is extremely vague.)	[Comment on "2.4 L2 SC1: More than one way is available to locate content within a set of delivery units."]
44	2.4 L2 SC2	TECHNICAL	LOW PRIORITY	Interesting to note that most DVDs fail this because they will not let you bypass the copyright notices and piracy warnings at the beginning of each. Do we need to provide an exemption for blocks of content required for contractual reasons?	[Comment on "2.4 L2 SC2: Blocks of content that are repeated on multiple perceivable units are implemented so that they can be bypassed."]
45	2.4 L2 SC4	TECHNICAL	LOW PRIORITY	The term "programmatic reference" is used by not defined. I think it is being used here to mean something functional (e.g. a link or control) that causes a contextual transition, but I'm not sure.	[Comment on "2.4 L2 SC4: The destination of each programmatic reference to another delivery unit is identified through words or phrases that either occur in text or can be programmatically determined."]
46	2.4 L2 SC4	TECHNICAL	MEDIUM PRIORITY	The goal of this criterion is unclear. It works if it's designed to benefit people who use assistive technology, but if it's designed to help anyone else then allowing compliance merely by exposing information programmatically undermines it. For example, all Web pages using normal links ("A" elements) would comply because many user agents show the destination of the link that has the focus, and the user can read that, mentally parse it, and compare it with the URL of the current page (also currently displayed) to determine if it's an external link (a link to another delivery unit). In fact, it would still comply even if the user agent didn't display either location, as long as they are programmatically available. Are those matching the intent of the guideline authors?	[Comment on "2.4 L2 SC4: The destination of each programmatic reference to another delivery unit is identified through words or phrases that either occur in text or can be programmatically determined."]
47	2.4 L3 SC2	TECHNICAL	LOW PRIORITY	This is pretty vague; what type of information would be required to comply? Luckily it's only L3 so it's not really important.	[Comment on "2.4 L3 SC2: Information about the user's location within a set of delivery units is available."]
48		EDITORIAL	LOW PRIORITY	It's just funny that the word "them" in this title could apply to either the mistakes or the users...grammatically and/or semantically.	[Comment on "2.5: Help users avoid mistakes and make it easy to correct them."]
49	2.4 L2 SC1	TECHNICAL	LOW PRIORITY	If you want content designed for audio-only output to be able to claim L2 compliance, you'll have to reword this, as they normally don't provide anything to the user as text.	[Comment on "2.4 L2 SC1: If an input error is detected, the error is identified and provided to the user in text."]
50	2.4 L2 SC3	TECHNICAL	MEDIUM PRIORITY	This seems unclear in a number of areas. I don't understand why this list of clauses was chosen to define when and where this criterion applies. Why is changing a value in a remote database more serious than changing a value in a local database? (Is it on	[Comment on "2.4 L2 SC3: For forms that cause legal or financial transactions to occur, that modify or delete data in remote data storage systems, or that submit test responses, at least one of the following is true:"]
51	3.1 L3 SC1	TECHNICAL	LOW PRIORITY	Aren't all these criteria of the format "A mechanism is available (to look up information)" the responsibility of the user agent?	[Comment on "3.1 L3 SC1: A mechanism is available for finding definitions for all words in text content."]
52	3.1 L3 SC5	TECHNICAL	LOW PRIORITY	I note that when it says providing "a spoken version of the text content" is sufficient to comply with this criterion, it addresses the needs of people who have difficulty with the act of reading, but not those who have difficulty reading at or above the upper secondary education level" because of difficulty with complex sentences or vocabulary (nor those who have hearing impairments). (However, it's only L3 so it isn't really important.)	[Comment on "3.1 L3 SC5: When text requires reading ability at or above the upper secondary education level, one or more of the following supplements is available:"]
53	3.2 L1 SC1	TECHNICAL	MEDIUM PRIORITY	This seems very unclear. I read this criterion's current wording as meaning that software needs to be able to programmatically determine when a change of context occurs, but that seems contradicted by Example 2, which talks only about being able to identify links that would cause a chance of context. (If Example 2 isn't about L1 S1, then I can't see what criterion it would be about.)	[Comment on "3.2 L1 SC1: Any change of context is implemented in a manner that can be programmatically determined. [I] "]
54	3.2 L1 SC1	TECHNICAL	LOW PRIORITY	Either this 3.2 Example 2 needs to be changed or the definition of "change of context" need to be redefined. This example says, "At the beginning of each link is an icon of an arrow with the text equivalent, 'Link will open in new window.'", but what link WOULDN'T result in change of context? Remember, change of context is defined as including changing the contents displayed in the current window, not just creating a new window.	[Comment on "3.2 L1 SC1: Any change of context is implemented in a manner that can be programmatically determined. [I] "]
55	3.2 L2 SC1	TECHNICAL	LOW PRIORITY	A reasonable goal but the wording seems vague. For example, does it prohibit a Web site from having a list of sections in a left-hand navigation pane, if it would show the pages in the current section and hide the pages in the other sections (which is a frequently used and generally well-regarded mechanism)? As silly as it sounds, would it technically prohibit having a series of pages specifically designed to present the same contents sorted by different keys? As the term "component" is not defined, could it be interpreted as only entirely repeated blocks of content, or structural elements, repeated sections of text, or repeated controls or groups of controls, etc.?	[Comment on "3.2 L2 SC1: Components that are repeated on multiple delivery units within a set of delivery units occur in the same order each time they are repeated. [V]"]
56	3.2 L2 SC2	TECHNICAL	MEDIUM PRIORITY	Great criterion, but since "change of context" is defined as including a "change of viewport" the criterion as written would prohibit the user agent from scrolling the viewport to display the control, link, etc. that receives focus, and that's clearly not what we intend. I actually think this is a problem with the definition of "change of context" rather than of this criterion...see my comments about that definition.	[Comment on "3.2 L2 SC2: When any component receives focus, it does not cause a change of context. [I]"]
57	3.2 L2 SC3	TECHNICAL	MEDIUM PRIORITY	As above, see my comments on the definition of "change of context", as that makes this criterion prohibit such commonly-used mechanisms as hiding or deactivating certain controls to reflect which options are available given the information already entered. (For example, a date entry field is only enabled when the preceding "Show only items created after:" check box is checked.)	[Comment on "3.2 L2 SC3: Changing the setting of any input field does not automatically cause a change of context . [V]"]
58	3.2 L2 SC4	EDITORIAL	LOW PRIORITY	I think this is OK, but perhaps in examples we should make clear that, for example, it's acceptable for one page to have a "Save Contact" button while the next page has a "Save Appointment" button, etc. That is, things can be consistent without being identical.	[Comment on "3.2 L2 SC4: Components that have the same functionality in multiple delivery units within a set of delivery units are labeled consistently. [I] "]
59	3.2 L3 SC1	TECHNICAL	LOW PRIORITY	This would prohibit having a graphical button have the text equivalent "Edit Contact" on one page and "Edit Appointment" on another, but I don't think we should prohibit that. (However, it is only L3, so I it can't be too important.)	[Comment on "3.2 L3 SC1: Graphical components that appear on multiple pages, including graphical links, are associated with the same text equivalents wherever they appear. [V]"]
60	3.2 L3 SC2	TECHNICAL	LOW PRIORITY	Is it acceptable if the content updates automatically by default, but the user can disable this by adjusting preference settings on the Web site or in the user agent? (This comment is low priority because the criteria is only L3.)	[Comment on "3.2 L3 SC2: Changes of context are initiated only by user action. [V]"]
61		EDITORIAL	MEDIUM PRIORITY	I suggest separating this into two separate Guidelines. I don’t understand why these two separate issues (ensure user interfaces are accessible, and provide alternatives when things—not just user interfaces—aren’t accessible) are lumped together. 4.2 L1 SC3 through SC6 and L2 SC1 are all about exposing information for use by assistive technology, which should always be done, and I don’t see any logical connection with L1 SC1, L1 SC2, or L3 SC1. Please see my suggestion above about reorganizing success criteria about programmatic access.	[Comment on "4.2: Ensure that user interfaces are accessible or provide an accessible alternative(s)"]
62	4.2 L1 SC 1	TECHNICAL	MEDIUM PRIORITY	An interesting circular argument: if a Web site doesn't meet all the Level 1 success criteria but it provides an alternate version that does, then I think this is saying the primary site complies with 4.2 L1 SC1...but is it at all useful for the content developer to comply with only one of the L1 success criteria? (I'm assuming this is not trying to imply that by providing an alternate version that is L1 compliant, the original site itself can claim L1 compliance, and yet there should be some incentive to provide the alternative version.)	[Comment on "4.2 L1 SC 1: If content does not meet all level 1 success criteria, then an alternate form is provided that does meet all level 1 success criteria. [V]"]
63	4.2 L1 SC 1	TECHNICAL	MEDIUM PRIORITY	Is it supposed to be implied that the alternate version must be advertised on or directly available from the original version? That would be implied by the [V] (visual change required) notation on this criterion. As with many other accessibility guidelines, the issue comes up of whether the more accessible options need to be known and/or immediately available in order to count towards compliance.	[Comment on "4.2 L1 SC 1: If content does not meet all level 1 success criteria, then an alternate form is provided that does meet all level 1 success criteria. [V]"]
64	4.2 L1 SC 2	EDITORIAL	MEDIUM PRIORITY	To say that something applies both to content that uses X and content that doesn't use X is to say nothing; therefore can't you change "Content using baseline technologies or non-baseline technologies, must meet the following criteria" to "Content must meet the following criteria"?	[Comment on "4.2 L1 SC 2: Content using baseline technologies or non- baseline technologies, must meet the following criteria: (a) Content that violates international health and safety standards for general flash or red flash is marked in a way that the user can avoid its appearance, (b) If the user can enter the content using the keyboard, then the user can exit the content using the keyboard."]
65	4.2 L1 SC 2	EDITORIAL	MEDIUM PRIORITY	I don't understand the point of this criterion. Why does it lump together to things that seem utterly disparate (way to avoid flashing and ability to exit a context using the keyboard)...why aren't these two separate criteria? However, the first portion seems to already be covered by 2.3 L1 SC1 and the second by 2.1 L1 SC1; the purpose of reiterating them here--or the functional difference between those and this--eludes me.	[Comment on "4.2 L1 SC 2: Content using baseline technologies or non- baseline technologies, must meet the following criteria: (a) Content that violates international health and safety standards for general flash or red flash is marked in a way that the user can avoid its appearance, (b) If the user can enter the content using the keyboard, then the user can exit the content using the keyboard."]
66	4.2 L1 SC 2	TECHNICAL	MEDIUM PRIORITY	When it says "If the user can enter the content using the keyboard, then the user can exit the content using the keyboard" we have to be clarify that this does not mean that every page has to have a "close this window" link. I think it is sufficient to rely on user agents to provide the ability to close their window and navigate "back" using the keyboard.	[Comment on "4.2 L1 SC 2: Content using baseline technologies or non- baseline technologies, must meet the following criteria: (a) Content that violates international health and safety standards for general flash or red flash is marked in a way that the user can avoid its appearance, (b) If the user can enter the content using the keyboard, then the user can exit the content using the keyboard."]
67	4.2 L1 SC 3	TECHNICAL	MEDIUM PRIORITY	This should also apply to output-only controls (and content) that are only updated when the page is rendered.	[Comment on "4.2 L1 SC 3: The role, state, and value can be programmatically determined for every user interface component of the web content that accepts input from the user or changes dynamically in response to user input or external events. [I]"]
68	4.2 L1 SC 4	TECHNICAL	MEDIUM PRIORITY	This should apply to controls that display information as well as those that take input. For example, take a page where a static text field displays the label "Name:" and to its right a static text field displays the value "George"; in this case the former text control is presenting the label of the latter, and this relationship is no less important to the viewer than it would be if the user could directly edit the displayed value.	[Comment on "4.2 L1 SC 4: The label of each user interface control that accepts input from the user can be programmatically determined and is explicitly associated with the control. [I]"]
69	4.2 L1 SC 5	TECHNICAL	LOW PRIORITY	Replace the phrase "changed programmatically" with "programmatically changed" throughout the document, and add a definition for the phrase. The document already defines and uses "programmatically determined", "programmatically identified", and "programmatically located", so using "programmatically changed" would be more consistent, readily identifiable, and appear with the related phrases in the alphabetically-arranged glossary.	[Comment on "4.2 L1 SC 5: The states and values of content that can be changed via the user interface can also be changed programmatically. [I]"]
70	4.2 L1 SC 5	TECHNICAL	MEDIUM PRIORITY	The term "changed programmatically" (or "programmatically changed") is undefined and vague enough that _all_ Web content will automatically comply, because assistive technology on all major operating systems can simulate mouse clicks and keystrokes. I believe the intent of this success criterion is that assistive technology be able to directly change the values--certainly without moving the mouse pointer or "hunting" by simulating TAB until the focus arrives as the desired control. Unfortunately the distinction is somewhat blurry; for example, it is not about whether the AT communicates directly with the user agent or content, since in many cases the AT would use an operating-system supplied wrapper to do that. In HFES/ANSI 200.2 we have a number of Checkpoints and Notes that work together to set out appropriate expectations.	[Comment on "4.2 L1 SC 5: The states and values of content that can be changed via the user interface can also be changed programmatically. [I]"]
71	4.2 L1 SC 5	TECHNICAL	MEDIUM PRIORITY	It seems like this the responsibility of user agents rather than content.	[Comment on "4.2 L1 SC 5: The states and values of content that can be changed via the user interface can also be changed programmatically. [I]"]
72	4.2 L1 SC 6	TECHNICAL	MEDIUM PRIORITY	As with "programmatically changed", the definition of "programmatically identified" could use clarification in order to ensure that the methods are actually practical for use by assistive technology.	[Comment on "4.2 L1 SC 6: Changes to content, structure, selection, focus, attributes, values, state, and relationships within the content can be programmatically determined. [I]"]
73	4.2 L1 SC 6	TECHNICAL	HIGH PRIORITY	Assistive technology needs to be able to determine these attributes even when they are not changing.	[Comment on "4.2 L1 SC 6: Changes to content, structure, selection, focus, attributes, values, state, and relationships within the content can be programmatically determined. [I]"]
74	4.2 L2 SC 1	TECHNICAL	LOW PRIORITY	We need to clarify this because it leaves undefined whether content must follow ALL accessibility conventions or merely AT LEAST TWO of them. Requiring all available conventions to be followed is too large a burden, whereas requiring only two (as the wording is plural) is too low a bar.	[Comment on "4.2 L2 SC 1: Accessibility conventions of the markup or programming language (API's or specific markup) are used. [I] "]