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Comments Working Draft of WCAG 2.0

From: Web Usability <rhudson@usability.com.au>
Date: Mon, 19 Dec 2005 17:02:56 +1100
To: "Public-Comments-Wcag20" <public-comments-wcag20@w3.org>
Message-ID: <GGEEINFOLDEIIBPBECEMKEBLCGAA.rhudson@usability.com.au>

Hi Working Group

Some comments of SC 3.1.5 follows:


Roger Hudson

Comments on the needs of people with cognitive disabilities and learning
difficulties and Success Criterion 3.1.5:

In my opinion, the needs of people with cognitive disabilities and learning
difficulties were never adequately addressed in WCAG 1.0, however the
situation does not appear to be improved with WCAG 2.0 and may even be
worse. Certainly a range of issues that could impact on the ability of
someone with cognitive disabilities to use a website are considered in WCAG
2.0 Guidelines 2.2 and 2.4, but the main issues relating to cognitive
disabilities and learning difficulties appear to be covered in Guidelines
3.1 and 3.2.

I am particularly concerned that WCAG 2.0 does not appear to contain an
adequate replacement for the WCAG 1.0, Checkpoint 14.1, “Use the clearest
and simplest language appropriate for a site’s content (Priority 1)”.  WCAG
2.0, Success Criterion 3.1.5 is probably the nearest equivalent:

Start Quote:
“3.1.5 When text requires reading ability more advanced than the lower
secondary education level, one or more of the following types of
supplemental content is available: (Level 3)
1.	A text summary that requires reading ability less advanced than the lower
secondary education level.
2.	Graphical illustrations of concepts or processes that must be understood
in order to use the content.
3.	A spoken version of the text content.”
End Quote.

I have two main concerns with 3.1.5:
	First, the nominated Success Criterion is Level 3, which suggests that it
is only necessary to “achieve additional accessibility enhancements” and
does not need to apply to all Web resources (without any indication of the
resources it should apply to).
	Second, 3.1.5 concentrates solely on a persons reading ability, which is
only one of the determining factors that can influence how well different
people with cognitive disabilities or learning difficulties are able to
understand a document. For example, what about people who can read well but
have considerable difficulty negotiating a complex text-type or
comprehending what is written? Or, the additional burden fully justified
text and the use of long line lengths can place on many people with reading

The “Understanding WCAG 2.0 (Working Draft 23 November 2005)” document
provides the following advice relating to 3.1.5:

Start quote:
“The intent of this success criterion is:
	To ensure that additional content is available to aid understanding of
difficult or complex text;
	to establish a testable measure indicating when such additional content is

This success criterion helps people with reading disabilities while also
allowing authors to publish difficult or complex Web content. Text
difficulty is described in terms of the level of education required to read
the text. Education levels are defined according to the International
Standard Classification of Education (UNESCO 1975, 1997), which was created
to allow international comparison among systems of education.

Difficult or complex text may be appropriate for most members of the
intended audience (that is, most of the people for whom the content has been
created). But there are people with disabilities, including reading
disabilities, even among highly educated users with specialized knowledge of
the subject matter. It may be possible to accommodate these users by making
the text more readable. If the text cannot be made more readable, then
supplemental content is needed.”
End quote.

>From the “Understanding WCAG 2.0” document, it appears that when deciding
whether or not supplementary content needs to be provided under Guideline
3.1.5, web authors and developers should use Level 2 of the International
Standard Classification of Education as the yardstick. However, I am not
aware where in Level 2 of ISCE, specific reference is made to readability or
comprehension of a document or how these should be determined. It is my
understanding the International Standard Classification of Education is
primarily concerned with providing a framework for the collection and
reporting of internationally comparable education statistics and not with
how the educational (or reading) abilities of individuals should be
determined or accommodated.

The second point relating to the intention of success criterion 3.1.5 is “to
establish a testable measure indicating when such additional content is
required”. Where in Level 2 of the International Standard Classification of
Education is there a testable measure that can be used to determine the
readability of a document? In order to comply with this success criterion,
are the web authors required to familiarise themselves with the educational
systems and criteria of all the countries with people who may want to access
the site?

In the case of WCAG 2.0, Success Criterion 3.1.5, the strive for testability
may ultimately undermine the overall intention of making text content
readable and understandable to the widest possible audience. Is it too
cynical to suggest that this is why the need to ensure documents can be
understood is now a Level 3 Success Criterion and so will be easier to

I strongly urge the WCAG 2.0 Working Group to reconsider the needs of people
with cognitive disabilities and learning difficulties. In particular, to
redefine what determines Level 1 Success Criterion so that the need for
documents to be clear and simple so that they may be more easily understood
is a requirement for Level 1 conformance. Also, if WCAG 3.1.5 is intended to
be testable, the Working Group should ensure the inclusion of advice on the
overall aim and intention of the testing process and how it could be done.

 As a final comment, does the Working Group believe the 23 November 2005
Draft of the WCAG 2.0 conforms to Guideline 3.1.5? If not, I hope the
“Understanding WCAG 2.0” document is not considered adequate ‘supplemental
Received on Monday, 19 December 2005 06:03:19 UTC

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