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SV: Call for Review: Working Draft of Web Content Accessibility Guidelines 2.0 - HO dnr 2005/3100

From: Sören Hansson <Soren.Hansson@ho.se>
Date: Mon, 19 Dec 2005 13:52:20 +0100
Message-ID: <165B06BCB69460479AC33C2C34E6E7622C6AB9@stex02.ho.se>
To: "Wendy Chisholm" <wendy@w3.org>, <public-comments-wcag20@w3.org>
Cc: "Bruno von Niman" <bruno@vonniman.com>, <Funda.Denizhan@statskontoret.se>, Sören Hansson <soren.hansson@tidkume.se>, <carl.alfvag@social.ministry.se>, "Thoren Clas" <Clas.Thoren@statskontoret.se>, "Birgitta Mekibes" <Birgitta.Mekibes@ho.se>, "Elisabet Svensson" <Elisabet.Svensson@ho.se>, "Hans von Axelson" <Hans.von.Axelson@ho.se>, Ken Gammelgård <Ken.Gammelgard@ho.se>, "Burell Magnus" <Magnus.Burell@statskontoret.se>, <lars.lindberg@social.ministry.se>, <olleo@w3.org>

Comments on Call for Review: Working Draft of Web Content Accessibility   Guidelines 2.0 from The Swedish National Accessibility Centre at the Office of the Disability Ombudsman, HO, by Sören Hansson.

Comments on the set questions
1. This draft represents a significant reorganization of the WCAG
    document set of guidelines and support documents.  It includes
    changes to the wording of individual  success criteria.  It also
    provides a rationale and a listing of techniques deemed sufficient
    for each success criterion.
    - In general, is the new organization easier to understand?
    - Are success criteria at the right conformance level?
    - Are success criteria accurately worded?  Are they understandable?

Our answer: Yes, the new organization is in general easier to understand. 

About the success criteria we have the following points of view. 

We want you to change 1.2.1 to "Captions for pre-recorded multimedia are provided intermixed with a text description of what is happening visually." Then it is possible to get both a text that close enough convey everything that are expressed in words and another text (preferable in another colour) that convey what is happening visually.

We want you to keep 1.2.2 to "Audio descriptions of video are provided for pre-recorded multimedia". Then it is possible to listen to the text, either the whole or just the one about what is happening, that is provided in 1.2.1 perhaps in another language than the original. The discussed change in the editorial note does not make it easier to get what is needed.  

About "1.2.4 Sign language interpretation is provided for multimedia" we believe deaf people's accessibility problems are more complex than for multimedia. 
We believe you could do better. We suggest that you make a criterion that says that web sites shall offer basic information about the organization/website and information of central social interest in sign language interpreted versions on the website (national sign language). This makes websites accessible to severely hearing-impaired or deaf people. 

It would also be very good if you could give a quality standard to which the show in sign language ought to live up to.

About 2.2.2 we do not know how widespread the problem is with individuals who are unable to turn blinking content off but we suggest that you find a general (standard) method to turn blinking content off that everybody are able to use. If you always know how to turn it off you perhaps may have a script from your browser supplier that turn it off before you noticed it as a problem.

We want you to change guideline 4.2 to just "4.2 Ensure that user interfaces are accessible". Do not accept inaccessible user interfaces. 

Acceptance of inaccessible user interface if an accessible alternative is provided may lead to acceptance of other forms of discriminations. A comparison with buildings may show the absurdity. It is not acceptable to build "new apartment houses with inaccessible main entrances even if you build another accessible entrance". The comparison lead to that we shall not accept inaccessible user interfaces on the web. Special solutions for accessibility shall only be used if there are no other solutions. General solutions shall be the norm. 

As a consistency of our standpoint about guideline 4.2 we do not want the success criterion "4.2.1 If content does not meet all level 1 success criteria, then an alternate version is available from the same URI that does meet all level 1 success criteria." Our standpoint is that this success criterion shall be removed. 

We have no comment on the editorial note on the 4.2.5 success criterion. 

2. This is the first publication of "Understanding WCAG 2.0." The WCAG WG
    considers this document to be essential for understanding the success
    criteria in the Web Content Accessibility Guidelines 2.0 (WCAG 2.0).
    - In general, does this document help you understand what
    WCAG 2.0 is, and how to use it?
    - Does this document adequately clarify each success criterion?
    - If not, what additional clarification is needed?

Our answer: In general we believe the document "Understanding WCAG 2.0." will help people to understand WCAG 2.0. The text however is too long. We also believe that the arguments have to carry the principle of all peoples same rights to public information in an accessible and in an equally valuable way all the way. We do not find this, especially not about the 4.2.1 success criterion.

Other comments that we have risen previously but did not find that you have paid attention to.
a) Offer basic information about the organization/website and information of central social interest in easy-to-read versions on the website. This makes websites accessible to people with a developmental disability or incipient dementia. If you do not pay attention to people with developmental disability (mentally retardation) we have to add this when we refer to WCAG in our accessibility guidelines, which you can find under http://www.tillganglig.se/start.asp?sida=1450  

b) Give some examples for how alt texts should be written in the document "Understanding WCAG 2.0." There are already too many bad examples on the Internet. 

>From 1 January 2006 the Swedish National Accessibility Centre will be part of the new government agency Handisam - The Swedish Agency for Disability Policy. Handisam will be coordinating the implementation of the national action plan for disability policy "From patient to citizen" (Government Bill 1999/2000:79) adopted by the Riksdag in the spring of 2000. 

You may already have paid attention to these suggestions and I apologise if I have missed that.

Best regards
Sören Hansson
++++++++++++++++++++++++++++
Postal address:
Office of the Disability Ombudsman
National Accessibility Centre
Sören Hansson
Box 49132, SE-100 29 Stockholm, Sweden
Visitors´ address: S:t Eriksgatan 44, 3 tr.
E-mail: soren.hansson@ho.se 
>From 1 January 2006 new e-mail: soren@handisam.se 
Phone: +46 8 6930367 or +46 70 2802925
Text phone: +46 8 4066559,
Fax: +46 8 20 43 53
Web site: www.ho.se 

-----Ursprungligt meddelande-----
Från: w3c-wai-ig-request@w3.org [mailto:w3c-wai-ig-request@w3.org] För Wendy Chisholm
Skickat: den 24 november 2005 01:47
Till: w3c-wai-ig@w3.org
Kopia: jbrewer@w3.org; po@trace.wisc.edu; john_slatin@forum.utexas.edu; Ben Caldwell
Ämne: Call for Review: Working Draft of Web Content Accessibility Guidelines 2.0


Dear WAI Interest Group Participants:

A new Working Draft of the Web Content Accessibility Guidelines 2.0 (WCAG
2.0) as well as two supporting documents were published 23 November 2005.
The Web Content Accessibility Guidelines Working Group (WCAG WG) invites
you to comment on these documents. W3C Working Drafts provide opportunities
for public comment during the development of a specification. This message
contains information on the document and how to comment. Please send
comments to the public comments mailing list by 21 December 2005:
      public-comments-wcag20@w3.org

WCAG 2.0 addresses accessibility of Web content for people with disabilities.
It will apply to a wider range of Web technologies than WCAG 1.0 and is
intended to be understandable to a wider audience.

Since the previous public Working Draft of WCAG 2.0, published on 30 June
2005, the WCAG WG has been addressing comments received on previous drafts.
With this Working Draft, the WCAG WG introduces a new format and a document,
"Understanding WCAG 2.0" that provides explanatory information for each
success criterion.  A good place to start a review of WCAG 2.0 is with the
"Introduction to  Web Content Accessibility Guidelines (WCAG) 2.0 Working
Draft Documents." The Introduction explains the relationships  between
WCAG 2.0 and the supporting documents, and links to the  current version
of  each document. The Introduction is available at:
      <http://www.w3.org/WAI/intro/wcag20>

The documents published on 23 November 2005:
      - Web Content Accessibility Guidelines 2.0
        <http://www.w3.org/TR/2005/WD-WCAG20-20051123/>
      - Understanding WCAG 2.0
        <http://www.w3.org/TR/2005/WD-UNDERSTANDING-WCAG20-20051123/>

Note:  The November 2005 Working Drafts do not include all of the techniques.
Only a small portion have been converted to the new format for this draft.
The rest will follow in the next release.
      - HTML Techniques for WCAG 2.0
        <http://www.w3.org/TR/2005/WD-WCAG20-HTML-TECHS-20051123/>


The Working Group is interested in discussion of the following questions.

1. This draft represents a significant reorganization of the WCAG
    document set of guidelines and support documents.  It includes
    changes to the wording of individual  success criteria.  It also
    provides a rationale and a listing of techniques deemed sufficient
    for each success criterion.
    - In general, is the new organization easier to understand?
    - Are success criteria at the right conformance level?
    - Are success criteria accurately worded?  Are they understandable?

2. This is the first publication of "Understanding WCAG 2.0." The WCAG WG
    considers this document to be essential for understanding the success
    criteria in the Web Content Accessibility Guidelines 2.0 (WCAG 2.0).
    - In general, does this document help you understand what
    WCAG 2.0 is, and how to use it?
    - Does this document adequately clarify each success criterion?
    - If not, what additional clarification is needed?


Please send your comments by 21 December 2005 to:
      public-comments-wcag20@w3.org
The archive for that mailing list is available at:
      http://lists.w3.org/Archives/Public/public-comments-wcag20/>


If possible, please include the following information when replying:
      a. Clearly specify the guideline, success criterion, or section that
         the comment is about.
      b. State the issue as clearly and simply as possible.
      c. Provide links, examples or references.
      d. Provide a suggestion for how to address the issue.
         Suggested wording is very helpful.
      e. Remember that the Working Group welcomes volunteers
         to help with the work.

When waiting for responses to comments:
   - You can track your issue in the open issues list
    <http://trace.wisc.edu/bugzilla_wcag/condensedreports/wcag2_issues.php>
   - Follow up on the mailing list if you don't find your issue in the
      open issues list.


Please let us know if you have any questions.  Additional information on the
Working Group is available at:
      <http://www.w3.org/WAI/GL/>


Note:
The feedback we receive on this draft will help us determine how close we
are to publishing a Last Call Working Draft.  Once we enter Last Call it will
take several months to progress through  the W3C Recommendation Track.
Until WCAG 2.0 becomes a W3C Recommendation, WCAG 1.0 will continue to
be the current and stable document to use. If your site currently conforms to
WCAG 1.0, be assured  that conformance to WCAG 2.0 will not require a
complete redesign of your  site but it will likely require some tweaks.


Note:
This message may be circulated to other lists, avoiding cross-postings
where possible.


Thank you in advance for your comments,

Wendy Chisholm - W3C Team Contact for WCAG WG
Gregg Vanderheiden - Co-chair of WCAG WG, and Director of Trace R&D Center
John Slatin - Co-chair of WCAG WG, and Director of the Accessibility
Institute at UT
Judy Brewer - Director, Web Accessibility Initiative, W3C
Received on Monday, 19 December 2005 12:53:17 UTC

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