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Comments on WCAG2.0 - W3C Working Draft 30 June 2005 - from The Swedish National Accessibility Centre

From: Sören Hansson <Soren.Hansson@ho.se>
Date: Fri, 22 Jul 2005 15:51:54 +0200
Message-ID: <165B06BCB69460479AC33C2C34E6E7621EF58F@stex02.ho.se>
To: <public-comments-wcag20@w3.org>
Cc: "Anna-Klara Mehlich" <Anna-Klara.Mehlich@ho.se>, "Anneli Joyce" <Anneli.Joyce@ho.se>, Kristina Wassén <Kristina.Wassen@ho.se>, Eva Carlson Wåhlberg <Eva.Carlson.Wahlberg@ho.se>, "Denizhan Funda" <Funda.Denizhan@statskontoret.se>, "Burell Magnus" <Magnus.Burell@statskontoret.se>, "Thoren Clas" <Clas.Thoren@statskontoret.se>, "Hans von Axelson" <Hans.von.Axelson@ho.se>, <lars.lindberg@social.ministry.se>, <olleo@w3.org>
Comments on Web Content Accessibility Guidelines 2.0 W3C Working Draft 30 June 2005 from The Swedish National Accessibility Centre at the Office of the Disability Ombudsman, HO, by Sören Hansson. 


1)       In general, is this WCAG 2.0 Working Draft easy to understand?

Our answer: Yes, mostly I find it very easy to understand. 


2)       Should a validity success criterion be addressed at Level 1 or Level 2?

Our answer: Accessibility is the primary goal. Validity is important but not essential for accessibility. Too much demand for validity may decrease creativity and development for future better accessibility. A white paper from W3C on the value of validity will together with an editorial note in the WCAG 2.0 be enough. People could point to that as a clear statement from W3C. It will remove the burden from WCAG 2.0 to promote validity.


3)       Is the baseline approach that will allow authors the flexibility to use new technologies which are most widely available and accessible, something to go on with?

Our answer: We support the suggested baseline approach. There are several benefits to separate the requirement and the guidelines from the solution. That makes it possible for better solutions and it does not hinder you from giving good examples of different solutions. That also invites the whole world to help with good solutions. There might be some trouble yet when some have to value the results of all solutions. Is it possible to find a method for self valuation? You may say that one shall use your suggested solution if they can not guarantee that their solution is accessible.  


4)       How many levels of conformance should be provided in WCAG 2.0? Should WCAG 2.0 have 2 or 3 levels of conformance? 

Our answer: The following reasoning above lead to only two levels of conformance should be provided. 


This is a question about how we look at the society and human rights. We believe that the society, including the web, shall be able to use by as many people as possible. We will follow the concept/principle of Design for All. (I believe you use the term Universal Design). If it is not possible within reasonable efforts to reach a Design for All solution you shall make a special solution for people with disabilities. Just making special solutions for people with disabilities is bad solutions that divide people into groups and you risk supporting discrimination. This does not prevent you to achieve additional accessibility enhancements for people with disabilities. Two levels is also cleaner and do not confuse so much. 


5)       Is the information in the Working Draft of WCAG 2.0 Checklist presented clearly? Is this format an effective tool to help determine conformance to WCAG 2.0?

Our answer: Yes, it makes the guidelines easier to follow but the checklist needs to be complemented when you implement ours and others comments with the guidelines.


6)       Does this draft address HO's previously raised issue?

Our answer: No, I can not find the in what way this draft meet following from the Office of the Disability Ombudsman previously raised issues. 

a)       It is still very important that pages are usable when scripts, applets, or other programmatic objects are turned off or not supported. It is also very important to help those, who make this information, with simple solutions to do the information accessible. If this is not possible the solution is to provide equivalent information on an alternative accessible page. But this solution is not a good solution since it is a special solution and not a universal design solution.


b)      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.


c)       Start each section of the website with a short summary in plain language. This makes it easer for everybody to understand if they have come to the right place or if they should search on another website. It gives also a good service to those who have hard of understanding whatever it depends on, for example languages difficulties, developmental disability or incipient dementia.  


d)      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.


Other comments

7)       Under guideline 1.1 there is an editorial note with the following question. "Does the above example help to clarify level 1 success criterion 5 or does it need additional clarification?

Our answer: There also ought to be an example where audio and video are combined. 


8)       Under Level 1 Success Criteria for Guideline 1.2 point 1 Captions are provided for prerecorded multimedia there are two questions. "Should a text transcript be required in addition to captions at Level 1?" and "There is concern by some that the captioning requirement is too high a bar at Level 1. Should it be moved out of level 1 or should it remain at Level 1 and use the scoping mechanism to scope uncaptioned multimedia out of the conformance claim?"

Our answer: If the captions follow standards and are possible to link to assistive technologies that makes it possible to change text size and text fonts there is no need to require text transcript. Otherwise yes and at Level 1 of course. 


But there also is a need for other solutions for a lot of small organizations that have no economic possibilities to caption all valuable information in videos which they want to show on Internet. Of course they shall give the same information in text but they shall not be forced to caption all videos. Otherwise the result instead will be information without videos. 


9)       Under Level 1 Success Criteria for Guideline 1.3 you talk about colors but you also ought to talk about fonts. A lot of people with dyslexia and/or visual impairment have benefits from changing the font. 


10)   Under Level 2 and Level 3 Success Criteria for Guideline 1.4 you also have to consider that color-blindness is about the same share for people who are visually impaired as for other. Therefore it may be better to talk about contrast together with color-blindness and then the contrast is depending of how bright/saturated the colors are. Two colors witch contrast very strongly but have the same brightness/saturation, for example red and green, may be impossible to separate for some people with color-blindness. Two colors with big difference in brightness/saturation on the contrary also have big contrast and can be seen by both those who are visual impaired and/or color-blind. 


Most important for people with color-blindness is however that no information shall built on that you have to be able to see a certain color. 


11)   Comments on Guideline 2.1 Make all functionality operable via a keyboard interface.

There is very often very troublesome to operate websites via a keyboard and this is partly due to lack of tab-positions and tab-order (when you tab through a website) partly due to insufficient showing of where the tabulator stops (very often nothing but a thin line hard to notice). Both these problems ought to be covered by this guideline.


12)   Another comment on Guideline 2.1 Make all functionality operable via a keyboard interface. I have not seen anything about "access keys". It allows the user to use keyboard keys for functions which are normally done using a mouse. For example, to follow a link, one might (in some environments) use the Alt key and a letter, as alternative to clicking on the link. This requires that the author has specified an access key assignment for that link, using the access key attribute. It would be good if that also became a standard for most websites. 


For the most commonly objects in a website following access keys ought to be used: 

S              Jump over the navigation, jump direct to the text content

0              About the website, accessibility information 

1              Start page 

2              News 

3              Web map 

4              Search function 

5              Usual question and answers (FAQ)

6              Help 

7              Contact


13)   Under "Who Benefits from Guideline 2.2 (Informative)" you ought to add people with physical disabilities that need more time to interact and people that are new on the web who also need more time.


14)   Actions are reversible aught to be Level 1 Success Criteria for Guideline 2.5.


15)   Comments to Principle 2: Interface elements in the content must be operable and Principle 3: Content and controls must be understandable. 

One of the guidelines under these principles has to clear out that links shall be understandable either through the text in the link or in some text equivalents. I have not seen it there. Perhaps it should be in Guideline 2.4 Provide mechanisms to help users find content, orient themselves within it, and navigate through it. 


It would also be good to have a guideline or some examples for how alt-texts should be written. There are already too many bad examples on the Internet. 


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 

Phone: +46 8 6930367 or +46 70 2802925

Text phone: +46 8 21 39 39,

Fax: +46 8 20 43 53

Website: www.ho.se <http://www.ho.se/>  
Received on Friday, 22 July 2005 13:52:10 UTC

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