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WCAG 2.0 Comment Submission

From: WCAG 2.0 Comment Form <nobody@w3.org>
Date: Wed, 21 Jun 2006 14:10:00 +0000 (GMT)
To: public-comments-wcag20@w3.org
Message-Id: <20060621141000.CF72647BA1@mojo.w3.org>

Name: Ulrike Peter
Email: upeter@ifib.de
Document: W2
Item Number: (none selected)
Part of Item: 
Comment Type: general comment
Comment (Including rationale for any proposed change):
We are concerned about Principle 3 “Content and controls must be understandable”. 


We appreciate the restructuring of WCAG2 into four general principles allowing more independence of technology. But we fear that in practice the focus will be exclusively on the success criteria. This risk should be countered.

We demand that the principles and the guidelines of WCAG2 are given more importance and value. The success criteria should be defined as one (of several) possibilities to secure the WCAG2. The limitations of the success criteria have to be pointed out. The focus should be laid on the assurance of the principles and guidelines.

Criticism on the success criteria of the third principle 

In the more general formulations of the revised WCAG2, also those checkpoints of WCAG1 can be found which have already become law in many European countries. Comparing the concrete implementation recommendations of WCAG2 (the success criteria) with those of WCAG1 (the checkpoints), it shows for the area of understandability that the aspects relating to the contents have got lost: In WCAG1, the requirement 14.1 „Use the clearest and simplest language appropriate for a site\'s content“ has the highest priority. In WCAG2, the guideline 3.1 includes content aspects of readability and text understanding. In the success criteria for 3.1, however, these requirements are missing. The success criteria included in WCAG2 now represent only side aspects of understandability which can be technologically checked. The much more important aspects in the area of understandability can only be submitted to standardized tests on the basis of expertise and considering the specific target groups of the web offer. In Germany,this is established practice, and know-how is available. The certification procedure based on the BITV, the German adoption of WCAG1, as well as the BIENE Award procedure follow these requirements on the basis of German law demanding not only the implementation of the „conditions“ (corresponding to the checkpoints of WCAG1), but also the implementation of the „requirements“ (corresponding to the guidelines of WCAG1).

The certification procedure of DIN CERTCO has been developed by leading representatives of science, practice and associations of people with disabilities. Beside the product quality of the web offer, also the process quality of the content tendance is evaluated. The BIENE Award is a competition carried out since 4 years awarding prizes to the best accessible German-language web offers which thus become models for the discussion. Besides expert tests, the test procedure also includes tests with people with different disabilities.

Exclusion of people with learning difficulties and cognitive limitations

The definition of target groups in the WCAG2 explicitly refers to people with learning difficulties and cognitive limitations. On the level of principles and guidelines we find the requirements of this target group, but not on the level of success criteria. This is where the exclusion takes place. Though the success criterium 3.1.5 demands that additional contents is offered if the language level of the texts is above the secondary education level, this does not mean that the requirements of the target group with learning difficulties and cognitive limitations are met. Further, it remains unclear how it is made sure that the texts keep the required level.

Proposed Change:
Received on Wednesday, 21 June 2006 14:10:01 UTC

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