Greg Lowney's Comments on WCAG 2.0 Draft of 2006-04-27

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Greg Lowney's Comments on WCAG 2.0 Draft of 2006-04-27

Commenter: Greg Lowney

Email: gcl-0039@access-research.org

Affiliation: Lowney Access Research, LLC

Date: 6/22/2006

 

 

COMMENT #1 Content that requires 4.2 can never conform (W2,Conformance
Levels and the Baseline,)

 

The Conformance section and SC 4.2 clearly contradict each other. The
section on Conformance currently reads "WCAG 2.0 conformance at level A
means that all Level 1 success criteria in the guidelines are met assuming
user agent support for only the technologies in the specified baseline." By
contrast, 4.2.1 and 4.2.3  say "At least one version of the content meets
all level N success criteria, but alternative version(s) that do not meet
all level N success criteria may be available from the same URI." 

 

Take for example a URI that has two versions of the same content, one not
meeting SC 1.1.1 and the other an accessible alternative that does meet
1.1.1. Can that URI conform at Single-A? Under the current wording of the
Conformance section, the answer is clearly NO! That page complies with 4.2.1
(by providing an accessible alternative), but it still fails 1.1.1: the
rules stated in the Conformance section provide no exemption from 1.1.1 just
because something passes 4.2.1, nor does 1.1.1 itself define any such
exemption.

 

If conforming with 4.2.1 is meant to provide exemptions from most other
Level 1 criteria, the document MUST say that in the normative Conformance
section or in the description of each success criterion.

 

You might say that the intent is understood, but the question is, is the
intent supported or contradicted by the actual wording of the normative
sections of the document?

 

Proposed Change:

 

Change Conformance to explicitly say that conformance requires that each URI
conforms with all SC of the appropriate level OR that an accessible
alternative that does so is available from the same URI (with a link to the
details of what that means, currently in the Understanding document's
discussion of Guideline 4.2).

 

OR, change the section "Conformance Levels and the Baseline" to say that
only conformance with criterion 4.2.1 is required to claim Single-A
conformance, and leave it to 4.2.1 to require all the rest of the Level 1
criteria."

 

 

COMMENT #2 Clarify when it's acceptable for content's default presentation
to not comply. (W2,Conformance Levels and the Baseline,)

 

This is closely related to the previous comment on Conformance, and a
follow-up to existing issue 1590.

 

I was unable to spot where, in the Conformance section or elsewhere, it is
made explicit whether success criteria need to be met all the time, or by
default, or only on request. For example, 1.4.1 says "Text or diagrams, and
their backgrounds, have a luminosity contrast ratio of at least 5:1"; is it
acceptable if that is a user-selectable option, and if so, does it have to
be on by default? The closest I can find to addressing this is Guideline
4.2, "Ensure that content is accessible or provide an accessible
alternative," under which SC 4.2.1 (for example) says "At least one version
of the content meets all level 1 success criteria, but alternate version(s)
that do not meet all level 1 success criteria may be available from the same
URI." This can be taken as making it clear that all success criteria can be
met at the user's request, and do not need to be met in the default
configuration. However, it seems strange to have success criteria in one
guideline (4.2) effectively define exceptions to every other success
criteria in the document, essentially saying "You know that thing we said
you have to do? Well, you don't have to do it under certain circumstances."
As a result, 4.2.x are the only success criteria that are actually required;
the rest are all conditionally required, although you won't find this out
unless you read 4.2.

 

Proposed Change: none provided

 

 

COMMENT #3 Not all assistive technologies are user agents (W2,Baseline,)

 

The paragraph defining "user agent" implies that it incldues all AT, whereas
it really only includes some AT. It reads: "It is important to note that
assistive technologies are included in this definition. Assistive
technologies include screen readers, screen magnifiers, on-screen and
alternative keyboards, single switches, voice recognition, and a wide
variety of input and output devices that meet the needs of people with
disabilities."

 

Proposed Change:

 

Add phrases shown in upper case: "It is important to note that MANY
assistive technologies are included in this definition. SUCH assistive
technologies include screen readers, screen magnifiers, on-screen and
alternative keyboards, single switches, voice recognition, and a wide
variety of input and output devices that meet the needs of people with
disabilities."

 

 

COMMENT #4 Remove abbreviations in example conformance claims
(W2,Conformance Claims,Examples)

 

The example conformance claims are invalid because they omit the full name
and URI of the guidelines, which are required according to the section
"Required components of a conformance claim". 

 

Proposed Change:

 

Replace "W3C's WCAG 2.0" with "Web Content Accessibility Guidelines 2.0 at
http://www.w3.org/TR/2006/REC-WCAG20-YYYYMMDD/"

 

 

COMMENT #5 Clarify scope of a URI in conformance claim (W2,Conformance
Claims,Required components of a conformance claim)

 

One required component of a conformance claim is "Scope of the claim (a URI,
list of URI's, or a set of URIs defined by a regular expression)," and the
examples each include a single URI. This, the Examples, and the Conformance
Notes all fail to clarify whether citing a single URI implies conformance is
claimed for that one web page (or equivalent), or all pages referenced by
it, or all pages "beneath it" on the server. For example, does claiming
conformance for http://telcor.example.com/nav/G7/intro.html mean that
conformance is claimed just for that one page, or for all the pages it links
to, or all the pages in the /nav/G7/ directory on the server, including or
not including subdirectories? I suggest clarifying this and also including
an example of a claim for an entire Web site or multi-page portion thereof.

 

Proposed Change: none provided

 

 

COMMENT #6 Remove JPEG from "specifications this content relies upon"
(W2,Conformance Claims,Examples)

 

The example conformance claims list things like jpeg as 'specifications that
this content "relies upon"'. How can jpeg ever be a relied upon
specification since the guidelines require Web pages to be usable even when
the images are turned off?

 

Proposed Change:

 

Remove JPEG from list of "specifications that this content relies upon", or
else clarify what is meant by including it."

 

 

COMMENT #7 Harmonize periods in WCAG references (W2,How to refer to WCAG 2.0
from other documents,Examples)

 

The guidance says that when referencing WCAG 2.0 with its full name and URI,
a period should be used after the date and before the parenthetical URI.
However, this is not how it's shown in the Examples. I suggest removing the
period from the guidance and leaving the examples as they are.

 

Proposed Change:

 

Remove period after date, to read: "Web Content Accessibility Guidelines
2.0, W3C World Wide Web Consortium Recommendation XX Month Year
(http://www.w3.org/TR/200X/REC-WCAG20-YYYYMMDD/, Latest version at
http://www.w3.org/TR/WCAG20/)"

 

 

COMMENT #8 Change "multiple disabilities" to "different disabilities"
(W2,1.1.1,Bullet 3)

 

In the phrase "different forms are provided to accommodate multiple
disabilities", the word "multiple" could be read as saying these forms
should address the needs of an individual with multiple disabilities, which
is a nice goal but not the baseline requirement.

 

Proposed Change:

 

Change "different forms are provided to accommodate multiple disabilities"
to "different forms are provided to accommodate different disabilities"."

 

 

COMMENT #9 Normalize order of clauses (W2,1.2.7,Description)

 

The order of the two clauses is reversed from all the other success criteria
for guideline 1.2.

 

Proposed Change:

 

Change "For prerecorded multimedia, a full multimedia text alternative
including any interaction is provided" to read "A full multimedia text
alternative including any interaction is provided for all prerecorded
multimedia."

 

 

COMMENT #10 Visually evident without color (W2,1.3.2,Description)

 

The phrase "visually evident without color" could be misinterpreted as
meaning "visually evident, and without color". Suggest rephrasing to be less
ambiguous.

 

Proposed Change:

 

Change "visually evident without color" to read "visually evident even if
any color cannot be perceived"."

 

 

COMMENT #11 Conveying information by contrast alone (W2,1.3.2,Description)

 

The guideline reads, "Any information that is conveyed by color is also
visually evident without color." This wording clearly implies that it is
acceptable to convey information by contrast, a technique that is discussed
in other criteria but overlooked both here and its Understanding. Is the
intent here to make sure information is visually evident without perceiving
color and contrast, or to say that conveying information by contrast alone
is acceptable? I suspect the former. If the latter, we should provide
guidance for 1.3.2 on minimum acceptable contrast between items when
color/contrast is used alone to denote differences in type, state, etc.,
just as we do for differences between foreground and background elsewhere.
Even if the former, such guidance on the use of contrast would be valuable
as a Level 2 or Level 3 criterion.

 

Proposed Change:

 

Change to read "Any information that is conveyed by color or contrast is
visually evident even if any color and contrast cannot be perceived.."

 

 

COMMENT #12 Clarify meaning of sequence (W2,1.3.3,Description)

 

The wording "When the sequence of the content affects its meaning, that
sequence can be programmatically determined" is ambiguous as to whether it
refers to intended viewing/reading order, keyboard navigation order,
presentation order (e.g. navigation links are at the top despite the
designer's intention that they not be actually read on every page), and/or
declaration order (e.g. content is declared early in the HTML despite being
positioned at the bottom of the page using vertical alignment attributes).
The Understanding section only addresses conveying intended reading order,
but if that is the intention, the wording of the Success Criterion should
reflect that. However, other ordering may be important to some types of
assistive technology (e.g. keyboard navigation order for use by speech
recognition software).

 

Proposed Change: none provided

 

 

COMMENT #13 Reliance on visual location for form control labels
(W2,1.3.5,Description)

 

1.3.5 says information required to operate the content should not rely on
visual location or orientation of components, but in HTML forms the
association between a control (e.g. radio button) and its visual label (e.g.
static text nex to it) are only exposed programmatically through the DOM and
visually by the spatial relationship between the two objects. The only way
to avoid relying on spatial cues is to use assistive technology; is that the
intention of this criterion, even though the word "programmatically" does
not appear in the wording and the Understanding and Techniques don't
explicitly mention steps to assist assistive technology?

 

Proposed Change: none provided

 

 

COMMENT #14 Remove contrast requirement for purely decorative areas
(W2,1.4.1,Description)

 

1.4.1 specifies a minimum luminosity contrast between text or diagrams and
their backgrounds. Often diagrams include portions that convey information
and other portions that are purely decorative; in such cases, shouldn't this
criterion apply only to portions of the text or diagram that are functional
or convey information? Large text used as a decorative element behind the
text of a Web page is an example of purely decorative text, and in such
cases you really need to retain low contrast with the background.

 

Proposed Change:

 

Change to read "Portions of text or diagrams that are not purely decorative
have a luminosity contrast ratio of at least 5:1 when compared with their
backgrounds."

 

 

COMMENT #15 Clarify meaning of background audio (W2,1.4.2,Description)

 

1.4.2 requires a mechanism to turn off "background audio that plays
automatically, without requiring the user to turn off all audio". This is
good except that "background audio" is not defined. Is it audio that is
played at the same time as other audio, but is considered to be less
important (i.e. background behind other audio)? Or Is it audio that is
purely decorative and/or atmospheric, but not required for understanding or
use of the web unit (regardless of whether other audio is playing)?

 

Proposed Change:

 

Define "background audio", or change "background audio" to either "audio" or
"purely decorative audio"."

 

 

COMMENT #16 "Four times quieter" is meaningless (W2,1.4.4,)

 

1.4.4 Note uses the phrase "four times (4x) quieter", but that seem a
meaningless term. One can only talk about something being "four times
louder" because loudness is measured relative to the absence of audible
sound. "Four times quieter" would only make sense if noise A is compared
with some other, even louder sound.

 

Proposed Change:

 

Change to read "Background sound that meets this requirement will be
approximately one quarter as loud as the foreground audio content."

 

 

COMMENT #17 Session time-outs are time-dependent (W2,2.1.1,)

 

2.1.1 requires all functionality of the content to be operable in a
non-time-dependent manner through a keyboard interface. However, many Web
sessions eventually time out, and there is no practical way to design the
server software to avoid this. Even when the Web content complies with
criterion 2.2.1 and 2.2.6, which in many cases requires the user have some
control over such time-outs, that does not make it comply with 2.1.1.

 

Proposed Change:

 

Define "non-time-dependent manner" as "method that does not require user
action within any period shorter than ten minutes", or else add a Note to
2.1.1 explaining that server-based session time-outs of at least some
minimum duration are not considered part of the content."

 

 

COMMENT #18 Normalize use of Time Limits vs. Time-Outs (W2,2.2.1,)

 

2.2.1 Is there a difference between a "time-out" and a "time limit"? The
title refers to "time limits" but the wording of the SC uses "time-outs" in
all but one instance.

 

Proposed Change:

 

Change "time-out" to "time limit" throughout 2.2.1."

 

 

COMMENT #19 Remove phrase "that is a function of the content" (W2,2.2.1,)

 

2.2.1 applies to each time-out "that is a function of the content". Does
that include time-outs that are applied by the server software, and of which
the Web unit may have no knowledge (e.g. session timing out from
inactivity)? Clarification is needed. The Understanding document addresses
this but fails to clarify it, but it looks like server-based session
time-outs would be non-conforming.

 

Proposed Change:

 

Remove the phrase "that is a function of the content".

 

Add clarification of server-based session time-outs to the Understanding
document or the SC itself."

 

 

COMMENT #20 Time limits on confirming ticket purchases (W2,2.2.1,Examples)

 

Is it intended that ticket purchasing Web sites fail to conform because they
only give the user two minutes to confirm a purchase before the seats are
returned to the general pool and the user must start the process over again?
If you don't want that fail, which of the exceptions would it fall under? (I
don't see it falling under any of them as currently written.) If you do want
it to fail, what would you recommend such sites do in order to become
compliant, allow the user to extend the time limit up to a maximum number of
times? This would be a good example to add.

 

Proposed Change:

 

Add to Understanding of Techniques an example of a ticket-purchasing Web
site that allows the user two minutes to confirm purchase of selected seats,
but warns the user when their time is almost out and allows the user to
extend this time limit some number of times with a simple action such as
clicking a "Extend time limit" button. "

 

 

COMMENT #21 Animated GIFs vs. prohibition on blinking (W2,2.2.2,Description)

 

2.2.2 requires content to not blink for more than three seconds or a method
be available to stop all blinking in the Web unit or authored component.
Many Web sites display GIF images that are provided by a third-party (e.g.
advertisements, or user-contributed photos); are such sites required to
ensure that none of those are animated GIFs, in case some blink? Is it
sufficient for the authors to define a baseline that includes user agents
that allow the user to stop blinking on the current Web unit (e.g. pressing
ESC)?

 

Proposed Change: none provided

 

 

COMMENT #22 Pausing vs. Stopping content (W2,2.2.3,Description)

 

2.2.3. requires that content can be paused by the user (barring certain
exceptions). Pausing, as opposed to Stopping, implies there is UI to
un-pause the content. Would it be acceptable to allow decorative content to
be stopped, but not provide UI to resume it? The current wording would
preclude that.

 

Proposed Change: none provided

 

 

COMMENT #23 Ambiguity in "skipped using" (UW,2.4.1,)

 

"Grouping blocks of repeated material in a way that can be skipped USING one
of the technology-specific techniques below (for a technology in your
baseline)" is ambiguously worded due to a dangling participle. I read it at
first as equivalent to saying "Group blocks of repeated material, using a
method that can be skipped using the techniques." 

 

Proposed Change:

 

Insert a comma so it reads "Grouping blocks of repeated material in a way
that can be skipped, USING one of the technology-specific techniques below
(for a technology in your baseline)"

 

 

COMMENT #24 Re-presenting information for review (W2,2.5.3,Description)

 

2.5.3 option 3 is that the user is able to review and confirm or correct
information before submitting it. However, in almost all cases the user can
pause after entering data, and review it before pressing ENTER or clicking
SUBMIT, etc. I believe the intent of this option is that pressing ENTER or
clicking SUBMIT should bring up a new Web unit that displays how the system
interpreted what the user wrote (as opposed to what they thought they were
writing). If so, shouldn't the wording make this clearer?

 

Proposed Change:

 

Change to read "The user is able to have the information they entered
re-presented to them so they may review and confirm or correct it before
final submission."

 

 

COMMENT #25 Recommend UNDO for all actions (W2,2.5.3,)

 

2.5 3 requires, for Double-A, that methods are provided to help avoid or
undo errors, but only for a certain narrowly-defined set of interactions. I
would recommend that these steps, or at least UNDO, be repeated as a level 3
success criterion, but applying to all interactions rather that just those
listed in 2.5.3.

 

Proposed Change:

 

Add a new Level 3 success criteria: 

 

"2.5.5 For all user actions, at least one of the following is true:

 

   1.      Actions are reversible.

 

   2.      Actions are checked for input errors before going on to the next
step in the process.

 

   3.      The user is able to have the information they entered
re-presented to them so they may review and confirm or correct it before
final submission."

 

"

 

 

COMMENT #26 Unambiguous parsing requires format specifications
(W2,4.1.1,Description)

 

4.1.1 requires that Web content to be parsed unambiguously. Does this
require the formal specifications be open, so that new user agents can parse
the content? For example, suppose the baseline specifies just one Web
browser, that implements rules for applying defaults to resolve any
potential ambiguities in HTML that might be interpreted differently if
another browser were used; is the HTML parsable unambiguously within the
scope of the baseline? As another example, suppose a Web uses a proprietary
data format that only a single plug-in can render; does it matter if it's
parsable unambiguously if there is only one renderer?

 

Proposed Change:

 

Insert the phrase ", using publicly available specifications", to read "Web
units or authored components can be parsed unambiguously, using publicly
available specifications, and the relationships in the resulting data
structure are also unambiguous."

 

 

COMMENT #27 "User agents" is already includes assistive technologies
(W2,4.1.2,Description)

 

4.1.2 includes the phrase "available to user agents, including assistive
technologies", but other criteria say "available to user agents" without the
"including assistive technologies". The phrase is not strictly required
since we define user agents as including assistive technologies; you may
feel it's useful to re-emphasize that here, but if that's the case, wouldn't
it also be warranted in those criteria that say "programmatically..." by
adding "including assistive technology" to the definitions of
programmatically set and programmatically determined?

 

Proposed Change:

 

Delete the phrase ", including assistive technologies", to read "For all
user interface components, the name and role can be programmatically
determined, values that can be set by the user can be programmatically set,
and notification of changes to these items is available to user agents."

 

 

COMMENT #28 Add "OR" to item 2 in ordered list (UW,4.2.1,Understanding)

 

In " Techniques for Addressing Success Criterion 4.2.1", the ordered list of
three items has "OR" between items 1 and 2, but nothing between items 2 and
3 to clarify their boolean relationship. 

 

Proposed Change:

 

Insert "OR" at the end of bullet item 2."

 

 

COMMENT #29 Need to accessibly document exit method for non-baseline content
(W2,4.2.2,Description)

 

4.2.2. says that if the user can enter content using the keyboard they must
also be able to exit it using the keyboard, even if the content uses a
non-baseline technology. This helps, but is not a complete solution, because
it does not require that the keyboard method be discoverable by the user,
especially if the user has a disability (e.g. a screen that cannot be read
by a screen reader displays "text" telling the user they can exit by
pressing F10, but the user who relies on the screen reader has know way of
figuring that out). This is addressed in Techniques, but I fear that is
inadequate because such documentation is so critical.

 

Proposed Change:

 

Change "If content can be entered using the keyboard, then the content can
be exited using the keyboard." to read: "If content can be entered using the
keyboard, then the content can be exited using the keyboard, and the method
for doing so is described using technology in the baseline."

 

 

COMMENT #30 Acronyms not always initial letters of multiple words
(W2,A.Acronym,)

 

Definition of ACRONYM is defined incorrectly as an "abbreviation made from
the initial letters", but it should be "abbreviation made from
non-contiguous letters of a name or phrase". These are usually the initial
letters, but not always; the name being abbreviated is usually made up of
more than one word, but not always; and the acronym sometimes contains extra
letters that don't occur in the original phrase, but are added in to aid in
pronunciation. 

 

Proposed Change:

 

Change to "abbreviation made from non-contiguous letters of a name or
phrase"."

 

 

COMMENT #31 Link to definition of "functionality" (W2,A.Alternate version,)

 

Definition of ALTERNATE VERSION is defined using the term "functionality",
which should be a link to that definition.

 

Proposed Change:

 

Make the word "functionality" a link to that definition."

 

 

COMMENT #32 API is not always between applications (W2,A.API,)

 

Definition of API is defined as "definitions of how communication may take
place between applications", but that should be "between application or
software components", as most API are used between components that are not
applications, and we don't want to limit our discussion to only those API
that are between one application and another. 

 

Proposed Change:

 

Change to "definitions of how communication may take place between
applications or software components"."

 

 

COMMENT #33 AT needs to meet both criteria (W2,A.Assistive Technology,)

 

Definition of ASSISTIVE TECHNOLOGY is defined as "a user agent that: 1... 2
..."; in all cases where a list of criteria is presented, it should be made
explicit whether the relationship between the elements in the list is AND or
OR. 

 

Proposed Change:

 

Change "a user agent that:" to "a user agent that both:".

 

Change "monitoring APIs." to "monitoring APIs, and"."

 

 

COMMENT #34 Authored Unit is defined ambiguously (W2,A.Authored Unit,)

 

Definition of AUTHORED UNIT should be reviewed to make sure that it agrees,
at a technical level, with the committee's intention. Currently it seems
ambiguous about whether a Web unit is one type of authored unit, or whether
an authored unit must consist of more than one Web units. Similarly, it is
ambiguous about whether a subset of the content on a Web unit (e.g. a
paragraph) written by a separate author than the surrounding content, is an
authored unit. Finally, it clearly implies that a set of Web units written
by multiple authors but intended to be used together as a set would not be
an authored unit. Are those all correct interpretations?

 

Proposed Change: none provided

 

 

COMMENT #35 Definition of Content is far too limited (W2,A.Content,)

 

Definition of CONTENT currently reads "information to be communicated to the
user by means of a user agent" and has a Note which reads "This includes the
code and markup that define the structure, presentation, and interaction, as
well as text, images, and sounds that convey information to the end-user.".

 

Content is defined as being limited to "information", but the definition of
"information" seems to exclude purely decorative elements and elements who
purpose is to create a specific sensory experience; both of those are
distinguished from informational content in the document, but seem to
clearly be part of the content. That should be acknowledged here. 

 

(Content also include controls whose purpose is to gather input from the
user, but I guess we don't need to call those out since they must also have
some presentation.) 

 

Similarly, the Note seemt to say that scripts included in a Web page are
part of the content, but these don't fit into the definition of
"information" as they might respond to user input or other triggers, without
having any presentation of their own. Thus, the Note seems to contradict the
definitions themselves.

 

It is unfortunate that the document defines "information", "purely
decorative elements", and content "designed to create a specific sensory
experience" as mutually exclusive, with no term that currently includes them
all. I believe that "content" should be that term, but it would require
broadening the definition of "content" beyond just "information" or
broadening the definition of "information".

 

Proposed Change:

 

Change to "information and decorative or sensory elements to be communicated
to the user by means of a user agent, as well as code or markup that define
the stucture, presentation, and interactions associated with those
elements"."

 

 

COMMENT #36 Initialisms are not pronounced as words (W2,A.Initialism,)

 

Definition of INITIALISM should make it clear that initialisms are not
pronounced as words; if they are, they would be acronyms instead of
initialisms. (At least, that's how I've heard it explained.)

 

Proposed Change:

 

Add "Note: Initialisms are generally read as strings of individual letters
rather than being pronounced as words."

 

 

COMMENT #37 Foreground is not always text (W2,A.Luminosity Contrast Ratio,)

 

Definition of LUMINOSITY CONTRAST RATIO assumes that the foreground is text,
but one success criterion applies it to non-text content such as diagrams.

 

Proposed Change:

 

Replaced both occurances of "text" with "foreground" in the definition."

 

 

COMMENT #38 Measuring contrast of non-solid-colors (W2,A.Luminosity Contrast
Ratio,)

 

Definition of LUMINOSITY CONTRAST RATIO assumes that the foreground and
background are both solid colors; it is unclear how this would be applied
when that is not the case, such as when the background is a gradient or
image, or when the foreground consists of many colors. A particularly
interesting case is when the foreground is anti-aliased, causing different
pixels to be different brightness (or, in the case of Microsoft's ClearType
technology, even different colors) but all designed to be perceived as a
single brightness of a single color.

 

Proposed Change: none provided

 

 

COMMENT #39 Definition of natural language is too broad (W2,A.Natural
Language,)

 

Definition of NATURAL LANGUAGE is "language used by humans to communicate",
but this is so broad that Fortran would be included, as it is a way humans
communicate with software.

 

Proposed Change:

 

Change to read "language used by humans to communicate with one another"."

 

 

COMMENT #40 Text must be readable by assistive technology (W2,A.Non-Text
Content,)

 

Definitions of TEXT and NON-TEXT CONTENT is ambiguous about whether an image
of text is text or non-text content. Please add clarification. This is a
problem because most success criteria are written assuming that "text" is
parsable by assistive technology (i.e. not just a picture of characters)
(e.g. "text alternatives"), but others seem to only require that "text" be
readable by humans (i.e. it can be just an image of characters) (e.g.
captions on DVDs).

 

Proposed Change:

 

Add to the definition of non-text content, "Note: This includes images of
words and characters that may look like text when viewed with human sight
but are not programmatically accessible."

 

 

COMMENT #41 Presentations are not perceivable by all users
(W2,A.Presentation,)

 

Definition of PRESENTATION says "rendering of the content and structure in a
form that can be perceived by the user". This is not technically correct, as
(a) it could render just the content, not the structure, (b) it is a form
*designed* to be perceived by *a* user. With the current definition, if the
user is blind, nothing on the display counts as presentation. 

 

Proposed Change:

 

Change to read "rendering of the content and structure in a form designed to
be perceived by the user"."

 

 

COMMENT #42 Simply rectangle size as percentage of screen (W2,A.General
Flash Threshold,)

 

Definitions of GENEAL FLASH THRESHOLD and RED FLASH THRESHOLD each have
three criteria, the first of which is a combined area of flashes occurring
concurrently and occupying more than one quarter of any 341 x 256 pixel
rectangle anywhere on the displayed screen area when the content is viewed
at 1024 x 768. Isn't that just another way of saying one quarter of any
rectangle that's 1/3 of the screen high and 1/3 of the screen wide? Wouldn't
the latter be sound less confusing and easier to test on non-1024x768
screens?

 

Proposed Change:

 

In both GENERAL FLASH THRESHOLD and RED FLASH THRESHOLD, change list item 1
to read "the combined area of flashes occurring concurrently (but not
necessarily contiguously) occupies more than one quarter of any rectangular
region that is one third of the screen high and one third of the screen
wide"."

 

 

COMMENT #43 Address close viewing of small regions of large displays
(W2,A.General Flash Threshold,)

 

Definitions of GENEAL FLASH THRESHOLD and RED FLASH THRESHOLD, it might be
worth noting, will eventually need to be revised when OLED technology allows
for increasing use of very large, animated displays. Picture one big OLED
display replacing the sign board in the lobby of a major office building,
listing all the businesses and their locations; in this case the user will
be focusing their attention on one small area of the large sign, but close
enough to read the text easily. In that case, the entire area the user is
looking at might be flashing, but it still would not be 1/3 of the screen
high and 1/3 of the screen wide.)

 

Proposed Change:

 

In both GENERAL FLASH THRESHOLD and RED FLASH THRESHOLD, append to list item
1, "or designed to occupy a region larger than 6" by 6" on the intended
physical display"."

 

 

COMMENT #44 Give example of specific sensory experience (W2,A.Specific
Sensory Experience,)

 

Definition of SPECIFIC SENSORY EXPERIENCE could use an example to help
readers understand it. I find it hard to come up with an example that one
couldn't argue also performs a function, even if that function is creating a
specific sensory experience.

 

Proposed Change:

 

Add "Example: A Web site advertising a horror-themed game plays subtly
disturbing music in order to make the user feel a sense of immersion in the
theme." (However, one could argue that such music "performs a function" in
this case.) "

 

 

COMMENT #45 Text must be readable by assistive technology (W2,A.Text,)

 

Definitions of TEXT and NON-TEXT CONTENT is ambiguous about whether an image
of text is text or non-text content. Please add clarification. This is a
problem because most success criteria are written assuming that "text" is
parsable by assistive technology (i.e. not just a picture of characters)
(e.g. "text alternatives"), but others seem to only require that "text" be
readable by humans (i.e. it can be just an image of characters) (e.g.
captions on DVDs).

 

Proposed Change:

 

Add to the definition of text, "Note: This does not include images of words
and characters that may look like text when viewed with human sight but are
not programmatically accessible."

 

 

COMMENT #46 Definition isn't broad enough to include all AT user agents
(W2,A.User Agent,)

 

Definition of USER AGENT is "any software that retrieves and renders Web
content for users". In several places it is emphasized that this includes
assistive technology, but this definition seems to exclude many types of
assistive technology such as speech recognition used for
command-and-control, which neither retrieves nor renders, but does rely on
access to the information being rendered. Also, the word "retrieves" seems
to imply fetching from some remote source (e.g. over the Web), which would
exclude screen readers; on the other hand, "retrieves" could be taken to
mean getting the data from anywhere, including from another user agent, but
by that interpretation a display driver would count as assistive technology.

 

Proposed Change:

 

Change to read "any software that retrieves and renders Web content for
users, or manipulates such content to assist the user in using the Web
content or controls"

 

    -- Greg