Comments on WCAG 2.0 Last Call -- Conformance scheme

Commenter: Al Gilman

Email: Alfred.S.Gilman@IEEE.org

Affiliation:

Date: 23 May 2006

Directions

Column 1: Enter the abbreviation for the Document you are commenting on:
- W2 for WCAG 2.0.
- UW(or HTM) for Understanding WCAG document (and for the How To Meet sections of this doc).
- TD for Techniques document.
Column 2: Enter the major section name or Item number of the guideline, success criterion, technique etc that you are commenting on.
- For example "Intro" for introduction "1.1" for a guideline 1.1, "3.2.1" for success criterion 3.2.1, "H-56" for HTML technique number H-56
Column 3: Enter the heading for the section you are commenting on.
- E.g. "Intent", or "Description", or "Examples", etc.
Column 4: Enter the type of comment you are making
- G = General (i.e., applies to whole document)
- T = Technical (i.e., deals with substance)
- E = Editorial (i.e., concerns grammar, wording, formatting, etc.)
- Q = Question (i.e. not requesting any change).
All : are required.
Filling out column 6 greatly increases our ability to understand and address your concern.

Please ensure that the comments submitted are as complete and "resolvable" as possible. Thank you.

1. Document Abbv. (W2/UW/TD)	2. Item Number (e.g. 1.1)	3. Part of Item (Heading)	4. Comment Type (G/T/E/Q)	5. Comment (Including rationale for any proposed change)	6. Proposed Change (Be specific)
W2	Conformance	(date-qualified claims)	G/T	Date-qualified claims are introduced in the discussion of migration from WCAG1 to WCAG2. They are also of interest to sites and appropriate to be used in staged adoption plans more generally.	Introduce and define terms for date-qualified claims earlier in the general discussion of a cliam. Don't wait until talking about WCAG1.
W2	Conformance claims optional components point 5	*The target audience information CANNOT specify anything related to disability or to physical, sensory or cognitive requirements.*	G/T	What is this language trying to say? Do you mean MUST NOT? Editorial: CANNOT would be appropriate for an observation as to what is feasible in the medium. This is a remark as to what the author believes is appropriate in this genre. It is also neither an accessibility issue nor is it always a good idea. Compare this with the language in Success Criterion 1.1.1 where there are specific provisions for a case where the whole purpose of the site is some sort of sensory or perceptual effect or test. In that case the content is allowed to be explained but not accorded universally accessible equivalent facilitation. In the case of such content, such as the tester for Daltonism, it would be both appropriate and polite to mention that this web presence is intended for those with substantial visual acuity to evaluate their color perception.	Strike the remark.
W2	conformance	When people who understand WCAG 2.0 test the same content using the same success criteria, the same results should be obtained with high inter-rater reliability.	G/T	This is not adequate reproducibility to be the basis of W3C-recommended interoperability. If the test points don't repeatably produce the desired outcome with lay testers, the statement of the criteria is too arcane for the Web with its millions of authors.	(1) Define, (2) take through the W3C Recommendation process, and (3) make conformance rely on: more-concrete testable assertions.
W2	baseline		G/T	The wide-open nature of the baseline means that the obvious interpretation of the W3C Candidate Recommendation phase could never be completed because there would be other baseline profiles that remained un-demonstrated.	Minimum: Spell out an explicit experiment plan for Candidate Recommendation. Define the baselines to be used to demonstrate the effectiveness of these guidelines. Better: Make PR [a.k.a. CR exit] contingent on demonstrating the joint statistical distribution of the proposed testable hypotheses and user success in using live contemporary web content.
W2	Scoping of conformance claims	concept of a "process"	G/T	What is a process in terms of WCAG conformance is unenforceably vague, and at least in terms of the first example given, unfairly narrow. Shopping generally progresses through browse, select, and checkout phases. Only the checkout is a rigidly serialized process. And on some sites you can get live assistance by which you could place your order by chat. So using a whole shopping site as an example of a 'process' which is subject to an "all or none" accessibility rule is unduly severe.	Include an accounting for equivalent facilitation separate from the individual testable hypotheses and integrated into the rollup of conformance assessment. (see next) You might want to remark that it's not cool for a shopping site to claim conformance for a subset of the site that doesn't let people complete a purchase. But don't try to fold that policy value judgement into a W3C technical report. Let the latter be technical.
W2	Conformance	roll-up, score-keeping	G/T	Some wiggle room is attempted in the statement of the individual success criteria, but the general process for arriving at a conformance claim satisfaction is still, as in WCAG, a "one strike and you're out" rule. Another way to describe it is that there is an "AND" combination of single point test results to get the overall score. This is a serious problem. This kind of rollup or score-keeping is seriously out of alignment with the general reduntant quality of natural communication including web content. In natural communication there is often more than one way to learn what there is to learn from an utterance. And in GUIs there is often more than one way to effect any given outcome. So long as there is a go-path and the user can find it, a noGo-path should not force a failing grade for the [subject of conformance claim] There is prior art in Mean Time Between Failures computations in reliability engineering, in the handling of redundant fallback capability.	An approach to consider: Make the assessment of overall score or rating incorporate the recognition of alternatives at all levels of aggregation and not just at the leaf level. In other words, take systematic account of equivalent facilitation. If there is an accessible way to learn or do what there is to learn or do, and an accessible way to find this when other paths prove problematic, that content should not fail as a result of the problems with the alternate path. It is not enough to address this in 1.1.1 and 4.2. It needs to be global.
W2	When referring to WCAG 2.0 from another standard with a "shall" statement	Level A or nothing	T	This clause is overly restrictive. The authors appear to be fixated on people writing public policy for the public web. There are other use cases which support cherry-picking requirements with full selectivity. One of these use cases is where a web development organization is subcontracting for media fragments -- icons and background images or the like -- from a subcontractor and writes a standard for acceptable data packages which requires metadata to go with each including provenance, sample ALT text, etc. In this case there is no reason that the customer organization should have to require all of Level A on the piece parts purchased from the subcontractor -- the purchasor will take care of the other aspects before putting the assembled web content out on the web. This requirement as now stated would make that a violation of the Recommendation.	Soften the language from an imperative to a Recommendation. Don't say "you mustn't cite arbitrary subsets," but rather say "if you cite only a subset of the Level 1 Success Criteria, don't represent this as WCAG 2.0 Conformance." -- alternate wording... W3C does not regard satisfying a profile of success criteria that does not contain all the Level One success criteria to merit the term "conformance to WCAG 2.0" Unless a specification or policy requires at least conformance to all Level 1 Success Criteria, do not represent that policy or specification as implementing WCAG 2.0 conformance.