Commenter: Takayuki Watanabe, Makoto Ueki, and Masahiro Umegaki (JIS WG2)
Email: nabe@lab.twcu.ac.jp
Affiliation: JIS WG2
Date: June 22, 2006

Enclosed please find 14 comments from JIS WG2.

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)



==== Comment #1
1) W2
2) Conformance
3) Baseline
4) G

5) Baseline is a good concept.  We support this concept because technologies that are considered to be accessible may differ among countries and among user domains.  Baseline concept in principle enables us to adopt WCAG 2.0 in various countries.

6) -


=== Comment #2
1) W2
2) Conformance
3) Baseline
4) G

5) Baseline concept may cause accessibility degeneracy.  We may have Web sites that conform to WCAG 2.0 but inaccessible to users.

Baseline concept separates the responsibility of content from that of user agents, which means content authors do not have to pay attention to what kinds of user agents can access their content but just use some baselines.  Content authors can use XHTML 1.0 even if not all major user agents can access the content written in XHTML 1.0.  (This is a case in Japan.  Major Japanese user agents can not use structure markups of HTML 4.01 and XHTML 1.0.)  In WCAG 2.0 this inaccessibility is blamed on user agents.  If there are major user agents that cannot access the technology included in the baseline, user cannot use the content even if content is made accessible.

6) New subsection "Attention to user agent capabilities" should be included to discuss this issue. Having a good UAAG and public awareness to UAAG is also important.


==== Comment #3
1) W2
2) Conformance
3) Optional components of a conformance claim
4) G

5) WCAG 2.0 should put more emphasis on the importance of having a list of user agents that the content has been tested on.  As pointed out in the comment #2, knowledge of which user agents can access that content is very important.

In Japan, our research [1] showed that Japanese major user agents were divided into two groups: JAWS and HPR can use structure markups and other important functions, while 95-Reader and PC-Talker can not.  Most Japanese users do not know the benefits of skip navigation, heading navigation, table-structure navigation, or search text in a page because their user agents do not have these capabilities.  (X)HTML is the basic technology which must be included in all baselines but major Japanese user agents cannot use some important accessibility functions of (X)HTML.  Thus, we can say that baseline concept is too rough to show which technologies are accessible to users.  Information of user agents is necessary to show that content is accessible to users.

In addition to that, user agents might be different among users with various disabilities.  It may happen that the same content is accessible to users with cognitive disabilities but not accessible to visual disabilities.

We think conformance claims that include a list of user agents that have been tested on and a detail list of specific capabilities of those user agents is an ideal but we know it requires too much burden to the authors.  Thus, we propose that WCAG 2.0 should put more emphasis on the importance of having a list of user agents that the content has been tested on.

[1] Watanabe, T. and Umegaki, M.
"Capability Survey of Japanese User Agents and Its Impact on Web Accessibility",
Proceedings of W4A 2006.
http://www.w4a.info/2006/prog/6-watanabe.pdf

6) -


==== Comment #4
1) W2 or UW
2) Baseline
3)
4) G

5) We need more concrete and realistic examples of baseline.  For example, the baseline used in public web sites in the US, the baseline used in W3C web sites.

6) -


===== Comment #5
1) W2
2) Conformance
3) Conformance claim
4) G

5) Conformance claims should be expressed in RDF format so as to both human and tools can read them.  Creative Commons License is a good example to have information both in normal text and marked with metadata.

6) -


==== Comment #6
1) W2
2) Conformance
3) Aggregated content
4) G

5) We think it is a good idea for WCAG 2.0 explaining how aggregated contents conform to WCAG because of their popularity.  Aggregated contents must be considered carefully because such kinds of content have been increasing on the web.  This paragraph, however, is difficult to understand: This paragraph deals with aggregated content, Web unit, authored units, and aggregated (authored) units, which terms and their differences are difficult.  It is difficult to understand what 'aggregated content' means.  Thus, Good examples of aggregated content, Web unit, and authored units are needed.

In addition to that we can not understand the responsibility of Web authors and aggregated contents. We also can not understand how authors make a conformance claim to aggregated content.

6) -


==== Comment #7
1) W2
2) Appendix A
3) Glossary
4) Q

5) What is the difference between "authored unit" and "authored component"?  We couldn't understand their meaning clearly.  The words used in WCAG 2.0 are ambiguous.  We need much more concrete examples of the current web technologies.  It allows the readers to understand the WCAG 2.0 more clearly.

6) -


==== Comment #8
1) W2
2) 2.5.3
3) Level 2 Success Criteria for Guideline 2.5
4) G

5) Scope of SC 2.5.3 is limited and narrow.  It deals with specific forms.  Thus, it should be moved to L3.

6)
Level 3 Success Criteria for Guideline 2.5
2.5.3 For forms that cause legal or financial transactions to occur, that modify or delete data in data storage systems, or that submit test responses, 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 review and confirm or correct information before submitting it.


==== Comment #9
1) UW
2) 1.1.1
3) Examples
4) G

5) JIS X 8341-3 has an example of sound effects such as beep, chime, and ding-dong, which sound notify the user that, for example, the answer is correct.  These sounds may be used in e-learning system.  In this case, people who are deaf, hard of hearing, or having trouble to understand audio information may not hear or understand the sound effects.

6) Add the following example to the "Examples" section.

8. A sound effect
The web page of the e-learning content uses the sound effects. The chime sound indicates that the answer is correct and the beep sound indicates that the answer is incorrect. An alternative text is shown on the page so that people who can't hear or understand the sound understand whether the answer is correct or incorrect.


==== Comment #10
1) W2
2) 1.4.2
3) Level 2 Success Criteria for Guideline 1.4
4) Q

5) JIS X 8341-3 also addresses the importance of volume control.  It allows the users who are hard of hearing to adjust the volume of the audio.  Is it unnecessary for WCAG 2.0 to require the mechanism of the audio volume control?

JIS 5.7 b) says:
<quote>
b) Sound should be controllable by users.

Information:
Hearing impaired users cannot detect that sound is being played.  Also, there are cases where louder volume is preferred.

Example:
To enable users to adjust volume, play, and stop, provides controls for play, stop, and volume adjustment. When using plugins, they can be used for this purpose
</quote>

6) -


==== Comment #11
1) UW
2) 3.1.3
3) Examples
4) G

5) New example should be added to Understanding document.  JIS X 8341-3 has an example of the words of foreign origin which may be unfamiliar to users.

6) The meaning of an unfamiliar adopted foreign word

The meaning or the translated word is provided within the page by using the parenthesis right after the word or the internal link from the word.


==== Comment #12
1) W2
2) 4.1.1
3) Level 1 Success Criteria for Guideline 4.1
4) Q

5) WCAG 2.0 doesn't require validity.  Can authors use UA-specific elements such as marquee, blink and so on?  It is less certain on this issue through the documents.

6) -


==== Comment 13
1) W2
2) 4.1.1
3) Level 1 Success Criteria for Guideline 4.1
4) G

5) Validity check is important process to increase accessibility.  "Guidelines for Different Components" (http://www.w3.org/WAI/intro/components.php#guidelines) says "WAI guidelines are based on the fundamental technical specifications of the Web, and are developed in coordination with:"  If WCAG does not mention to validity, readers of WCAG think WCAG WG thinks little of Web standards.

6) We propose to add Level 2 Success Criteria that requires validity.


==== Comment #14
1) W2
2) 2.2 / 3.1
3)
4) Q

5) WCAG 2.0 doesn't mention about the speed of text which is moving on the page.  It is hard for people with visual disabilities and cognitive limitations to read and understand the text.  Can the author use the fast scrolling text?

6) -