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WCAG 2.0 Comment Submission

From: WCAG 2.0 Comment Form <nobody@w3.org>
Date: Thu, 11 May 2006 04:30:58 +0000 (GMT)
To: public-comments-wcag20@w3.org
Message-Id: <20060511043058.23EE666368@dolph.w3.org>

Name: Roger Hudson
Email: rhudson@usability.com.au
Document: W2
Item Number: Technology assumptions and the 
Part of Item: 
Comment Type: GE
Comment (Including rationale for any proposed change):
The introduction of the “baseline” could result in some web content providers believing that it is acceptable to provide content that will be inaccessible to some people with disabilities. It appears that under WCAG 2.0, a site developer or some higher authority (eg Government regulator) can set a baseline using W3C and non-W3C technologies so long as there are “assumed” accessible user agents that support them. 

WCAG 2.0 allows develops to “assume” a technology will be supported and provides no guidance on what this assumption should be based on. In addition, there is no definition of what constitutes an “accessible user agent”. Are the early versions of PDF and Flash plug-ins accessible user agents? Or, only more recent versions? And, who decides whether a current or future user agent is accessible or not?

The guidelines provide examples of assistive technologies, but there appears to be no requirement for a nominated baseline technology to be supported by a significant proportion of assistive technologies that are in current use.

With WCAG 2.0 it appears that it will be up to the person with a disability to obtain (purchase) the technology, which the site proprietor deems appropriate, in order to access a site, rather than the responsibility of the site proprietor to ensure their content is accessible to users of a wide range of assistive technologies. Such a requirement is unreasonable, especially given the high unemployment rate among people with disabilities, and it is also not in accord with “beneficial” approaches to disability such as those adopted in disability discrimination legislation. Such approaches recognise that everyone has a responsibility to make society more universally accessible.

Finally, I am concerned the introduction of the proposed “baseline” concept will place a greater burden on organizations who are responsible for promoting and ensuring best practice in the area of website accessibility, in many different countries.

Proposed Change:
In my view the whole baseline concept needs to be revisited. However, since this is unlikely I would like to suggest the Working Group considers the following.

1.	Avoid the use of the words “assume” and “assumed”. If they are used, provide a clear indication of what can and cannot be assumed.


2.	Define what is meant by an accessible user agent (as distinct from a user agent).

3.	Include a requirement for all technologies used on a site to be supported by a wide range of assistive devices that are at least one generation older than the version in current release. (Clearly there will be a need to indicate what is a ‘wide range’ and the number is likely to be different for different technologies – eg for screen readers perhaps it might be four programs whereas for magnifiers it might just be two.)
Received on Thursday, 11 May 2006 04:31:05 UTC

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