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Re: WCAG 2.0 Public Working Draft: Response to WG Response

From: Loretta Guarino Reid <lorettaguarino@google.com>
Date: Tue, 11 Dec 2007 15:31:13 -0800
Message-ID: <824e742c0712111531o6259983bib9ffd092f933287a@mail.gmail.com>
To: S.Vassallo@e-bility.com
Cc: public-comments-wcag20@w3.org

SC 1.1.1 captures the sense that alternatives must be meaningful by
requiring that they can be used in place of the non-text content.
Failure F30 highlights particularly common examples of non-meaningful
text alternatives:

F30: Failure of SC 1.1.1 due to using text alternatives that are not
alternatives (e.g. filenames or placeholder text)

The success criteria for Guideline 1.2 must be satisfied by web pages
that contain synchronized media. So although SC 1.1.1 only requires
that they have a label, SC 1.2.1 would require captions and SC 1.2.2
would require audio descriptions or full text alternatives. Therefore,
we do not believe it is necessary to repeat this information in the


Loretta Guarino Reid, WCAG WG Co-Chair
Gregg Vanderheiden, WCAG WG Co-Chair
Michael Cooper, WCAG WG Staff Contact

On behalf of the WCAG Working Group

> > ----------------------------------------------------------
> > Comment 1: Guideline does not mention the need for equivalent
> > alternatives (only SC).
> > Source: http://lists.w3.org/Archives/Public/public-comments-wcag20/2007Jun/0266.html
> > (Issue ID: 2096)
> > ----------------------------
> > Original Comment:
> > ----------------------------
> >
> > As stated by the Guideline, the primary benefit in providing text
> > alternatives for any non-text content is that it can be changed into
> > other forms people need such as large print, braille, speech, symbols
> > or simpler language. However, unless the alternative conveys the same
> > information it may be of little use.
> >
> > Courts and Government policy makers will most likely use the W3C
> > normative guidelines as their benchmark for determinations of
> > accessibility conformance and since the Success Criterion 1.1.1
> > (Non-text Content) already has as a checkpoint that "All non-text
> > content has a text alternative that presents equivalent information
> > ...", it would be beneficial and consistent to include equivalence in
> > the actual Guideline.
> >
> > Proposed Change:
> > Edit Guideline 1.1 to read "Provide equivalent text alternatives for
> > any non-text content so that it can be changed into other forms people
> > need such as large print, braille, speech, symbols or simpler
> > language"
> >
> > ---------------------------------------------
> > Response from Working Group:
> > ---------------------------------------------
> >
> > We did have equivalent in there at one point. But not all of the text
> > alternatives are equivalent. In some cases it is impossible for the
> > text alternative to be equivalent. There are a number of text
> > alternatives that label content. Thus, the guideline was changed to
> > match this situation. The different points under SC 1.1.1 explain the
> > different situations in which equivalent text alternatives are
> > required vs when a label is deemed sufficient.
> >
> --------------------------------
> Response to response
> --------------------------------
> Thanks Loretta. I note that SC 1.1.1 and related SC for Guidelines 4.1 &
> 1.2 are Level A and that "all Level A success criteria must be satisfied
> in order to achieve A (single-A) conformance". My main concern was to
> clarify that text equivalents need to meaningful, as so often they are not.
> I also noticed in the "Understanding WCAG 2.0" document "Techniques for
> Addressing Success Criterion 1.1.1" there was mention of additional
> requirements using "AND" where "a short description can not serve the
> same purpose or present the same information as the non-text content".
> However, there does not appear to be any additional requirement for
> multimedia where a short description is not sufficient.
> If it is not possible to include "equivalent" in the wording of the
> actual Guideline then perhaps (something like) the following could be
> added to the  Sufficient Techniques for multimedia in 1.1.1 (e.g.
> Situation B) ...
> AND providing a transcript AND/OR providing synchronized alternatives
> for multimedia (Guideline 1.2)
> PS: I have grappled with this and recognise it is a difficult area (and
> one being actively debated even within the accesibility community) due
> to the significant benefit of this medium to some people with disability
> balanced against the resource intensiveness of creating accessible
> alternatives for multimedia at present. If possible I would like to find
> a way to acknowledge that for a multimedia site to be fully accessible
> equivalent alternatives for multimedia are required (with exceptions if
> appropriate e.g. a test or exercise that must use a particular sense)
> and my feeling was that the techniques area provides this opportunity.
> Not having this provision implies sites can be accessible without it and
> while the technology is not fully developed now to easily create
> transcripts or synchronized alternatives on the fly, it may be in the
> future (plus the WCAG 2.0 guidelines are not technology dependent). For
> situations where this does present undue hardship there is also
> provision in the DDA law (in Australia) for further consideration to be
> taken into account. To my knowledge, similar mechanisms, such as undue
> burden or undue hardship, also exist in most other jurisdictions where
> disability discrimination legislation is in place.
Received on Tuesday, 11 December 2007 23:31:27 UTC

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