Re: Your comments on WCAG 2.0 Public Working Draft of May, 2007 [SEC=UNCLASSIFIED]

We have tried to include all of the qualitative guidance that we have
received in the advisory techniques.  We have also re-written the
introduction to emphasize the importance of going beyond the testable
SC and implementing as many of the sufficient and advisory techniques
as possible.

In addition the WCAG WG has initiated an effort to develop an
"application note" under the framework of WCAG 2.0 on access to Web
Pages by people with cognitive, language and learning disabilities.
The application note would include approaches that are more general,
qualitative, and not bound by testability, so that all guidance can
be treated equally without
levels or constraint due to the nature of the advice. This effort
will include the Cognitive Rehabilitation Engineering Research Center
which focuses on cognitive disabilities, and we welcome additional
participation.

WAI continues to be interested and committed to
developing guidance to address Web accessibility needs in the broad
area of cognitive disabilities, and will continue to explore this
area through our other WAI 2.0 guidelines, research discussions, and
in potential future guidelines development.

Regards,

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

On Nov 19, 2007 8:46 PM, Bruce Maguire <BruceMaguire@humanrights.gov.au> wrote:
> Dear Loretta
>
> Firstly, may I thank you and the other members of the committee for
> giving us the opportunity to offer some comments on the response that
> you provided to our submission relating to the May 17 WCAG2.0 draft.
>
> It is clear from the committee's response that it correctly understood
> the comments that we provided. We appreciate the time and care taken by
> the committee in formulating their response. Our follow-up comments are
> below, and use the numbering from our original submission:
>
> 1. If the web accessibility and cognitive disability communities are
> satisfied that including a statement about the need for further testing
> would divert focus away from the  valuable guidelines and techniques
> that we already have in this area, then we support removing it.
> Moreover, we would continue to encourage the committee to give further
> consideration to incorporating more of the qualitative guidelines that
> have been identified. From a policy perspective, we are concerned that
> the need to refer developers to both WCAG2.0 and some other set of
> (non-normative) guidelines will lead to confusion and disharmony. If,
> for example, the Commission determined that a particular set of
> guidelines would most effectively meet the needs of users with cognitive
> disabilities in Australia, but regulatory bodies in other countries
> adopted different sets of guidelines, we would end up with a situation
> where it would be very difficult for developers of websites with an
> international Coverage to comply (or assess their level of compliance)
> with all of the different guidelines and, conversely, it would be
> extremely difficult for an individual with a disability to use
> disability discrimination legislation to successfully prosecute a web
> developer who complied with guidelines in one jurisdiction but not with
> those in the individual's own (a web developer might readily invoke a
> defense of unreasonableness or unjustifiable hardship/undue burden
> because of the plethora of guidelines with which they had to comply).
> The most effective solution we see to this is the development of
> internationally-agreed guidelines for addressing the needs of web users
> with cognitive, language or learning disabilities. We urge the committee
> to consider mechanisms by which the WAI could assist in the process of
> developing such guidelines.
>
> 2. We welcome the committee's suggested change and await the next draft
> to assess its implications fully.
>
> Regards
> Bruce Maguire
> Policy/Project Officer
> Human Rights and Equal Opportunity Commission
>
>
>
>
> -----Original Message-----
> From: Loretta Guarino Reid [mailto:lorettaguarino@google.com]
> Sent: Sunday, 4 November 2007 3:35 PM
> To: Bruce Maguire
> Cc: public-comments-WCAG20@w3.org
> Subject: Your comments on WCAG 2.0 Public Working Draft of May, 2007
>
> Dear HREOC,
>
> Thank you for your comments on the 17 May 2007 Public Working Draft of
> the Web Content Accessibility Guidelines 2.0 (WCAG 2.0
> http://www.w3.org/TR/2007/WD-WCAG20-20070517/). The WCAG Working Group
> has reviewed all comments received on the May draft, and will be
> publishing an updated Public Working Draft shortly. Before we do that,
> we would like to know whether we have understood your comments
> correctly, and also whether you are satisfied with our resolutions.
>
> Please review our resolutions for the following comments, and reply to
> us by 19 November 2007 at public-comments-wcag20@w3.org to say whether
> you are satisfied. Note that this list is publicly archived. Note also
> that we are not asking for new issues, nor for an updated review of the
> entire document at this time.
>
> Please see below for the text of comments that you submitted and our
> resolutions to your comments. Each comment includes a link to the
> archived copy of your original comment on
> http://lists.w3.org/Archives/Public/public-comments-wcag20/, and may
> also include links to the relevant changes in the WCAG 2.0 Editor's
> Draft of May-October 2007 at
> http://www.w3.org/WAI/GL/WCAG20/WD-WCAG20-20071102/
>
> Thank you for your time reviewing and sending comments. Though we cannot
> always do exactly what each commenter requests, all of the comments are
> valuable to the development of WCAG 2.0.
>
> Regards,
>
> 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: Addressing the needs of people with cognitive, language or
> learning disabilities
> Source:
> http://lists.w3.org/Archives/Public/public-comments-wcag20/2007Jul/0037.
> html
> (Issue ID: 2320)
> ----------------------------
> Original Comment:
> ----------------------------
>
> Concern and Rationale:
> We regret that the Guidelines in their current form do not adequately
> address the needs of people with cognitive, language or learning
> disabilities. We believe that attention to the needs of these users is a
> necessary part of accessibility, and that websites which do not address
> these needs are, to that extent, inaccessible. However, we do
> acknowledge the challenges of addressing these needs through guidelines
> developed within a testable framework, and we encourage the W3C to
> conduct more research in this area to identify best-practice solutions,
> and to expand the Guidelines once more comprehensive information has
> been obtained. We also urge the development committee to re-examine the
> Guidelines in case it can identify a greater number of success criteria
> that relate to the needs of people with cognitive, language or learning
> disabilities and which meet the 80% confidence level for human testing.
> In the meantime, we would recommend a stronger statement about the
> importance of addressing the needs of these user groups so that
> developers do not use WCAG2.0 as an escape route for ignoring them.
> Therefore:
>
> Suggested Change:
> After "There is a need for more research and development in this
> important area": Delete period, add Comma, and the following text:
> "and developers should seek relevant expert advice about current best
> practice to ensure that web content is accessible as far as possible to
> people with these disabilities."
>
> ---------------------------------------------
> Response from Working Group:
> ---------------------------------------------
>
> The Working Group hoped that the inclusion of the sentence "There is a
> need for more research and development in this important area." would
> encourage support in the research community for additional work in these
> areas. At the request of several reviewers, we have removed it.
>
> We added the following sentence based on comments submitted:
> "Authors are encouraged to consider the full range of techniques,
> including the advisory techniques, as well as to seek relevant advice
> about current best practice to ensure that Web content is accessible, as
> far as possible, to this community."
>
> ----------------------------------------------------------
> Comment 2: Define testability in glossary
> Source:
> http://lists.w3.org/Archives/Public/public-comments-wcag20/2007Jul/0037.
> html
> (Issue ID: 2321)
> ----------------------------
> Original Comment:
> ----------------------------
>
> Concern and Rationale:
> We support endeavours to incorporate principles of testability into
> accessibility standards and guidelines, as this provides greater
> certainty for those who seek to implement them and also for those who
> wish to assess the extent to which they have been followed. However,
> there is no formal definition of "testable" and "testability" either in
> the Introduction or in the Glossary of WCAG2.0. In particular, there is
> no mention of the 80% confidence level requirement for human testers.
> Given the significance of testability within the WCAG2.0 framework, we
> suggest providing a complete normative definition that highlights the
> role of both machine and human testing, together with a discussion of
> the rationale of the concept. The absence of such definition and
> discussion limits the ability of policy-makers to interpret, promote and
> apply the concept accurately.
>
> Suggested Change:
> Link "testable", In the sentence "All WCAG 2.0 success criteria are
> written to be testable." to a definition in the Glossary. Add definition
> to Glossary.
>
> ---------------------------------------------
> Response from Working Group:
> ---------------------------------------------
>
> Our current introduction has been shortened and there is only a part of
> single sentence that mentions testing as follows.
>
> "WCAG 2.0 builds on WCAG 1.0 [WCAG10] and is designed to apply broadly
> to different Web technologies now and in the future, and to be testable
> with a combination of automated testing and human evaluation."
>
> However in our Understanding WCAG document we go into more detail as
> follows:
>
> "All WCAG 2.0 success criteria are written as testable criteria for
> objectively determining if content satisfies them. Testing the success
> criteria would involve a combination of automated testing and human
> evaluation. The content should be tested by those who understand how
> people with different types of disabilities use the Web.
>
> Testing and testable in the context refer to functional testing, that is
> verifying that the content functions as expected, or in this case, that
> it satisfies the success criteria. Although content may satisfy all
> success criteria, the content may not always be usable by people with a
> wide variety of disabilities. Therefore, usability testing is
> recommended, in addition to the required functional testing. Usability
> testing aims to determine how well people can use the content for its
> intended purpose. It is recommended that users with disabilities be
> included in test groups when performing usability testing."
>
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Received on Tuesday, 11 December 2007 23:34:17 UTC