(Roger Hudson) Fwd: WCAG 2 response to WG response

--------- Forwarded message ----------
From: Roger Hudson <rhudson@usability.com.au>
Date: Dec 13, 2007 4:02 PM
Subject: RE: WCAG 2 response to WG response
To: Loretta Guarino Reid <lorettaguarino@google.com>


Hi Lorreta,

Thanks for sending me the WG response to my response.

I am sorry but I just don't understand how you are suggesting 1.1.1 offers
any support for people with cognitive or learning difficulties. Guideline
1.1 and 1.1.1, from my reading of the latest last call draft, seem to
explicitly relate to the provision of text alternatives for non-text
content. What I was specifically concerned about were people who had a
problem reading or comprehending complex pieces of text, not people who need
text alternatives for non-text content for I feel they are adequately
catered for in WCAG 1 and 2.

Do I take from this comment, "we do not have any requirements on the quality
of the alt-text because that would create the same kind of testability
problem", that the Working Group is not going to be concerned about the
quality of the actual text alternative for non text content? If so, why
include the phrase "presents equivalent information"?

Regards

Roger

Roger Hudson
Web Usability
Ph: 02 9568 1535
Mb: 0405 320 014
Email: rhudson@usability.com.au
Web: www.usability.com.au
-----Original Message-----
From: Loretta Guarino Reid [mailto:lorettaguarino@google.com]
Sent: Wednesday, 12 December 2007 10:44 AM
To: Roger Hudson

Cc: public-comments-wcag20@w3.org
Subject: Re: WCAG 2 response to WG response

Yes the alt-text is a good comparison.  And we do not have any
requirements on the quality of the alt-text because that would create
the same kind of testability problem.

The only failure is the use of the same placeholder term on all
graphics (since that is easy to reliably detect/test for).

Please note that there are many provisions at  Level A and Level AA
that provide access for people with cognitive disabilities such as
1.1.1 that allows content to be read aloud or translated into symbols
etc.   In fact a majority of the provisions relate to issues that have
been identified for one or another cognitive language or learning
disability.   We know that there are many other issues that we were
not able to address.  We have initiated an effort in conjunction with
the Cognitive RERC on developing an application note on access to Web
Pages by people with congnitive, language and learning disabilities
that is 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.

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 7: doing a little more for people with cognitive limitations
> Source:
>
http://lists.w3.org/Archives/Public/public-comments-wcag20/2007Jun/0279.html
> (Issue ID: 2109)
> ----------------------------
> Original Comment:
> ----------------------------
>
> Guideline 3.1 is concerned with the need to make text readable and
> understandable. In general WCAG 2.0 contains very few provisions for
> improving the accessibility of web content for people with cognitive
> disabilities or learning difficulties.
>
> When this lack of specific guidance relating to people with cognitive,
> language and learning limitations were raised by me and other people
> following the release of the WCAG Last Draft in 2006, the general
> response of the Working Group was, \"We have added some best practices
> for cognitive, learning, and language disabilities as advisory
> techniques. We have not been able to propose many additional success
> criteria that meet WCAG\'s testability requirements.\"
>
> I agree it is hard to make some of the requirements for improving
> accessibility for people with cognitive, language and/or learning
> limitations machine testable. However, my reading of the definition of
> testability includes the provision for reliable human testable
> compliance. It is my view, many issues that were previously dismissed
> as not testable, are in fact testable by qualified human testers.
>
> Proposed change: I believe the Working Group should include the
> following Level AA Success Criterion for guideline 3.1. At the least,
> this will go some small way to addressing the short comings in
> relation to cognitive and learning limitations in the proposed draft
> of WCAG 2.0.
>
>
> Proposed Change:
> 3.1.? Comprehension: Barriers to the readability or comprehension of
> text, tables and forms be avoided, or a mechanism for obtaining
> supplementary content or an alternative version is provided. (level
> AA)
>
> Techniques could include:
>
> Use the clearest and simplest language appropriate for a site's content.
>
> Provide a mechanism for users to easily change text font size and the
> line-height of paragraphs.
>
> Avoid the use of complex and highly decorative backgrounds for text or
> provide a mechanism for users to easily remove the background.
>
> Avoid the use of highly decorative font styles for text or provide a
> mechanism for users to easily change the text style.
>
> Avoid the use of text line lengths in excess of 80 characters or
> provide a mechanism for users to easily reduce column width or line
> length.
>
> Avoid the use of text lines that are both left and right justified or
> provide a mechanism for users to easily obtain a version that is not
> fully justified.
>
> For technical or complex content that is to be accessible to a general
> audience (for example legal documents or insurance conditions),
> provide an additional simple-language version.
>
> (NB: I realise some of these techniques are included for other Success
> Criterion, however I believe that restating them here will help focus
> attention on the importance of considering the needs of people with
> cognitive, language and/or learning difficulties.)
>
> ---------------------------------------------
> Response from Working Group:
> ---------------------------------------------
>
> It is true that we allow human testability. However, the human
> testability must render consistent results across various experts.
> Because the inherent ambiguities in this field and the current level
> research, there are only a few techniques that we can add with
> confidence of agreement. However, we have added several new advisory
> techniques to SC 3.1.5.
>
> We have added a new success criterion at Level AAA
>
> "For the visual presentation of blocks of text, a mechanism is
> available to achieve the following:
>
>         * foreground and background colors can be selected by the user
>         * width is no more than 80 characters
>         * text is not aligned on both the left and the right [LC-1253]
> [LC-569 (add)]
>         * line spacing is at least space-and-a-half within paragraphs,
> and paragraph spacing is larger than line spacing [LC- 569]
>         * text is resized without assistive technology up to 200
> percent in a way that does not require the user to scroll horizontally
> to read a line of text "
>
> We believe that satisfying this success criterion will help people
> with some types of cognitive limitations.
>
> --------------------------------
> Response to response
> --------------------------------
> This is the response to one of my comments that I am the most dissatisfied
> with since it still fails to address my real concern over the lack of
> support given to people with cognitive, learning and language limitations.
I
> am pleased however to see that some of the suggested techniques may have
> contributed to a new Success Criterion relating to the presentation of
> blocks of text, but note that it is at Level AAA - i.e. the level that is
> least likely to be complied with.
>
> No amount of good-intention words relating to the importance of addressing
> the need of people with cognitive disabilities will replace the absence of
a
> meaningful Success Criterion at either A or AA. When it comes to
encouraging
> clients and developers to consider the needs of people with cognitive,
> learning and language difficulties, I am not sure WCAG 2.0 is any real
> advance on WCAG 1.0.
>
> I don't feel my suggested SC was too onerous. It suggested barriers to
> comprehension should be avoided but was deliberately not too prescriptive
as
> to how this could be done. However, I think the suggested techniques
> provided a useful guide to the issues that should be considered when
> complying with the suggested SC. This combination of a specific Level AA
> Guideline and suggested techniques would I believe have helped underscore
> the significance of this issue with website developers and their clients.
>
> I feel that your comments relating to human testability when it comes to
> cognitive disabilities may just be a convenient way of avoiding the issue.
> If an image of a navigation item or a complex flow chart just had
> 'alt=picture',I would assume that the WG would not consider that this
> complied with the Guideline that requires the use of "a text alternative
> that presents equivalent information". Unless you are willing to accept
> vague img attributes such as this, it is likely to come down to humans to
> determine if the value of the attribute does actually present equivalent
> information.
>
> If a qualified human can determine whether or not a text description is an
> adequate alternative to an image, why do you feel it is not possible for
> qualified humans to determine if the complexity of a piece of text is such
> that an alternative way of presenting the information should be
considered?

Received on Friday, 14 December 2007 01:02:47 UTC