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Your comments on WCAG 2.0 Last Call Draft of April 2006

From: Loretta Guarino Reid <lorettaguarino@google.com>
Date: Thu, 17 May 2007 16:28:20 -0700
Message-ID: <824e742c0705171628u5af1a9ddn56092e8709a1233f@mail.gmail.com>
To: "Brian Kelly" <b.kelly@ukoln.ac.uk>
Cc: public-comments-WCAG20@w3.org

Dear Brian Kelly ,

Thank you for your comments on the 2006 Last Call Working Draft of the
Web Content Accessibility Guidelines 2.0 (WCAG 2.0
http://www.w3.org/TR/2006/WD-WCAG20-20060427/). We appreciate the
interest that you have taken in these guidelines.

We apologize for the delay in getting back to you. We received many
constructive comments, and sometimes addressing one issue would cause
us to revise wording covered by an earlier issue. We therefore waited
until all comments had been addressed before responding to commenters.

This message contains the comments you submitted and the 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 updated WCAG 2.0
Public Working Draft at http://www.w3.org/TR/2007/WD-WCAG20-20070517/.

PLEASE REVIEW the decisions  for the following comments and reply to
us by 7 June at public-comments-WCAG20@w3.org to say whether you are
satisfied with the decision taken. Note that this list is publicly

We also welcome your comments on the rest of the updated WCAG 2.0
Public Working Draft by 29 June 2007. We have revised the guidelines
and the accompanying documents substantially. A detailed summary of
issues, revisions, and rationales for changes is at
http://www.w3.org/WAI/GL/2007/05/change-summary.html . Please see
http://www.w3.org/WAI/ for more information about the current review.

Thank you,

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:

Source: http://www.w3.org/mid/20060621185239.74B5347BA1@mojo.w3.org
(Issue ID: LC-876)

Part of Item:
Comment Type: general comment
Comment (including rationale for proposed change):

Whilst WAI has been a political success, the WAI model (reliant of
WCAG, ATAG and UUAG) is fundamentally flawed and has quite clearly
failed.  The individual guidelines themselves are flawed, as we are
seeing with the move to WCAG 1.0.

In addition, the WAI guidelines, which seek to address *Web*
accessibility can act to the detriment of wider accessibility, which
may be addressed at an operating system level, for example, or by
other approaches, such as that taken by the IMS AccessForAlll

It should also be noted that IMS has a different definition of
disability to WAI, which is based on a social model, rather thab
WAI\'s medical model.  It is unfortunate that the WAI approach is
based on a model which is not universally applicable.

However rather than seeking to develop a more open and user-focussed
approach, WCAG 2 takes a very technical approach which is difficult to
understand.  It also fails to allow for a diversity of approaches to

This is very worrying, as WAI should be seeking to develop a broad
model which will provide a solid foundation for building
accessibility.  Attempting to build a standard on the flawed approach
of WCAG 2.0 will be counter-productive for accessibility and undermine
the work of W3C.

It should also be noted that an over-prescriptive appoach can (is)
leading to continued use of provietary solutions (e.g. on Intranets)
as there is less of a legal reliance to make non-Web applications

For further information see:

Contextual Web Accessibility - Maximizing the Benefit of Accessibility

Forcing Standardization or Accommodating Diversity? A Framework for
Applying the WCAG in the Real World,

Proposed Change:

My proposals:

o Withdraw WCAG 2.0
o Produce an errata for WCAG 1.0
o Develop an open approach/model for accessibility
o Be explicit in \'difficult\' examples of applications of WAI
guidelines (e.g. Podcasting)

Response from Working Group:

WCAG was chartered with specific goals and requirements (see

WCAG 2.0 works within the same framework as WCAG 1.0, so it is not
clear how withdrawing WCAG 2.0 and producing an errata for WCAG 1.0
would address your issues with the WAI model being inappropriate.

Although WAI specifically addressed only web accessibility, other
standards efforts look at web and non-web accessibility, and we have
worked closely with those standards bodies to ensure that WCAG is as
consistent and harmonious with them as possible. We do not believe
they are in conflict.

With regard to the other aspect of your comment dealing with WAI model
being inadequate that topic is beyond our charter.   We have forwarded
your comments to the WAI director so that you can take up your
discussion with her if you like.
Received on Thursday, 17 May 2007 23:28:39 UTC

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