Your comments on WCAG 2.0 Last Call Draft of April 2006 (2 of 3)

Comment 16:

(Issue ID: LC-1277)

Comment: Para one is all abut working group process - leave out

The second para in this section opens with stuff about W3C (working
group) process - it doesn't seem to belong here at all

Proposed Change:

Reconsider this whole section - TR readers don't need to know about
the workings or history of the working group.

Response from Working Group:

We have modified the document as you suggested.

Comment 17:

(Issue ID: LC-1278)

Comment: Some screen readers do not recognise addition levels of
within a data table.

Proposed Change:

Split Comparison table into a series of tables at each  row. Also
better for printing when browsers support CSS 'keep with next'
approach in print stylesheet.

Response from Working Group:

The mapping has been removed from the WCAG document itself so that it
will be easier to maintain over time and to reflect new techniques as
they come out. The working group will work in coordination with the
EOWG WCAG 2.0 Materials Support Task Force in the creation of
transition materials and will consider these comments when the mapping
is updated.

Comment 18:

(Issue ID: LC-1279)

Comment: para 1 says thaty WCAG 2.0 makes web content available to a
wide range of disabilities, including "blindness and low vision,
deafness and hearing loss, learning difficulties, cognitive
limitations, limited movement, speech difficulties, and others". It
seems that learning difficulties and cognitive limitations are not
addressed to any significant extent, in fact even less than WCAG 1.0.
It seems the emphasis is even more on 'blindness and low vision' and
'limited movement'. THis may be becasue the strong move to
testability, but given that this is the case, then lets not kid
everyone (or no-one) that WCAG 2.0 address all disabilities.

Proposed Change:

change wording to leave these out at this stage. Seriously consider
the next task for the working group to be to properly address the
needs of these groups with suplement or addenda to WCAG 2.0 (or
release as a WCAG 2.1)

Response from Working Group:

We have added language to the Introduction, the Conformance section,
and the Quick Reference to highlight the fact that WCAG 2 only
addresses some of the needs of people with cognitive, learning, and
language disabilities, and to call out the need for more research in
this area. WAI is exploring ways in which to support and encourage
work in this important area.

We have added some best practices for cognitive, learning, and
language disabilities as advisory techniques, and we have proposed 3
new success criteria in this area.

Comment 19:

(Issue ID: LC-1280)

Comment: Many SC seem out of place at their specified levels. It seems
many SC Levels have not been reconsidered since the November 2005
release whe the levels related to 'coding', 'design/appearance' and
'additional'. As this is no longer the basis for the Levels, then the
SC need to be more closely re-examined as to the appropriate level
they should fall under.

Proposed Change:

re-examine all SC in the light of the April 2006 Conformance Level
definitions (cf Nov 2005 Levels definitions)

Response from Working Group:

The description of conformance levels in WCAG 2 has been rewritten to
clarify the levels, and we have reviewed the level of the success
criteria for appropriateness:

The word "levels" does not mean that some success criteria are more
important than others. Each success criterion in WCAG 2.0 is essential
to some users, and the levels build upon each other. However, even
content that conforms at AAA (triple-A) may not be fully accessible to
every person with a disability.

*In general, Level A success criteria achieve accessibility by
supporting assistive technology while putting the fewest possible
limits on presentation. Thus people with a wide range of disabilities
using a wide range of assistive technologies, from voice input and
eye-tracking devices to screen readers and screen magnifiers, are able
to access content in different ways. In other words, Level A success
criteria support the ability of both mainstream and specialized user
agents to adapt content to formats that meet their users' needs.

* The success criteria in Level AA provide additional support for
assistive technology. At the same time, they also support direct
access to content by the many people who use conventional user agents
without assistive technology. In general, Level AA success criteria
place more limits on visual presentation and other aspects of content
than the success criteria in Level A.

*Level AAA success criteria increase both direct access and access
through assistive technology. They place tighter limits on both
presentation and content."

Comment 20:

(Issue ID: LC-1281)

Comment: "If text alternatives cannot serve the same purpose, then
text alternatives at least identify the purpose of the non-text
content." Surely in this case the content has failed SC 1.1.1?

Proposed Change:

leave the second sentence out!

Response from Working Group:

Thank you for pointing out this issue with the wording of the first
bullet in SC 1.1.1. The intent of the second sentence, as explained in
the How to Meet SC 1.1.1 document, is to cover cases such as a test
where a particular sense must be used or where content is designed to
create a specific sensory experience. We have modified the success
criteria to clarify this.

Comment 21:

(Issue ID: LC-1282)

Comment: "If the purpose of non-text content is to confirm that
content is being operated by a person rather than a computer,
different forms are provided to accommodate multiple disabilities."

Proposed Change:

"If the purpose of non-text content is to confirm that content is
being ?accessed? by a person rather than a computer, different forms
are provided to accommodate multiple disabilities."

Response from Working Group:

Thank you for suggesting this change. We have implemented your suggestion.

Comment 22:

(Issue ID: LC-1283)

Comment: It is too easy to fail SC at Level 1 - most organisations I
have worked with will not go to this length in most cases, hence will
never be able to claim even "A" conformance. In fact, on most
Government and corporate sites I have worked with, the provision of a
transcript and/or a script gives all the information needed to
substitute for the multimedia

Proposed Change:

Level 1 should have SC along the lines of "provide a transcript if
spoken words only and no action" and "provide a script including the
dialogue if video wit activity"

SC 1.2.1 & 1.2.2 should be moved up a level, and all other SC
reconsidered as to the appropriate level.

Response from Working Group:

The working group considered carefully the levels assigned to all the
GL 1.2 success criteria. SC 1.2.1 and 1.2.2 are level A success
criteria because vision and hearing impaired users will not be able to
access multimedia without this information. SC 1.2.2 can be satisfied
by a full transcript. But captioning is a much better augmentation for
the deaf than a separate transcript, since much can be communicated
non-verbally, even when there is no action.

Comment 23:

(Issue ID: LC-1284)

Comment: "variations in presentation of text can be programmatically
determined." - yes, a graphical browser can display  italicised text,
but not much, if any, AT can determine its existance.

Proposed Change:

reconsider/clarify/strengthen this SC, or drop the last part.

Response from Working Group:

SC 1.3.1 and 1.3.4 have been combined to read "Information and
relationships conveyed through presentation can be programmatically
determined or are available in text, and notification of changes to
these is available to user agents, including assistive technologies."
This wording ensures that it is the meaning conveyed by the
presentation that must be programmatically determined, and allows the
author to indicate the meaning in text if it is not feasible to do so
programmatically. The How to Meet document describes this in some

Currently, many assistive technologies can determine the existence of
variations in presentation, albeit with minimal usability. It is the
information conveyed that is required by this success criterion. The
information needs to be conveyed in a usable manner.

Comment 24:

(Issue ID: LC-1285)

Comment: After playing with the luminosity algorithm for some time
now, selected colour combinations are still almost unreadable - eg the
algorithm allows blue-on-blue and orange-on-red, both combinations are
very difficult to read by anyone. For an example see IMHO, the colour-difference aspect of
the old draft colour contrast algorithm needs to be reintroduced. For
colours schemes that pass luminosity, but fail colour difference, see
some of the combinations on and
related pages.

Proposed Change:

add a colour difference aspect into the colour contrast SC

Response from Working Group:

While the contrast ratios used in the new algorithm do not include the
calculations for color difference from the AERT algorithm, it requires
a higher contrast ratio than would generally be required to address
the needs of users with limited color perception. We have revised the
contrast ratio somewhat to account for the conversion from nonlinear
to linear RGB values and have provided examples of how various color
combinations would be perceived with various color vision deficiencies
in the Understanding documents.

Comment 25:

(Issue ID: LC-1286)

Comment: Under the new Conformance level definitions, I strongly
suggest that 1.4.1 & 1.4.2 should be Level 1 and that 1.4.3 & 1.4.4
should be Level 2

Proposed Change:

reconsider the Levels the SC fall under - move them up a level

Response from Working Group:

The description of conformance levels in WCAG 2 has been rewritten to
clarify the levels (see ).

Because background audio can interfere with assistive technology, SC
1.4.1 (formerly 1.4.2) has been moved to level A.

Because level A attempts to put the fewest possible limitations on
presentation, and because assistive technology will be able to present
 the text or text equivalents of this content to the user, the working
group felt that SC 1.4.2 (formerly 1.4.1) was most appropriate at
level AA.

Because of the additional limitations they put on presentation, the
working group felt that SC 1.4.4 (formerly 1.4.3) and SC 1.4.5
(formerly 1.4.4) are most appropriate at level AAA.

Comment 26:

(Issue ID: LC-1287)

Comment: 20 seconds may well not be long enough to 'hit any key' for
some people with severe physical or motor disabilities. Also, what
form does the warning take? It needs to be accessible to all as well!

Proposed Change:

drop this bullet

Response from Working Group:

Although it is possible that 20 seconds will be insufficient for some
users, the specific time period is required to make this success
criterion testable, and a number was chosen that meets the Working
Group's best estimate of a reasonable amount of time that meets the
needs of nearly all people with disabilities.

The success criterion specifically avoids making requirements about
how the warning is provided to the user or how they may respond.
Techniques address this issue, with some examples worked out in
existing techniques and some examples suggested by undrafted

Comment 27:

(Issue ID: LC-1288)

Comment: This should be a level 2 SC - for many people with reading
difficulties, or using AT, reading a page is a time consuming
exersize, and page refreshes may not allow them to read to the end.

Proposed Change:

move this SC up a level & consider strengthening it WRT content
refreshing automatically

Response from Working Group:

Automatic page refreshes or updates are a type of time limit covered
by SC 2.2.1, which is a Level A success criterion.

See SC 2.2.1 at

Comment 28:

(Issue ID: LC-1289)

Comment: Under the new Conformance level definitions, I strongly
suggest that 2.4.3 should be a Level 1 SC & that 2.4.5 should be a
Level 2 SC

Proposed Change:

adjust the levels of 2.4.3 & 2.4.5

Response from Working Group:

We have added "descriptive" to SC 2.4.2 (formerly SC 2.4.3) and moved
it to level A.

SC 2.4.6 (formerly 2.4.5) has been moved to Level AA. It addresses
descriptive headings and labels, which may need to be understood in
context. While headings may not have sufficient descriptive power in
isolation, when viewed in the context of a structured document, they
do have sufficient descriptive power.

Comment 29:

(Issue ID: LC-1290)

Comment: What is the difference between 2.4.4 & 2.4.8? They seem very similar.

Response from Working Group:

We have reworded SC 2.4.4 to clarify its intent and to remove the term
"programmatically associated". It now reads:
2.4.4 The purpose of each link can be determined from the link text
and its programmatically determined link context.

where "Programmatically determined link context" is defined at as:

programmatically determined link context
       1. Additional information that can be programmatically
determined from relationships with a link; and
       2. can be extracted, combined with the link text, and presented
to users in different modalities.

    Example 1: Screen readers provide commands to read the current
sentence when focus is on a link.

    Example 2: Examples of information that can be extracted, combined
with link text, and presented to users in different modalities include
text that is in the same sentence, paragraph, list, or table cell as
the link or in a table header cell that is associated with the table
cell that contains the link.

Received on Thursday, 17 May 2007 23:31:23 UTC