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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 16:32:20 -0700
Message-ID: <824e742c0705171632o667607c4tbe8ca0777d5383ce@mail.gmail.com>
To: "David Sloan" <dsloan@computing.dundee.ac.uk>
Cc: public-comments-WCAG20@w3.org

Dear David Sloan ,

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/07516E2AF8EF64469CD4EC1BBA47F581012C501F@mailex.computing.dund
(Issue ID: LC-1311)

Response to WCAG 2.0

>From the following UK organisations:

* JISC TechDis Service, Higher Education Academy Building, Innovation
Way, York, YO10 5BR
* BECTA (British Educational Communications and Technology Agency),
Millburn Hill Road, Science Park, Coventry, CV4 7JJ
* UKOLN, University of Bath, Bath, BA2 7AY
* JISC CETIS (Centre For Educational Technology Interoperability
Standards), Research Institute for Enhancing Learning, Padarn, School
of Education, University of Wales Bangor, Normal Site, Bangor,
Gwynedd, LL57 2PZ
* Scottish Disability Team (SDT), Ewing Annexe, University of Dundee,
Dundee, DD1 4HN
* Digital Media Access Group (DMAG), School of Computing, University
of Dundee, Dundee, DD1 4HN

Contact: David Sloan, Digital Media Access Group (DMAG), School of
Computing, University of Dundee, Dundee, DD1 4HN; dsloan @


The above organisations, all active in the UK
education/technology/disability field, broadly support the principles
of inclusive Web design as set out by WCAG 2.0. We also have some
reservations, many of which have been expressed elsewhere, over the
practical application of WCAG 2.0 in its present form. We offer some
general recommendations which, if followed, we believe will better
serve Web content providers in the community in which we work.


The 'Last Call' draft of version 2.0 of the Web Content Accessibility
Guidelines (WCAG) has, since publication in April, attracted a
significant amount of public comment, much of it of a negative nature.
The authors of this response are all organisations heavily involved in
promoting the appropriate use of technology to make access to
education in the UK by disabled people as easy and effective as
possible. We realise the importance of what will be the successor to
the current de facto global standard for web accessibility in
influencing commissioners and developers of Web content and
applications, and all believe that WCAG 2.0 must build on WCAG 1.0 to
improve, rather than inhibit levels of accessibility online.

We do not wish to repeat other detailed responses by providing a line
by line critique of the current draft. Instead we present a
higher-level view, outlining our concerns and our support where


We note the many other responses that have been submitted to WAI in
response to WCAG, and while we share the concerns expressed over the
likely difficulty many developers will have in applying WCAG to HTML
development, we strongly support the need to present Web accessibility
as something more than "just following guidelines".

We are also conscious of the difficulty of developing accessibility
guidelines, while also emphasising that readers must also be familiar
with the ways in which disabled people access and use the Web; and the
role of authoring and browsing tools - and their limitations - in
ensuring an optimally accessible Web.

Our involvement in education has influenced our belief that Web
accessibility should be considered on two levels:

* Developing Web sites to minimise the chances of excluding access by
people with sensory, physical or cognitive impairments.
* Using the potential of Web resources to improve access to real-world
information, experiences and services for disabled people.

This requires a holistic approach to Web accessibility - where
development is driven by enabling the target audience to access and
use the site for the intended purpose in the intended environment,
whatever that may be [1, 2, 3]. In the UK, the recent emergence of PAS
78 [4] has highlighted the importance of other factors in optimising
Web accessibility beyond technical conformance.

We believe that the principles and guidelines set out in the WCAG 2.0
Last Call draft offer a solid platform on which to build on the two
levels above. In particular, the technology-neutral approach adopted
by WCAG supports authors in providing the best solution for the
resource and audience in mind, whatever that may be. We further
believe that the Baseline concept is an important step to enabling a
more audience-focused approach to development, by allowing WCAG
conformance to be specified in the context of a defined user
environment that accurately represents reality.

We also note the tensions that appear to have emerged between the Web
Standards movement and the Web Accessibility movement. We support the
principle of open standards adoption, we know of the accessibility
benefits that standards-conformance can bring; but we also realise
that standards-compliance is not always equivalent to optimal
accessibility of experiences, services and information for disabled
people. Therefore we appreciate the difficulty that WAI has faced in
deciding where and how to include designing to HTML (and other)
standards within WCAG 2.0. Standards-conformance should be strongly
encouraged; at the same time, considering the relationship between
WCAG and disability legislation around the world, the potential
situation of a Web site being declared unlawful (or being removed for
fear of being unlawful) because it fails to validate to a particular
technical standard, despite no evidence to indicate that a specific
group of disabled people face undue discrimination, must be avoided.

As noted, we are concerned at the level of negative reaction to WCAG,
much of which has come from prominent individuals in the field of web
accessibility, notably [5]. We echo these concerns:
Extent of supporting documentation and relationship between WCAG 2.0
and Techniques for HTML development

The amount of documentation supporting the guidelines is immense;
increasing complexity of navigation between guidelines and supporting
documentation. We have welcomed the appearance in recent months of
high-quality supporting material that has appeared on the redesigned
WAI web site. However, we fear that the split between general
guidelines and non-normative direction for specific technology
development may lead to inappropriate solutions being applied. Given
that, initially, most users of WCAG 2.0 will be HTML authors, this
complexity, and in particular the relationship between WCAG and HTML
Techniques needs to be revisited.


We reject the arguments expressed elsewhere that the Baseline concept
promotes a return to browser-specific development. However we
recognise that there is scope for authors to abuse the Baseline
concept, which therefore needs to be defined more coherently. We would
anticipate that in the UK, were a case of alleged discrimination under
the DDA to come to court, any court decision should look at the
baseline (if specified) and its appropriateness to the target
audience, and therefore baseline definition becomes a critical task.
Support for people with learning difficulties/disabilities

We share concerns expressed by others over the lack of focus on
supporting people with varying cognitive impairments. We would like to
see more encouragement given to supporting people who have difficulty
reading on-screen text, through for example encouraging appropriate
use of multimedia alternatives if they exist or can easily be created,
but we also realise that there remains much work to do in this area.
Nevertheless we have lent our support to the sentiments expressed in
the Formal Objection co-ordinated by Lisa Seeman and Jonathan


We feel that the way in which WCAG conformance has been addressed is
excessively complex. In the UK, our legal obligations are to ensure
that facilities and services are made accessible, and thus
concentration should be on making tasks optimally accessible, and
reporting on that success. The WCAG however deals with conformance at
an artificial level - i.e. "Web unit", introducing as it does a new
set of terminology that may confuse many people. We would prefer to
see a more task-oriented approach to conformance, whereby lack of
conformance requires a responsibility to document alternative routes
to achieving task completion - this should be stated explicitly in the


HTML application of WCAG

We see the most critical task as redefining the relationship between
WCAG 2.0 and the WCAG 2.0 HTML Techniques. There is a need to support
the most common WCAG 2.0 use case (those seeking support for
HTML/XHTML development) by making it clear to developers what is and
is not permitted in WCAG-conformant design. Clarification on the WCAG
position on validation of HTML/CSS is also necessary, given the nature
of many comments on the current draft and worries that WCAG
conformance may promote increased use of invalid HTML.

NB We note strong support amongst Web developers for focus to move to
amending WCAG 1.0 as a matter of urgency; and that development of WCAG
2.0 be continued longer-term in parallel with a redefinition of the
role of second-generation Web Content Accessibility Guidelines in a
world where there is increasing diversity in the nature and source of
Web content (for example podcasts, collaborative online publishing
areas, email discussion list archives, to name but a few), but where
UAAG support by widely-used user agents is likely to remain
disappointing. While we have indicated our support for the
'principles' approach that WCAG 2.0 has taken, we would support the
WAI should it decide to refocus efforts in producing a revised WCAG
1.0 as an interim measure.

Amount of supporting documentation

There is a need to reduce the perceived amount of reading required. We
assume that the errors and logical absurdities pointed out by other
commentators will be addressed; however we would also like to see a
reduction in the amount of new concepts that must be learned by a
reader. Some examples illustrating key concepts within the guidelines
would be a very useful aid in this area.

NB We note the recent appearance of the WCAG 2.0 Quick Reference -
which is a major step in this area.


To ensure a practically useful conformance system, there is a need to
shift focus from 'Web units' to user tasks. Defining what can be done
in a Web site, and which groups may find these tasks difficult or
impossible, is we argue of more relevance that a report of an
artificial entity's conformance against a set of checkpoints. WCAG
conformance should be seen as a means to achieving accessible
experiences, and not an end in its own right.


Clarification of the concept is necessary so as to limit
misinterpretations and potential abuses. If not already happening,
there is an urgent need for WAI to work with influential agencies
across the globe to ensure that appropriate and reasonable baselines
are defined and published for specific sectors.

Web Standards v Web Accessibility

The balance between Web Standards and Web Accessibility is altogether
more difficult to address. We realise that external developments will
be difficult for WAI to control, but we strongly urge WAI to
re-establish links with those involved in any rival developments so
that we have harmony in the way we all seek to achieve the common goal
of an optimally accessible Web.


1. Kelly, B., Sloan, D., Phipps, L., Petrie, H. and Hamilton, F.
(2005) Forcing Standardization or Accommodating Diversity? A Framework
for Applying the WCAG in the Real World. Proceedings of the 2005
International Cross-Disciplinary Workshop on Web Accessibility (W4A).
2. Kelly, B., Phipps, L. and Howell, C. (2005) Implementing A Holistic
Approach To E-Learning Accessibility. In: Cook, J. and Whitelock, D.
Exploring the frontiers of e-learning: borders, outposts and
migration; ALT-C 2005 12th International Conference Research
Proceedings, ALT Oxford.
3. Sloan, D., Kelly, B., Heath, A., Petrie, H. Fraser, H. and Phipps,
L. (2006) Contextual Web Accessibility - Maximizing the Benefit of
Accessibility Guidelines. Proceedings of the 2006 International
Cross-Disciplinary Workshop on Web Accessibility (W4A).
4. British Standards Institute (2006) Publicly Available Specification
PAS 78:2006 Guide to good practice in commissioning accessible web
sites. http://www.bsi-global.com/ICT/PAS78/index.xalter
5. Clark J (2006) To Hell with WCAG 2.0. A List Apart 217.

Response from Working Group:

* HTML application of WCAG

We have created a new Quick Reference document,
http://www.w3.org/WAI/WCAG20/quickref/20070517/ , that provides a
concise listing of the WCAG success criteria and the techniques for
meeting them.  The HTML techniques for each success criteria lead the

Amount of supporting documentation

We have introduced the Quick Reference to provide a short summary of
all the "How To Meet" information.   We plan to break up the
"Understanding" Document into modules, one for each success criterion.
(The current consolidated document with all of the sections in it will
also be available for those interested.) The techniques will also be
available as separate documents. This makes a lot of documents but you
will only need to look at the documents for the success criterion that
you are interested in.  Consider it a free book of support material
for WCAG and another on its techniques, all conveniently linked from
the guidelines and Quick Reference document.

* Conformance

We have included a provision requiring full processes to be
accessible.  We use the term Web page instead of Web unit. The basic
unit of conformance, however, is still the Web page.

* Baseline

We have completely reworked the baseline concept and dropped the name.
 While it is still somewhat complex it is because the process is
complex.   We have eliminated as much ambiguity as we can from

* Web Standards and Web Accessibility

We have established links with other Web Standards groups and
Developer groups as well. WCAG standards are now referenced in draft
ISO standards.  We are harmonizing with 508 standards in the US.  And,
we are working with BenToWeb, a project within the EU WAB Cluster.

It has been challenging to write success criteria that are technology
neutral, testable, and easy to understand. We have taken great pains
to write the success criteria so that they are technically accurate
but technology neutral. We are using the Understanding document to
make it easier to understand the implications of the success criteria,
and to provide specific techniques for some technologies. However, we
don't want to restrict the range of solutions by making the list of
known solutions normative. We do not believe that we could update
normative Understanding and Technique documents quickly enough to keep
pace with the changes in technologies and user agents. The W3C process
is long for any document.

This approach also allows WCAG 2.0 to avoid introducing some of the
"until user agent" problems from WCAG 1.0.
Received on Thursday, 17 May 2007 23:32:40 UTC

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