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Your comments on WCAG 2.0 Last Call Draft of April 2006 (1 of 3)

From: Loretta Guarino Reid <lorettaguarino@google.com>
Date: Thu, 17 May 2007 16:34:27 -0700
Message-ID: <824e742c0705171634k424d8d28w81fda83295152e04@mail.gmail.com>
To: "Greg Lowney" <gcl-0039@access-research.org>
Cc: public-comments-WCAG20@w3.org

Dear Greg Lowney ,

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
archived.

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/001501c59b26$aaec1bb0$6800a8c0@lucky13
(Issue ID: LC-1146)

"Grouping blocks of repeated material in a way that can be skipped
USING one of the technology-specific techniques below (for a
technology in your baseline)" is ambiguously worded due to a dangling
participle. I read it at first as equivalent to saying
"Group blocks of repeated material, using a method that can be skipped
using the techniques."

Proposed Change:

Insert a comma so it reads
"Grouping blocks of repeated material in a way that can be skipped,
USING one of the technology-specific techniques below (for a
technology in your baseline)"

----------------------------
Response from Working Group:
----------------------------

The draft has been updated as proposed.

----------------------------------------------------------
Comment 2:

Source: http://www.w3.org/mid/001501c59b26$aaec1bb0$6800a8c0@lucky13
(Issue ID: LC-1147)

In " Techniques for Addressing Success Criterion 4.2.1", the ordered
list of three items has "OR" between items 1 and 2, but nothing
between items 2 and 3 to clarify their boolean relationship.

Proposed Change:

Insert "OR" at the end of bullet item 2.

----------------------------
Response from Working Group:
----------------------------

We agree. However, the third item in this list has been removed as
part of a resolution to another issue, so the need for an additional
"OR" here is no longer present.

----------------------------------------------------------
Comment 3:

Source: http://www.w3.org/mid/001501c59b26$aaec1bb0$6800a8c0@lucky13
(Issue ID: LC-1148)

"The Conformance section and SC 4.2 clearly contradict each other. The
section on Conformance currently reads ""WCAG 2.0 conformance at level
A means that all Level 1 success criteria in the guidelines are met
assuming user agent support for only the technologies in the specified
baseline."" By contrast, 4.2.1 and 4.2.3  say ""At least one version
of the content meets all level N success criteria, but alternative
version(s) that do not meet all level N success criteria may be
available from the same URI.""

Take for example a URI that has two versions of the same content, one
not meeting SC 1.1.1 and the other an accessible alternative that does
meet 1.1.1. Can that URI conform at Single-A? Under the current
wording of the Conformance section, the answer is clearly NO! That
page complies with 4.2.1 (by providing an accessible alternative), but
it still fails 1.1.1: the rules stated in the Conformance section
provide no exemption from 1.1.1 just because something passes 4.2.1,
nor does 1.1.1 itself define any such exemption.

If conforming with 4.2.1 is meant to provide exemptions from most
other Level 1 criteria, the document MUST say that in the normative
Conformance section or in the description of each success criterion.

You might say that the intent is understood, but the question is, is
the intent supported or contradicted by the actual wording of the
normative sections of the document?"

Proposed Change:

"Change Conformance to explicitly say that conformance requires that
each URI conforms with all SC of the appropriate level OR that an
accessible alternative that does so is available from the same URI
(with a link to the details of what that means, currently in the
Understanding document's discussion of Guideline 4.2).

OR, change the section ""Conformance Levels and the Baseline"" to say
that only conformance with criterion 4.2.1 is required to claim
Single-A conformance, and leave it to 4.2.1 to require all the rest of
the Level 1 criteria."

----------------------------
Response from Working Group:
----------------------------

We have moved the requirements of success criterion 4.2.1 out of the
guidelines and into the conformance section, and we have changed the
definition of the conformance levels to require that each web page
either satisfy all success criteria at that level or satisfy the
alternate version requirement.

----------------------------------------------------------
Comment 4:

Source: http://www.w3.org/mid/001501c59b26$aaec1bb0$6800a8c0@lucky13
(Issue ID: LC-1149)

This is closely related to the previous comment on Conformance, and a
follow-up to existing issue 1590.

I was unable to spot where, in the Conformance section or elsewhere,
it is made explicit whether success criteria need to be met all the
time, or by default, or only on request. For example, 1.4.1 says
""Text or diagrams, and their backgrounds, have a luminosity contrast
ratio of at least 5:1""; is it acceptable if that is a user-selectable
option, and if so, does it have to be on by default? The closest I can
find to addressing this is Guideline 4.2, ""Ensure that content is
accessible or provide an accessible alternative,"" under which SC
4.2.1 (for example) says ""At least one version of the content meets
all level 1 success criteria, but alternate version(s) that do not
meet all level 1 success criteria may be available from the same
URI."" This can be taken as making it clear that all success criteria
can be met at the user's request, and do not need to be met in the
default configuration. However, it seems strange to have success
criteria in one guideline (4.2) effectively define exceptions to every
other success criteria in the document, essentially saying ""You know
that thing we said you have to do? Well, you don't have to do it under
certain circumstances."" As a result, 4.2.x are the only success
criteria that are actually required; the rest are all conditionally
required, although you won't find this out unless you read 4.2.

----------------------------
Response from Working Group:
----------------------------

We have moved the requirements on alternate versions from guideline
4.2 to the conformance section. The current wording should clarify
that inaccessible versions are permitted, but only if they provide an
accessible mechanism to reach an accessible version:

Alternate Versions: If the Web page does not meet all of the success
criteria for a specified level, then a mechanism to obtain an
alternate version that meets all of the success criteria can be
derived from the nonconforming content or its URI, and that mechanism
meets all success criteria for the specified level of conformance. The
alternate version does not need to be matched page for page with the
original (e.g. the alternative to a page may consist of multiple
pages). If multiple language versions are available, then conforming
versions are required for each language offered.

----------------------------------------------------------
Comment 5:

Source: http://www.w3.org/mid/001501c59b26$aaec1bb0$6800a8c0@lucky13
(Issue ID: LC-1150)

The paragraph defining "user agent" implies that it incldues all AT,
whereas it really only includes some AT. It reads: "It is important to
note that assistive technologies are included in this definition.
Assistive technologies include screen readers, screen magnifiers,
on-screen and alternative keyboards, single switches, voice
recognition, and a wide variety of input and output devices that meet
the needs of people with disabilities."

Proposed Change:

Add phrases shown in upper case: "It is important to note that MANY
assistive technologies are included in this definition. SUCH assistive
technologies include screen readers, screen magnifiers, on-screen and
alternative keyboards, single switches, voice recognition, and a wide
variety of input and output devices that meet the needs of people with
disabilities."

----------------------------
Response from Working Group:
----------------------------

We removed this paragraph because it was redundant with the
definitions and we were removing unnecessary informative information
from the conformance section. We have clarified the relationship
between user agents and assistive techologies in the current
definitions.

----------------------------------------------------------
Comment 6:

Source: http://www.w3.org/mid/001501c59b26$aaec1bb0$6800a8c0@lucky13
(Issue ID: LC-1151)

The example conformance claims are invalid because they omit the full
name and URI of the guidelines, which are required according to the
section "Required components of a conformance claim".

Proposed Change:

Replace "W3C's WCAG 2.0" with "Web Content Accessibility Guidelines
2.0 at http://www.w3.org/TR/2006/REC-WCAG20-YYYYMMDD/"

----------------------------
Response from Working Group:
----------------------------

The draft has been revised as proposed.

----------------------------------------------------------
Comment 7:

Source: http://www.w3.org/mid/001501c59b26$aaec1bb0$6800a8c0@lucky13
(Issue ID: LC-1152)

One required component of a conformance claim is "Scope of the claim
(a URI, list of URI's, or a set of URIs defined by a regular
expression)," and the examples each include a single URI. This, the
Examples, and the Conformance Notes all fail to clarify whether citing
a single URI implies conformance is claimed for that one web page (or
equivalent), or all pages referenced by it, or all pages "beneath it"
on the server. For example, does claiming conformance for
http://telcor.example.com/nav/G7/intro.html mean that conformance is
claimed just for that one page, or for all the pages it links to, or
all the pages in the /nav/G7/ directory on the server, including or
not including subdirectories? I suggest clarifying this and also
including an example of a claim for an entire Web site or multi-page
portion thereof.

----------------------------
Response from Working Group:
----------------------------

We have completely rewritten the Conformance section. The format of
this description is no longer specified. The corresponding required
component is now:

4. A description of the URIs that the claim is being made for,
including whether subdomains are included in the claim.

We have fixed the existing examples to clarify that the first applies
to the entire site and the second applies only to the specific page.
We have added examples to illustrate the use of boolean and regular
expressions in a conformance statement.

----------------------------------------------------------
Comment 8:

Source: http://www.w3.org/mid/001501c59b26$aaec1bb0$6800a8c0@lucky13
(Issue ID: LC-1153)

The example conformance claims list things like jpeg as
'specifications that this content "relies upon"'. How can jpeg ever be
a relied upon specification since the guidelines require Web pages to
be usable even when the images are turned off?

Proposed Change:

Remove JPEG from list of "specifications that this content relies
upon", or else clarify what is meant by including it.

----------------------------
Response from Working Group:
----------------------------

"Relies upon" means that it is used in this content and must be
supported by the user agent in order to claim conformance. If jpeg
were used to satisfy SC 3.1.5 by providing an illustration as
supplemental content, then jpeg would be relied upon.

----------------------------------------------------------
Comment 9:

Source: http://www.w3.org/mid/001501c59b26$aaec1bb0$6800a8c0@lucky13
(Issue ID: LC-1154)

The guidance says that when referencing WCAG 2.0 with its full name
and URI, a period should be used after the date and before the
parenthetical URI. However, this is not how it's shown in the
Examples. I suggest removing the period from the guidance and leaving
the examples as they are.

Proposed Change:

Remove period after date, to read: "Web Content Accessibility
Guidelines 2.0, W3C World Wide Web Consortium Recommendation XX Month
Year (http://www.w3.org/TR/200X/REC-WCAG20-YYYYMMDD/, Latest version
at http://www.w3.org/TR/WCAG20/)"

----------------------------
Response from Working Group:
----------------------------

The draft has been updated as proposed.

----------------------------------------------------------
Comment 10:

Source: http://www.w3.org/mid/001501c59b26$aaec1bb0$6800a8c0@lucky13
(Issue ID: LC-1155)

In the phrase "different forms are provided to accommodate multiple
disabilities", the word "multiple" could be read as saying these forms
should address the needs of an individual with multiple disabilities,
which is a nice goal but not the baseline requirement.

Proposed Change:

Change "different forms are provided to accommodate multiple
disabilities" to "different forms are provided to accommodate
different disabilities".

----------------------------
Response from Working Group:
----------------------------

The bullet has been revised to read:

If the purpose of non-text content is to confirm that content is being
accessed by a person rather than a computer, then text alternatives
that identify and describe the purpose of the non-text content are
provided and alternative forms in different modalities are provided to
accommodate different disabilities

----------------------------------------------------------
Comment 11:

Source: http://www.w3.org/mid/001501c59b26$aaec1bb0$6800a8c0@lucky13
(Issue ID: LC-1156)

The order of the two clauses is reversed from all the other success
criteria for guideline 1.2.

Proposed Change:

Change
"For prerecorded multimedia, a full multimedia text alternative
including any interaction is provided" to read
"A full multimedia text alternative including any interaction is
provided for all prerecorded multimedia."

----------------------------
Response from Working Group:
----------------------------

We revised the term to "full text alternative for multimedia including
any interaction." The success criterion has been updated to read,
"1.2.7 A full text alternative for multimedia including any
interaction is provided for all prerecorded multimedia."

----------------------------------------------------------
Comment 12:

Source: http://www.w3.org/mid/001501c59b26$aaec1bb0$6800a8c0@lucky13
(Issue ID: LC-1157)

The phrase "visually evident without color" could be misinterpreted as
meaning "visually evident, and without color". Suggest rephrasing to
be less ambiguous.

Proposed Change:

Change "visually evident without color" to read "visually evident even
if any color cannot be perceived".

----------------------------
Response from Working Group:
----------------------------

SC 1.4.1 (formerly 1.3.2) has been revised to read:

Use of Color: Any information that is conveyed by color differences is
also visually evident without the color differences.

----------------------------------------------------------
Comment 13:

Source: http://www.w3.org/mid/001501c59b26$aaec1bb0$6800a8c0@lucky13
(Issue ID: LC-1158)

The guideline reads, "Any information that is conveyed by color is
also visually evident without color." This wording clearly implies
that it is acceptable to convey information by contrast, a technique
that is discussed in other criteria but overlooked both here and its
Understanding. Is the intent here to make sure information is visually
evident without perceiving color and contrast, or to say that
conveying information by contrast alone is acceptable? I suspect the
former. If the latter, we should provide guidance for 1.3.2 on minimum
acceptable contrast between items when color/contrast is used alone to
denote differences in type, state, etc., just as we do for differences
between foreground and background elsewhere. Even if the former, such
guidance on the use of contrast would be valuable as a Level 2 or
Level 3 criterion.

Proposed Change:

Change to read "Any information that is conveyed by color or contrast
is visually evident even if any color and contrast cannot be
perceived.."

----------------------------
Response from Working Group:
----------------------------

We have combined SC 1.3.1 and 1.3.4 into a level A criterion that
reads, "1.3.1 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." We have also revised SC
1.3.2 to read, "1.4.1 Use of Color: Any information that is conveyed
by color differences is also visually evident without the color
differences."

The working group believes that the revised level A criterion
addresses your concerns regarding the use of conveying information via
contrast alone.

----------------------------------------------------------
Comment 14:

Source: http://www.w3.org/mid/001501c59b26$aaec1bb0$6800a8c0@lucky13
(Issue ID: LC-1159)

The wording "When the sequence of the content affects its meaning,
that sequence can be programmatically determined" is ambiguous as to
whether it refers to intended viewing/reading order, keyboard
navigation order, presentation order (e.g. navigation links are at the
top despite the designer's intention that they not be actually read on
every page), and/or declaration order (e.g. content is declared early
in the HTML despite being positioned at the bottom of the page using
vertical alignment attributes). The Understanding section only
addresses conveying intended reading order, but if that is the
intention, the wording of the Success Criterion should reflect that.
However, other ordering may be important to some types of assistive
technology (e.g. keyboard navigation order for use by speech
recognition software).

----------------------------
Response from Working Group:
----------------------------

Yes, it is the intent that SC 1.3.2 (formerly 1.3.3) cover only
reading order. Keyboard navigation order is covered under SC 2.4.3
(formerly 2.4.6). The other aspects of the comment - presentation
order and declaration order are considered to be aspects of or
sufficient techniques for the above two issues. To clarify this, SC
1.3.2 was reworded: "When the sequence in which content is presented
affects its meaning, a correct reading sequence can be
programmatically determined  and sequential navigation of interactive
components is consistent with that sequence."
Received on Thursday, 17 May 2007 23:35:09 UTC

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