- From: Loretta Guarino Reid <lorettaguarino@google.com>
- Date: Thu, 17 May 2007 16:34:14 -0700
- To: "Greg Gay" <g.gay@utoronto.ca>
- Cc: public-comments-WCAG20@w3.org
Dear Greg Gay , 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/20060511202531.694EBBDA8@w3c4.w3.org (Issue ID: LC-465) Item Number: Success Criterion 4.2.1 Part of Item: Comment Type: GE Comment (Including rationale for any proposed change): 4.2.1 also suggests that the accessible version be the primary version, with a link to the inaccessible version. In reality that is never the case, nor would you likely be able convince a client/developer to use an HTML version of their splash page in favour of a fancy Flash version Proposed Change: Ideally there should be reciprocol links between the two versions. ---------------------------- Response from Working Group: ---------------------------- We have moved discussion of alternate versions of content to the Conformance section of the Guidelines. "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." We have also added an advisory technique titled, "Providing reciprocal links between conforming and non-conforming versions." ---------------------------------------------------------- Comment 2: Source: http://www.w3.org/mid/20060511202657.E6605BDA8@w3c4.w3.org (Issue ID: LC-466) Item Number: Success Criterion 4.2.1 Part of Item: Comment Type: ED Comment (Including rationale for any proposed change): Wording of 4.2.1 is easily misinterpreted. Proposed Change: "Where content is presented using a technology that is not in the baseline, or is in the baseline but does not meet level 1 success criteria, provide reciprocol links between that version and another version of that same content, with equivalent functionality, that does meet level 1 success criteria." ---------------------------- Response from Working Group: ---------------------------- We have moved discussion of alternate versions of content to the Conformance section of the Guidelines. 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. We have also added an advisory technique titled, "Providing reciprocal links between conforming and non-conforming versions." ---------------------------------------------------------- Comment 3: Source: http://www.w3.org/mid/20060515151645.E147A6636B@dolph.w3.org (Issue ID: LC-469) Comment (Including rationale for any proposed change): There is currently no item number relevant to this comment. Technique G96 seems to be the only place within the WCAG 2.0 documents that mentions anything about "relative positioning", or more specifically use of relative measures. Using relative measures is particularly important for low vision users who use a browser function to blow up the text size. It is also important for those using small screens like PDAs. Proposed Change: This requirement seems to fit best under WCAG principle 4, regarding robust. Perhaps a new guideline 4.1.3, at level 2. something like "Ensure that content can be resized without losing its symmetry" Then in the techniques describing the use of relative measures for sizing block level items, text, images, etc. ---------------------------- Response from Working Group: ---------------------------- Although resizing is primarily a user agent function, we have added new success criteria to address the author's responsibility for supporting text resizing: Level AA: Visually rendered text can be resized without assistive technology up to 200 percent and down to 50 percent without loss of content or functionality. Level AAA: Visually rendered text can be resized without assistive technology up to 200 percent and down to 50 percent without loss of content or functionality and in a way that does not require the user to scroll horizontally. ---------------------------------------------------------- Comment 4: Source: http://www.w3.org/mid/20060511192524.6DF3847BA5@mojo.w3.org (Issue ID: LC-531) Item Number: (none selected) Part of Item: Comment Type: TE Comment (Including rationale for any proposed change): There doesn't seem to be a place to comment on the Baseline Document, so I'll post it here: http://www.w3.org/WAI/WCAG20/baseline/ The potential for many baselines is possible, and each baseline will have an overall level of accessibility associated with it. For example, a baseline that includes only HTML 4, is going to be more universally accessible than a baseline that includes HTML 4, Flash, Java, and Javascript. For clients or developers using the latter baseline, we would essentially tell them that if their content made full use of the Flash, Java, and Javascript accessibility features, they can comply at Level 2 (hypothetically speaking). But, for a client who creates the same site that uses the first baseline (HTML 4 only), and has gone to the trouble of creating alternatives for their Flash, Java, and Javascript content, will have created a more accessible site than the site that uses second baseline and does not have any alternative formats. What motivation would there be for the developer of the site using the first baseline, if they can just place all the technologies in the baseline, and forget about creating more accessible alternative content. Proposed Change: The solution to this may be associating some base accessibility value with a variety of standard baselines, baselines which remain non-normative, and evolve as technologies evolve. ---------------------------- Response from Working Group: ---------------------------- The conformance section of WCAG2 has been completely rewritten. The term "baseline" has been replaced by "accessibility-supported Web technologies". The issue of what it means to be an accessibility-supported Web technology is addressed in the section " Accessibility Support of Web Technologies", at http://www.w3.org/TR/2007/WD-WCAG20-20070517/#accessibility-support . ---------------------------------------------------------- Comment 5: Source: http://www.w3.org/mid/20060511193210.21A3447BA5@mojo.w3.org (Issue ID: LC-532) Item Number: Technology assumptions and the Part of Item: Comment Type: ED Comment (Including rationale for any proposed change): For the section prior to ...assumptions and the baseline... which isn't included in the items that can be commented on. References are made to Level 1 2 3, then Note 1 that follows refers to Triple-A conformance. Prior to this though, there has been no mention of A, AA, AAA confomance rankings. Novices to the guidelines may not make the connection if it is not described explicitely. Not until much further down the page is the association made. Proposed Change: Perhaps a note explaining the association, or a reference to an anchor further down the page would be appropriate here. ---------------------------- Response from Working Group: ---------------------------- We have completely rewritten the introduction and the conformance section, and conformance levels are now defined before they are used. ---------------------------------------------------------- Comment 6: Source: http://www.w3.org/mid/20060511194049.172C847BA5@mojo.w3.org (Issue ID: LC-533) Item Number: Technology assumptions and the Part of Item: Comment Type: TE Comment (Including rationale for any proposed change): There is a relatively easy possibility of Level AAA compliance by virtue of ommision. By default, the vast majority of sites will meet 50% of the level 3 guidelines without trying. The following are arguably not relevant on most Web sites. --------------------- Irrelevant for most sites 1.2.5 (w/ no MM) 1.2.6 (w/ no MM) 1.2.7 (w/ no MM) 1.4.3 (use standard B/W) 1.4.4 (with no audio content) 2.1.2 (with no time dependence) 2.2.4 (no timed events) 2.2.5 (no auto updated content) 2.2.6 (no timeout) 2.3.2 (use no flashing components) 2.4.6 (don\'t use tab to create inconsitent tab ordering 3.1.6 (write in an alphabetic language) 3.2.5 (use no auto redirects) 4.2.4 (use only baseline technologies) --------------------------- Potentially 13 L3 met by omission So without any extra effort, a site without any of the above technologies would meet enough level 3 criteria to comply, even though none of the guidelines are relevant. Things that could be done relevant to the content of the majority of sites Relevant to most sites 2.4.5 (use descriptive titles, headings, and labels) 2.4.7 (use breadcrumb links to navigate, and identify location within a hierarchy) 2.4.8 (use meaningfult link text) 2.5.4 (describe expected input for form fields) 3.1.3 (provide a glossary) 3.1.4 (expand all abbreviations) 3.1.5 (Use low level language) --------------------------- Potentially 7 L3 relevant to most sites. Proposed Change: Perhspa 75% of level 3 items would be more appropriate, or maybe 50%, which includes at least 4 or 5 items (or maybe all) from the second list of more common level 3 items. ---------------------------- Response from Working Group: ---------------------------- We have changed the definition of Level AAA conformance so that all Level AAA Success Criteria that apply to the content types used must be satisfied. ---------------------------------------------------------- Comment 7: Source: http://www.w3.org/mid/20060511194643.C7BD247BA5@mojo.w3.org (Issue ID: LC-534) Item Number: Conformance claims Part of Item: Comment Type: GE Comment (Including rationale for any proposed change): Re: Conformance notes. http://www.w3.org/TR/2006/WD-WCAG20-20060427/conformance.html#conformance-claims The Note suggests that the default version of the content displayed (i.e. Web unit that is returned when no negotiation is conducted) is the one that must comply. This would mean that myself for example, as a fully able user with no content negotiation enabled, would be forced to view the most accessible version of a content unit, despite, perhaps, a less accessible, more interactive, "flashy" version being more appropropriate for my needs. Proposed Change: I think the second statement (in parentheses) "...one of the negotiated forms must comply" makes more sense as the default here, with perhaps the added note that "...the most accessible version is easily accessed should the primary version not be accessible". A common example is the Flash splash page that includes a link to an accessible HTML version of the same content. In the initial statement it suggested that as a developer I would have to default to the HTML version of the page, with a link to the Flash version instead. Developers and their clients will not agree to this, but they will agree to a link that leads to a more accessible version.. ---------------------------- Response from Working Group: ---------------------------- We have removed discussion of content negotiation and moved requirements related to alternate versions to the Conformance section of the Guidelines. The revised conformance criteriaon now reads: 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 8: Source: http://www.w3.org/mid/20060511195339.A362647BA5@mojo.w3.org (Issue ID: LC-535) Item Number: Success Criterion 1.2.2 Part of Item: Comment Type: TE Comment (Including rationale for any proposed change): Guideline 1.2 Guidelines 1.2.2 and 1.2.3 are not mutually exclusive. Perhaps it should be, if an audio description is provided, compliance is at level 2. If a transcript is provided instead, compliance is at level 1. 1.2.2 "Audio descriptions of video, or... are provided for prerecorded multimedia." 1.2.3 "Audio descriptions of video are provided for prerecorded multimedia. Proposed Change: Drop "Audio descriptions of video" from 1.2.2. Audio description are relatively difficult to implement, while text transcripts are quite easy. Leave the transcript at level 1, which is attainable by everyone, and keep audio descriptions to level 2. ---------------------------- Response from Working Group: ---------------------------- SC 1.2.2 and 1.2.3 are indeed not mutually exclusive. If they were, we couldn't have them both as success criteria. However, making the change you suggest would remove options for authors at level A. In some cases it is easier and/or more effective to provide the full text alternative. In other cases it is easier and/or more effective to provide the audio equivalents. The current wording allows the author to chose at level A, but does require them to use audio description at level AA. Audio description would of course satisfy both level A and AA if it were provided. Therefore removing Audio Description from level A would make it harder for authors, not easier since it removes an option. ---------------------------------------------------------- Comment 9: Source: http://www.w3.org/mid/20060511195927.48A1833205@kearny.w3.org (Issue ID: LC-536) Item Number: Success Criterion 1.2.7 Part of Item: Comment Type: TE Comment (Including rationale for any proposed change): Guidelines 1.2.2 and 1.2.7 are not mutually exclusive. 1.2.2 "... a full multimedia text alternative including any interaction, are provided for prerecorded multimedia." 1.2.7 "For prerecorded multimedia, a full multimedia text alternative including any interaction is provided Proposed Change: Drop 1.2.7 in favour 1.2.1 at level 1, with Audio descriptions removed in favor of keeping them with 1.2.3 at level 2. ---------------------------- Response from Working Group: ---------------------------- Correct. SC 1.2.2 and 1.2.7 are not mutually exclusive. If they were we could not require both. The option is provided at Level A. At level AA Audio descriptions are required (which would also satisfy level A). At level AAA the text description is required, which would be in addition to the audio description required in level AA. The working group did not want to require SC 1.2.7 at level A but did want to have it as an option there and as a level AAA success criterion if it was not provided at level A. ---------------------------------------------------------- Comment 10: Source: http://www.w3.org/mid/20060511200217.4083633205@kearny.w3.org (Issue ID: LC-537) Item Number: Success Criterion 1.4.1 Part of Item: Comment Type: GE Comment (Including rationale for any proposed change): Guideline 1.4 Luminosity Contrast Ratio in its current form appears to be a less than perfect measure of contrast. For example black text on a white background is more readable than white text on a black background, yet both have the same ratio. In the future as the algorithms for measuring contrast become better, the suggested 5:1 ratio in 1.4.1, may no longer be valid. Proposed Change: A general statement should be made in the guideline, something like ...use foreground and background colours that provide sufficient contrast...", and move LCR and the suggested ratio to the techniques document, where it can be adjusted as measure of contrast become better defined. ---------------------------- Response from Working Group: ---------------------------- The change you propose would make the success criteria untestable. All success criteria need to be testable to qualify. So we need to provide specific description of what 'sufficient contrast' is. ---------------------------------------------------------- Comment 11: Source: http://www.w3.org/mid/0060511200418.D1BC733205@kearny.w3.org (Issue ID: LC-538) Item Number: Success Criterion 1.4.3 Part of Item: Comment Type: TE Comment (Including rationale for any proposed change): As suggested for 1.4.1, Luminosity Contrast Ratio in its current form appears to be a less than perfect measure of contrast. For example black text on a white background is more readable than white text on a black background, yet both have the same ratio. In the future as the algorithms for measuring contrast become better, the suggested 10:1 ratio in 1.4.1, may no longer be valid. Proposed Change: A general statement should be made in the guideline, something like ...use foreground and background colours that provide *high* contrast...", and move LCR and the suggested ratio to the techniques document, where it can be adjusted as measure of contrast become better defined. ---------------------------- Response from Working Group: ---------------------------- The change you propose would make the success criteria untestable. All success criteria need to be testable to qualify. So we need to provide specific description of what 'sufficient contrast' is. It is not always true that black text on a white background is more readable. For older people and people with impaired vision white on black is generally more readable because there is less light scatter (for media opacities) and fewer problems with adaptation levels. ---------------------------------------------------------- Comment 12: Source: http://www.w3.org/mid/20060511200749.A05E433205@kearny.w3.org (Issue ID: LC-539) Item Number: Success Criterion 2.2.1 <-- this appears to be a typo Part of Item: Comment Type: GE Comment (Including rationale for any proposed change): I'm not sure about the distinction between 2.1.1 and 2.1.2. Does it mean if there is required time dependant content, such as a reaction time test, the web unit can not comply at level 3. This could potentially be an issues, albeit unlikely, if a site were pursuing Level 2 or 3 conformance, but had a time dependant test, for example. Proposed Change: In such a case I would expect an accessibility statement or statement of scope to exclude the timed test, thus rendering the guideline irrelevant to a claim of Level 2 or 3 compliance. 2.1.2 sounds like it may not be enforcable. Perhaps remove it. ---------------------------- Response from Working Group: ---------------------------- It is the specific intent that timed content such as timed tests not be able to conform to this success criterion. The goal is to encourage the development of other non-time-based forms instead. ---------------------------------------------------------- Comment 13: Source: http://www.w3.org/mid/20060511201228.7F4DA33207@kearny.w3.org (Issue ID: LC-540) Item Number: Success Criterion 3.1.5 Part of Item: Comment Type: TE Comment (Including rationale for any proposed change): Though for public content, guideline 3.1.5 would apply, for non-public content, such as an online course aimed at a professional audience, there should be no requirement that it be "lower secondary" . How will evaluators measure language level. Perhaps using a FOG index for English. How would they assess across languages, where a FOG index is not valid? Would lower secondary be too high when an audience is from a third word country, where reading levels tend to be much lower? There has to be some acknowledgement of the audience reading the content. I thought I had suggested in a previous review of a WCAG 2 draft, that audience be worked into the baseline, though I can't find the specific reference at the moment. I understand that would complicate things significantly. If not included in the baseline, there does need to be some way to define the acceptable level of language for the intended audience. With regard to including the audience in a measure of readability, see: http://en.wikipedia.org/wiki/Readability Proposed Change: It might read something like "Where information is aimed at a non specific audience, for which reading level is unknown....use lower secondary..." ---------------------------- Response from Working Group: ---------------------------- Even specific target audiences may contain people who can understand the subject matter but have disabilities that make it difficult to deal with complex text. While reducing the complexity of the text will help all such people, the success criterion only requires additional supplementary material that will assist some of those users. We agree that all computerized readability programs have limitations, but they can be helpful in providing an easy check for whether the language used is clearly above or below the lower secondary level. The working group has no solution to problems of differing literacy levels, except as this is reflected in the definition of lower secondary level for different cultures. Low literacy levels as a result of lack of education, rather than cognitive disabilities, is outside the charter of the working group. ---------------------------------------------------------- Comment 14: Source: http://www.w3.org/mid/20060511201705.12011BDA8@w3c4.w3.org (Issue ID: LC-542) Item Number: How to Meet Success Criterion 3.1.5 Part of Item: Intent Comment Type: GE Comment (Including rationale for any proposed change): The statement "help people with reading disability" in the intent section of the How to meet 3.1.5 section is incorrect. The ability to comprehend high level language is not related to reading disability. Reading disability is strictly associated at a more general level with lessened ability to mentally convert visual textual information, into verbal auditory information (phonemic awareness). There is no concept of sematic disability associated with reading disability. By definition, a person with a reading disability does not have a sematic processing disability, with normal or above normal intelligence. There are several references throughout the HowTo document that refer to reading disability as an inability to understand. These statements need to be removed. They are not true (see: howto 3.1.6). Reading disability does not affect a person's ability to understand. Proposed Change: Remove references to to simplified language being an accomodation for those with a reading disability. ---------------------------- Response from Working Group: ---------------------------- We have revised the descriptions of the benefits of different success criteria for people with cognitive disabilities by using descriptions that are based on functional limitations. ---------------------------------------------------------- Comment 15: Source: http://www.w3.org/mid/Heteronyms &Capitonyms (Issue ID: LC-543) Item Number: Success Criterion 3.1.6 Part of Item: Comment Type: QU Comment (Including rationale for any proposed change): Is guideline 3.1.6 relevant to alphabetic langauges. I was unable to determine the meaning of this guideline as it applies to English, or other alphabetic languages. If it is relevant to alphabetic languages, examples should be provided, or it should be stated that it applies to syllabic, or orthographic languages. Proposed Change: ---------------------------- Response from Working Group: ---------------------------- Guideline 3.1.6 is indeed relevant to alphabetic languagues. Examples have been added to the "Intent of this success criterion" section of "How to Meet 3.1.6" to illustrate this. The revised section reads as follows: "For example, in the English language heteronyms are words that are spelled the same but have different pronunciations and meanings, such as the words desert (abandon) and desert (arid region). Additionally, in some languages certain characters can be pronounced in different ways. In Japanese, for example, there are characters like Han characters(Kanji) which have multiple pronunciations. Screen readers may speak the characters incorrectly without the information on pronunciation. When read incorrectly, the content will not make sense to users." ---------------------------------------------------------- Comment 16: Source: http://www.w3.org/mid/20060511202206.8DAC5BDA8@w3c4.w3.org (Issue ID: LC-544) Item Number: Success Criterion 4.1.1 Part of Item: Comment Type: TE Comment (Including rationale for any proposed change): In guideline 4.1.1 does "parsed unambiguosly" mean "well formed" or "valid"? The techniques seem to suggest that markup must be valid, though you would be hard pressed to find invalid code that disrupts any relatively recent screen reader's ability to read a Web unit. It takes severely broken markup to affect accessibility, or specific types of errors (such as broken table structures). While I am all for valid markup, it is *not* a requirement for accessibility in most cases, particularly at level 1. I can see this requirement at level 2 perhaps. Proposed Change: What would be appropriate here to have a well formed requirement at level 1, and valid at level 2. And still this really has to do with compatibility with future technologies, rather than affects on accessibility using current technologies. ---------------------------- Response from Working Group: ---------------------------- We have reworded SC 4.1.1 to require that content can be parsed without error. The working group looked at this topic carefully over an extended period of time and concluded that requiring strict adherence to all aspects of specifications does not necessarily result in an increase in accessibility. For example, it is possible to create invalid pages that present no accessibility barriers. It is also possible in certain situations to enhance accessibility through the use of markup that is not part of the specification. The working group must work within its charter and only include things that directly affected accessibility. Some aspects of "use technologies according to specification" and validity do relate to accessibility. However, others do not. So requiring validity would take us beyond our charter. We do recommend it though and it is our #1 technique listed for conforming to SC 4.1.1. ---------------------------------------------------------- Comment 17: Source: http://www.w3.org/mid/20060511202433.8FF65BDA8@w3c4.w3.org (Issue ID: LC-545) Item Number: Success Criterion 4.2.1 Part of Item: Comment Type: ED Comment (Including rationale for any proposed change): Guideline 4.2.1 This guideline does not read like a guideline (same with 4.2.3), is not immediately clear what it means without reviewing the HowTo, and can be interpreted in different ways (i.e. ...may [also] be, or ...may [instead] be...). I interpret it first as meaning I can include a link from the accessible version to the innaccessible version. In fact it should be the opposite that is true (and I'm sure based on the howto that is what was intended), including a link from the innaccessible version to the accessible one. Proposed Change: Ideally there should be reciprocol links between the two versions. ---------------------------- Response from Working Group: ---------------------------- We have moved discussion of alternate versions of content to the Conformance section of the Guidelines, and we have clarified by adding the following conformance requirement 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. We have also updated the understanding document to clarify situations when different sufficient techniques would apply.
Received on Thursday, 17 May 2007 23:35:09 UTC