Your comments on WCAG 2.0 Last Call Draft of April 2006

Dear Karen Mardahl  ,

Thank you for your comments on the 2006 Last Call Working Draft of the
Web Content Accessibility Guidelines 2.0 (WCAG 2.0 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, and may
also include links to the relevant changes in the updated WCAG 2.0
Public Working Draft at

PLEASE REVIEW the decisions  for the following comments and reply to
us by 7 June at 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 . Please see 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:

(Issue ID: LC-1310)

Dear WCAG Working Group Members,

This is a response to the Web Content Accessibility Guidelines 2.0 (WCAG
2.0) from the Accessibility Special Interest Group (AccessAbility SIG)
of the Society for Technical Communication (STC).

Although this response is being sent by the leadership of the
AccessAbility SIG, it represents the work of a subcommittee on behalf of
the entire special interest group.

All AccessAbility SIG members are technical authors, and many are web
users with disabilities, some are usability practitioners, and some are
web accessibility experts. As such, the group has particular expertise
with both web accessibility and document design, as well as having
first-hand experience of the issues web users with disabilities face.

We know that WCAG 2.0 is the result of hard work by a lot of people for
a long time, and we appreciate these efforts. However, the AccessAbility
SIG would like to express its concerns regarding the current WCAG 2.0
document and to offer our assistance with re-thinking, re-structuring,
and re-writing the accompanying documents. We feel that the information
in the supporting documents is very difficult to use and needs
significant restructuring in order to be meaningful to the target

The Working Group has indicated that the deadline for review of the WCAG
documents should focus on the WCAG 2.0 guidelines themselves, and that
the supporting documents ("Understanding WCAG 2.0" and "Techniques for
WCAG 2.0") do not have a deadline for comments, although reviewers "may
find them helpful in understanding or implementing the provisions in the

The guidelines in the WCAG 2.0 document comprise approximately 10 pages
in a documentation set that is well over 650 printed pages.
Unfortunately, we feel that it is impossible to assess or approve the
guidelines in the main document without reviewing the supporting
documents in full, a daunting task at best. We recommend extending the
deadline further and including commentary on the entire set of documents
as a unit.


The goals of WCAG 2.0 are laudable. As stated in "Overview of WCAG 2.0
Documents" (

"WCAG 2.0 is being developed to apply to different Web technologies, be
easier to use and understand, and be more precisely testable, as
documented in Requirements for WCAG 2.0."

According to the "Requirements for WCAG 2.0", W3C Working Group Note 25
April 2006 (

(begin quotation)

The primary goal of WCAG 2.0 is the same as 1.0: to promote
accessibility of Web content. Additional goals discussed in this
document are:

1. Ensure that requirements may be applied across technologies
2. Ensure that the conformance requirements are clear
3. Design deliverables with ease of use in mind
4. Write to a more diverse audience
5. Clearly identify who benefits from accessible content
6. Ensure that the revision is "backwards and forward compatible"

(end quotation)


Although we agree that general technical standards can be useful, the
target audiences (web authors, web developers, policy makers and
managers) need first and foremost practical guidance which relates to
their tasks.  We suggest reconsidering both the concept and the writing
of the WCAG 2.0.

The users of the WCAG 2.0 will benefit enormously if the WCAG Working
Group (WG) could consider:

- Ensuring that the structure of the document and the language are
accessible and easy to understand for target audiences.

- Re-thinking the purpose and focusing on providing practical guidance
to the target audiences.

Our main concerns:

1. The concept of the WCAG 2.0: the WCAG 2.0 "tries to be everything to
everybody for all time"--as a result, the guidelines are too general and
lack practicality.

The Requirements document for WCAG 2.0 (,
under point 4 "Write to a more diverse audience") defines the different
users of the WCAG and the tasks these users will be performing for which
they will need guidance from the WCAG 2.0. These tasks are very concrete
and--as practitioners experienced in document design--we firmly believe
the current WCAG 2.0 will not be helpful to these users in achieving
their goals.

We also believe that the WCAG 2.0 guidelines need to be more measurable
as well as testable to enable heuristic evaluation as part of
accessibility assessments.

2. The writing of the WCAG 2.0: structure, language, and navigational
structure make the document hard to understand and navigate.

Again referring to the Requirements document, point 3 states "Design
deliverables with ease of use in mind". Based on our experience as
technical authors, we are convinced that the current WCAG 2.0 will be
very hard to use by the target audiences.

Unfortunately, WCAG 2.0 is not easier to use and understand than WCAG
1.0. The primary goal of promoting accessibility has been all but lost
for the practitioners of web content accessibility because of
problematic goals, complexity of language, and the cumbersome
organization of the documents that has evolved over time.


In our opinion, there are three goals that need to be reconsidered to
make WCAG 2.0 more effective:

1. Ensuring that the revision is forward compatible--while a good
guiding principle for the authors of WCAG itself--should not be made
part of the guidelines for people needing to apply the technologies
today. Trying to make guidelines anticipate the future is a serious
problem and can only result in vague guidelines. Since no one can
predict what the future will hold, the guidelines should address today's
technologies and be updated as the future unfolds.

2. The Conformance section needs to be totally reconsidered. The
conformance levels are difficult to interpret, will discourage
compliance, and will give web developers a false sense that they have
mastered them when they have not.

3. Although individual guidelines are more testable in terms of true or
false statements, the ability to draw those conclusions has become more
difficult. Heuristic evaluation has been made significantly more
difficult than before.


We also consider the style and language of the WCAG 2.0 central document
to be difficult to understand and assimilate by the target audience.
Rather than serving diverse audiences, few people will be able to
understand the guidelines.

The conformance requirements and glossary are particularly unclear. The
conformance section is difficult to read, and the language is confusing
due to the use of  jargon. We would highly recommend rewriting this
section at a lower reading level in addition to reconsidering the


We would recommend placing the majority of the Conformance section after
the guidelines, not before, so that people actually reach the guidelines
without getting bogged down, and limiting the information that precedes
the guidelines to a brief description of the conformance levels.

The design deliverables are not easy to use. Trying to cover all
technologies at once requires so much explanation and so many examples
that the guidelines have expanded to three documents of over 650 printed
pages. The material is highly repetitive, as well as difficult to
navigate. We recommend a restructuring of the accompanying documents by
technology, or by target audience.

For a more detailed analysis, please refer to an article in the STC's
technical journal by members of the AccessAbility SIG: "Communication
Challenges in the W3C's Web Content Accessibility Guidelines", Catherine
M. Brys and Wim Vanderbauwhede, Technical Communication, February 2006
(Volume 53, Number 1), pp. 60-78 (19). [1]


We strongly recommend that the WCAG Working Group re-consider the
concepts, the writing, and the organization of WCAG 2.0 before making
the entire set of documents a W3C Recommendation. We feel that it is
impossible to assess or approve the guidelines in the main document
without the supporting documents. We think that the WCAG 2.0 lack
practicality and that the writing of the supporting documents needs to
be reconsidered.

We raise these issues and offer our assistance because we believe
that--if the final draft of the WCAG 2.0 becomes a W3C recommendation as
it stands--people with disabilities will lose out. Confusion and
misinterpretation will lead to less accessible web sites. Complicated
and hard-to-use guidelines will alienate web developers and prevent them
from trying to achieve web accessibility.

We believe that the AccessAbility SIG is well-placed to assist with
revisions to the WCAG 2.0 and its accompanying documents. The
accessibility of web content for people with disabilities worldwide is
at stake.

Best regards,

Karen Mardahl, Lisa Pappas, Mike Murray, Dan Voss, Fabien Vais
Incoming and Outgoing Co-Managers
on behalf of the AccessAbility SIG of STC

[1] For reference, a partially accessible PDF of the Technical
Communication article is available at
(1593 kB).  Since we only have access to the published article and not
the source material, we tagged the document so that the text is
substantially available. However, many of the links and some of the
other details could not be made accessible in time for the Working Group
submission deadline. (This merely illustrates a general problem in the
electronic publishing world--many major journals provide their articles
as non-accessible PDFs, often even scanned copies of printed  versions,
which are totally inaccessible and even hard to read when printed.)
Although this article discusses an earlier draft of the WCAG 2.0, most
of the principles still apply.

Response from Working Group:

Thank you for your careful comments.

Here are some of the things we have done to address your concerns.

Easier language to understand
- Wrote simpler guidelines
- Removed as many technical terms (jargon) as possible replacing them
with plainer language or, where possible, their definitions
- Eliminated several new or unfamiliar terms. (authored unit, etc.)
- Removed the term Baseline and replaced it with "web technologies
that are accessibility supported" and then defined what it means to be
accessibility supported.
- Removed the nesting of definitions where we could (i.e. definitions
that pointed to other definitions)
- Tried to word things in manners that are more understandable to
different levels of Web expertise
- Added short names/handles on each success criterion to make them
easier to find and compare etc.
- Simplified the conformance

Shortening the document overall
- Shortened the introduction
- Moved much of the discussion out of the guidelines and put it in the
Understanding WCAG 2.0 document
- Shortened the conformance section and moved it after the guidelines
- Moved mapping from WCAG 1 to a separate support document (so it can
be updated more easily)

Creating a Quick Practitioner-oriented Summary / Checklist-like document
- Created a Quick Reference document that has just the Guidelines,
success criteria and the techniques for meeting the success criteria.

Received on Thursday, 17 May 2007 23:39:12 UTC