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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 16:39:02 -0700
Message-ID: <824e742c0705171639u3698bd8dq50e5e6a61259e315@mail.gmail.com>
To: "Lars Ballieu Christensen" <lbc@sensus.dk>
Cc: public-comments-WCAG20@w3.org

Dear Lars Ballieu Christensen ,

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/20060527094305.1EB4D47B9F@mojo.w3.org
(Issue ID: LC-652)

Part of Item:
Comment Type: GE
Comment (including rationale for proposed change):

As a practitioner with 10 years  experince in advising site owners and
developers on how to develop web sites that are accessible to the
widest range of users using the widest range of technilogies, I find
the following the following issues in WCAG2 highly problematic:

The introduction of a technology baseline; the concept of a baseline
is in my opinion in itself in direct conflict with the idea of
creating inclusive solutions; I fear that the baseline will be used
widely to formally pass accessbility tests by omitting all potentially
tricky technologies from the baseline. In my opinion, the baseline is
a mistake that should be removed from the document. If the aim is to
promote an inclusive envisonment, the whole notion of accepting lower
standards in, say, private intranets is absurd as it will preent
people with special needs to work in these environments.

The document is still heavily biased towards the visually impaired. By
and large, other groups of people with special needs are in practice
omitted from the substance of the guidelines. These include, but are
not limited to, the deaf, dyslexic, people with reading difficulties,
and the cognitively disabled. The standard remedy of demanding that
all non-textual information also be represented as textual information
is simply not enough.

The idea of granting triple-A conformance status to a web site if it
passes half (randomly selected?) the level 3 success criteria does not
make sense. It suggests either that the level 3 success criteria are
irrelevant to the general accessibilily or that it is more important
to be able to pass the test than to comply with the level 3 success

Proposed Change:

1. Omit the concept of a baseline from the document.

2. Accommodate other - and in many cases much larger - user groups
than merely the visually disabled. Complement the text alternative
requirement with requirements for other alternatives including
simplified text and sign language.

3. Decide whether and which of the level 3 success criteria are
important. Leave out the unimportant and make the rest mandatory for
gaining triple-A conformance status.

Response from Working Group:

1. The notion of baseline (now referred to as "accessibility-supported
Web technologies") is not an attempt to weaken the guidelines or
create less inclusive environments. It is a recognition that the level
of support in browsers and assistive technology is constantly
changing, and that any attempt to define "accessible technologies"
based on the support available at the current time will deprive people
with disabilities from the benefits of on-going innovation on the
internet. For instance, we want all users to benefit from the use of
CSS. At the time that WCAG1 was published, user agent support was not
sufficient to include CSS in acceptable technologies.

2. We believe the guidelines address a wide range of physical
disabilities, including deafness, hearing impairments, mobility
impairment, and seizure disorders. The reliance on text is because it
is the format that lends itself best to rendering in a wide variety of
modalities. Text can be converted to speech, rendered on braille
displays, or displayed visually. It may facilitate translation of text
into different language levels at some point.  This does not mean that
providing a text representation solves all accessibility problems.

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.

3. The definition of triple-A conformance has been changed to require
all level AAA success criteria.
Received on Thursday, 17 May 2007 23:39:15 UTC

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