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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 16:41:59 -0700
Message-ID: <824e742c0705171641w193894c2h10bdd41e50944f5e@mail.gmail.com>
To: "Monica Løland" <mol@handicap.dk>
Cc: public-comments-WCAG20@w3.org

Dear Monica Løland, The Danish Council of Organisations of Disabled
People (DSI)  ,

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/20060622140230.A84D433201@kearny.w3.org
(Issue ID: LC-884)

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

In general DSI would like to point out that some of the new terms and
their definitions makes the language used in WCAG 2.0 difficult to
understand, especially for foreigners and consequently difficult to
translate into other languages.

Proposed Change:

Simplify the language and carefully explain new terms.

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

We have reworked the entire document to make it shorter and easier to
read. This includes:
- Shortening the introduction
- Moving much of the discussion out of the guidelines and puttin it in
the Understanding WCAG 2.0 document
- Shortening the conformance section and moving it after the guidelines
- Writing simpler guidelines
- Removing as many technical terms (jargon) as possible, replacing
them with simpler language or their definitions
- Removing the nesting of definitions where we could (i.e. definitions
that pointed to other definitions)
- Moving information about mapping between WCAG 1 and WCAG 2 to a
separate support document (so it can be updated more easily)
- Creating a Quick Reference documents that has just the Guidelines,
success criteria and the techniques for meeting the success criteria.
- Trying to word things in manners that are more understandable to
different levels of Web expertise
- Adding short names/handles on each success criterion to make them
easier to find and compare etc.
- Simplifying the conformance section
- Using plainer language wherever possible (e.g. – use "Web page"
instead of "Web Unit")
- Eliminating several new or unfamiliar terms. (authored unit, etc.)
- Making the whole document much shorter.


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

Source: http://www.w3.org/mid/20060622140440.6080D33205@kearny.w3.org
(Issue ID: LC-885)

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

Success criteria 1.1.1 is difficult to parse. When using the phrase
"One of the following is true" to a criteria where several of the
following can be true, if different types of non-text content are
used, the criteria can be misinterpreted. DSI recommend that the
phrasing of parallel logical conditions should be consistent across
all success criteria. In 2.2.1 the phrase is used correctly.

Proposed Change:

We mean that the success criteria of 1.1.1 should be rephrased or
split up into several success criteria.

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

We have modified 1.1.1 as follows:

1.1.1 Non-text Content: All non-text content has a text alternative
that presents equivalent information, except for the situations listed
below.

    * Controls-Input: If non-text content is a control or accepts user
input, then it has a name that describes its purpose. (See also
Guideline 4.1 Maximize compatibility with current and future user
agents, including assistive technologies )
    * Media, Test, Sensory: If non-text content is multimedia , live
audio-only or live video-only content, a test or exercise that must be
presented in non-text format , or primarily intended to create a
specific sensory experience , then text alternatives at least identify
the non-text content with a descriptive text label. (For multimedia,
see also Guideline 1.2 Provide synchronized alternatives for
multimedia .)
    *  CAPTCHA: 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.
    * Decoration, Formatting, Invisible: If non-text content is pure
decoration, or used only for visual formatting, or if it is not
presented to users, then it is implemented such that it can be ignored
by assistive technology

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

Source: http://www.w3.org/mid/20060622140855.C78FC47BA1@mojo.w3.org
(Issue ID: LC-886)

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

For deaf web users, there are two basic demands to be met to achieve
full accessibility.
-	Sign Language is the native language for the deaf, the first
language on which thinking and communication is based. Danish is a
foreign language learnt by reading and writing. Therefore information
provided in sign language will always be preferable to information
provided in Danish text. (A new survey states that half of the deaf
population has no School leaving exams in Danish, since they were not
able to meet the language demands. Døves uddannelses- og
arbejdsmarkedsforhold. Castberggaard 2006)
-	all information provided by sound, should also be provided visually.

Sign language interpretation is mentioned in Level 3 Success Criteria
for Guideline 1.2. in the WCAG 2.0 Guidelines. This placing does not
ensure full accessibility to the deaf community, since EU documents
only have to meet the demands on Level 2.

Proposed Change:

Broadband Network (ADSL) gives new opportunities to send multimedia,
and the guidelines should therefore see that these new opportunities
is utilized to achieve full accessibility. Sign language
interpretation should at least be a Level 2 Success Criteria.

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

The working group considered carefully the levels assigned to all the
GL 1.2 success criteria.  Delivery of sign language interpretation is
more  specialized, and difficult as compared to text captioning.  Even
with proper tools, a web author cannot do this without special
training and skills, including the ability to translate into another
language.  Also some multimedia is fully usable at small size and
marginal bandwidth setting and captions only marginally increase the
demands.  By comparison, sign language interpretation requires a
relative large size, high resolution, and fast delivery rate.  These
aspects of sign language interpretation make the sucess criterion
appropriate for Level AAA.

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

Source: http://www.w3.org/mid/20060622140951.C8D2B47BA1@mojo.w3.org
(Issue ID: LC-887)

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

Success Criteria 3.1.5: "When text requires reading ability more that
the lower secondary education level, supplemental content is
available…" should be placed at level 2 instead of level 3. EU and
many national governments meet WCAG conformance at level 2, which
means that people with cognitive disabilities will not be granted full
accessibility if 3.1.5 remains on Level 3. In WCAG 1.O checkpoint 14.1
was a level 1 criteria: "Use the clearest and simplest language
appropriate for a site\'s content".

Proposed Change:

Success Criteria 3.1.5: "When text requires reading ability more that
the lower secondary education level, supplemental content is
available…" should be placed at level 2 instead of level 3. EU and
many national governments meet WCAG conformance at level 2, which
means that people with cognitive disabilities will not be granted full
accessibility if 3.1.5 remains on Level 3. In WCAG 1.O checkpoint 14.1
was a level 1 criteria: "Use the clearest and simplest language
appropriate for a site\'s content".

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

The working group agrees that writing as clearly and simply as
possible is highly desirable, but could not find a way to test whether
this had been achieved.

The description of conformance levels in WCAG 2 has been rewritten to
clarify the levels:

The word "levels" does not mean that some success criteria are more
important than others. Each success criterion in WCAG 2.0 is essential
to some users, and the levels build upon each other. However, even
content that conforms at AAA (triple-A) may not be fully accessible to
every person with a disability.

*In general, Level A success criteria achieve accessibility by
supporting assistive technology while putting the fewest possible
limits on presentation. Thus people with a wide range of disabilities
using a wide range of assistive technologies, from voice input and
eye-tracking devices to screen readers and screen magnifiers, are able
to access content in different ways. In other words, Level A success
criteria support the ability of both mainstream and specialized user
agents to adapt content to formats that meet their users' needs.
* The success criteria in Level AA provide additional support for
assistive technology. At the same time, they also support direct
access to content by the many people who use conventional user agents
without assistive technology. In general, Level AA success criteria
place more limits on visual presentation and other aspects of content
than the success criteria in Level A.
*Level AAA success criteria increase both direct access and access
through assistive technology. They place tighter limits on both
presentation and content."

Because of the tighter limits that this success criterion places on
content, we feel it is appropriate at level AAA.

We have added new success criteria addressing scalability of text:

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 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 and in a way that does not require the user
to scroll horizontally.

In addition, we have added advisory techniques to improve the
legibility of text:

- Avoiding text that is both left and right justified.
- Providing sufficient inter-line and inter-column spacing

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

Source: http://www.w3.org/mid/20060622141132.4855E47BA1@mojo.w3.org
(Issue ID: LC-888)

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

According to WCAG 2.0 conformance at level Triple-A (AAA) is met when
all Level 1, all Level 2 and at least 50 % of the Level 3 success
criteria that apply to the content types used are met. How are the 50
% selected – randomly?

Proposed Change:

We mean that it is important for WCAG to decide in advance which of
the Level 3 criteria shall be met to obtain Triple-A conformance.

----------------------------
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 6:

Source: http://www.w3.org/mid/20060622141353.8A56D47BA1@mojo.w3.org
(Issue ID: LC-889)

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

WCAG 2.0 introduces the new term baseline in the conformance section
which is difficult to understand.

Proposed Change:

The introduction of the conformance section in WCAG 2.0 should be
provided with a clear explanation of what a baseline is and how it
should be used. If the term baseline is not understood it might be
misused.

----------------------------
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 .
Received on Thursday, 17 May 2007 23:42:21 UTC

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