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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 16:44:28 -0700
Message-ID: <824e742c0705171644l3c8db04eu5003ac7e36e837bb@mail.gmail.com>
To: "Takayuki Watanabe, Makoto Ueki, and Masahiro Umegaki" <nabe@lab.twcu.ac.jp>
Cc: public-comments-WCAG20@w3.org

Dear Takayuki Watanabe, Makoto Ueki, and Masahiro Umegaki ,

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/20060623095914.FE78.NABE@lab.twcu.ac.jp
(Issue ID: LC-1313)

Comment: Baseline is a good concept. We support this concept because
technologies that are considered to be accessible may differ among
countries and among user domains. Baseline concept in principle
enables us to adopt WCAG 2.0 in various countries.

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

We hope that the concept of baseline (now accessibility supported Web
technologies) will help authors understand the situation for the human
language of their content, so that they can create content that will
be suitable for their users.

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

Source: http://www.w3.org/mid/20060623095914.FE78.NABE@lab.twcu.ac.jp
(Issue ID: LC-1314)

Comment: Baseline concept may cause accessibility degeneracy. We may
have Web sites that conform to WCAG 2.0 but inaccessible to users.

Baseline concept separates the responsibility of content from that of
user agents, which means content authors do not have to pay attention
to what kinds of user agents can access their content but just use
some baselines. Content authors can use XHTML 1.0 even if not all
major user agents can access the content written in XHTML 1.0. (This
is a case in Japan. Major Japanese user agents can not use structure
markups of HTML 4.01 and XHTML 1.0.)  In WCAG 2.0 this inaccessibility
is blamed on user agents. If there are major user agents that cannot
access the technology included in the baseline, user cannot use the
content even if content is made accessible.

Proposed Change:

New subsection "Attention to user agent capabilities" should be
included to discuss this issue. Having a good UAAG and public
awareness to UAAG is also important.

----------------------------
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 .

Since user agent and assistive technology support varies widely in
different regions of the world, we encourage knowledgeable
organizations to become respositories of this knowledge and make it
available to authors so that they can make well-grounded choices. We
hope that this would also encourage user agent developers to improve
the support provided by their user agents.

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

Source: http://www.w3.org/mid/20060623095914.FE78.NABE@lab.twcu.ac.jp
(Issue ID: LC-1315)

Comment: WCAG 2.0 should put more emphasis on the importance of having
a list of user agents that the content has been tested on. As pointed
out in the comment #2, knowledge of which user agents can access that
content is very important.

In Japan, our research [1] showed that Japanese major user agents were
divided into two groups: JAWS and HPR can use structure markups and
other important functions, while 95-Reader and PC-Talker can not. Most
Japanese users do not know the benefits of skip navigation, heading
navigation, table-structure navigation, or search text in a page
because their user agents do not have these capabilities. (X)HTML is
the basic technology which must be included in all baselines but major
Japanese user agents cannot use some important accessibility functions
of (X)HTML. Thus, we can say that baseline concept is too rough to
show which technologies are accessible to users. Information of user
agents is necessary to show that content is accessible to users.

In addition to that, user agents might be different among users with
various disabilities. It may happen that the same content is
accessible to users with cognitive disabilities but not accessible to
visual disabilities.

We think conformance claims that include a list of user agents that
have been tested on and a detail list of specific capabilities of
those user agents is an ideal but we know it requires too much burden
to the authors. Thus, we propose that WCAG 2.0 should put more
emphasis on the importance of having a list of user agents that the
content has been tested on.

[1] Watanabe, T. and Umegaki, M.
"Capability Survey of Japanese User Agents and Its Impact on Web Accessibility",
Proceedings of W4A 2006.
http://www.w4a.info/2006/prog/6-watanabe.pdf

----------------------------
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 .

WCAG describes the requirements for a technology to be an
accessiblity-supported Web technology. Although the author is
responsible for choosing accessibility-supported technologies, we
recognize that extensive knowledge of the capabilities of user agents
and assistive technologies is needed to make this choice. Since user
agent and assistive technology support varies widely in different
regions of the world, we encourage knowledgeable organizations to
become respositories of this knowledge and make it available to
authors so that they can make well-grounded choices.



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

Source: http://www.w3.org/mid/20060623095914.FE78.NABE@lab.twcu.ac.jp
(Issue ID: LC-1316)

Comment: We need more concrete and realistic examples of baseline. For
example, the baseline used in public web sites in the US, the baseline
used in W3C web sites.

----------------------------
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 .

So the question becomes "What technologies are considered
accessibility-supported for public web pages?", that is, web pages for
which the author has no special knowledge about what user agents and
assistive technologies are available to users.

To answer this, one would need need:
1. Accessibility support analyses for candidate technologies,
documenting the user agent (browser and assistive technology) support
for that technology.
2. Analysis of browser and assistive technology available to users.

Ideally, this information would be gathered in a publicly available
location that could be consulted by anyone creating a public website.
Until such a database is available, it may be necessary for authors to
consult with knowledgeable sources for advice.


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

Source: http://www.w3.org/mid/20060623095914.FE78.NABE@lab.twcu.ac.jp
(Issue ID: LC-1317)

Comment: Conformance claims should be expressed in RDF format so as to
both human and tools can read them. Creative Commons License is a good
example to have information both in normal text and marked with
metadata.

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

Conformance to WCAG neither requires or prohibits the use of specific
formats for describing conformance. The working group expects to
provide informative information describing a variety of strategies for
documenting conformance in cooperation with the education and outreach
working group in the future.

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

Source: http://www.w3.org/mid/20060623095914.FE78.NABE@lab.twcu.ac.jp
(Issue ID: LC-1318)

Comment: We think it is a good idea for WCAG 2.0 explaining how
aggregated contents conform to WCAG because of their popularity.
Aggregated contents must be considered carefully because such kinds of
content have been increasing on the web. This paragraph, however, is
difficult to understand: This paragraph deals with aggregated content,
Web unit, authored units, and aggregated (authored) units, which terms
and their differences are difficult. It is difficult to understand
what 'aggregated content' means. Thus, Good examples of aggregated
content, Web unit, and authored units are needed.

In addition to that we can not understand the responsibility of Web
authors and aggregated contents. We also can not understand how
authors make a conformance claim to aggregated content.

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

We have completely rewritten the conformance section. We have removed
the terms authored units and aggregated (authored) units.

We have made conformance claims less regulatory and more descriptive,
that is, a conformance claim describes what is conformant to the
guidelines. We think it is more appropriate for policy makers to
determine appropriate exceptions.

We have provided a way to make a statement about parts of a page that
do conform if the whole page doesn't.

We have clarified the situation by removing all exceptions and adding
the following at the end of the conformance section:

Note: If pages can not conform (for example, conformance test pages or
example pages) they would not be included in the conformance claim.

Statement of partial conformance (See
http://www.w3.org/TR/2007/WD-WCAG20-20070517/#conformance-partial )

Sometimes, Web pages are created that will later have additional
content added to them. For example, an email program, a blog, or an
article that allows users to add comments to the bottom. Another
example would be a company or individual who compiles a page from
multiple sources. Sometimes, the content from the other sources is
automatically inserted into the page over time.

In both of these cases, it is not possible to know at the time of
original posting what the content of the pages will be. Two options
are available:

1. A conformance claim is made based on best knowledge. If a page of
this type is monitored and kept conformant (non-conforming content is
immediately removed or made conforming) then a conformance claim can
be made since, except for error periods, the page is conformant. No
conformance claim should be made if it is not possible to monitor or
correct non-conforming content.
2. A "statement of partial conformance" is made. A statement that the
page does not conform, but could conform if certain parts were removed
can be made. The form of that statement would be, "This page would
conform to WCAG 2.0 at level X if the following parts from
uncontrolled sources were removed."
1. This "statement of partial conformance" cannot be used for content
that is under the author's control.
2. The "following parts" of the page that would need to be removed
would be described in terms that users can understand. (e.g. they
can't be described as "all parts that we do not have control of"
unless they are clearly marked as such.)

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

Source: http://www.w3.org/mid/20060623095914.FE78.NABE@lab.twcu.ac.jp
(Issue ID: LC-1319)

Comment: What is the difference between "authored unit" and "authored
component"?  We couldn't understand their meaning clearly. The words
used in WCAG 2.0 are ambiguous. We need much more concrete examples of
the current web technologies. It allows the readers to understand the
WCAG 2.0 more clearly.

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

We have have reformulated the success criteria and glossary to remove
both "authored unit" and "authored component" from the guidelines.

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

Source: http://www.w3.org/mid/20060623095914.FE78.NABE@lab.twcu.ac.jp
(Issue ID: LC-1321)

Comment: Scope of SC 2.5.3 is limited and narrow. It deals with
specific forms. Thus, it should be moved to L3.

Proposed Change:

Level 3 Success Criteria for Guideline 2.5
2.5.3 For forms that cause legal or financial transactions to occur,
that modify or delete data in data storage systems, or that submit
test responses, at least one of the following is true:
1. Actions are reversible.
2. Actions are checked for input errors before going on to the next
step in the process.
3. The user is able to review and confirm or correct information
before submitting it.

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

Level AAA is not appropriate because the success criterion can be
satisfied by all forms that cause legal commitments or financial
transactions to occur, that modify or delete data in data storage
systems, or that submit test responses. The limitations on
presentation and content imposed by the success criterion do not
warrant moving it to level AAA.

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

Source: http://www.w3.org/mid/20060623095914.FE78.NABE@lab.twcu.ac.jp
(Issue ID: LC-1322)

Comment: JIS X 8341-3 also addresses the importance of volume control.
It allows the users who are hard of hearing to adjust the volume of
the audio. Is it unnecessary for WCAG 2.0 to require the mechanism of
the audio volume control?

JIS 5.7 b) says:

b) Sound should be controllable by users.

Information:
Hearing impaired users cannot detect that sound is being played. Also,
there are cases where louder volume is preferred.

Example:
To enable users to adjust volume, play, and stop, provides controls
for play, stop, and volume adjustment. When using plugins, they can be
used for this purpose

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

Control of volume is a user agent issue. Most players already have
volume controls on them.  Content, due to security issues, usually
cannot directly access the hardware volume control and thus can only
turn volume down not up.   We therefore do not include a
recommendation for content to also include a volume control, though
user agents should. This belongs to the domain of User Agents and is
covered in the User Agent guidelines (UAAG 1.0) which reads as
follows:

"Guideline 4. Ensure user control of rendering...User agents rendering
audio have to allow the user to control the audio volume globally and
to allow the user to control distinguishable audio tracks."


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

Source: http://www.w3.org/mid/20060623095914.FE78.NABE@lab.twcu.ac.jp
(Issue ID: LC-1323)

Comment: WCAG 2.0 doesn't require validity. Can authors use
UA-specific elements such as marquee, blink and so on?  It is less
certain on this issue through the documents.

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

Not all deprecated elements and attributes present a problem for
assistive technologies. The blink element is covered by F47: Failure
of SC 2.2.2 due to using the blink element. For marquee, authors would
need to meet the requirements defined in SC 2.2.3.

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 11:

Source: http://www.w3.org/mid/20060623095914.FE78.NABE@lab.twcu.ac.jp
(Issue ID: LC-1324)

Comment: Validity check is important process to increase
accessibility. "Guidelines for Different Components"
(http://www.w3.org/WAI/intro/components.php#guidelines) says "WAI
guidelines are based on the fundamental technical specifications of
the Web, and are developed in coordination with:"  If WCAG does not
mention to validity, readers of WCAG think WCAG WG thinks little of
Web standards.

Proposed Change:

We propose to add Level 2 Success Criteria that requires validity.

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

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 12:

Source: http://www.w3.org/mid/20060623095914.FE78.NABE@lab.twcu.ac.jp
(Issue ID: LC-1325)

Comment: WCAG 2.0 doesn't mention about the speed of text which is
moving on the page. It is hard for people with visual disabilities and
cognitive limitations to read and understand the text. Can the author
use the fast scrolling text?

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

Text that is being scrolled automatically would be covered by SC 2.2.3 and F16:

   2.2.3 Content can be paused by the user unless the timing or
movement is part of an activity where timing or movement is essential.
   F16: Failure of SC 2.2.3 due to including scrolling content where
there is not a mechanism to pause and restart the content

If an author uses scrolling text, there must be a way to pause the
text to give the person time to read and understand it.

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

Source: http://www.w3.org/mid/20060623095914.FE78.NABE@lab.twcu.ac.jp
(Issue ID: LC-1326)

Comment: JIS X 8341-3 has an example of sound effects such as beep,
chime, and ding-dong, which sound notify the user that, for example,
the answer is correct. These sounds may be used in e-learning system.
In this case, people who are deaf, hard of hearing, or having trouble
to understand audio information may not hear or understand the sound
effects.

Proposed Change:

Add the following example to the "Examples" section.

8. A sound effect
The web page of the e-learning content uses the sound effects. The
chime sound indicates that the answer is correct and the beep sound
indicates that the answer is incorrect. An alternative text is shown
on the page so that people who can't hear or understand the sound
understand whether the answer is correct or incorrect.

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

Thank you for this suggestion. We have added it to How to Meet Success
Criterion 1.1.1.

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

Source: http://www.w3.org/mid/20060623095914.FE78.NABE@lab.twcu.ac.jp
(Issue ID: LC-1327)

Comment: New example should be added to Understanding document. JIS X
8341-3 has an example of the words of foreign origin which may be
unfamiliar to users.

Proposed Change:

The meaning of an unfamiliar adopted foreign word

The meaning or the translated word is provided within the page by
using the parenthesis right after the word or the internal link from
the word.

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

Thanks for your comment. We've added examples of providing the meaning
of unfamiliar adopted foreign words.
Received on Thursday, 17 May 2007 23:45:02 UTC

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