Your comments on WCAG 2.0 Last Call Draft of April 2006

Dear Ulrike Peter ,

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-840)

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

We are concerned about Principle 3 "Content and controls must be

We appreciate the restructuring of WCAG2 into four general principles
allowing more independence of technology. But we fear that in practice
the focus will be exclusively on the success criteria. This risk
should be countered.
We demand that the principles and the guidelines of WCAG2 are given
more importance and value. The success criteria should be defined as
one (of several) possibilities to secure the WCAG2. The limitations of
the success criteria have to be pointed out. The focus should be laid
on the assurance of the principles and guidelines.

Criticism on the success criteria of the third principle
In the more general formulations of the revised WCAG2, also those
checkpoints of WCAG1 can be found which have already become law in
many European countries. Comparing the concrete implementation
recommendations of WCAG2 (the success criteria) with those of WCAG1
(the checkpoints), it shows for the area of understandability that the
aspects relating to the contents have got lost: In WCAG1, the
requirement 14.1 „Use the clearest and simplest language appropriate
for a site\'s content" has the highest priority. In WCAG2, the
guideline 3.1 includes content aspects of readability and text
understanding. In the success criteria for 3.1, however, these
requirements are missing. The success criteria included in WCAG2 now
represent only side aspects of understandability which can be
technologically checked. The much more important aspects in the area
of understandability can only be submitted to standardized tests on
the basis of expertise and considering the specific target groups of
the web offer. In Germany, this is established practice, and know-how
is available. The certification procedure based on the BITV, the
German adoption of WCAG1, as well as the BIENE Award procedure follow
these requirements on the basis of German law demanding not only the
implementation of the „conditions" (corresponding to the checkpoints
of WCAG1), but also the implementation of the „requirements"
(corresponding to the guidelines of WCAG1).

The certification procedure of DIN CERTCO has been developed by
leading representatives of science, practice and associations of
people with disabilities. Beside the product quality of the web offer,
also the process quality of the content tendance is evaluated. The
BIENE Award is a competition carried out since 4 years awarding prizes
to the best accessible German-language web offers which thus become
models for the discussion. Besides expert tests, the test procedure
also includes tests with people with different disabilities.

Exclusion of people with learning difficulties and cognitive limitations
The definition of target groups in the WCAG2 explicitly refers to
people with learning difficulties and cognitive limitations. On the
level of principles and guidelines we find the requirements of this
target group, but not on the level of success criteria. This is where
the exclusion takes place. Though the success criterium 3.1.5 demands
that additional contents is offered if the language level of the texts
is above the secondary education level, this does not mean that the
requirements of the target group with learning difficulties and
cognitive limitations are met. Further, it remains unclear how it is
made sure that the texts keep the required level.

Proposed Change:

Response from Working Group:

Thank you for the reference to the DIN CERTCO certification process
and to the BIENE Award.

The working group has had difficulty developing success criteria for
Principle 3 that are testable, human-language independent and that
apply to all web pages, and that address the needs of people with
different cognitive, language, and learning disabilities.

We have added language to the Introduction to highlight the fact that
WCAG 2 only addresses some of the needs of people with cognitive,
learning, and language disabilities, and calls 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. Since advisory
techniques do not need to be testable or universal, we have been able
to include techniques based on some of the BIENE requirements, as well
as best practices suggested by researchers on cognitive, learning, and
language disabilities. The new advisory techniques include:

*Using the clearest and simplest language appropriate for the content
*Avoiding centrally aligned text
*Avoiding text that is fully justified (to both left and right
margins) in a way that causes poor spacing between words or characters
*Using left-justified text for languages that are written left to right
*Using appropriate justification for languages that are written right-to-left
*Limiting text column width
*Avoiding chunks of italic text
*Avoiding overuse of different styles on individual pages and in sites
*Making links visually distinct
*Using images, illustrations, video, audio, or symbols to clarify meaning
*Providing practical examples to clarify content
*Using a light pastel background rather than a white background behind
black text
*Highlighting a link or control when the mouse hovers over it
*Avoiding the use of unique interface controls unnecessarily
*Using upper and lower case according to the spelling rules of the
text language
*Avoiding unusual foreign words

Received on Thursday, 17 May 2007 23:45:39 UTC