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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 16:45:21 -0700
Message-ID: <824e742c0705171645i40e70ceap7031729cc639e03@mail.gmail.com>
To: "Wayne Dick" <wed@csulb.edu>
Cc: public-comments-WCAG20@w3.org

Dear Wayne Dick ,

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/20060524200306.7AC3233209@kearny.w3.org
(Issue ID: LC-604)

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

Rationale:  In my experience, simple magnification is not very helpful
for reading web pages.  Visual readers with print disabilities always
need more.  Now, lots of software labeled \"screen magnifier\" does
more than magnify, but some products just zoom and that is not very
helpful. In the WCAG 2.0 Glossary definition of Assistive Technology,
the example of screen magnifier is the only remedy given for
individuals with partial sight.  There are no examples, other than
screen readers, given for other print disabled readers who are
sighted.  I am afraid that developers who want to test WCAG 2.0
compliance will test against screen magnifiers (especially simple zoom
magnifiers) and conclude they have met the needs of sighted users with
print disabilities.  The example does mention change in color, but
there are many other style changes that assist visual reading.  Also,
motor limitations cause some print disability rather than the more
common conditions, dyslexia or partial sight.  So I suggest the
following example.  Note: I had no word for this type of technology so
I just coined \"Visual Reading Assistants\".  Examples of visual
reading assistant products are: specialized style sheets, IBM\'s
WebAdapt2Me and Home Page Reader and WYNN from Freedom Scientific.  I
talked to Phill Jenkins from IBM and he suggested \"Reading Assistive
Technology\".  That\'s good but might seem circular in the definition
of assistive technology.  There is a significant needs difference
between readers with sight who have print disabilities and readers
without sight.  While screen readers work for both, sighted readers
are never trained in Braille so visually accessible text represents
the only static medium available for sighted readers with print
disabilities.  A static reading medium is necessary for serious
literature that requires deep concentration.  A non-aural medium is
also necessary for deaf readers with print disabilities.  Zoom
technology does not comes close to addressing this need, so I don\'t
want developers coming away with the impression that screen magnifiers
solve the problem for this population.

Proposed Change:

Change to definition -- Assistive Technology... Example...
Visual Reading Assistants - Several products modify the document
styles such as font size and color, spacing of lines, letters and
words, and the font family.  These products may also synchronize
speech with text, reflow large text to fit the page and add keyboard
navigations.  They are used by print disabled readers who are sighted
but who cannot read standard print formats owing to a variety of
visual, perceptual or motor limitations.

Response from Working Group:

We have revised the bullet on screen magnifiers in the definition of
assistive technology to:
"screen magnifiers and other visual reading assistants, which are used
by people with visual, perceptual and physical print disabilities to
change text font, size, spacing, color, synchronization with speech,
etc in order to improve the visual readability of rendered text and

Comment 2:

Source: http://www.w3.org/mid/20060605215429.9216433205@kearny.w3.org
(Issue ID: LC-714)

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

Rationale: In the term programmatically determined, the concept of
total determinism is not clear enough.  There needs to be a clear
difference between programmatically determined (recognized by a
deterministic algorithm) and non-deterministically accessed by an AI
heuristic --as in optical character recognition.

Proposed Change:

Change:  In Introduction: Important New Terms Used in WCAG 2.0
Add to the description of programmatically determined…\"This means
that the author is responsible for ensuring that the content is
delivered in such a way that software can access it [with no chance of
error]\".  You could also say positively… [with perfect accuracy].

Response from Working Group:

We have clarified the meaning of "programatically determined" in the
section on Important New Terms Used in WCAG 2.0. See
http://www.w3.org/TR/2007/WD-WCAG20-20070517/#new-terms .

Comment 3:

Source: http://www.w3.org/mid/20060605230630.9C48933205@kearny.w3.org
(Issue ID: LC-715)

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

Rationale:  Often the \"variation in text\" can be determined
programmatically but the information this variation conveys cannot.

Proposed Change:

Change: Include the bracketed words…
1.3.4 Information that is conveyed by variations in presentation of
text is also conveyed in text, or [the information conveyed by] the
variations in presentation of text can be programmatically determined.
[How to meet 1.3.4]

Response from Working Group:

SC 1.3.1 and 1.3.4 have been combined to read "Information and
relationships conveyed through presentation can be programmatically
determined or are available in text, and notification of changes to
these is available to user agents, including assistive technologies."
This wording ensures that it is the meaning conveyed by the
presentation that must be programmatically determined, and allows the
author to indicate the meaning in text if it is not feasible to do so
programmatically. The How to Meet document describes this in some

Comment 4:

Source: http://www.w3.org/mid/20060605231615.6879933205@kearny.w3.org
(Issue ID: LC-716)

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

The section of the Principle 4 is most confusing.  Throughout success
criteria  for 4.2 there references by link to earlier success critera
the linking language is so terse that it is hard to follow.

Proposed Change:

Go through the entire section and add more descriptive language than
in the earlier principles.  This is 4 is trickier.  In most of the
document keeping things short is good, but in 4 the cross referencing
makes it hard to interpret what is being said.

Response from Working Group:

To make this easier to understand, we have moved the former success
criteria for 4.2 into the conformance section.

Conformance requirement 4 addresses conditions that must be satisfied
when multiple versions of content are provided. There may be multiple
versions because the author wishes to provide a version that uses
technologies that are not accessibility supported, or because versions
are provided that are tailored for supporting people with particular
disabilities.  Conformance requirement 6 describes the conditions
necessary to keep the alternate versions from interfering with the
user's ability to access the conforming version of the content.

Comment 5:

Source: http://www.w3.org/mid/web-6806611@romulus.csulb.edu
(Issue ID: LC-732)

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

I found the definition of Assistive  Technology a little unclear.  The
 concept of retrieving data from host  agents is difficult.  Maybe the
 attached wording could help.

Assistive technology (in the context of this document)

    a user agent that:

 1. provides services beyond those offered by the host user agents to
meet the requirements of users with disabilities. Additional services
include alternative renderings (e.g., as synthesized speech or
magnified content), alternative input methods (e.g., voice),
additional navigation or orientation mechanisms, and content
transformations (e.g., to make tables more accessible).
 2.relies on services provided by one or more other \"host\" user
agents. Assistive technologies communicate data and messages with host
user agents by using and monitoring.APIs.

Note: In this definition the host user agents are user agents in the
general sense of the term. The output of host user agents may not be
easily read by any humans, but it may provide important services to
assistive technologies like retrieving Web content from program
objects or parsing markup into identifiable bundles.

 Example: Examples of assistive technologies that are important in the
context of this document include the following:

* screen magnifiers, which are used by people with visual disabilities
to enlarge and change colors on the screen to improve the visual
readability of rendered text and images;
* screen readers, which are used by people who are blind or have
reading disabilities to read textual information through synthesized
speech or braille displays;
* voice recognition software, which may be used by people who have
some physical disabilities;
* alternative keyboards, which are used by people with certain
physical disabilities to simulate the keyboard;
* alternative pointing devices, which are used by people with certain
physical disabilities to simulate mouse pointing and button

Note: This definition is based on User Agent Accessibility Guidelines
1.0 Glossary

Proposed Change:

Response from Working Group:

Thank you for the suggestions for how to improve the definition of
Assistive Technology. We have modified the definition based on your
Received on Thursday, 17 May 2007 23:45:55 UTC

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