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Your comments on WCAG 2.0 Public Working Draft of May, 2007

From: Loretta Guarino Reid <lorettaguarino@google.com>
Date: Sat, 3 Nov 2007 19:32:05 -0700
Message-ID: <824e742c0711031932o25cf230fo3c859b65a3a61739@mail.gmail.com>
To: "William Loughborough" <love26@gorge.net>
Cc: public-comments-WCAG20@w3.org

Dear William Loughborough,

Thank you for your comments on the 17 May 2007 Public Working Draft of
the Web Content Accessibility Guidelines 2.0 (WCAG 2.0
http://www.w3.org/TR/2007/WD-WCAG20-20070517/). The WCAG Working Group
has reviewed all comments received on the May draft, and will be
publishing an updated Public Working Draft shortly. Before we do that,
we would like to know whether we have understood your comments
correctly, and also whether you are satisfied with our resolutions.

Please review our resolutions for the following comments, and reply to
us by 19 November 2007 at public-comments-wcag20@w3.org to say whether
you are satisfied. Note that this list is publicly archived. Note also
that we are not asking for new issues, nor for an updated review of
the entire document at this time.

Please see below for the text of comments that you submitted and our
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 WCAG 2.0 Editor's
Draft of May-October 2007 at

Thank you for your time reviewing and sending comments. Though we
cannot always do exactly what each commenter requests, all of the
comments are valuable to the development of WCAG 2.0.


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: use of null alt
Source: http://lists.w3.org/Archives/Public/public-comments-wcag20/2007Jun/0028.html
(Issue ID: 1977)
Original Comment:

Source: http://www.w3.org/mid/4609E878.5040407@gorge.net
(Issue ID: LC-1657)

Item number: 1.1.1

Comment (Including rationale for any proposed change)

The fourth bullet in 1.1.1 says "If non-text content is pure
decoration, or used only for visual formatting, or if it is not
presented to users, it is implemented such that it can be ignored by
assistive technology."

The strong implication is that this provision is there to make for
less "babble" of unwanted descriptions of items with little/no
non-visual intent. This is typically done by using "" (null alt-text)
in place of "alt", "longdesc", whatever and does make for a
less-cluttered audio environment in the case of a screen reader.

Of greater significance is that it erects an exclusionary wall around
a blind user who might be working in a Web Shop and in order to
properly deal with the elements in question would be shut out from
meaningful communication with co-workers.

This should be re-examined from that point of view.

Proposed Change:

"pure decoration" should not be exempt from descriptive mandates via
text. It is OK to make it easy for some blanket filtering, perhaps by
putting "decor" at the
beginning of the alt-text and having the screen reader know therefrom to
not voice that one.

Response from Working Group:

The fourth bullet of SC 1.1.1 requires that "decorative" content be
implemented so that it can be ignored by AT. It is up to the AT to
decide whether or not to ignore it. We agree that it would be useful
for AT to provide different modes or filters, depending on the user's
preference. However, unless the content has been identified as
decorative, the user agent will be unable to provide that choice.

The success criterion in WCAG are intended to cover the normal mode of
operation to an end user. A blind developer working in a Web shop
would probably be able to use different tools to view the content than
an end user (e.g. viewing the source), and so would not be excluded in
the manner suggested.

Response from William:

I am not satisfied with the resolution of my comment on 1.1.1 because it
still permits 1) a lazy author to simply use null alt-text ("") in place
of a description of a non-text element; 2) precludes the possibility of
getting past what your comment about my comment says: "The success
criterion [sic] in WCAG are intended to cover the normal mode of
operation to an end user." There is no "normal mode" - many people want
to know what's there whether the author deems them "purely decorative"
or not. Such users are more important to the Web than those who are
bothered by spoken alt-text covering such elements.

Response from Working Group:

Thank you for your comment. The vast majority of screen reader users
that have provided input into the WCAG 2.0 do not want to have
decorative graphics announced. AT manufacturers implemented the null
alt setting in response to the lobby of their users. Without null alt
text on purely decorative images there can be a lot of noise on the
screen. For instance there may be hundreds of spacer images on the

WCAG 2.0 is consistent with the WCAG 1.0 and most other Web
accessibility standards on this issue. WCAG 2.0 requires that Alt text
"presents equivalent information" for all images except for the
situations listed, one of which is purely decorative images. If an
author places null alt text on a graphic that contains information
then they have failed the SC 1.1.1 and cannot claim conformance even
at the most basic Level A. This success criterion is testable by
humans. In determining whether a graphic is decorative, the context of
use of the image must be considered. The same image may have different
requirements for text alternatives in different contexts. It is also
noteworthy that some screen readers allow the user to change the
custom settings so that images that have null alt text read the file
name (scr) instead.

In specific circumstances such as the one described, customising the
screen reader would be appropriate. For example, the JAWS screen
reader can be highly customized through its standard settings and the
use of scripts to respond to elements of a page in a particular way.
For example JAWS can be set to announce the 'alt' value if it is
present but to announce the 'src' value in the absence of a value for
the 'alt' attribute. The path and/or file name of an image can be
implemented to provide the information required about the image. This
can be done by going to Utilities/HTML Options/Graphics in JAWS.

Note that use of placeholder text is a failure:

F30: Failure of SC 1.1.1 due to using text alternatives that are not
alternatives (e.g. filenames or placeholder text)

We have added a technique describing the use of the ARIA
'presentation' role. In principle, an object could be indicated as
presentational with this feature, yet also provide a non-null text
alternative. The default behavior for most user agents would be to
ignore elements with this role, but a user agent could be configured
to provide access to the text alternative if desired in unusual

Comment 2: Cognitive disabilities - connect with target audience
Source: http://lists.w3.org/Archives/Public/public-comments-wcag20/2007Jun/0097.html
(Issue ID: 2006)
Original Comment:

The facts as I've experienced them over 80 years is
that the "excluded" 20% (a gross underestimate in my
opinion) are in some "lower caste" in virtually all
parts of the globe - much like certain cultures'

"Untouchable" but hopefully not "unreachable."

"They" (which will include most of "us" at some time
if we live long enough!) are warehoused, experimented
on, tortured, and abused in just about every way so
allthough providing some measure of accessibility to
Webstuff (while it seems like a minor gain compared
to "gene pool purification") is of major importance.

Inclusion requires connection.

The first step is towards "nothing about us without
us." We must connect with the target audience else we
will continue their exclusion.

And, no, I don't know where to start, but I bet Bro.
Chetwynd and Ms. Seeman have some ideas?


Response from Working Group:

The Working Group recognizes that "cognitive, learning, and language
disabilities" is a broad term that is not a single, homogeneous
community, but covers a variety of disabilities. The working group
welcomes participation from all people, and would welcome more
participation by people with a wide range of physical and cognitive
Received on Sunday, 4 November 2007 02:32:36 UTC

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