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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 20:56:21 -0700
Message-ID: <824e742c0711032056j6b02e3d2ob9fa35ffb35a67bd@mail.gmail.com>
To: "Adobe - Matt Morgan-May" <mattmay@adobe.com>
Cc: public-comments-WCAG20@w3.org

Dear Matt,

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: Definition of Web page
Source: http://lists.w3.org/Archives/Public/public-comments-wcag20/2007Jun/0417.html
(Issue ID: 2306)
Original Comment:

Web page
A very underpowered term when applied to formats other than HTML. Example 1
(virtual reality shopping) is a really far-fetched scenario, and itıs an
awful one to have first. Though I would like to see how this would be
applied to an environment like Second Life, where you can post just about
any kind of content imaginable, including URIs that open in an external
browser. Is Second Life a "Web page", or a collection of them, or a user
agent, or all of the above?

A PDF document, even a fairly complex one, would fit under the definition of
³Web page². But Flash is less cut and dry. Flash can be embedded as an
object in a document, but itıs also a user agent (and in the case of Adobe
AIR, formerly Apollo, it can itself be an HTML user agent). If we are
delivering a UA to a user, and the author wants to conform to WCAG 2, do we
then have to conform to UAAG instead? What about third-party authors of AIR

Response from Working Group:

Basically, a Web page is whatever is served at a URI. Particularly for
web applications, different implementations of identical functionality
may consist of different numbers of Web pages. One implementation may
dynamically update the Web page content at a point where another
implementation loads a new Web page.

The working group wrestled a long time over what to do with
technologies like Flash or Javascript where authors can implement
their own user interface components. The user agent in these cases are
the interpreters, and the responsibility for conforming to UAAG-like
requirements becomes the author's. As a result, elements of UAAG have
been incorporated into WCAG to the extent needed to handle these
content created programmatic elements, and success criteria have been
crafted so that they can be satisfied either by the user agent (in the
case of more static technologies like HTML and PDF) or by the author
directly when he is responsible for creating the user interface
components. The author is ultimately responsible for ensuring that he
has chosen a technology in which it is possible to satisfy WCAG
("accessibility supported") and has used that technology in a way that
does satisfy WCAG.

The Shopping example has been removed from the introduction and is
provided only along with other examples in the definition and
Understanding documents. (and is listed as the last example).

It is not clear that Second-Life is actually a Web application rather
than a downloaded application that is run from the desktop and that
accesses data over the internet but, for the most part, not using

Comment 2: Programmatically determined
Source: http://lists.w3.org/Archives/Public/public-comments-wcag20/2007Jun/0417.html
(Issue ID: 2307)
Original Comment:

Programmatically determined
Does the author get to declare for which versions of UA or AT the content is
programmatically determinable? How often will that determination be made,
and by whom?

Also, ³mark-up² should be ³markup².

Response from Working Group:

In order for many people with disabilities to be able to use Web
content, the Web content must work with their assistive technologies.
 Saying that it could work with software is not sufficient.
Presumably the content works with the browser which is software - but
not sufficient for many users with disabilities.  And the ability for
a utility or other special piece of software to access the information
 also would not be useful to users if the content did not actually
work with assistive technologies.

However it is not possible to work with ALL assistive technologies.
As a result we have introduced the concept of Accessibility Supported.
 This refers to the ability of content technologies to work with
assistive technologies.  We are also providing methods for documenting
support by different assistive technologies  as well as the
accessibility features in mainstream user agents.

All instances of "mark-up" have been changed to "markup".

Comment 3: accessibility supported
Source: http://lists.w3.org/Archives/Public/public-comments-wcag20/2007Jun/0417.html
(Issue ID: 2308)
Original Comment:

Accessibility supported
Releasing a standard without even an informative pointer to a reference list
of ³accessibility-supported² technologies is like coming out with a new car,
but refusing to either certify your own mechanics, or point people to a
resource where they can find one. The result in either case would be the
same: consumers would have trouble finding trustworthy resources, and when
things go wrong for them, they will begin to distrust the producer. Without
a concrete set of technologies that meet these criteria, or at a bare
minimum a set of pointers to definitions of accessibility-supported
technologies, WCAG 2 is not fully defined.

Also in this definition, GIF and MPEG are specified by name. But GIF cannot
be considered an accessible enough format to meet the ³Web page² bar, and
³MPEG² isnıt a format, itıs a JTC1 WG: MPEG-1, MPEG-2, MPEG-4, MPEG-7, and
MPEG-21 are the standards they produce.

Response from Working Group:

We have described the information required to document the status of
accessibility support for a technology at
. Determining which technologies are accessibility supported in
different environments is beyond our scope. The working group does not
have the resources to gather this information for all technologies,
user agents, and assistive technologies.

Comment 4: Human language and Sign language
Source: http://lists.w3.org/Archives/Public/public-comments-wcag20/2007Jun/0417.html
(Issue ID: 2309)
Original Comment:

Sign language
A sign language is included under ³human language,² but that is not in the
definition here. Also, sign language is not a visual language to people who
are deaf and blind.

Response from Working Group:

A true sign language is an example of a human language, and is
accepted as such by linguists and has legal recognition.

The term visual in the definition is the same as stating that spoken
English is an auditory language, in that it describes the medium of
conveyance; not the ability of the receiver. However, it is true that
some sign language systems have been developed for Deaf-Blind usage
which rely only on tactile contact so we have clarified the
definition: "language that is spoken, written or signed (through
visual or tactile means) to communicate with humans".

Comment 5: Uses of "above" and "below"
Source: http://lists.w3.org/Archives/Public/public-comments-wcag20/2007Jun/0417.html
(Issue ID: 2310)
Original Comment:

1.3.3 (Level A):  ³Instructions provided for understanding and operating
content do not rely on shape, size, visual location, or orientation of
In English-language documents, at least, it is commonly understood that
³above² refers to the content previous to that point (³hereto,²
³heretofore²), and ³below² refers to the content after that point
(³hereafter,² ³hereinafter²). Provided that the content being referenced is
in the appropriate place in the document order, there should be no
restriction on statements such as ³Choose one of the links below:² or ³All
of the above².

Response from Working Group:

Response to Reviewer:
We have added this explanation about the uses of "above" and "below"
to Understanding SC 1.3.3.

"In some languages, it is commonly understood that "above" refers to
the content previous to that point in the content and "below" refers
to the content after that point. In such languages, if the content
being referenced is in the appropriate place in the reading order and
the references are unambiguous, statements such as "choose one of the
links below" or "all of the above" would conform to this success

Comment 6: 20dB difference
Source: http://lists.w3.org/Archives/Public/public-comments-wcag20/2007Jun/0417.html
(Issue ID: 2311)
Original Comment:

1.4.6: ³Note: Background sound that meets this requirement will be
approximately one quarter as loud as the foreground speech content.²
As I understand it, the Decibel scale is log-10. A 20dB difference is not a
factor of 4, it is a factor of 100. If the desired difference in sound is
4:1 foreground to background, the correct figure should be -6dB.

Response from Working Group:

For power 20dB would be 100x.
For perceived loudness, 20dB is 4x or 4:1.

For more information, refer to "About Decibels"

Comment 7: Guideline too broad
Source: http://lists.w3.org/Archives/Public/public-comments-wcag20/2007Jun/0417.html
(Issue ID: 2312)
Original Comment:

Guideline 2.3: ³Do not create content that is known to cause seizures²
The content being evaluated cannot be ³known to cause seizures² until it
actually causes a seizure. What are known to cause seizures here are the
flashing patterns specified by the document. Therefore, the guideline should
read: ³Do not create flashing patterns that are known to cause seizures.²

Response from Working Group:

The guideline is meant to cover more than flashing.  We don't have any
more than flashing as a success criterion at this time.  But, we have
an advisory technique for avoiding patterns that cause seizures as
well. If new types of content that cause seizures are discovered, they
should also be avoided.

However, you are correct that we shouldn't focus on content causing
seizure, but rather, the method. We have therefore reworded Guideline
2.3 to say, "Do not design content in a way that is known to cause

Comment 8: Obsolete level references
Source: http://lists.w3.org/Archives/Public/public-comments-wcag20/2007Jun/0417.html
(Issue ID: 2313)
Original Comment:

Under the heading: ³When referring to WCAG 2.0 from another standard with a
Œshallı statement²
There are references to ³Level 1², ³Level 2² and ³Level 3² that should be

Response from Working Group:

Thanks for catching this. We have updated the draft as proposed. This
section has become a Appendix B in Understanding WCAG 2.0.
Received on Sunday, 4 November 2007 03:56:37 UTC

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