W3C home > Mailing lists > Public > public-comments-wcag20@w3.org > November 2007

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

From: Loretta Guarino Reid <lorettaguarino@google.com>
Date: Sat, 3 Nov 2007 21:42:49 -0700
Message-ID: <824e742c0711032142q4c837a8ay366423203d0b6708@mail.gmail.com>
To: "Inclusion Europe" <self-advocacy@inclusion-europe.org>
Cc: public-comments-WCAG20@w3.org

Dear Inclusion Europe,

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: Reading level changed to primary education level
Source: http://lists.w3.org/Archives/Public/public-comments-wcag20/2007Jun/0260.html
(Issue ID: 2156)
Original Comment:

Most people with cognitive disabilities do not complete lower
secondary education. In order to provide accessibility for the large
majority of this group, texts must be as easy to read as possible.
Since this success criterion is of paramount importance for people
with cognitive disabilities, the reading level must be changed to be
equivalent to primary education.

Proposed Change:
New wording for success criterion 3.1.5:

When text requires reading ability more advanced than the PRIMARY
education level, supplemental content or an alternate version is
available that does not require reading ability more advanced than the
PRIMARY education level.

Response from Working Group:

The working group explored the impact of changing SC 3.1.5 to using a
primary education reading level.  We were able to find very few
examples of text on the internet that was written at this reading
level, even when text was targeted at early primary school students.
>From the examples that we were able to find, we think that this
reading level target would limit authors severely and could not be
satisfied for most content.

We are also concerned that while reading level is a testable property
of text, it is a fairly crude measure of how easy the content is to
understand.  We think that the needs of people with cognitive
disabilities will be better met if authors follow the advisory
techniques on using clear and easy to understand language, rather than
try to write at an unrealistic reading level.

Comment 2: Include criterion 3.1.5 in levels A and AA
Source: http://lists.w3.org/Archives/Public/public-comments-wcag20/2007Jun/0302.html
(Issue ID: 2157)
Original Comment:

To be able to access content in easy-to-understand language is of
paramount importance for people with cognitive disabilities. It is in
fact the core success criterion for this group of disabled people that
must be met by all public websites. Therefore, it must be associated
with level A and not only with level AAA.

Proposed Change:
Include success criterion 3.1.5. also in levels A and AA.

Response from Working Group:

Because of the tighter limits that this success criterion places on
content, we feel it is appropriate at level AAA.  Many legal documents
cannot have alternative or supplemental content, and cannot be
expressed in language at the primary level.

Comment 3: Clearly identify supplemental content or alternate version
Source: http://lists.w3.org/Archives/Public/public-comments-wcag20/2007Jun/0303.html
(Issue ID: 2158)
Original Comment:

People with cognitive disabilities have difficulties in reading and
understanding text. This has been recognized in success criterion
3.1.5. This also means that they have difficulties identifying on a
website which of the contents is the supplemental content or alternate
version that would be accessible for them.

Therefore, supplemental content or an alternate version must be
clearly identified as being accessible for people with cognitive
disabilities without requiring them to read the whole text. This can
be done for example by using the European Easy-to-Read Logo
(www.inclusion-europe.org/etr) that is already used for this purpose
in many European countries. A logo comparable to the logo for physical
access has the advantage to be language independent.

Proposed Change:
To insert a new success criterion 3.1.5.bis or modify the criterion
3.1.5 as follows:

Supplemental content or alternate versions for people with cognitive
disabilities must be clearly identified by an access symbol and must
be accessible from the referring page by one click.

Example of success criterion 3.1.5.bis:

Website of the European Commission, DG Employment and Social Affairs
at http://ec.europa.eu/employment_social/fundamental_rights/index_en.htm

Response from Working Group:

We have added "clearly marked" to SC 3.1.5 so that it reads:
"When text requires reading ability more advanced than the lower
secondary education level, clearly marked supplemental content or an
alternate version is available that does not require reading ability
more advanced than the lower secondary education level."
  We have also added an advisory technique:
"Clearly marking, by use of text or icon, content which has been
optimized for easy reading (future link)"

 We are not mandating any particular markings since we do not want to
limit the use of this technique.

Comment 4: Symbols illustrating texts can be ignored by assistive technology
Source: http://lists.w3.org/Archives/Public/public-comments-wcag20/2007Jun/0304.html
(Issue ID: 2159)
Original Comment:

To make texts more accessible for people with cognitive disabilities,
it is common practice to illustrate each paragraph with a symbol that
summarizes the main idea of the text next to it. This communication
symbol does not provide any supplementary information to a person who
can read the text without any difficulties for understanding it.

Proposed Change:
To change the exceptional situation 4 listed under success criterion
1.1.1 as follows:

"Decoration, Formatting, Invisible, Communication Symbols: If non-text
content is pure decoration, or used only for visual formatting, or if
it is not presented to users, or if it is a communication symbol
illustrating the main idea of a text for better understanding by
people with cognitive disabilities, then it is implemented such that
it can be ignored by assistive technology.

Inclusion Europe also proposes to add the following sentences to the

"Providing communication symbols to illustrate texts is an effective
method for many users, including those with cognitive disabilities.
This provision should not discourage those types of cues as long as
the communication symbols can be ignored by assistive technology."

Response from Working Group:

We agree that supplementing text with pictures is sometimes helpful to
people with cognitive disabilities and we have a sufficient technique
(G103) for Success Criteria 3.1.5 to do that.

We think it is problematic however to allow non-decorative graphics to
be marked so that their existence would be ignored by people using
screen readers. It would become a loophole that could adversely affect
accessibility for blind people. We believe that they should both be
visually presented for those who can see and presented via alternate
text for those who cannot. If the alternate of the graphic is
completely explained by text that is on the page, then there can be a
short alternate text that refers to the text on the page. Technique
G74 covers this approach.

We have adjusted the title of G103 to "Providing visual illustrations,
pictures, and symbols to help explain ideas, events, and processes"

Comment 5: Human testers should always be persons with disabilities
Source: http://lists.w3.org/Archives/Public/public-comments-wcag20/2007Jun/0305.html
(Issue ID: 2160)
Original Comment:

In the organizational section, it is stipulated that "some WCAG 2.0
success criteria require human testers for part or all of the test".
Inclusion Europe would like to emphasize that those human testers must
always be people with different kinds of disabilities themselves.

Proposed Change:
To change the text of the second paragraph of the point "Success
Criteria" under Organization of the WCAG 2.0 document as follows:

All WCAG 2.0 success criteria are written to be testable. While some
can be tested by computer programs, others require human testers for
part or all of the test. Human testers must always be persons with
disabilities themselves.

Response from Working Group:

A methodology for conformance evaluation requires the involvement of
human testers, but WCAG 2.0 does not define requirements with regard
to such an evaluation methodology. While we encourage authors to test
their Web pages with a wide variety of users, including users with
disabilities, this is not necessary to conform to WCAG.

Our current intro has been shortened and there is only a part of
single sentence that mentions testing as follows.

"WCAG 2.0 builds on WCAG 1.0 [WCAG10] and is designed to apply broadly
to different Web technologies now and in the future, and to be
testable with a combination of automated testing and human

However in our Understanding WCAG document we go into more detail as follows:

"All WCAG 2.0 success criteria are written as testable criteria for
objectively determining if content satisfies them. Testing the success
criteria would involve a combination of automated testing and human
evaluation. The content should be tested by those who understand how
people with different types of disabilities use the Web.

"Testing and testable in the context refer to functional testing, that
is verifying that the content functions as expected, or in this case,
that it satisfies the success criteria. Although content may satisfy
all success criteria, the content may not always be usable by people
with a wide variety of disabilities. Therefore, usability testing is
recommended, in addition to the required functional testing. Usability
testing aims to determine how well people can use the content for its
intended purpose. It is recommended that users with disabilities be
included in test groups when performing usability testing."

Comment 6: Replace example 4
Source: http://lists.w3.org/Archives/Public/public-comments-wcag20/2007Jun/0306.html
(Issue ID: 2161)
Original Comment:

The Microsoft Word Readability Scores for the text provided in the
example 4 (Starting with "In a dazzling and dramatic portrait...")
show a Flesch-Kinkaid score of 9.9 and not of 6.9 as mentioned in
success criterion 3.1.5. The example should be replaced. On the
website www.inclusion-europe.org, there are plenty of texts and
publications with a Flesch-Kinkaid score lower than 7. Any of them can
be used as example.

Proposed Change:
Change example text in success criterion 3.1.5. On the website
www.inclusion-europe.org, there are plenty of texts and publications
with a Flesch-Kinkaid score lower than 7. Any of them can be used as

Response from Working Group:

Thank you for catching this error. We have replaced this example with
an example at an appropriate reading level.

Comment 7: Mention of the Microsoft Word Readability Formulas
Source: http://lists.w3.org/Archives/Public/public-comments-wcag20/2007Jun/0307.html
(Issue ID: 2162)
Original Comment:

Microsoft Word is making readability formulas available and they are
easy to access. Mentioning this in the paragraph speaking about those
formulas will help people who are trying to find for which education
level they have written their texts.

Proposed Change:
Sentence to be added in the paragraph about readability formulas (last
paragraph before level education table):

Microsoft Word Readability Formulas are available on each computer
when running the spell checker if you specify in the options of this
engine that you want to have the statistics when it has finished to
check your documents.

Response from Working Group:

we have added the following Sentence in the paragraph about
readability formulas

"Readability formulas are available for at least some languages when
running the spell checkers in popular software if you specify in the
options of this engine that you want to have the statistics when it
has finished checking your documents."

Comment 8: Addition of a related resource
Source: http://lists.w3.org/Archives/Public/public-comments-wcag20/2007Jun/0308.html
(Issue ID: 2163)
Original Comment:

European Guidelines on how to write text in an easy-to-read format
have been written and translated into twelve European languages. They
are presently under revision, but they are still an excellent resource
for anybody who would like to write content in a way that is
accessible for people with cognitive disabilities.

Proposed Change:
Add in the Related Resources of the Success Criterion 3.1.5.

-       European Easy-to-Read Guidelines. Inclusion Europe, Brussels, 1998
(under revision). Available in eleven European languages at

-       European Easy-to Read Logo. Inclusion Europe, Brussels.

Response from Working Group:

The URIs in your comment, www.inclusion-europe.org/etr, don't appear
to be valid. However, we found other reference to this work at
http://www.osmhi.org/?page=139 and
and we have included these references.
Received on Sunday, 4 November 2007 04:43:02 UTC

This archive was generated by hypermail 2.4.0 : Friday, 17 January 2020 19:14:45 UTC