- From: Loretta Guarino Reid <lorettaguarino@google.com>
- Date: Sat, 3 Nov 2007 21:44:12 -0700
- To: "Jared Smith" <jared@webaim.org>
- Cc: public-comments-WCAG20@w3.org
Dear Jared Smith, 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 http://www.w3.org/WAI/GL/WCAG20/WD-WCAG20-20071102/ 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. Regards, 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: Wording suggests that a link context is required Source: http://lists.w3.org/Archives/Public/public-comments-wcag20/2007Jun/0380.html (Issue ID: 2249) ---------------------------- Original Comment: ---------------------------- "... can be determined from the link text and its programmatically determined link context" seems to suggest that *both* the link text and the link context are required for determination. If a link is all alone on a page, it may have no link context and would thus make this determination impossible. Changing "and" to "or" clarifies this, but then allows the purpose to be determined by link context alone, something you do not want to allow. Also, the word "purpose" is quite vague. Purpose describes what the user does with the link (click it???). "Function" or "target context" or similar may be more appropriate. At a minimum, "purpose" needs to be defined. Additional commentary at http://webaim.org/blog/2007/06/27/wcag-20-polishing-the-rough-edges/#linkcontext Proposed Change: Suggested wording: "The function of each link can be determined from the link text or the link text and its programmatically determined link context." --------------------------------------------- Response from Working Group: --------------------------------------------- We have changed SC 2.4.4 to read "2.4.4 Link Purpose (Context): The purpose of each link can be determined from the link text or the link text together with its programmatically determinable link context." ---------------------------------------------------------- Comment 2: Transcript = text allows no captions Source: http://lists.w3.org/Archives/Public/public-comments-wcag20/2007Jun/0381.html (Issue ID: 2250) ---------------------------- Original Comment: ---------------------------- A content creator can simply designate the transcript for a video as the "text" and the video itself as the "multimedia alternative to text", thus there would be no requirement to ever provide captions for any video that has a transcript. The intention is to allow non-captioned alternatives (possibly for those with cognitive disabilities), but by simply providing a transcript (Level AAA - see next comment), developers can essentially bypass this Level A requirement for ALL pre-recorded multimedia. Additional thoughts at http://webaim.org/blog/2007/06/27/wcag-20-polishing-the-rough-edges/#captions Proposed Change: I'm not sure how to specifically address this. "Multimedia alternative to text" needs to be sufficiently defined so it cannot be construed to be applied to a transcript. --------------------------------------------- Response from Working Group: --------------------------------------------- We have changed the definition of "multimedia alternatives to text" to address this problem. If the full text alternative is shown as part of the Web page, this meets the exception. If the full text alternative is provided as a supplement or text alternative, then it no longer meet this exception. multimedia alternatives to text: multimedia that presents no more information than is already presented in text or images of text and that is intended to be an alternative to that text ---------------------------------------------------------- Comment 3: Transcripts not given adequate relevance Source: http://lists.w3.org/Archives/Public/public-comments-wcag20/2007Jun/0383.html (Issue ID: 2251) ---------------------------- Original Comment: ---------------------------- Captions alone do not provide adequate multimedia accessibility to many users (screen reader users, deaf, deaf-blind, cognitive disabilities, non-native speakers, those using print/braille output, etc.). Due to the multimedia exception to SC 1.1.1 (Level A), transcripts are not required for multimedia unless Level AAA conformance is desired (SC 1.2.7). SC 1.2.2 (also Level A) requires full text alternative OR audio descriptions (unless visual content is in audio), so this does nothing to provide adequate accessibility to the audience listed above. Transcripts provide higher assistive technology support and have no more (arguably much less) impact on presentation than captions or audio descriptions, yet have been relegated to the highest conformance level. Captions are required at Level A, yet transcripts are at Level AAA even though they may provide better accessibility to a larger population. Additional thoughts at http://webaim.org/blog/2007/06/27/wcag-20-polishing-the-rough-edges/#transcripts Proposed Change: Remove the multimedia exception from SC 1.1.1 OR assign SC 1.2.7 to a lower conformance level. --------------------------------------------- Response from Working Group: --------------------------------------------- The preference is given to captions and audio descriptions because, except those who are deaf-blind, users that we have heard from want and prefer those accommodations. Also, whenever you go to a full text transcript you lose much information and experience, and you lose the ability to experience the content together. Also you lose the ability to experience together. Full multimedia text alternative ARE allowed at level A for audio descriptions because it is often impossible to get sufficient description in between the regular audio when there is constant dialog going on (such as with training videos). ---------------------------------------------------------- Comment 4: What about non-visually evident? Source: http://lists.w3.org/Archives/Public/public-comments-wcag20/2007Jun/0388.html (Issue ID: 2255) ---------------------------- Original Comment: ---------------------------- SC 1.4.1 addresses visual identification of content without relying on color alone. This ignores and there is no other criteria that addresses the fact that color and other stylistic differences are inaccessible to non-visual users. Color, italics, bold, font size, font face, etc. can be used to convey information. These are all potentially inaccessible to screen reader users, braille outputs, the deaf-blind, those using technologies that don't support these visual styles (such as many cell phones), or those that override or disable visual styles. This audience is potentially larger than the audience for which color alone may render visual content inaccessible. Proposed Change: Add a success criteria: "Information conveyed through color or visually stylistic differences is also available without color or the visually stylistic differences." --------------------------------------------- Response from Working Group: --------------------------------------------- Success criterion 1.4.1 speaks specifically to the case of visual perception of color. Other text styling etc are covered by success criterion 1.3.1. This provision is only about color-blindness. Success criterion 1.3.1 ensures that all visual styling etc is also available to AT. But, people who are color blind do not use AT so a separate provision is provided. We have added a note to 1.4.1 to make this clear: Note 1: This success criterion addresses color perception specifically. Other forms of perception are covered in Guideline 1.3. ---------------------------------------------------------- Comment 5: Readability is broken Source: http://lists.w3.org/Archives/Public/public-comments-wcag20/2007Jun/0390.html (Issue ID: 2257) ---------------------------- Original Comment: ---------------------------- What methods and technologies could be used for determining conformance? There are many diverse measures for reading level. Why lower secondary education level? This seems a very arbitrary and capricious measurement. Because of the testability requirement, this SC ignores the audience and the content creator's ability to develop content for a unique (as opposed to a generic) audience. Readers of some content (some technical information, Shakespeare's writings, quotations such as The Gettysburg address, etc.) would not benefit from a lower reading level alternative. These alternatives could even be less accessible. There is also cognitive load and difficulty in providing access to these alternative (see your own discussion on accessing alternative versions - http://www.w3.org/WAI/GL/2007/05/alternate-versions.html) Readability (Level AAA) is absolutely the most important aspect of understandability. It's certainly much more important for accessibility and AT support than identifying language (Level A) or identifying errors (Level A). What good is an error if you can't read it? This seems to have been relegated to Level AAA because the "lower secondary" test would not stand up at any other conformance level. More commentary at http://webaim.org/blog/2007/06/27/wcag-20-polishing-the-rough-edges/#readinglevel Proposed Change: Change the wording to, "Use the clearest and simplest language appropriate." Optionally, you could add, "... or provide an alternative or supplementary content that does not require reading ability more advanced than the lower secondary education level." "Appropriateness" of language is no less testable than "equivalent information" of alternatives in SC 1.1.1. --------------------------------------------- Response from Working Group: --------------------------------------------- The working group agrees that using the clearest and simplest language appropriate is highly desirable, but could not find a way to test whether this had been achieved. The use of reading level is a way to introduce testability into a success criterion that encourages clear writing. We do not agree that the "appropriateness" of language is as testable as "equivalent information" of alternatives. The clearest and simplest language for communicating concepts in a legal document or a technical topic may be well above the reading level of this success criterion, and may be hard for a non-expert to understand. However, how is one to determine whether the language used is the clearest, simplest language that is appropriate to the topic? We agree that the best way to satisfy this success criterion is to write the content itself simply and clearly, and writing at the desired reading level is one of the sufficient techniques listed. However, since we believe this is not always possible, and because we recognize that supplementary content can be a powerful technique for people with some classes of cognitive disability, the success criterion permits alternatives and supplements. According to the Open Society Mental Health Initiative, the concept of Easy to Read cannot be universal, and it will not be possible to write a text that will suit the abilities of all people with literacy and comprehension problems. Because of the tighter limits that this success criterion places on content, we feel it is appropriate at level AAA.
Received on Sunday, 4 November 2007 04:44:28 UTC