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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 21:44:12 -0700
Message-ID: <824e742c0711032144i1f2e07b6ta62109b2e05c3fa4@mail.gmail.com>
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

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: 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

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

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,

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

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

Additional thoughts at

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

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

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

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

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

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