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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 21:51:02 -0700
Message-ID: <824e742c0711032151v6f01de83w41a975661cf08b93@mail.gmail.com>
To: "Jon Gunderson" <jongund@uiuc.edu>
Cc: public-comments-WCAG20@w3.org

Dear Jon Gunderson,

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: Language changes should be Level A
Source: http://lists.w3.org/Archives/Public/public-comments-wcag20/2007Jun/0048.html
(Issue ID: 1969)
Original Comment:

Source: http://www.w3.org/mid/20060612134547.CA28447B9F@mojo.w3.org
(Issue ID: LC-760)

Part of Item:
Comment Type: TE
Comment (including rationale for proposed change):

This should be success criteria 1 like in the Priority 1 WCAG 1.0
requirement.  It is impossible for people using speech to guess at
language changes.  We have a lot of web based foriegn  language
courses at UIUC and we have identified that speech users cannot
determine when to manually switch their synthesizer languages, even
when they know that there are more than one language on the resource.

If changes in language are available modern screen readers will
automatically switch the lanaguge of the synthesizer.

Proposed Change:

Move this requirement to Success Criteria 1

Response from Working Group:

There were comments to combine 3.1.1 and 3.1.2, to move them up and to
move them down. After much discussion, the consensus of the working
group was to leave them in the current positions.

Response from Jon Gunderson:
The working group response is very disappointing.  I believe it is
probably much easier for someone to guess the overall language of a
web resource than language changes within the web resources.  I cannot
understand any arguments on why language CHANGES are not critical for
accessibility especially for anyone using speech (Visual impairments
and learning disabilities).  I have seen students have to drop courses
at UIUC because language changes were not part of the content.  In the
era of on-line learning you will be allowing content with multiple
languages to comply at a Single-A level without their content being
usable by many people with disabilities.

Response from Working Group:

The working group spent much time considering 3.1.2 at a higher level.
However, the working group did not feel there was enough to move it to
level A and there are good reasons for not requiring it at level A.
SC 3.1.2 had many complicating factors with respect to what exactly is
a change of language in a passage.  A rather lengthy note was added to
clarify situations that are not to be considered a change of language.

Comment 2: Conformance section is confusing
Source: http://lists.w3.org/Archives/Public/public-comments-wcag20/2007Jun/0049.html
(Issue ID: 1970)
Original Comment:

Source: http://www.w3.org/mid/20060612141417.35612BDA8@w3c4.w3.org
(Issue ID: LC-762)

Part of Item:
Comment Type: TE
Comment (including rationale for proposed change):

These requirement seems to deal with collections of web resources
(units).  I think that this should be stated that you are creating
some type of conformance for a collection of resources. It would make
it much clearer.  I think this should also be in the conformance

If a resource does not meet the requirements, it just doesn't meet the

Proposed Change:

1. Move this requirement to conformance section
2. Clearly state you want people to be able to make conformance claims
on collections of resources.

Response from Working Group:

We have revised the conformance section significantly and have
clarified how claims for collections of versions can be made: 4.)
Alternate Versions: If the Web page does not meet all of the success
criteria for a specified level, then a mechanism to obtain an
alternate version that meets all of the success criteria can be
derived from the nonconforming content or its URI, and that mechanism
meets all success criteria for the specified level of conformance. The
alternate version does not need to be matched page for page with the
original (e.g. the alternative to a page may consist of multiple
pages). If multiple language versions are available, then conforming
versions are required for each language offered.

Response from Jon Gunderson:
I think the conformance section is confusing.  Suggesting a page that
is not accessible is now accessible because it references an
alternative page that is accessible is misleading about the page.  The
only thing that is accessible is the alternative page and that should
be the only thing that can be labeled as passing.  The linking page to
the alternative stands on its own accessibility merits.  This type of
conformance option also perpetuates the myths that accessibility means
creating something so different that alternative page is needed and
accessibility is a burden since it requires twice the work to create
duplicate pages.  This was a necessary requirement for WCAG 1.0, but I
think is out date for the world we live in now.

Response from Working Group:

We no longer refer to a page as conformant if it has a conforming
alternative.  But we do allow pages with conforming alternate versions
within the scope of conformance since we do not know how to make some
content technologies directly accessible.

Comment 3: add our titling requirement as a technique for creating
accessible titles
Source: http://lists.w3.org/Archives/Public/public-comments-wcag20/2007Jun/0050.html
(Issue ID: 1971)
Original Comment:

Source: http://www.w3.org/mid/20060621140004.F18FF66364@dolph.w3.org
(Issue ID: LC-838)

Part of Item:
Comment Type: substantive
Comment (including rationale for proposed change):

I recommend this requirement be moved to SC1. If descriptions of an
image are SC1, then are not descriptions or titles of a web page of
equal importance? This should be merged with requirements of 2.4.5 and
that descriptions/titles should be \"unique\" for collections of a web
resources as part of the success criteria.

See UIUC Web Accessibility Best Practices:

Proposed Change:

I recommend this requirement be moved to SC1 and merged with the
requirements of 2.4.5.

Response from Working Group:

We have added "descriptive" to SC 2.4.3 and moved it to level A.

The success criterion does not require that titles be unique because
the working group is concerned that requiring uniqueness will lead to
titles that are not as descriptive and usable. It may be very
difficult to create titles that are descriptive, unique, and
reasonably short. For example, a Web page that generates titles
dynamically based on its content might need to include part of the
dynamic content in the title to ensure that it was unique.  We are
also concerned that authors may make titles unique mechanically, such
as by including a unique number in the title that is unrelated to the
content. For these reasons, although we encourage unique titles in the
techniques for this SC, we are not including uniqueness in the SC

SC 2.4.5 has been moved to Level AA. It addresses descriptive headings
and labels, which may need to be understood in context. While headings
may not have sufficient descriptive power in isolation, when viewed in
the context of a structured document, they do have sufficient
descriptive power.

Comment 4:

Source: http://www.w3.org/mid/20060621140642.A792066364@dolph.w3.org
(Issue ID: LC-839)

Part of Item:
Comment Type: substantive
Comment (including rationale for proposed change):

If descriptions of an image are SC1, then are not descriptions of a
web page titles and headings of equal importance?

Proposed Change:

Change to SC1.  Consider merging with requirement of SC 2.4.3.

Response from Working Group:

SC 2.4.5 has been moved to Level AA. It addresses descriptive headings
and labels, which may need to be understood in context. While headings
may not have sufficient descriptive power in isolation, when viewed in
the context of a structured document, they do have sufficient
descriptive power.

Response from JRG:
Titling in our best practices in more than just the TITLE element.  It
includes matching the TITLE content with H1 content on a web page.
This provides a machine verifiable way for testing for unique titles.
While automated tools can be easily fooled, the web developer
obviously has to know they are doing it to get around this
requirement.  I think titling is just as important as text equivalents
for images.

I request that you add out titling requirement as a technique for
creating accessible titles:

Tools for testing titling using TITLE and H1 and other accessibility features:

Firefox Accessibility Extension

Functional Accessibility Evaluator

Response from Working Group:

Thank you for you suggestion. We have added an advisory technique for
SC 2.4.2 (Web pages have descriptive titles) of "Using unique titles
for Web pages." This technique will complement the advisory technique
for SC 2.4.6 (Headings and labels are descriptive) of "Using unique
section headings in a Web page."  It is not always appropriate for
TITLE and H1 to contain exactly the same text. TITLE often contains
the web site name but H1 usually does not (e.g. because there's a logo
outside H1 that serves that purpose).

Conformance to the Guidelines is based on the Web Page in question,
not the site. There are some cases when it would be very difficult to
require a unique Title for every page on a web site. There are also
many grey areas about what makes up a web site. Is a corporate site
that has divisions and servers in dozens of countries one web site or
many sub sites? Some sites have millions of pages. To require unique
Title for each page would be extremely difficult especially in cases
where there are different responsibility centres in different
countries governing different areas of a site.
Received on Sunday, 4 November 2007 04:51:15 UTC

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