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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 21:57:53 -0700
Message-ID: <824e742c0711032157l3fa24e71hb87befbf28f99adc@mail.gmail.com>
To: "Lisa Seeman" <lisa@ubaccess.com>
Cc: public-comments-WCAG20@w3.org

Dear Lisa Seeman,

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: Support for Learning Disabilities
Source: http://lists.w3.org/Archives/Public/public-comments-wcag20/2007Jun/0094.html
(Issue ID: 2004)
----------------------------
Original Comment:
----------------------------

I agree with Jonathan, in that the current draft does not have the
wording that I was hoping.

Specifically we want people to look at other specifications until WCAG
adequately supports people with Learning Disabilities. That is why it
was important that the words "There is a need for more research and
development in this important area." are removed, as this implies that
WCAG 2.0 has done its best under the currently available knowledge.

People will assume from the current wording, that there are no better
options to include people with learning disabilities. Even worse -
they may think that other standards are non credible.

It is important to note that some sites WANT to include people with
learning disabilities. The very least we should not make it less
likely for them to succeed.

I will try and review the draft over the weekend.
All the best
Lisa

Lisa expanded on this with the following:

>From http://lists.w3.org/Archives/Public/public-comments-wcag20/2007Jun/0245.html

Issue 1:  from the introduction (about learning disabilities) Note
this comment comes from many people who voiced the formal objection to
the previous version

quote: "Although some of the accessibility issues of people with
cognitive, language, and learning disabilities are addressed by WCAG
2.0, either directly or through assistive technologies, the WCAG 2.0
guidelines do not address many areas of need for people with these
disabilities. There is a need for more research and development in
this important area."

recommendation: We must remove the sentence  "There is a need for more
research and development in this important area" . It will result in
less accessible content for many people.

To understand why I feel that is crucial please review my assumptions
Assumption 1:  There are organisations that have guidelines that offer
more support for people with learning disabilities then WCAG 2.0
Assumption 2: There are web authors that wish to make content, or at
least part of the content (such as emergency information) accessible
to as many people as they possibly can. There are sites that want to
include people with leaning and cognitive disabilities. Assumption 3:
Some of the criteria that have been proven to help accessibility for
people with learning disabilities and are recommended in other
specifications have been excluded from WCAG because of issues such as
adoptability, undue burden , widely applicable etc. These criteria are
 not all excluded because of a lack of research. These criteria are
often reliable.

If a web author who very much wants to accommodate people with severe
learning disabilities, reads the sentences "the WCAG 2.guidelines do
not address many areas of need for people with these disabilities."
They will know there is more to do. However, if they then read" There
is a need for more research and development in this important area."
They will assume that WCAG is the best option right now for including
people with learning disabilities.  The implication is that the only
reason that WCAG does not address many areas of need for people with
these disabilities is because the research is inadequate. Other
guidelines will seem less credible.

The result of this sentence is that the author who would like to
accommodate people with cognitive disabilities will do a worse job.

(All accessibility will benefit form more research, placing the
sentence hear, misrepresents the situation.)

Alternate answer from David (but now David agree's to remove sentence)

The Working Group hoped that the inclusion of the sentence "There is a
need for more research and development in this important area." would
encourage support in the research community for additional work in
these areas. The working group believes most cognitive professionals
would say there is need for more research and that this is an emerging
field. We don't know of other standards in web design that have
significanly different suggestions for cognitive, language and
learning than what we have included in the WCAG 2.0 (when we take into
consideration the advisory techniques).

The testability requirement has made it difficult to make many of the
cognitive language and learning techniques sufficient. But if we
remove testability, then the *entire* WCAG would be "advisory" and no
one would know whether they actually met the guideline or not. This
would not be consistent with other standards or with other W3C
recommendations.

In order to improve the balance between accommodation of other
disabilities and cognitive disabilities in the WCAG we are proposing
to tag each technique (sufficient and advisory) that can help people
with cognitive disabilities and then create a view of those tagged
techniques to form supplementary document called:

"WCAG 2.0 suggested techniques that make web sites more accessible for
people with cognitive disabilities"

In the preface we would say:

"Techniques that help people with cognitive, language and learning
disabilities are often, by their very nature, untestable. That does
not mean that they are not useful or important to some users. We have
included here a list of techniques that have been identified to help
some people with cognitive language and learning disabilities..."

---------------------------------------------
Response from Working Group:
---------------------------------------------

The Working Group hoped that the inclusion of the sentence "There is a
need for more research and development in this important area." would
encourage support in the research community for additional work in
these areas.  At the request of several reviewers, we have removed it.

We added the sentence based on comments submitted:

Authors are encouraged to consider the full range of techniques,
including the advisory techniques, as well as to seek relevant advice
about current best practice to ensure that Web content is accessible,
as far as possible, to this community.


In Context it reads:

All of these layers of guidance (guidelines, success criteria, and
sufficient and advisory techniques) work together to provide guidance
on how to make content more accessible. Authors are encouraged to view
and apply all layers that they are able to, including the advisory
techniques, in order to best address the needs of the widest possible
range of users.

Note that even content that conforms at the highest level (AAA) will
not be accessible to individuals with all types, degrees, or
combinations of disability particularly in the cognitive language and
learning areas. Authors are encouraged to consider the full range of
techniques, including the advisory techniques, as well as to seek
relevant advice about current best practice to ensure that Web content
is accessible, as far as possible, to this community. Metadata may
assist users in finding content most suitable for their needs.

----------------------------------------------------------
Comment 2: Wording of SC 1.4.3 and SC 1.4.5
Source: http://lists.w3.org/Archives/Public/public-comments-wcag20/2007Jun/0245.html
(Issue ID: 2076)
----------------------------
Original Comment:
----------------------------

Issue 2:  from  1.4.3 and 1.4.5 (about low contrast images)
quote "   <http://www.w3.org/TR/2007/WD-WCAG20-20070517/#textdef> Text (and
images of text) have a
<http://www.w3.org/TR/2007/WD-WCAG20-20070517/#contrast-ratiodef> contrast
ratio of ...."

I recommend changing the text to "
<http://www.w3.org/TR/2007/WD-WCAG20-20070517/#textdef> Text (and images of
text) are available with a
<http://www.w3.org/TR/2007/WD-WCAG20-20070517/#contrast-ratiodef> contrast
ratio of ...."

In other words the images may be Swapped for high contrast versions. This
enables the content provider to provide accessibility when required and
maintain the look and feel of their graphics.

---------------------------------------------
Response from Working Group:
---------------------------------------------

We don't need to change the wording to accommodate the option you
suggest.  The guidelines already allow pages to conform as long as any
parts that don't, have an equivalent that does.  Hence - a technique
whereby content that did not have enough contrast had an alternative
that could be called up from the page that would meet the contrast -
would conform.

If you would like to write up such a technique we would be happy to
include it as a sufficient technique.  in the meantime, we have put in
a placeholder sufficient technique with the following title to make it
clear that this is a possibility.

"Providing a mechanism on the page for replacing any low contrast text
or images text with text or images of text that meet the specified
contrast ratio."

----------------------------------------------------------
Comment 3: SC 2.2.1 - Adjust and Extend only when no other option
Source: http://lists.w3.org/Archives/Public/public-comments-wcag20/2007Jun/0245.html
(Issue ID: 2077)
----------------------------
Original Comment:
----------------------------

Issue 3:  from   2.2.1 (about timed text)

Quote "
*
Adjust: the user is allowed to adjust the time limit before encountering it
over a wide range that is at least ten times the length of the default
setting; or

*
Extend: the user is warned before time expires and given at least 20 seconds
to extend the time limit with a simple action (for example, "hit any key"),
and the user is allowed to extend the time limit at least ten times; or

"

I am uncomfortable with these options. At least these options could be
limited to " when there is no other option"

I am often having page information reset for me - at huge loss of data and
time. sometimes the problem is I have got distracted or am doing something
else for a short time and boom - hours of work gone. How can you be sure
that the user knows to hit the key?



This kind of thing makes me which for testing centric guidelines - oh well

---------------------------------------------
Response from Working Group:
---------------------------------------------

We have added the following to Understanding SC 2.2.1, to encourage
authors to adopt the least intrusive approach:

These options are listed in the order that will be most helpful for
the user. Disabling time limits is better than customizing the length
of time limits, which is better than requesting more time before a
time limit occurs.

----------------------------------------------------------
Comment 4: Raise priority level of SC 3.3.3 and 3.3.6
Source: http://lists.w3.org/Archives/Public/public-comments-wcag20/2007Jun/0245.html
(Issue ID: 2078)
----------------------------
Original Comment:
----------------------------

Issue 4:  From 3.3.3 and 3.3.6  - about error preventions

quote  " 3.3.3 Error Prevention (Legal, Financial, Data): For forms that
cause  <http://www.w3.org/TR/2007/WD-WCAG20-20070517/#legalcommitmentsdef>
legal commitments or financial transactions to occur,

3.3.6 Error Prevention (All): For forms that require the user to submit
information"

I recommend moving 3.3.3 to conformance  level 1 and 3.3.6 to conformance
level two - making both of them one conformance  level higher then they are
now

 My reason is as follows:

If a person claims accessibility at any level that at least you should no
that legal commitments will not be incurred without the disabled  user being
aware of it.

The fear and experiences of bad transactions and getting  your data messed
up by hard to use forms is a common experience and a barrier to the world
and convenience of internet use for many disabled uses. Many people with
disabilities are afraid of using  internet services because of this,. Yet
often people with disabilities need the online alternative the most. They
need to be able to use them without fear.

---------------------------------------------
Response from Working Group:
---------------------------------------------

This is a new provision in WCAG 2.0 and the working group is not sure
that it can be applied in all situations.  The group is not
comfortable shifting these two provisions [3.3.4 Error Prevention
(Legal, Financial, Data)] and [3.3.6 Error Prevention (All)] up a
level to A and AA.

----------------------------------------------------------
Comment 5: Meaning of "Non support" requirement
Source: http://lists.w3.org/Archives/Public/public-comments-wcag20/2007Jun/0245.html
(Issue ID: 2079)
----------------------------
Original Comment:
----------------------------

Issue 5:  From  the end sections

Quote"  Non support: The content continues to meet the conformance
requirements when the (non accessibility-supported) technology is turned on,
turned off, or is not supported by a user agent."

I found this very unclear - what does this mean?

---------------------------------------------
Response from Working Group:
---------------------------------------------

We have reworded the conformance clause to make it clearer:

It now reads:

5.) Non-Interference: If Web technologies that are not accessibility
supported are used on a page, or accessibility-supported technologies
are used in a non-conforming way, then they do not block the ability
of users to access the rest of the page. Specifically, the Web page as
a whole continues to meet the conformance requirements under all of
the following conditions:

1. when any (non accessibility-supported) technology is turned on in a
user agent, and

2. when it is turned off in a user agent, and

3. when it is not supported by a user agent

Note: The following success criteria all apply to full pages including
technologies that are not accessibility supported or relied upon to
meet the other success criterion because they deal with things that
could interfere with overall use of the page: 1.4.2 - Audio Control,
2.1.2 - No Keyboard Trap, 2.3.1 - Three Flashes or Below Threshold,
and 2.2.2 - Pausing.

This is explained more fully in Understanding Conformance Requirement 5:
http://www.w3.org/WAI/GL/WCAG20/WD-UNDERSTANDING-WCAG20/conformance.html#uc-247-head

----------------------------------------------------------
Comment 6: Optional components of conformance claim
Source: http://lists.w3.org/Archives/Public/public-comments-wcag20/2007Jun/0245.html
(Issue ID: 2080)
----------------------------
Original Comment:
----------------------------

Issue 5:  from  the conformance claim sections at the end

quote "


Optional components of a conformance claim

*
Information about any additional steps taken that go beyond the success
criteria to enhance accessibility.

"

Can we add hear  "Information about the cognitive abilities are required to
use the page such as visual memory, auditory memory, language abilities,
reading level , etc"

Can we add  "what advisory techniques were used " ?
Can we add  "Information about any additional protocols used to aid access
for people with cognitive and learning disabilities "

---------------------------------------------
Response from Working Group:
---------------------------------------------

The language, "Information about any additional steps taken that go
beyond the success criteria to enhance accessibility" includes all of
the items you mention with the exception of specifying the
requirements needed from certain disabilities.  There is nothing to
prevent specifying this information, but we decided to not encourage
specifying particular disability information in the WCAG itself.  We
have added notes to the "Understanding" document to make it clear that
"what advisory techniques were used" and "Information about any
additional protocols used to aid access for people with cognitive and
learning disabilities" is included in "Information about any
additional steps taken that go beyond the success criteria to enhance
accessibility."

The language in the Understanding Conformance Claims is:

Information about any additional steps taken that go beyond the success criteria

One of the optional components of a conformance claim is "Information
about any additional steps taken that go beyond the success criteria
to enhance accessibility." This can include additional success
criteria that have been met, advisory techniques that were
implemented, information about any additional protocols used to aid
access for people with particular disabilities or needs, etc. Any
information that would be useful to people in understanding the
accessibility of the pages may be included.

http://www.w3.org/WAI/GL/WCAG20/WD-UNDERSTANDING-WCAG20/conformance.html#uc-248-head

----------------------------------------------------------
Comment 7: Understanding section references - missing issue in Principle 3
Source: http://lists.w3.org/Archives/Public/public-comments-wcag20/2007Jun/0245.html
(Issue ID: 2081)
----------------------------
Original Comment:
----------------------------

Issue 6 : missing section in guideline 3

Take the following inaccessible sentence "please see section 2.3 56 to test
conformance against technique 45.3.m" ?


*       Is the term "2.3.56" considered  jargon or acronyms that it needs an
explanation? So far I can not find a  success criteria that prohibit this
sentence.
*       Further,  if it is considered  jargon and  a glossary of jargon is
provided - would that conform?
*       Imagine someone without a visual or auditory short term memory (you
can simulate that by imaging the numbers were symbols that all look a bit
alike)  - Will a glossary help?   (answered:  it will not )


Useful labels needed to be used in place of the 3,2,4.28d.m stuff

---------------------------------------------
Response from Working Group:
---------------------------------------------

We agree that this reference is not jargon and is not covered by SC
3.1.3 (Unusual words).

NOTE: If the document being referred to was conformant then you would
have the descriptive labels that you want in that sentence. If the
document being referred to was not conformant - then it may not have
descriptive labels and you would have the problem you cite.

We have also added two advisory techniques to Guideline 3.1 to make it
easier for people to look up reference when they encounter them.

"Making any reference to a location in a Web page into a link to that location."
"Making references to a heading or title include the full text of the title."
Received on Sunday, 4 November 2007 04:58:09 UTC

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