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

From: Geert Freyhoff <G.Freyhoff@inclusion-europe.org>
Date: Mon, 19 Nov 2007 09:51:06 +0100
Message-ID: <8ACBF34973134E4FB695C781E7C467CEAB0194@hardy.inclusion-europe.org>
To: <public-comments-wcag20@w3.org>
Cc: <lorettaguarino@google.com>

Dear Ms Guarino Reid, Mr Vanderheiden, and Mr Cooper,

Thank you very much for taking our comments into account. Please find
below the comments of Inclusion Europe on your proposals.

Yours sincerely,

Geert Freyhoff
Director 

----------------------------------------------------------
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.

-----------------------------------------------
INCLUSION EUROPE COMMENT:
-----------------------------------------------

"We were able to find very few examples of text on the internet that was
written at this reading level..."

This is the problem that adults with intellectual disabilities are
facing: Although the internet is nowadays the most important
communication tool, it is not accessible for them. There is very little
information adapted to their needs. Thus, the point that presently
little information exist for this groups points to the need for clearer
standards.

This is why we ask from the authors to provide besides the original text
alternative versions that match the needs of this group of people as
soon as the content requires a higher level of comprehension than the
primary education 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.

-----------------------------------------------
INCLUSION EUROPE COMMENT:
-----------------------------------------------

This answer from the Working Group shows the limited knowledge and
experience in the Working Group about accessibility issues for people
with intellectual disabilities. There are many examples of legal
documents that have been translated into easy-to-read format, meaning in
an alternative content expressed in a language that does not require
more than primary level education to be understood.

Out of many examples of legal texts that were provided in alternative
easy-to-read format, we want to highlight just the following: the
Austrian government has asked and paid for the translation of new laws
in a way that is accessible for people with intellectual disabilities.
The results are available at:
http://www.atempo.at/index.php?node=606&id=520&size=2&lang=1&
http://www.atempo.at/index.php?node=599&id=511&size=2&lang=1&
http://www.atempo.at/index.php?node=510&id=435&size=2&lang=1&

Additional examples include the UN Convention on the Rights of People
with Disabilities, the UN Standard Rules for the Equalization of
Opportunities for People with Disabilities, the European Commission
Directive on Equal Treatment in Employment and Occupation, as well as
many national laws and policies in many European countries.

Beyond legal texts, people with intellectual disabilities are interested
in the same things than other adults: music, motorbikes, soccer,
dancing, and of course rights, only to name a few. It is therefore clear
discrimination when authors provide information requiring a higher
degree of understanding than primary level education and when they do
not provide alternative content.

Inclusion Europe therefore points out that keeping this criterion at the
AAA level is a clear case of indirect, i.e. structural, discrimination.
 
----------------------------------------------------------
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.

-----------------------------------------------
INCLUSION EUROPE COMMENT:
-----------------------------------------------

Since simple access is of paramount importance for people with
intellectual disabilities, Inclusion Europe suggests the following
wording: "When text requires reading ability more advanced than the
lower secondary education level, clearly marked and accessible with one
click supplemental content or alternate version..." 
 
----------------------------------------------------------
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
explanations:

"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"


-----------------------------------------------
INCLUSION EUROPE COMMENT:
-----------------------------------------------

No comment

----------------------------------------------------------
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 evaluation."

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."

-----------------------------------------------
INCLUSION EUROPE COMMENT:
-----------------------------------------------

"The content should be tested by those who understand how people with
different types of disabilities use the Web."

Inclusion Europe believes that it is quite naive to expect a
non-disabled tester to understand how a person with very limited
intellectual abilities (or equally people with other disabilities) will
use the web. The best qualified persons to understand how people with
disabilities use the web are people with disabilities themselves!

Therefore, we cannot do less than asking once again to change the text
by saying "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 different disabilities themselves.



----------------------------------------------------------
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
example.

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

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

-----------------------------------------------
INCLUSION EUROPE COMMENT:
-----------------------------------------------

Thank you



 
----------------------------------------------------------
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."

-----------------------------------------------
INCLUSION EUROPE COMMENT:
-----------------------------------------------

Thank you


----------------------------------------------------------
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
www.inclusion-europe.org/etr.

-       European Easy-to Read Logo. Inclusion Europe, Brussels.
www.inclusion-europe.org/etr.

---------------------------------------------
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
http://www.osmhi.org/contentpics/139/European%20Guidelines%20for%20ETR%2
0publications%20(2).pdf
and we have included these references.


-----------------------------------------------
INCLUSION EUROPE COMMENT:
-----------------------------------------------

Our server had some major problems and we had to change our website
hosting, which meant that our website was not accessible for several
months in first half of 2007.

Things have now been repaired and everything is working fine again.
Since Inclusion Europe is the author of this work and since we will
publish in 2008 revised versions of the Guidelines under this address,
we would be very grateful if you could add this exact address in the
examples:
www.inclusion-europe.org/etr

Thank you very much in advance for your understanding.
Received on Monday, 19 November 2007 13:33:11 UTC

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