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Response to comments on WCAG 2.0 Public Working Draft of May, 2007

From: Brian Hardy <Brian.Hardy@visionaustralia.org>
Date: Tue, 20 Nov 2007 09:36:58 +1100
Message-ID: <A921AF4A5FC01245A8D846D004B61B360517BF39@kooxch01.visionaustralia.org>
To: <public-comments-wcag20@w3.org>
Cc: "Sofia Celic" <Sofia.Celic@visionaustralia.org>, <andrew.arch@visionaustralia.org.au>
Hello Gregg and Working Group, 

Vision Australia is unsatisfied with not having such an essential
accessibility as images of text addressed in any way at the "A" level. 

The two SC (1.4.5 & 1.4.9) are both good, but as this is an essential
issue for our organisation's primary client group, and we cannot accept
them at the current levels, with nothing at "A".

With respect to our other comments, some appear to have been addressed,
but others we are not sure about at this stage. With Sofia Celic on
leave and major national training obligations in the last couple of
weeks, we are not able to indicate definitely whether the WG response is
satisfactory or unsatisfactory in the time you have allowed. We may well
provide additional comment on the Last Call working draft.


Brian Hardy 
Vision Australia Accessible Information Solutions 

Phone: (03) 9864 9525   Mobile: 0419 102 451 
Phone International: +61 3 9864 9525 
E-mail: brian.hardy@visionaustralia.org 


Comment 1: Prohibiting images of important text
(Issue ID: 2128)
Original Comment:

Currently WCAG 2.0 allows the use of images of text. Some
user groups with low vision may miss important content where
text within images contains important information. This may
be because the user requires a particular visual presentation
of the content, such as a particular font size or combination
of foreground and background colours to be able to perceive the text.

WCAG 2.0 currently has an advisory technique for Success Criterion
1.4.4 of "Avoiding the use of text in raster images". We do
not feel this is sufficient at an advisory technique status.

If images of important text are allowed these user groups
would need to "turn images off" to be able to apply their
presentation needs to the text alternative. Here are some
problems with that:

- This is something most users would not know of, let alone
how to do it.

- In Internet Explorer (still the most common use browser)
the user would be required to make changes in the 'Advanced'
tab (in Internet
Options) to stop image downloads. Not many people are
comfortable making changes in the "Advanced" area of any
program. Also, the setting to display all of the text
alternative of an image would be required (again an
'Advanced' setting in IE).

- Image text alternatives do not necessarily render at the
same size as the surrounding text

- Viewing a page with image text alternatives potentially
results in content being shifted so as to confuse the visual
reading order; overlapping image text alternative with other
text in the page; and cropped image alt text; generally
making the content harder or impossible to read.

- users may not be able to change browser settings in some
circumstances (such as at their place of employment where
access to settings is prohibited or limited)

Another important area is that of accessing image maps. How
would a user accessing pages with images off necessarily know
of the presence of an image map, let alone be able to access
the map regions? Most browsers do not render the text
alternative for and outlines of map regions. This issue goes
beyond images of text so we are also submitting a separate
comment regarding image maps.

Proposed Change:
Add a success criterion at Level A or AA that prohibits use
of images containing important text.

We acknowledge that the success criterion may need to include
some exceptions, such as where the important text is already
provided as text, or where logos are concerned.

Response from Working Group:

We now have two SC dealing with this:

at Level AA we have
"1.4.5 Images of Text (Limited): When an accessibility
supported technology exists to achieve the visual
presentation, text is used to convey information
rather than images of text unless the image of
the text can be visually customized to the user's

We have also at Level AAA:
"1.4.9 Images of Text (Essential): Images of text
are only used for pure decoration or where a
particular presentation of text is essential to
the information being conveyed."



Brian Hardy 
National Manager Market Development 
Vision Australia Accessible Information Solutions 

Phone: (03) 9864 9525   Mobile: 0419 102 451 
Phone International: +61 3 9864 9525 
E-mail: brian.hardy@visionaustralia.org 

454 Glenferrie Road Kooyong Victoria 3144 AUSTRALIA 
Postal: PO Box 860 Hawthorn Victoria 3122 AUSTRALIA 

NSW Office: 4 Mitchell Street Enfield NSW 2136 

QLD Office: Kent St, Woolloongabba QLD 4102


Websites: www.visionaustralia.org.au/ais  |  www.louisbrailleaudio.com
<http://www.louisbrailleaudio.com/>  | 
www.it-test.com.au <http://www.it-test.com.au/> 

Received on Tuesday, 20 November 2007 14:16:45 UTC

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