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RE: Your comments on WCAG 2.0 Public Working Draft of May, 2007 [SEC=UNCLASSIFIED]

From: Bruce Maguire <BruceMaguire@humanrights.gov.au>
Date: Tue, 20 Nov 2007 15:46:22 +1100
Message-ID: <B0F28387571A7B458CDCE242982C23C704E06C59@EXCH.paradise.aust>
To: "Loretta Guarino Reid" <lorettaguarino@google.com>
Cc: <public-comments-WCAG20@w3.org>

Dear Loretta

Firstly, may I thank you and the other members of the committee for
giving us the opportunity to offer some comments on the response that
you provided to our submission relating to the May 17 WCAG2.0 draft.

It is clear from the committee's response that it correctly understood
the comments that we provided. We appreciate the time and care taken by
the committee in formulating their response. Our follow-up comments are
below, and use the numbering from our original submission:

1. If the web accessibility and cognitive disability communities are
satisfied that including a statement about the need for further testing
would divert focus away from the  valuable guidelines and techniques
that we already have in this area, then we support removing it.
Moreover, we would continue to encourage the committee to give further
consideration to incorporating more of the qualitative guidelines that
have been identified. From a policy perspective, we are concerned that
the need to refer developers to both WCAG2.0 and some other set of
(non-normative) guidelines will lead to confusion and disharmony. If,
for example, the Commission determined that a particular set of
guidelines would most effectively meet the needs of users with cognitive
disabilities in Australia, but regulatory bodies in other countries
adopted different sets of guidelines, we would end up with a situation
where it would be very difficult for developers of websites with an
international Coverage to comply (or assess their level of compliance)
with all of the different guidelines and, conversely, it would be
extremely difficult for an individual with a disability to use
disability discrimination legislation to successfully prosecute a web
developer who complied with guidelines in one jurisdiction but not with
those in the individual's own (a web developer might readily invoke a
defense of unreasonableness or unjustifiable hardship/undue burden
because of the plethora of guidelines with which they had to comply).
The most effective solution we see to this is the development of
internationally-agreed guidelines for addressing the needs of web users
with cognitive, language or learning disabilities. We urge the committee
to consider mechanisms by which the WAI could assist in the process of
developing such guidelines.

2. We welcome the committee's suggested change and await the next draft
to assess its implications fully.

Regards
Bruce Maguire
Policy/Project Officer
Human Rights and Equal Opportunity Commission


 

-----Original Message-----
From: Loretta Guarino Reid [mailto:lorettaguarino@google.com] 
Sent: Sunday, 4 November 2007 3:35 PM
To: Bruce Maguire
Cc: public-comments-WCAG20@w3.org
Subject: Your comments on WCAG 2.0 Public Working Draft of May, 2007

Dear HREOC,

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: Addressing the needs of people with cognitive, language or
learning disabilities
Source:
http://lists.w3.org/Archives/Public/public-comments-wcag20/2007Jul/0037.

html
(Issue ID: 2320)
----------------------------
Original Comment:
----------------------------

Concern and Rationale:
We regret that the Guidelines in their current form do not adequately
address the needs of people with cognitive, language or learning
disabilities. We believe that attention to the needs of these users is a
necessary part of accessibility, and that websites which do not address
these needs are, to that extent, inaccessible. However, we do
acknowledge the challenges of addressing these needs through guidelines
developed within a testable framework, and we encourage the W3C to
conduct more research in this area to identify best-practice solutions,
and to expand the Guidelines once more comprehensive information has
been obtained. We also urge the development committee to re-examine the
Guidelines in case it can identify a greater number of success criteria
that relate to the needs of people with cognitive, language or learning
disabilities and which meet the 80% confidence level for human testing.
In the meantime, we would recommend a stronger statement about the
importance of addressing the needs of these user groups so that
developers do not use WCAG2.0 as an escape route for ignoring them.
Therefore:

Suggested Change:
After "There is a need for more research and development in this
important area": Delete period, add Comma, and the following text:
"and developers should seek relevant expert advice about current best
practice to ensure that web content is accessible as far as possible to
people with these 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 following 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."

----------------------------------------------------------
Comment 2: Define testability in glossary
Source:
http://lists.w3.org/Archives/Public/public-comments-wcag20/2007Jul/0037.

html
(Issue ID: 2321)
----------------------------
Original Comment:
----------------------------

Concern and Rationale:
We support endeavours to incorporate principles of testability into
accessibility standards and guidelines, as this provides greater
certainty for those who seek to implement them and also for those who
wish to assess the extent to which they have been followed. However,
there is no formal definition of "testable" and "testability" either in
the Introduction or in the Glossary of WCAG2.0. In particular, there is
no mention of the 80% confidence level requirement for human testers.
Given the significance of testability within the WCAG2.0 framework, we
suggest providing a complete normative definition that highlights the
role of both machine and human testing, together with a discussion of
the rationale of the concept. The absence of such definition and
discussion limits the ability of policy-makers to interpret, promote and
apply the concept accurately.

Suggested Change:
Link "testable", In the sentence "All WCAG 2.0 success criteria are
written to be testable." to a definition in the Glossary. Add definition
to Glossary.

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

Our current introduction 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."

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Received on Tuesday, 20 November 2007 18:23:37 UTC

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