- From: Loretta Guarino Reid <lorettaguarino@google.com>
- Date: Mon, 24 Mar 2008 07:19:59 -0700
- To: public-comments-WCAG20@w3.org
---------- Forwarded message ---------- From: Roger Hudson <rhudson@usability.com.au> Date: Sun, Mar 23, 2008 at 8:12 PM Subject: RE: Your comments on WCAG 2.0 Last Call Working Draft of December, 2007 To: Loretta Guarino Reid <lorettaguarino@google.com> Hi Loretta and Members of the Working Group, Thanks for sending me the responses to my comments regarding the December 07 Draft of WCAG 2.0. As a general comment, I don't feel that the responses really address many of the issues I raised. However, this was not unexpected given the driving desire to get WCAG 2.0 out as soon as possible. I am not sure whether the apparent failure to comprehend some of my concerns is the result of my inability to express myself clearly, or unwillingness on the part of the WG to understand them. While I appreciate the Working Group's desire for clarity and testability, I also think that it is important to have guidelines that advance the cause of accessibility and guidelines that are practical to implement. I am concerned that some of WCAG 2.0 will be dismissed by large sections of the web industry as basically not reflecting their real world needs – see my comments relating to social networking sites and the broadcast media. Following, are comments on some of the responses by the Working Group to my comments on the December 07 Draft. Regards, best wishes and thanks for your work, Roger Roger Hudson Web Usability Ph: 02 9568 1535 Mb: 0405 320 014 Email: rhudson@usability.com.au Web: www.usability.com.au -----Original Message----- From: Loretta Guarino Reid [mailto:lorettaguarino@google.com] Sent: Tuesday, 11 March 2008 11:21 AM To: Roger Hudson Cc: public-comments-WCAG20@w3.org Subject: Your comments on WCAG 2.0 Last Call Working Draft of December, 2007 Dear Roger Hudson, Thank you for your comments on the 11 Dec 2007 Last Call Working Draft of the Web Content Accessibility Guidelines 2.0 (WCAG 2.0 http://www.w3.org/TR/2007/WD-WCAG20-20071211). The WCAG Working Group has reviewed all comments received on the December draft. Before we proceed to implementation, we would like to know whether we have understood your comments correctly and whether you are satisfied with our resolutions. Please review our resolutions for the following comments, and reply to us by 31 March 2008 at public-comments-wcag20@w3.org to say whether you accept them or to discuss additional concerns you have with our response. Note that this list is publicly archived. 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 10 March 2008 at http://www.w3.org/WAI/GL/WCAG20/WD-WCAG20-20080310/. Note that if you still strongly disagree with our resolution on an issue, you have the opportunity to file a formal objection (according to 3.3.2 of the W3C Process, at http://www.w3.org/2005/10/Process-20051014/policies.html#WGArchiveMinorityViews) to public-comments-wcag20@w3.org. Formal objections will be reviewed during the candidate recommendation transition meeting with the W3C Director, unless we can come to agreement with you on a resolution in advance of the meeting. 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: doing a little more for people with cognitive limitations Source: http://lists.w3.org/Archives/Public/public-comments-wcag20/2007Dec/0051.html (Issue ID: 2373) Status: VERIFIED / PARTIAL/OTHER ---------------------------- Original Comment: ---------------------------- Thanks for sending me the WG response to my response. I am sorry but I just don't understand how you are suggesting 1.1.1 offers any support for people with cognitive or learning difficulties. Guideline 1.1 and 1.1.1, from my reading of the latest last call draft, seem to explicitly relate to the provision of text alternatives for non-text content. What I was specifically concerned about were people who had a problem reading or comprehending complex pieces of text, not people who need text alternatives for non-text content for I feel they are adequately catered for in WCAG 1 and 2. Do I take from this comment, "we do not have any requirements on the quality of the alt-text because that would create the same kind of testability problem", that the Working Group is not going to be concerned about the quality of the actual text alternative for non text content? If so, why include the phrase "presents equivalent information"? Roger Roger Hudson Web Usability Ph: 02 9568 1535 Mb: 0405 320 014 Email: rhudson@usability.com.au Web: www.usability.com.au -----Original Message----- From: Loretta Guarino Reid [mailto:lorettaguarino@google.com] Sent: Wednesday, 12 December 2007 10:44 AM To: Roger Hudson Cc: public-comments-wcag20@w3.org Subject: Re: WCAG 2 response to WG response Yes the alt-text is a good comparison. And we do not have any requirements on the quality of the alt-text because that would create the same kind of testability problem. The only failure is the use of the same placeholder term on all graphics (since that is easy to reliably detect/test for). Please note that there are many provisions at Level A and Level AA that provide access for people with cognitive disabilities such as 1.1.1 that allows content to be read aloud or translated into symbols etc. In fact a majority of the provisions relate to issues that have been identified for one or another cognitive language or learning disability. We know that there are many other issues that we were not able to address. We have initiated an effort in conjunction with the Cognitive RERC on developing an application note on access to Web Pages by people with congnitive, language and learning disabilities that is more general, qualitative, and not bound by testability so that all guidance can be treated equally without levels or constraint due to the nature of the advice. Regards, Loretta Guarino Reid, WCAG WG Co-Chair Gregg Vanderheiden, WCAG WG Co-Chair Michael Cooper, WCAG WG Staff Contact --------------------------------------------- Response from Working Group: --------------------------------------------- SC 1.1.1 ensures that all text is machine readable. That allows the text to be translated into other forms to meet user needs. For people with cognitive, language and learning disabilities it allows the page to be read aloud, translated into a user's symbol system, or translated into a simpler form. In fact we were talking to language translation experts recently and they felt that this was a real possibility using current and emerging language translation technologies. Regarding the quality of alt text, we do not require that it be of high quality, but we do require that it be equivalent and we do provide clear examples of things that are not equivalent. ---------------------------------------------------------- Comment 2: Cognitive Support Source: http://lists.w3.org/Archives/Public/public-comments-wcag20/2008Jan/0013.html (Issue ID: 2389) Status: VERIFIED / PARTIAL/OTHER ---------------------------- Original Comment: ---------------------------- The previous two drafts generated 1,500 comments which according to the Working Group, "comprises a significant community contribution to the guidelines". Much of the response by the Working Group to these comments was in the form of additional clarifications and techniques in two non-normative documents that do not have the status of WCAG 2.0. WCAG 1.0 adopted a general position of offering guidance in the area of accessibility; whereas during the development of WCAG 2.0, it appears that a prime aim has been to prepare a document that is more akin to a "standard". Perhaps, this is best illustrated by the Working Group's determination that the value of a Success Criteria be determined by its testability, and in particular machine testability. Given this apparent move from offering guidance to providing a (machine) testable standard, it would seem likely that the normative components of WCAG 2.0 will be the main area of concern when determining legal liability or responsibility for ensuring web accessibility. It should be noted, that in regard to the definition of "normative" the WCAG 2.0 Glossary states, "Content identified as "informative" or "non-normative" is never required for conformance". I am concerned that many issues relating directly to people with cognitive, learning or language difficulties, which were raised in response to the previous two drafts of WCAG 2.0, are still not addressed in the core WCAG 2.0 document. In fact, I believe it could be argued that from a legal perspective WCAG 2.0 offers less rather than more protection or support than WCAG 1.0 for what is arguable the largest community of disabled people in many countries. Proposed Change: --------------------------------------------- Response from Working Group: --------------------------------------------- We do not believe WCAG 2 offers less *protection* for people with cognitive disabilities. While some provisions that might benefit some users are not included, WCAG 2 does not prohibit conforming Web sites from following such guidance, nor does it prohibit policies from adding additional guidance (where testability is not a concern). The additional resources provided are intended to support this. While it is true that WCAG 2.0 has an emphasis on testable criterion, it is not true that there is any bias toward machine testing except for a couple provisions like 'flash' where things happen too quickly to be evaluated well by humans. In fact almost all of the provisions require humans in testing. That said, it is true that the cognitive, language and learning areas are some of the most difficult to identify testable techniques for direct access. In WCAG 1.0, there were provisions like "Use the clearest and simplest language appropriate for a site's content," but in practice we found that the provision was largely ignored. The attempt in WCAG 2.0 was to create provisions that could be tested and that would be included when sites were tested. We have tried to include all of the qualitative guidance that we have received in the advisory techniques. We have also re-written the introduction to emphasize the importance of going beyond the testable SC and implementing as many of the sufficient and advisory techniques as possible. In addition, the WCAG WG has initiated an effort to develop an "application note" under the framework of WCAG 2.0 on access to Web Pages by people with cognitive, language and learning disabilities. The application note would include approaches that are more general, qualitative, and not bound by testability, so that all guidance can be treated equally without levels or constraint due to the nature of the advice. This effort will include the Cognitive Rehabilitation Engineering Research Center which focuses on cognitive disabilities, and we welcome additional participation. The WAI continues to be interested and committed to developing guidance to address Web accessibility needs in the broad area of cognitive disabilities, and will continue to explore this area through our other WAI 2.0 guidelines, research discussions, and in potential future guidelines development. It is hopeful to note that assistive technologies for people with cognitive disabilities, including free open source technologies, are on the horizon. A large number of the provisions in WCAG 2.0 are designed to provide the information needed by these new and emerging technologies. The group feels that WCAG 2.0 has more enforceable provisions that deal with cognitive language and learning disabilities than WCAG 1.0. Still, the guidelines point out clearly that WCAG 2.0 is not enough for these groups and that more work is needed and that Web authors need to look beyond WCAG for all disabilities but particularly for users with cognitive language and learning disabilities. --------------------------------------------------- Comment on WG Response --------------------------------------------------- I agree with the WG that many people ignored the WCAG 1.0, provision "Use the clearest and simplest language appropriate for a site's content. (14.1)". But I for one, did take it seriously. At the risk of repeating myself, I would like to briefly outline a case just last year. A large government department (who recognise that over 30% of their clients are functionally illiterate), recently asked me to assess a site designed to provide information to their clients. The information was all text based, often using quite complex language. When I suggested they include a short Flash animation to communicate the same basic information to those who might have a problem reading all this text they responded, we have to make our sites Priority 1 and Priority 2 compliant and this would be very difficult to do if we include Flash. I then drew their attention to WCAG 1.0 – CP 14.1 (P1) and 14.3 (P3) and advised them to include the Flash so that their site was both more accessible and more inline with the intentions of WCAG. They agreed to do so, but I think this was only because I was able to show them that there was a Priority 1 requirement to make something understandable and if this was not possible provide some form of alternative. What I want to know; where in the normative part of WCAG 2.0 is there anything similar? With reference to this response: "The group feels that WCAG 2.0 has more enforceable provisions that deal with cognitive language and learning disabilities than WCAG 1.0." SC 3.1.5 – Reading Level, which is at AAA, does offer some support for people with reading difficulties, but are there any other enforceable provisions that are at A or AA level? I fully support the good intentions and long term hopes of the WG but I wanted to see was a little more muscle in the normative document. I am intrigued by the notion that it is acceptable to remove a provision because in the view of the WG, "in practice we found that the provision was largely ignored". I will return to this point later. ---------------------------------------------------------- Comment 3: accessibility of social networking site content Source: http://lists.w3.org/Archives/Public/public-comments-wcag20/2008Jan/0014.html (Issue ID: 2390) Status: VERIFIED / PARTIAL/OTHER ---------------------------- Original Comment: ---------------------------- During the last few years, there has been an explosion in the use of social networking sites like Flickr, Youtube and Myspace and it is not clear how WCAG relates to all this new content on the web. Much of the content on these social networking sites does not comply with WCAG. It is probably unreasonable to expect all the users of these sites to be aware of what is required to make their contributions accessible and unrealistic to assume that they will have the desire to do so. When it comes to the accessibility of social networking sites, maybe we should look more at the processes that allow people to put material on the web, rather than the final content. That is, everyone should have the opportunity to participate, for example the process should allow a blind person as well as a person with cognitive limitations to set up a blog or a myspace page or put photos up onto Flickr, and then make this material available to as wider audience as they wish. The applications (tools) should encourage the users of these sites to include accessibility features. But if they don't, the application should degrade gracefully so that the resulting content does not cause problems for assistive technology users and wherever possible provides some basic text alternatives derived from the titles or descriptions provided by the person uploading the content. Proposed Change: The issue of the accessibility of user-generated content on social networking sites should be directly addressed in WCAG. In particular, there should be guidance about who is responsible for ensuring the content of these sites is accessible and how this could be best achieved. --------------------------------------------- Response from Working Group: --------------------------------------------- WCAG describes the properties of a conforming web page, not the process used to generate the web page. Because there is a mix of authors on social networking web pages, with the users becoming authors of parts of their own pages, they are examples of Web pages which may only be able to make a statement of partial conformance. (http://www.w3.org/WAI/GL/WCAG20/#conformance-partial) The Web site authors make the standard portions of the Web pages conform to WCAG 2 but they cannot make the full page conform without monitoring it and fixing any non-conforming content. Those pages would have to be excluded from a claim of conformance but could state that they would conform if all contributed content is excluded. Since such sites are often authoring tools, they should be encouraged to meet the Authoring Tool Accessibility Guidelines, as well. ------------------------------------------------------ Comment on WG response ------------------------------------------------------ There is a vast and rapidly increasing amount of content on social networking sites and nearly all of it is inaccessible. With my comment, all I was trying to suggest is that the new WGAG should recognise this fact and make some suggestions about how to improve the situation. Dismissing this as a "process" issue doesn't make it go away. WCAG 1.0 failed to come to grips with non-W3C format material and we know where that led, what will happen if the W3C fails to come to grips with this recent phenomenon? I feel that in a practical sense, when it comes to the accessibility of web content there is a qualitative and quantitative difference between the content of a social networking site like Myspace, and a site from for example a government department with information that could be critically important to all web users, including those with disabilities. To return to the Working Group belief that it is acceptable to remove a provision that is "largely ignored", what happens with WCAG if, for example the majority of new web content, totally ignores all the WCAG provisions? ---------------------------------------------------------- Comment 4: meaningful and logical sequence Source: http://lists.w3.org/Archives/Public/public-comments-wcag20/2008Jan/0015.html (Issue ID: 2391) Status: VERIFIED / NOT ACCEPTED ---------------------------- Original Comment: ---------------------------- The actual wording of this Criterion appears to relate only to the need for a "correct reading sequence" to be programmatically determined. No definition is provided for what is meant by "correct reading sequence" and the Understanding SC 1.3.2 document appears to be primarily concerned with ensuring assistive technologies do not distort the presentation of material in such a way as to confuse the users of these technologies. I feel that it is also important for material to be presented in a logical and clear way, particularly for people with cognitive and learning disabilities. Of course, I recognise it is not possible to determine if something is "logical" with a machine; however I believe it is very possible for human testers to reliably determine when the sequence of content or information is not meaningful or logical. SC 1.3.2 should be rewritten so that it is also able to provide some assistance to people with cognitive limitation, see following example; Proposed Change: 1.3.2 Meaningful Sequence: When the sequence in which content is presented affects its meaning, the reading order of the material is logical and a correct reading sequence can be programmatically determined. (Level A) --------------------------------------------- Response from Working Group: --------------------------------------------- A correct reading order will be one in which the words of a sentence are in order and the sentences of a paragraph are in order. That is, the order of the words in the sequence cannot be changed without affecting its meaning. The working group has considered the use of "logical" in various success criteria in the past, and has come to the conclusion that it is not testable. In this case, the current explanation of correct reading order captures the property that human testers would find agreement about. We recognize that there are additional requirements related to how information is organized that affects people with some cognitive and learning disabilities. However, we have not been able to develop success criterion for determining when the content has been organized in a way that addresses those requirements. ---------------------------------------------- Comment on WG response --------------------------------------------- It would be useful to include your definition of correct reading order in the Glossary, which is normative: "A correct reading order will be one in which the words of a sentence are in order and the sentences of a paragraph are in order. That is, the order of the words in the sequence cannot be changed without affecting its meaning." ---------------------------------------------------------- Comment 5: meaning of accessibility supported unclear Source: http://lists.w3.org/Archives/Public/public-comments-wcag20/2008Jan/0016.html (Issue ID: 2392) Status: VERIFIED / PARTIAL/OTHER ---------------------------- Original Comment: ---------------------------- The whole issue of "accessibility supported" evolved from the concept of "Baseline" which was widely misunderstood and/or incomprehensible by many people. Unfortunately I don't find "accessibility support" much clearer. The definitions and descriptions of "accessibility supported", which are provided in the WCAG 2.0 and "Understanding Accessibility Supported" documents, and the implications for web pages, I find difficult to understand. Does the issue of "accessibility supported technologies" only come into play if someone wishes to make a formal claim for conformance? Or, does it also relate a more general determination of whether or not a web page conforms to a particular Success Criterion? If so, who will be responsible for determining the supported technologies? When a regulator or court is asked to determine if a web site is inaccessible, is it the expectation of the Working Group that the guidelines for determining if a technology is accessibility supported will be taken into consideration? It seems to me that the information about "accessibility supported technologies" in the WCAG document body and Glossary raises a number of issues or questions including: 1. The document talks about a technology being able to support accessibility but it does not appear to mention the implementation of that technology. For example, Flash, AJAX, PDF that are well made can be accessible, but poorly implemented are totally inaccessible. Is it sufficient to use an "accessibility supported technology" or should the use of that technology be accessible? 2. The Working Group and W3C don't see the need to specify "which or how many assistive technologies must support a Web technology in order for it to be classified as accessibility supported". Point 2 in the Glossary says, "The web content technology must have accessibility-supported user agents that are available to users". Does this mean that a content technology can be considered accessible so long as a version of user-agent that supports that content technology is available in the market place regardless of the price of the user-agent or how many people use it? 3. In my opinion, Point 2d in the Glossary is pretty worthless. Charging someone with a disability more for a user agent (assistive technology) than you would charge a non-disabled person is not really the point and many countries have discrimination or trade laws that would already cover this situation. Surely, the key issue is the additional cost of accessing a web service that someone who is dependant on an assistive technology needs to pay when compared to someone who can access the same service without requiring an assistive technology. Given that only one of the four conditions in Point 2 needs to be true, Point 2d appears to be the ultimate escape clause under the guise of offering protection and needs to be rewritten. Obviously, assistive technology manufacturers shouldn't be asked to provide their products without charge. However, I believe it is equally obvious that making available a 1 million dollar tool that is priced the same for everyone, but is only essential for a person with a disability who wants to access a specific service, is not an equitable or fair solution. I fully recognise that my interpretation of the meaning and intent of "accessibility supported" maybe wrong, and if that is the case I apologise for my mistake. But if I am wrong, then it is likely others may experience problems understanding this. Proposed Change: The Working Group should consider re-writing the information relating to "accessibility supported" with the aim of providing greater clarity. --------------------------------------------- Response from Working Group: --------------------------------------------- You raise a number of questions. Lets look at them in turn. RE your numbered questions: 1) It is necessary that conforming content both use techniques that satisfy the success criteria, and that those techniques are implemented using technologies that are supported by user agents and assistive technology. One of the conformance requirements is that the success criteria must be met using accessibility supported technologies. However if one uses accessibility supported technologies - but does not use them properly then the SC would not be met (and of course conformance could not be be claimed for levels that include that SC). In the cases you specified, the content would fail the SC so just using an accessibility-supported technology but not using it properly would not be adequate to claim conformance. Note that HTML done poorly would also fail the SC. 2) The working group recognizes that the need for information on which technologies are 'accessibility-supported' is important to use of the guidelines. Such data can only come from testing different versions of user agents and assistive technology and recording whether the features of the technology are supported. We expect that this information may need to be compiled from multiple sources. WAI will be working with others to establish an approach for collecting information on the accessibility support of various technologies by different user agents and assistive technologies. WCAG 2.0 is still in development. We expect that during Candidate Recommendation period we will have some initial information on accessibility supported technologies, to demonstrate how this approach will work once WCAG 2.0 becomes a W3C Recommendation. The Candidate Recommendation process itself requires that there be examples that demonstrate conformance. So there will certainly be some information about accessibility supported technologies in order to get out of the candidate recommendation stage for WCAG 2.0. 3) The first three items in part 2 (of the definition) that you cite all involve the person with a disability using the same technology as everyone else. So the problem of a person with a disability paying more would not arise. The only reason that the language was required in part (d) was that (d) allowed for a special version of a plug in. For example, at one time the standard PDF plug in was not accessible. Instead, a special version that was accessible was provided. According to (d) that one had to be as easy to find and not cost any more than the standard one. Today, the standard PDF plug in is accessible so it would fall under (b). If you read (d) carefully it says that the tools that the person with a disability must use cannot cost more than the mainstream tools. So other than people who must use AT (and must pay for the AT) there cannot be additional 'services' that are required that cost more than the services used by people without disabilities. Other questions you raised: Question: "Does the issue of "accessibility supported technologies" only come into play if someone wishes to make a formal claim for conformance? Or, does it also relate a more general determination of whether or not a web page conforms to a particular Success Criterion? " Answer: It relates to conformance, regardless of whether a claim is made or not. Question: "If so, who will be responsible for determining the supported technologies?" Answer: The author is responsible. They may rely on lists provided to them by others (the field, their company, a customer, etc.) Question: "When a regulator or court is asked to determine if a web site is inaccessible, is it the expectation of the Working Group that the guidelines for determining if a technology is accessibility supported will be taken into consideration?" Answer: Yes. If the regulation or court is using WCAG 2.0 as a reference they would usually use (and should use) all the normative aspects of WCAG 2.0. What regulators or courts actually do, though, is up to them. -------------------------------------------------- Comment on WG comment ------------------------------------------------- I guess we are just going to have to wait and see how this pans out during the Candidate phase. I am afraid that without clearer guidelines in regard to what can be deemed to be accessibility supported, and if as you indicate, "The author is responsible" for determining if a technology is accessibility supported, this notion will make it harder for governments to legislate/regulate for accessibility. Without clear guidelines, I believe there is a real risk that entities will be able to play the jurisdictional game in order to avoid their responsibilities in the area of accessibility. ---------------------------------------------------------- Comment 6: Media exemption to 1.1.1 Source: http://lists.w3.org/Archives/Public/public-comments-wcag20/2008Jan/0017.html (Issue ID: 2393) Status: VERIFIED / PARTIAL/OTHER ---------------------------- Original Comment: ---------------------------- I don't fully understand the intention of the "media" exemption to the requirement to provide a text alternative for all non-text content under SC 1.1.1. I assume it is an attempt to accommodate the increasing presentation of audio and video material on the web by media not traditionally associated with the web; and, the need to balance the accessibility implications of this use with a desire to have guidelines that don't impose undue hardship on web proprietors or stifle the development of the web. The terminology used for the Media related exemption is potentially ambiguous in the context of the broadcast industry. In particular, it appears to address just two distinctly different programming formats, "live" and "prerecorded", without providing adequate definitions for either. The WCAG 2.0 Glossary defines the term "live audio-only" as "a time-based live presentation that contains only audio" and a very similar definition is provided for "live video-only". While these definitions might be adequate for a sports broadcast or the coverage of an unfolding news event, they do no appear to be sufficient for many of the situations faced by the broadcast media today. The current definitions of live audio-only and live video-only need to be expanded in order to meet the real-world needs of the media. The phrase 'time-based' is not very meaningful since within the broadcast industry all material could be said to be time-based. The proposed Media exemption does not recognise that sometimes a media broadcast (program) might be an amalgam of live and prerecorded material. For example, daily live radio programs often contain prerecorded segments: In some cases differences in time-zones or the schedule of the interviewee require an interview that is presented live to be prerecorded; or a live program may incorporate prerecorded documentary-style feature segments. With regard to television, it is not uncommon to have programs that are presented as live, but which in fact consist entirely of prerecorded segments with the only live component being the studio presenter who tops and tails them, and in some cases even this is prerecorded. Also, the broadcast of live-to-air (real-time) programs that contain absolutely no prerecorded material is becoming increasingly rare; even sports broadcasts often now contain prerecorded comments from the players. It should be noted, the Guidelines indicate use of "prerecorded" audio and video "files" is covered by SC1.1.1, but no definitions are provided for the words "prerecorded" and "files". Does a prerecorded interview with a player that is stored as an audio file require a text alternative within the context of the WCAG 2.0? Or, should it be treated as being part of a live audio or video presentation and so require only a descriptive label? The increasing convergence of media is resulting in more and more radio and television broadcast material now being presented over the web in a variety of ways. For example, ABC Radio National in Australia produces live and prerecorded programs and simultaneously "streams" all them over the internet at the time of broadcast. 95% of these programs are also available as "streamed media on demand", which means they can be listened to (but not downloaded) at a different time. In addition, over 50 of the daily or weekly programs are available for download as MP3 or Podcast files. These are primarily word based (non-music) information style programs. I understand the national broadcasters in Canada and the UK do something very similar. The presentation of steamed media on demand and podcasts on websites may further complicate the distinction between live and prerecorded content. This material, by its very nature, is not live in the sense that it is a recording of something that has happened at sometime in the past. In some cases however, it might be a recording of a live-to-air program and as such may be considered an alternative presentation of the initial program and so exempt from the need to provide a text alternative; this assumes the initial program is a live-only program within the meaning SC1.1.1. >From a practical point of view, it might be useful to consider making a distinction between 'scripted' and 'non-scripted' content since any requirement to provide a text alternative for a scripted program is likely to be less onerous. However, this should not mean that 'non-scripted' material with historical value (e.g. an interview with someone concerning a significant world event) is exempt from the requirement to provide a text alternative when it is being presented on the web for posterity. Is the intention of the Media exemption to SC 1.1.1, and the associated definition, to exempt only live-to-air material from the need to provide a text alternative? And consequently, require all prerecorded material that is contained in a television or radio program to have a text alternative when it is presented on the web. If so, the considerable difficulties most broadcasters will experience in meeting such a demand is likely to lead to it being generally ignored. And, a general refusal by the broadcast industry to conform to a Level A Success Criterion could undermine the status of WCAG. Proposed Change: The Glossary should contain definitions for the terms "live" and "prerecorded" that relate to the current status of the broadcast industry and are likely to be meaningful to people working in the broadcast industry. The Working Group should consider providing greater flexibility in the Media exemption to SC 1.1.1, while still retaining the overall desire for text alternatives to be provided for television and radio broadcast material that is re-presented on the web. The Working Group might like to consider extending the Media exemption to allow programs that are presented in "real-time" (e.g. daily radio shows, sports broadcasts, current affairs tv) to contain a percentage of "prerecorded" material (e.g. 25%) without the need to provide a transcript for that material. The Working Group might like to consider incorporating a time-dimension into the Media exemption for SC 1.1.1. For example, a text alternative for non-text content should be provided within 14 days. This would allow broadcasters sufficient time to prepare text alternatives for substantial programs and would enable them to continue to provide "streamed media on demand" for 14 days without the need to include a text alternative. --------------------------------------------- Response from Working Group: --------------------------------------------- Answering your questions in turn: 1) No - the media exemption is not in response to any mainstream use of media. It is meant for media alternatives to what is already on the page where the media alternatives are provided for accessibility reasons. This is defined if you click the link for the phrase "media alternative for text" in the provision. (note we changed "alternative for text" to "media alternative for text" in the provision) 2) Regarding terminology - we have now defined "live" and "prerecorded". These new definitions should address your 'sports' and 'unfolding news event' question as well. 3) Correct. All broadcast streaming material would be time based. 4) We have reworded the 1.2 success criteria to remove the ambiguity. If there is mixed live and prerecorded, each follows the guideline for its type of media. Although not required, it would of course be preferred if the mixed media were to follow the more accessible "prerecorded" rules. 5) With regard to 14 day exemptions and the like, those types of rules are outside of the scope of WCAG. WCAG is like a measuring stick. It is used to measure the level of accessibility but not to state where different levels should be applied. ------------------------------------------------ Comment on WG response ------------------------------------------------ I apologise if I misunderstood the intention of the "Media, Test, Sensory" exemption provided in the December 07 Draft. However, I would like the WG to address the issue of the increasing use of the web to provide audio and video content that is a mix of live and pre-recorded material. As with my response to Comment 3, we just can't pretend it doesn't happen. Look at the website of any major broadcaster and you will see many examples of what I described. Based on your responses to my comments, I assume this must covered by Guideline 1.2. While it is nice to see definitions of "live" and "pre-recorded", they are very brief and I don't believe they address the fundamental issues I raised. With the exception of streamed media, nearly all the broadcast material that different broadcasters make available on the web is in essence pre-recorded before it goes on the web, this is the nature of the process. It is unrealistic to assume broadcasters are going to make transcripts of all this material simultaneously available. When I suggested the WG might look at providing some sort of time frame with reference to the need to provide text alternative for video/audio material, the Working Group responded, "Those types of rules are outside of the scope of WCAG. WCAG is like a measuring stick. It is used to measure the level of accessibility but not to state where different levels should be applied." I find it hard to reconcile this response with the WG willingness to precisely define the amount of screen that can flash at a "typical viewing distance" when determining the general flash and red flash thresholds: - Is this not indicating where different levels should be applied? To return to the Working Group belief that it is acceptable to remove a provision that is "largely ignored", what happens with WCAG if, for example many, or all, of the main media organisations in the world, feel that complying with WCAG is just not a realistic options. As I said in my original comment, "a general refusal by the broadcast industry to conform to a Level A Success Criterion could undermine the status of WCAG." ---------------------------------------------------------- Comment 7: Provide no keyboard trap information in context Source: http://lists.w3.org/Archives/Public/public-comments-wcag20/2008Jan/0018.html (Issue ID: 2394) Status: VERIFIED / NOT ACCEPTED ---------------------------- Original Comment: ---------------------------- In cases where moving focus away from a component with the keyboard is relatively complex, this criterion requires users to be advised of a method for doing this. However, neither the Success Criterion nor the How to Meet and Understanding documents appear to suggest where or how this advice should be provided. It would seem to be most appropriate to offer the advice within the context of the component and in my view providing the advice on a generic accessibility information page would not be adequate. Proposed Change: Success Criterion rewritten as follows: 2.1.2 No Keyboard Trap: If keyboard focus can be moved to a component of the page using a keyboard interface, then focus can be moved away from that component using only a keyboard interface, and, if moving focus away requires more than unmodified arrow or tab keys, a mechanism is provided in conjunction with the component to advise users how to move focus away. (Level A) --------------------------------------------- Response from Working Group: --------------------------------------------- We have purposely not specified in the SC where the instructions would need to be provided. It may be on the page. Or, for an application, the instructions may appear at the front pages rather than being repeated on hundreds of pages that are essentially identical in operation, but gather different data. ---------------------------------------------------------- Comment 8: Essential Exception Source: http://lists.w3.org/Archives/Public/public-comments-wcag20/2008Jan/0019.html (Issue ID: 2395) Status: VERIFIED / PARTIAL/OTHER ---------------------------- Original Comment: ---------------------------- When it comes to time limits the Criterion requires at least one of a number of conditions to be true. These include, "Essential Exception: the time limit cannot be extended without invalidating the activity." There appears to be no additional definition of what constitutes "essential" or advice on interpreting this condition. As it stands, it appears that it would be possible to declare that any event maybe deemed to be invalidated by extending the time-limit. Proposed Change: The Working Group consider removing "Essential Exception" since it would appear that all likely essential exceptions would already be covered by the "Real-time Exception" condition. If this is not possible, the Working Group should provide a precise indication (with example) of what constitutes an Essential Exception. Received on Tuesday, 22 January 2008 00:40 --------------------------------------------- Response from Working Group: --------------------------------------------- We have added a definition of essential that reads: essential if removed, would fundamentally change the information or functionality of the content, and information and functionality can not be achieved in another way that would conform ---------------------------------------------------------- Comment 9: Changing SC for re-authentication after time limit expiration Source: http://lists.w3.org/Archives/Public/public-comments-wcag20/2008Jan/0020.html (Issue ID: 2396) Status: VERIFIED / NOT ACCEPTED ---------------------------- Original Comment: ---------------------------- Time limits can present problems for many people with disabilities and these problems can be greatly exacerbated when a session expires and data is lost. Currently this is a Level AAA Criterion. Although moving this up to Level AA has been rejected before by the Working Group, I don't believe the explanation offered in Point 2.2.6 of the Issues and Changes Summary document is sufficient to justify keeping this Criterion at Level AAA. Proposed Change: Move SC 2.2.5 Re-authenticating up to Level AA. --------------------------------------------- Response from Working Group: --------------------------------------------- Our apologies. In trying to keep the changes document short, we shortened some of our rationales. Here is the full rationale for not changing the level: The working group has discussed this issue at length. The criteria for having something at Level AA is that it must be something that can reasonably be applied to all Web content. But there are valid reasons, such as financial security or personal information where this cannot be done because it is against regulations to preserve any of this information once a session expires or is terminated. Also, this success criterion requires control of the server that may not be possible for some authors and technologies. It is also a new success criterion in WCAG 2.0 and there is little if any experience with the requirement and the solutions. For these reasons, the Working Group decided to put this requirement at Level AAA. ---------------------------------------------------------- Comment 10: Change SC level for flashing content Source: http://lists.w3.org/Archives/Public/public-comments-wcag20/2008Jan/0021.html (Issue ID: 2397) Status: VERIFIED / NOT ACCEPTED ---------------------------- Original Comment: ---------------------------- Guideline 2.3.2, which relates to flashing content that is known to cause seizures, contains two Success Criteria. The first, which is at Level A, requires web pages to have no content that flashes more than three times in one second or the flash is below defined "general flash and red flash thresholds". The second criterion, which is at Level AAA, requires web pages not to contain anything that flashes more than three times a second. When it comes to determining the "general flash and red flash thresholds" the amount of screen that the flashing content can occupy is precisely defined in one sense, however there appears to be an assumption that typical viewing involves a display area of 1028 x 768 pixels and a viewing distance of 56-66 cm. The Understanding SC 2.3.1 document does not appear to provide any advice or examples for meeting the needs of users with impaired vision who do not conform to these typical viewing conditions. For screen magnifier users it is not uncommon for the entire display area to occupy less than 25% of a typical 1028 x 768 screen. Also, the field of view for people with tunnel vision or other vision impairments is often very different to the "typical". For these people, the combined area of flashing content that is deemed acceptable under the "general flash and red flash thresholds" may well be excessive. Given that Guideline 2.3 recognises certain flashing content is a known to cause seizures, I believe WCAG 2.0 should provide greater support for people with impaired vision who might also be at risk of seizures, and give greater guidance to developers in how to minimise this risk. Proposed Change: Move SC 2.3.2 Three Flashes up to Level AA. --------------------------------------------- Response from Working Group: --------------------------------------------- Success Criterion 2.3.2 bans many things including video of natural phenomenon (e.g. lightning strikes) common video occurrences (sun shining through a row of trees) and some movie effects (any machine gun) even if they are small or muted. As such, it is quite restrictive of content. The group did not feel that it should be at level AA. -------------------------------------- Comment on WG response ------------------------------------- I wasn't aware SC 2.3.2 was intended to ban natural phenomenon, but since you have brought this to my attention, I feel that it is rather absurd to have a W3C Recommendation that bans video of natural phenomenon like lightning strikes from being presented on the web. This is hardly likely to gain the ringing endorsement of the scientific community. As to my general request for greater consideration to be given to people who do not conform to "typical viewing" parameters, I accept that the WG is not open for movement on this issue. With reference to your point about common video occurrences and some movie effects, I will venture to suggest that sites with moving images of the "sun shining through a row of trees" or "machine gun" fire are out-numbered by orders of magnitude by sites with tacky flashing stars, smiling graphics or advertisements. Maybe the WG response to my comment says more about the composition and social/cultural tastes of the Working Group than it does about improving the web experience for people with impaired vision who are at risk of seizures. ---------------------------------------------------------- Comment 11: labels and headings definition not sufficient Source: http://lists.w3.org/Archives/Public/public-comments-wcag20/2008Jan/0022.html (Issue ID: 2398) Status: VERIFIED / ACCEPTED ---------------------------- Original Comment: ---------------------------- The text of this criterion is, "Labels and headings are descriptive. (Level AA)." This definition is too short and does not sufficiently describe the intent of the criterion. Proposed Change: The Working Group should consider rewriting SC 2.4.6. For example; 2.4.6 Descriptive Labels and Headings: Labels and headings are descriptive and allow the relationships between the different sections of web page content to be easily determined. (Level AA) --------------------------------------------- Response from Working Group: --------------------------------------------- We have clarified SC 2.4.6 to read: "2.4.6 Labels Descriptive: Headings and labels describe topic or purpose." We have added the following sentences to Understanding 2.4.6 "Labels and headings do not need to be lengthy. A word or even a single character may suffice if it provides an appropriate cue to finding and navigating content." ---------------------------------------------------------- Comment 12: provide greater support for people with cognitive, language or reading difficulties Source: http://lists.w3.org/Archives/Public/public-comments-wcag20/2008Jan/0023.html (Issue ID: 2399) Status: VERIFIED / NOT ACCEPTED ---------------------------- Original Comment: ---------------------------- Like many others, I have argued in the past that WCAG 2.0 does not provide sufficient formal recognition of the importance of meeting the needs of people with cognitive, learning or language limitations. I believe this is still the case with the current Last Call Draft. Given the Working Group's obsession with testability when it relates to Success Criteria concerned with cognitive and learning difficulties (a requirement that does not appear to be so fervently demanded when it comes to other disabilities), I recognise that the Working Group is never going to accept a general notion that web content should use clear and simple language that is appropriate to the needs of the audience (similar to WCAG 1.0 â€" 14.1). However, within Guideline 3.1, I feel that more should be done to help ensure that people with cognitive, learning or language difficulties are able to access web content which can directly affect their health and liberty. The "Understanding SC 1.2.1 Captions" document appears to recognise that at least some "legal documents" and "instructional manuals" might need to contain non-text synchronised media in order to assist comprehension, however there is no explicit requirement to include this material. While the issue of ensuring text equivalents are provided for non-text content is well catered for in WCAG 2.0, very little is done to ensure assistance is provided for web users who have difficulties reading or interpreting text. The following suggested Success Criterion draws on the apparent acknowledgement in SC 3.3.4 that, with some web content the potential consequences of inaccessibility are greater. Even though I am not comfortable with the idea of associating cognitive, learning and language difficulties with reading ability, the suggested criterion uses the readability of "lower secondary education level" as a yardstick since it appears that this provides a degree of testability that is acceptable to the Working Group. Proposed Change: The Working Group should consider including the following new Level A Success Criterion for Guideline 3.1: 3.1.* Understandable (Legal, Financial, Health): For Web pages that provide legal, financial and health instructions, warnings or regulations that are essential for the preservation of the individual's health and liberty, at least one of the following is true: (Level A) 1. Readable: The text does not require a reading ability more advanced than lower secondary education level. 2. Text alternative: An alternative simple language version with equivalent information that does not require a reading ability more advanced than lower secondary education level is also provided. 3. Non-text alternative: An alternative non-text version (for example audio or video) that contains equivalent information is also provided. --------------------------------------------- Response from Working Group: --------------------------------------------- We looked at this very carefully but the working group does not feel that it can require that legal documents, for example, can be required to be easy to read. There are many reasons for the language used in these types of documents. Also it is often not legal to have an alternate form of the document that a person would read that is different from what they are agreeing to. Regarding the audio form, we do require at level A that all documents have a text form that is readable by assistive technologies. There are also free utilities on the web and built into popular operating systems that will read a text document aloud.
Received on Monday, 24 March 2008 14:20:50 UTC