Re: CFC - Update WCAG 3 Working Draft (Corrected)

-1

The basis of my objection at this time is the fact that this Working
Group *STILL
*has not addressed FPWD industry feedback related to subjective testing -
feedback that is now over 2 years old:

   - https://github.com/w3c/silver/labels/section%3A%20scoring,
   - https://github.com/w3c/silver/labels/section%3A%20conformance

I will cite one example here:

*"Gregg Vanderheiden expounded in his review on the serious problems that
the current draft imposes on conformance testing and test reproducibility.
We agree with Vanderheiden’s observation: Qualitative scoring cannot be
used for conformance testing; a test must comprise criteria that either
fail or pass if said criteria are to be employed in any legislative manner.
Otherwise, two testers may produce altogether different results, which is
unacceptable for WCAG in its present role in European legislation."*
(WCAG 3 comments_Siteimprove_Codebusters_April7_2021.docx
<https://github.com/w3c/silver/files/6281581/WCAG.3.comments_Siteimprove_Codebusters_April7_2021.docx>
linked
at https://github.com/w3c/silver/issues/508)


Meanwhile, the current draft continues to state:

*"Qualitative tests: Tests that rely on a qualitative evaluation based on
existing criteria. Test results may vary between testers who understand the
criteria." *

I strongly object to updating the Editors Draft while also ignoring
critical feedback this Working Group has sat on for more than 2 years; we
are ignoring a serious if not critical concern - if the final WCAG 3 cannot
be rigorously and accurately/consistently tested, legislators will likely
NOT adopt it (or so suggests multiple industry comments received but not
substantively responded to).

And we all know the sad reality is that without the iron fist, it doesn't
matter how beautiful, robust or "complete" the velvet glove is. (ref:
https://idioms.thefreedictionary.com/an+iron+fist+in+a+velvet+glove)

JF



On Tue, Jul 18, 2023 at 8:55 AM Shawn Lauriat <lauriat@google.com> wrote:

> +1
>
> On Tue, Jul 18, 2023 at 8:38 AM Sarah Horton <sarah.horton@gmail.com>
> wrote:
>
>> +1
>>
>> Sarah Horton (she/her)
>> sarah.horton@gmail.com
>>
>> On Jul 17, 2023, at 1:46 PM, Bradley Montgomery, Rachael L <
>> rmontgomery@loc.gov> wrote:
>>
>> My apologies. This sent before it was finished. Please respond to the
>> copy below.
>>
>> Call For Consensus — ends Thursday July 21st at 2pm Boston time.
>>
>>
>> We previously agreed update the WCAG 3 Working Draft from the Editor's
>> Draft <https://w3c.github.io/silver/guidelines/>. (May 2nd Resolution
>> <https://www.w3.org/2023/05/02-ag-minutes.html#resolution01>)
>>
>> Our pre-cfc email
>> <https://lists.w3.org/Archives/Public/w3c-wai-gl/2023JulSep/0005.html> did
>> raise any additional concerns.
>>
>> If you have concerns about this proposed consensus position that have not
>> been discussed already and feel that those concerns result in you “not
>> being able to live with” this decision, please let the group know before the
>>  CfC deadline.
>>
>>
>> Kind regards,
>>
>>
>> Rachael
>>
>>
>>

-- 
*John Foliot* |
Senior Industry Specialist, Digital Accessibility |
W3C Accessibility Standards Contributor |

"I made this so long because I did not have time to make it shorter." -
Pascal "links go places, buttons do things"