[COMMENTS] Website Accessibility Conformance Evaluation Methodology (WCAG-EM) 1.0

Dear team,

Thanks for publishing these in-draft guidelines; it does give a good feel
for an approach to testing accessibility.

I began my research into web accessibility in 2003/2004 whilst an
undergraduate at Durham University. I worked closely with the university's
disability department, and employed the services of some of its members
(inc. disabled users) to test a website I built to model my research.

Below are my comments with respect to the published guidelines.

1. Greater intimacy with target audience

STEP 2 discusses the target website; I feel this should also include a
sample of the target audience. Websites are built with an audience in mind,
and it is my view that a sample of that audience should be invited to test
the product continuously.

2. Have text only

Those with disabilities, particular visual impairments, care not for
graphics or presentation. Testing should also include the option to
completely switch off layout and images, and have content linear to improve
navigation, e.g. if it's made a best practice to left-align all links and
texts, then a user can move the cursors to the left of the page and as they
move down the screen reader will pick up each link and paragraph.

3. Cross-browser compatibility

Many corporations still run legacy versions of web browsers. Backwards
compatibility with modern web technologies may impact meeting WCAG 2.0
guidelines. Additionally, cross-browser accessibility for a website can be
problematic. Therefore, I do recommend testing guidelines include testing
across multiple desktop/mobile browsers. In STEP 3, I would recommend
testing the pages across multiple browsers.

4. Set minimum criteria

The recommendation for 'AA' rating is a great baseline. I do feel through
the evaluation process, there should be continuous feedback. In STEP 5, I
do feel the report should identify 'recommendations for improvement' on
which the developer/s can re-work the solution. Additionally, with my first
point ('greater intimacy with target audience'), document if any disabled
testers were used to evaluate the product - it does not need to include the
disabled testers name, only there disability (and document observations
through questionnaires post testing).

In closing, I would like to support the W3C on it's work with
accessibility. If I can support you, or your team in any way please do
reach out.

I'm a consultant within Accenture's Digital practice, having previously
worked at IBM and advised on web accessibility to a large government
account. One of my colleagues from IBM, Bill Curtis-Davidson, will I hope
have a few good words to say about me.

Many thanks,
Sham