- From: Loïc Martínez Normand <loic@fi.upm.es>
- Date: Mon, 15 Apr 2013 23:41:42 +0200
- To: public-wcag-em-comments@w3.org
- Message-ID: <CAJpUyz=GzPGqHOpPRu-9ubc_QLd_jYqC-j9gwBiHoGvQsFwNLw@mail.gmail.com>
Dear members of the WCAG 2.0 Evaluation Methodology Task Force (Eval TF). In the last weeks I've been reviewing the latest draft (26 February 2013) of the Website Accessibility Conformance Evaluation Methodology (WCAG-EM) 1.0. In this message I provide all my detailed comments, structured according to the table of contents of WCAG-EM. Before my detailed comments I would like to raise several issues: - The TF has done an incredible amount of work to prepare the current draft of WCAG-EM and I haven't had as much time as I would have liked to for preparing my comments, so some of them may look rude. My apologies in advance. - You already know that I'm an observer of the Eval TF. Don't hesitate to ask me about any clarification about my comments. They may be too cryptic in some cases.I will do my best to reply to your questions. - It is highly probable that my comments will raise issues where you already have reached consensus. It is not my intention to reopen debates or break that consensus. My detailed comments are below. Best regards, Loïc *Introduction* (http://www.w3.org/TR/WCAG-EM/#introduction) - *Terms and definitions* (http://www.w3.org/TR/WCAG-EM/#terms) - - *Complete processes*. First, I think it should be singular (complete process). In addition, the current text is not a definition as it just quotes text from WCAG 2.0. I suggest the following text as definition: "Complete process: sequence of steps that need to be completed in order to accomplish an activity". - *Common functionality*. Given the definition (functionality that if removes *fundamentally* changes the purpose of the website), the term "common" is not strong enough. I believe that the term should emphasize the essential or fundamental character of this functionality that is, by definition, more important than non-fundamental functionality. I suggest one of the following: - - Critical functionality (taken from note 2) - Fundamental functionality (taken from the definition) - Purpose-defining functionality (again, based on the definition) - *Common web pages*. I think that this definition (web pages that are relevant to the entire website) lacks precision. I think that the concept that defines these pages is that their underlying functionality is not specific for a given website, but is general to many web sites. Maybe they could be named "general-purpose web pages" and then the definition could be "web pages whose purpose is general and not specific to the website they belong". But I am not completely sure about this. - *(new definitions)* Given their relevance to WCAG-EM, I suggest adding two definitions from WCAG that are essential to the process of conformance evaluation: "conformance" and "satisfies a success criterion". This last one means that a success criterion is satisfied (passes) unless it fails and to me has great implications in the evaluation of accessibility: a success criterion passes for a page unless it is demonstrated that it fails. - - *conformance*: satisfying all the requirements of a given standard, guideline or specification - *satisfies a success criterion*: the success criterion does not evaluate to 'false' when applied to the page *Using this methodology* (http://www.w3.org/TR/WCAG-EM/#usage) - *Scope of applicability* (http://www.w3.org/TR/WCAG-EM/#applicability) - - *Particular types of websites* ( http://www.w3.org/TR/WCAG-EM/#specialcases) - - *Website with separable areas*. - - First of all I think that it would be relevant to talk about "independence" between the areas. The first sentence could be "In some cases websites may have clearly separable areas where using one area does not require or depend on using another area of the website". - Then the example could be modified into something different: "An example could be a service company website with three areas: a public area for information purposes, a customer area for providing services to existing customers and an employee area for providing services to people working in the company". - The last sentence can be maintained. - The result of applying all my proposals would be: "In some cases websites may have clearly separable areas where using one area does not require or depend on using another area of the website. An example could be a service company website with three areas: a public area for information purposes, a customer area for providing services to existing customers and an employee area for providing services to people working in the company. Such areas can be considered as individual websites rather than sub-sites for the purpose of this document." - *Evaluation tools (Optional)* ( http://www.w3.org/TR/WCAG-EM/#tools) - - I don't understand why this section is labelled as "optional". It just describes the relationship between the methodology and evaluation tools. I suggest removing the "(optional)". - *Review teams (Optional)* (http://www.w3.org/TR/WCAG-EM/#teams) - - I don't understand why this section is labelled as "optional". This section "Using this methodology" does not seem to me a place to define "requirements" for users of the methodology (and in fact the previous sections - scope of applicability, required expertise, evaluation tools - don't require anything). The "methodology requirements" do really start in the next level-1 section ("Conformance Evaluation Procedure"). - I suggest removing the "(optional"). - In addition the wording of the paragraph could be modified to avoid references to "requirements" by deleting the third sentence: "The methodology defined by this document can be carried out by an individual evaluator with the skills described in section Required Expertise. However, using the combined expertise of review teams provides better coverage for the required skills and helps identify accessibility barriers more effectively. Specific guidance is provided in Using Combined Expertise to Evaluate Web Accessibility." - *Involving users (Optional)* (http://www.w3.org/TR/WCAG-EM/#users). - - I don't understand why this section is labelled as "optional". I suggest making the same changes: removing the "(optional)" and deleting the third sentence. *Conformance evaluation procedure* (http://www.w3.org/TR/WCAG-EM/#procedure) - One issue with terminology: I think there is lack of consistence while using the words "stages" and "steps". I suggest using "stage" for the high-level elements (1, 2, ..) and "steps" for the inner levels (1a, 1b, ...). - The description of the diagram (paragraph below the diagram) seems to be incomplete. It seems to me that there are back arrows from each step to any previous step: that is, for instance, from step 5 to steps 4, 3, 2 and 1. Am I right interpreting the diagram? - - If I am right then the description has to be changed: "The diagram depicts each of the five steps defined in this section with arrows forth between each of two consecutive steps: 1. Define the Evaluation Scope; 2. Explore the Target Website; 3. Select a Representative Sample; 4. Audit the Selected Sample and 5. Report the Evaluation Findings. There are also arrows back from each step to any of its previous steps." - If I am wrong then the diagram should be changed to avoid this confusion. - *Step 1: Define the Evaluation Scope* ( http://www.w3.org/TR/WCAG-EM/#step1) - - *Step 1.a: Define the Scope of the Website* ( http://www.w3.org/TR/WCAG-EM/#step1a) - - Paragraph 1. Second sentence. The wording of this sentence is strange. I understand that WCAG-EM cannot use normative language (shall, should), but the use of "may" doesn't work for me. What about "This scope definition will follow the terms established in section Scope of Applicability"? - *Step 1.b: Define the Goal of the Evaluation* ( http://www.w3.org/TR/WCAG-EM/#step1b) - - The terminology is confusing. The name of the step is "define the goal of the evaluation", whereas the content talks about "types of evaluation". These two should be aligned. Either the title of the step is changed into "Define the type of evaluation" or the content of the step is changed to describe different goals instead of evaluation types. - *Step 1.d: Define the Techniques and Failures to be Used (Optional)* (http://www.w3.org/TR/WCAG-EM/#step1d) - - I strongly believe that this step does not belong to this stage (1. Define evaluation scope) but to the next one (2. Explore the target website). More precisely, I think it should be renumbered as step 2e. The reason is that, to me, one can only define techniques and failures once the functionality, the types of web pages and the technologies relied upon are known. - If this step is moved to become 2e, then the last paragraph should be revisited and changed accordingly. For instance, the second sentence ("This definition...") refers to the exploration stage. - *Step 2: Explore the Target Website* ( http://www.w3.org/TR/WCAG-EM/#step2) - - *Step 2.b: Identify Common Functionality of the Website* ( http://www.w3.org/TR/WCAG-EM/#step2b) - - As I have suggested alternatives for "common functionality" (such as "critical functionality", "fundamental functionality" or "purpose-defining functionality" this step should be modified to be consistent with the new term. - *Step 2.d: Identify Web Technologies Relied Upon* ( http://www.w3.org/TR/WCAG-EM/#step2d) - - There is a problem with the use of "relied upon" in this step. According to the definition of technologies that are "relied upon" what it means is that the content would not conform WCAG if those technologies were not supported. But the description of step 2.d talks about "technologies relied upon to provide the website", which is a different concept. My suggestion is either to avoid the use of "relied upon" in this step or to use it related to WCAG conformance and not to the overall website. - My preferred option is the first one: to avoid the use of "relied upon" and use the term "technologies used" instead. - If the second option is selected then this step would require two "substeps": (1) to identify all the technologies that are used to provide the website and (2) to identify which of those technologies are relied upon for accessibility purposes. - *Step 3: Select a Representative Sample* ( http://www.w3.org/TR/WCAG-EM/#step3) - - I have on general comment on the "sampling" stage. I have not seen any guidance related to how to measure the confidence level based on parameters of the sample. But this confidence level is essential when declaring the results of the evaluation of the website as a whole. Some guidance should be included in the steps below. - *Step 3.e: Include a randomly selected sample* ( http://www.w3.org/TR/WCAG-EM/#step3e) - - I agree that a random sample can act as a verification indicator of the results found in the structured sample, but I don't really agree that a random sample can be used to increase the confidence in the results of the evaluation of the structured sample. - The reason is that the structured sample and the random sample are two different samples and my understanding from my (low) knowledge on statistics is that these two different samples cannot be combined into a single sample to derive a global result for the website with an increased confidence level. - So I think that this step should be focused on using the random sample as a "control sample" to see whether the results of the structured sample are replicated in the random sample. - Another possible use of the random sample would be to increase the probability of finding new accessibility errors that were not present in the structured sample. - In addition I would like to know the reason for the numbers used. Why 5%? Why a minimum of 5 pages? What if the website only contained 10 pages and 6 of them were already part of the structured sample? It would be great to have some reasoning explaining how the probability of finding new errors could increase by increasing the percentage of pages selected in the random sample. - *Step 3.f: Eliminate Redundancies in the Sample (Optional)* ( http://www.w3.org/TR/WCAG-EM/#step3f) - - I don't agree with this step being optional. I cannot think of any good reason to maintain duplicated pages in the sample. That would decrease the relevance of the sample and the confidence level of the result, wouldn't it? I think that this step should be mandatory. - *Step 4: Audit the Selected Sample* ( http://www.w3.org/TR/WCAG-EM/#step4) - - General comment about step 4: some of the content of this step seems to me to be out of scope. WCAG-EM is about testing conformance to WCAG 2.0, that is, to determine whether a web site conforms to the technical requirements of WCAG 2.0, which are the 61 success criteria and the 5 conformance requirements. WCAG-EM should not deal with other types of accessibility evaluations, such as user testing or the concept of "accessibility-in-use" as defined in current research. So the first substep, as 4.a (check for use cases), seems to me out of scope. - What I expected as content of step 4 is guidance about: - - how to evaluate each success criterion for each element of a web page of the sample, including guidance about the best approach: inspection, testing by experts, testing by users... - how to combine the results obtained for each element in order to get a result for the page, - how to evaluate the 5 conformance requirements once the result of each SC is known for the page, - how to combine the results obtained for each page to get the global result for the site (that then will be reported in step 5). - - Note 1. - - The first note is confusing. If there are repetitive elements on every web page it makes sense to evaluate them only once, and then record and reuse the evaluation results. It is clear that an evaluator should not evaluate several times the same repetitive elements but it is also important to note that the result assigned after the first evaluation has to be used when evaluating each page where the repetitive elements appear! - My understanding of the second sentence of this note is that it implies that the repetitive elements are only evaluated once and their result is only used once... I'm probably misreading it, but I think that the text would benefit from some rewrite. - In addition I don't see the point of referring back to step 1.b in this note. What would be the difference on dealing with repetitive elements depending of the type of expected report? - My proposal for that second sentence would be: - - "An evaluator does not need to repeatedly identify successes and failures in meeting the conformance target for these repetitive elements on every web page. The success and failures for such repetitive elements can be identified once and then be reused in all the pages those elements appear." - Note 2. - - I think that the wording of this note is confusing. It should clearly explain that, according to WCAG 2.0, "no matching content for SC" is really "SC is satisfied" with no question. It should also explain that the "not applicable" could be used as a "description" of the result but not as a result. - My proposal: - - According to WCAG 2.0, Success Criteria to which there is no matching content are satisfied. In such cases, an evaluator may use text such as "Not applicable" as a description associated to the outcome "satisfied", to denote the particular situation where a success criterion was satisfied because no relevant content was applicable. - - *Step 4.a: Check for the Broadest Variety of Use Cases* ( http://www.w3.org/TR/WCAG-EM/#step4a) - - The title of misleading, because the requirement 4.a is about checking the conformance requirements, not about use cases. - I suggest changing the title: "Step 4.a: Check the conformance requirements". - I find that this step has gaps in the content I expected it to have. In my opinion checking for the 5 conformance requirements is not a straightforward task and more guidance is needed. I would like to have guidance outlining a process such as: - - a) Look for failures (as published) - b) If no failures are found, check if any SC fails - c) If no SC fails and a "in-depth analysis" has been selected in step 1.b, then determines which techniques have been used to conform to each SC - ... - My proposed process is based on the definition of "satisfies a SC" in WCAG: "the success criterion does not evaluate to 'false'", Given that definition, it is not really needed to find/determine the techniques. It should be enough to be sure that no SC fails. - All the text about scenarios, use cases, personas and user involvement is, to me, out of scope when dealing about testing for conformance with a standard. These type of things are essential during the development process when following a user-centred approach, but I believe that they don't provide added value in the context of checking the conformance of WCAG 2.0. If this text about scenarios and users is to be kept, I'd suggest it being transformed into a note. - *Step 4.b: Assess Accessibility Support for Features* ( http://www.w3.org/TR/WCAG-EM/#step4b) - - First, this should be linked to step 2.d (identify web technologies relied upon). The first "cut" for features that have accessibility support is to look for the ones using technologies identified in step 2.b. - Second, and according to my comment for step 4.a, I think this could be optional as it is only needed when the evaluation report will contain detailed information about how each SC is met (see my outlined process, step c)). - *Setp 4.c: Use Techniques and Failures Where Possible (Optional)* ( http://www.w3.org/TR/WCAG-EM/#step4c) - - I agree that the use of techniques is optional, but I fundamentally disagree in the use of failures. Even if failures are part of an informative document it is 100% sure that if one of those failures is found, then the corresponding SC fails for the page being evaluated. I cannot imagine any exception to that idea. - As I already explained above, given the definition of "satisfying a SC", the concept of "failures" is an essential tool for evaluators and should not be optional - So I propose dividing this into two: - - 4.c.1 Use failures (mandatory) - 4.c.2 Use techniques (optional) - If this is accepted then the text of these two steps should be rewritten to fit the new structure. - *Step 4.d: Archive Web Pages for Reference (Optional)* ( http://www.w3.org/TR/WCAG-EM/#step4d) - - I think that it would be good to have an explanation of the reasons to make this step optional. My first idea when reading the title of the step was to ask for it to be mandatory, as I thought that any evaluator should really archive the pages being evaluated (at least the URI and data required to be able to re-evaluate the page if needed). But then I read the details of this step and I tend to agree that all this information is optional. This is why I think that some clarification is needed. - *Step 4.e: Record Software Tools and Methods Used* (Optional) ( http://www.w3.org/TR/WCAG-EM/#step4e) - - I think that this step should not be optional. I agree that it is not always necessary to report on this information but evaluators should always record the information so it can be accessed if needed. - *Step 5: Report the Evaluation Findings* ( http://www.w3.org/TR/WCAG-EM/#step5) - - *Step 5.a: Provide Documentation for Each Step* ( http://www.w3.org/TR/WCAG-EM/#step5a) - - In the list of information documented in the report there is one reference missing: step 3.f (optional), that should be listed with all the other sub-steps of step 3. - I think that the approach for documented failures in the detailed report could be similar to the one in the basic report, but on a page by page basis. That is, if a success criterion fails, then at least one example is provided in the page. My proposal for replacing the last sentence: - - "Where failures in meeting WCAG 2.0 Success Criteria on a web page are identified, at least one examples is provided for each identified failire in the page." - *Step 5.c: Provide a Performance Score (Optional)* ( http://www.w3.org/TR/WCAG-EM/#step5c) - - I appreciate the effort spent in providing some guidance in this difficult area of web accessibility reporting. The three options are well explained with details on their sensitiveness. - This area of accessibility metrics is still under research and I think that WCAG-EM should at least acknowledge the W3C report ( http://www.w3.org/TR/accessibility-metrics-report/) that was produced after a symposium organized in December 2011 ( http://www.w3.org/WAI/RD/2011/metrics/). - *Appendix C: Example Reports* (http://www.w3.org/TR/WCAG-EM/#reports ) - - I have no comments as the review note says that this section is to be updated to better align with step 5. -- --------------------------------------------------------------- Loïc Martínez-Normand DLSIIS. Facultad de Informática Universidad Politécnica de Madrid Campus de Montegancedo 28660 Boadilla del Monte Madrid --------------------------------------------------------------- e-mail: loic@fi.upm.es tfno: +34 91 336 74 11 ---------------------------------------------------------------
Received on Monday, 15 April 2013 22:08:13 UTC