RE: Oracle comments on WCAG-EM W3C Working Draft 26 February 2013

Hi Peter,

Thank you very much for these comments, we will include them in the Disposition of Comments we are working on this week.
Kindest regards,

Eric Velleman


________________________________
Van: Peter Korn [peter.korn@oracle.com]
Verzonden: vrijdag 17 mei 2013 3:19
Aan: public-wcag-em-comments@w3.org
CC: Peter Korn
Onderwerp: Oracle comments on WCAG-EM W3C Working Draft 26 February 2013

Dear EvalTF,

While these few comments come to you after the deadline, we hope that it may still be possible to consider them in your work.

Step 2b. "Common Functionality"

The term "Core Functionality" seems a much better choice here.  It better fits the description: "all functionality of a website that, if removed, fundamentally changes the use or purpose of the website for users"

Step 4.a: Check for the Broadest Variety of Use Cases
The second paragraph, starting with the text "To carry out an evaluation effectively, it is often useful to construct and apply personas..." over-emphasizes a specific approach, particularly with language like the second sentence "It is critical to consider...".  It should be possible to evaluate against WCAG 2.0 on a purely technical, objective basis.  As such, this material could be presented as an advisory statement.  As written now it goes beyond the scope of WCAG 2.0 conformance.
Step 4.c: Use Techniques and Failures Where Possible (Optional)

This section appropriately describes the proper use of techniques (that they are informative and not mandatory).  However, the document would be improved if this were particularly emphasized.  We are seeing entities that are requiring the use of WCAG 2.0 also requiring the use of these techniques as THE way of demonstrating compliance.

Step 4: Audit the Selected Sample

There was little direction related to web applications related to any documentation that may have been provided with the web application, or published by the company selling the web app.  For example, the Oracle whitepaper Testing Oracle Products for Accessibility<http://www.oracle.com/us/corporate/accessibility/testing-oracle-products-wp-159857.pdf>, mentions many things related to the accessibility of web applications, including:

  *   making sure to read documentation to understand how the product is meant to be used, such as keystrokes
  *   documentation that might point out workarounds, including alternative paths through a website
  *   enablement of applicable accessibility modes, if any
  *   if using AT, ensuring that a defect found is not in the AT itself, and that the user is proficient
  *   if using automated test tools, ensuring that it is accurately representing the SC and sufficient/failure techniques that it claims to meet

Step 5.b: Provide a Conformance Evaluation Statement
While the title uses the phrase "statement", within the body it returns to using the word and concept of "conformance", which, as defined by WCAG, only exists with perfection.

Also in this section, the note: "Note: It is not possible to make an accessibility evaluation statement for a website that is still in development" appears to ignore the reality that many websites and web applications are in "continuous development", and are never finished (cf. the long lived "beta" applications from a number of well-known companies).
5.c: Provide a Performance Score (Optional)
This is an invitation to consumers of WCAG-EM reports to set a "yes/no" bar that is at some specific point below 100% perfection (e.g. a score of 95 or higher is required).  Such a move would be of little additional improvement to the present situation.  We do not believe this should be even a suggested part of WCAG-EM.


Finally, the document in general would benefit from a note mentioning some of the potential legal ramifications of using WCAG-EM.  For example, if a company creates such a WCAG-EM audit even with the intent of correcting the items found, it could be used against them in a court of law (such documents can be found in discovery and would likely be looked for, even if not published).  At a minimum, the document should advise anyone performing  this type of work that it would be wise to consult legal counsel before starting (this is touched on in the Note at the end of 5.a, but really should be called out at the top in more detail).


On behalf of my colleagues at Oracle,

Peter

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Peter Korn | Accessibility Principal
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