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FYI Danish Council of Organisations of Disabled People (DSI) comments to WCAG 2.0

From: <hbj@visinfo.dk>
Date: Mon, 26 Jun 2006 09:27:17 +0200
To: "'EOWG \(E-mail\)'" <w3c-wai-eo@w3.org>
FYI the comments from DSI


Statement from The Danish Council of Organisations of Disabled People (DSI)
to WCAG 2.0 Guidelines


In general DSI would like to point out that some of the new terms and their
definitions makes the language used in WCAG 2.0 difficult to understand,
especially for foreigners and consequently difficult to translate into other



Success criteria 1.1.1 is difficult to parse. When using the phrase “One of
the following is true” to a criteria where several of the following can be
true, if different types of non-text content are used, the criteria can be
misinterpreted. DSI recommend that the phrasing of parallel logical
conditions should be consistent across all success criteria. In 2.2.1 the
phrase is used correctly. We mean that the success criteria of 1.1.1 should
be rephrased or split up into several success criteria.



For deaf web users, there are two basic demands to be met to achieve full

-         Sign Language is the native language for the deaf, the first
language on which thinking and communication is based. Danish is a foreign
language learnt by reading and writing. Therefore information provided in
sign language will always be preferable to information provided in Danish
text. (A new survey states that half of the deaf population has no School
leaving exams in Danish, since they were not able to meet the language
demands. DÝves uddannelses- og arbejdsmarkedsforhold. Castberggaard 2006) 

-         all information provided by sound, should also be provided


Sign language interpretation is mentioned in Level 3 Success Criteria for
Guideline 1.2. in the WCAG 2.0 Guidelines. This placing does not ensure full
accessibility to the deaf community, since EU documents only have to meet
the demands on Level 2. Broadband Network (ADSL) gives new opportunities to
send multimedia, and the guidelines should therefore see that these new
opportunities is utilized to achieve full accessibility. Sign language
interpretation should at least be a Level 2 Success Criteria.   



Success Criteria 3.1.5: “When text requires reading ability more that the
lower secondary education level, supplemental content is available…” should
be placed at level 2 instead of level 3. EU and many national governments
meet WCAG conformance at level 2, which means that people with cognitive
disabilities will not be granted full accessibility if 3.1.5 remains on
Level 3. In WCAG 1.O checkpoint 14.1 was a level 1 criteria: “Use the
clearest and simplest language appropriate for a site's content”.


Conformance levels

According to WCAG 2.0 conformance at level Triple-A (AAA) is met when all
Level 1, all Level 2 and at least 50 % of the Level 3 success criteria that
apply to the content types used are met. How are the 50 % selected –
randomly? We mean that it is important for WCAG to decide in advance which
of the Level 3 criteria shall be met to obtain Triple-A conformance. 



WCAG 2.0 introduces the new term baseline in the conformance section which
is difficult to understand. The introduction of the conformance section in
WCAG 2.0 should be provided with a clear explanation of what a baseline is
and how it should be used. If the term baseline is not understood it might
be misused.


Helle BjarnÝ 
Visual Impairment Knowledge Centre 
Rymarksvej 1, 2900 Hellerup, Denmark 
Phone: +45 39 46 01 01 
fax: +45 39 61 94 14 
e-mail hbj@visinfo.dk 
Direct phone: +45 39 46 01 04 



Received on Monday, 26 June 2006 07:27:35 UTC

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