This Web page includes all the comments we have received about how the WCAG 2.0 Last Call Working Draft addresses the needs of people with cognitive, language, and learning disabilities. The comments were received between 27 April and 22 June 2006.
We put all comments into a database, and assigned a number to each one. For example, "LC 470" means "Last Call comment number 470." We also gave a short title to each one, to help the Working Group keep track of related comments. Some comments may have the same title.
These responses are shown in the Resolution section, but we have not sent them out yet. Please review these responses so we can discuss them on Tuesday, March 13.
Near the end of the page there are several “Open” comments. The Working Group has not discussed these yet, or else has not come up with a response. We would also like to discuss these issues on Tuesday.
Document: Understanding WCAG 2.0
Submitter:
Greg Gay <g.gay@utoronto.ca> Affiliation:
ATRC UofT
Location: meaning-supplements
Comment:
Item Number: How to Meet Success
Criterion 3.1.5
Comment (Including rationale for any proposed
change):
The statement "help people with reading disability" in the intent section of the How to meet 3.1.5 section is incorrect. The ability to comprehend high level language is not related to reading disability. Reading disability is strictly associated at a more general level with lessened ability to mentally convert visual textual information, into verbal auditory information (phonemic awareness). There is no concept of sematic disability associated with reading disability. By definition, a person with a reading disability does not have a sematic processing disability, with normal or above normal intelligence. There are several references throughout the HowTo document that refer to reading disability as an inability to understand. These statements need to be removed. They are not true (see: howto 3.1.6). Reading disability does not affect a person's ability to understand.
Proposed Change:
Remove references to to simplified language being an accomodation for those with a reading disability.
We have revised the descriptions of the benefits of different success criteria for people with cognitive disabilities by using descriptions that are based on functional limitations.
For SC 3.1.1 and SC 3.1.2, the benefits section now contains:
For SC 3.1.3, the benefits section now contains:
This success criterion may help people with cognitive, learning or language disabilities who:
For SC 3.1.4, the benefits section now contains:
This success criterion may help people with cognitive, learning or language disabilities who:
For SC 3.1.5, the benefits section now contains:
This success criterion may help people with certain cognitive, language, or learning disabilities who:
Based on: D166 Reading. 2001. International Classification of Functioning, Disabilities, and Health. World Health Organization. See also B16701 Reception of written language: mental functions of decoding written messages to obtain their meaning.)
For SC 3.1.6, the benefits section now contains:
Document: WCAG 2.0 Guidelines
Submitter:
Roger Hudson <rhudson@usability.com.au>
Location:
meaning-supplements
Comment:
Comment (including rationale for
proposed change):
I have two main concerns with 3.1.5:
First, the nominated Success Criterion is Level 3, which suggests that it is only necessary to \"achieve additional accessibility enhancements\" and does not need to apply to all Web resources (without any indication of the resources it should apply to).
Second, 3.1.5 concentrates solely on a persons reading ability, which is only one of the factors that can influence how well different people with cognitive disabilities or learning difficulties are able to understand a document. For example, what about people who can read well but have considerable difficulty negotiating a complex text-type or comprehending what is written? Or, the additional burden fully justified text and the use of long line lengths can place on many people with reading difficulties?
Proposed Change:
I suggest SC 3.1.5 be a Level 2 criterion at the minimum.
The working group agrees that writing as clearly and simply as possible is highly desirable, but could not find a way to test whether this had been achieved. We have added the following sentence to the Intent Section of SC 3.1.5, and have also added it as an Advisory Technique:
"Content should be written as clearly and simply as possible."
The description of conformance levels in WCAG 2 has been rewritten to clarify the levels:
The word "levels" does not mean that some success criteria are more important than others. Each success criterion in WCAG 2.0 is essential to some users, and the levels build upon each other. However, even content that conforms at AAA (triple-A) may not be fully accessible to every person with a disability.
Because of the tighter limits that this success criterion places on content, we feel it is appropriate at level 3.
We have added new success criteria addressing scalability of text per another comment:
SC 1.4.5: Visually rendered text can be resized without assistive technology up to 200 per cent without loss of content or functionality.
SC 1.4.6: Visually rendered text can be resized without assistive technology up to 200 per cent without loss of content or functionality in a way that does not require the user to scroll horizontally.
We mention them here because ensuring that things reflow (no horizontal scrolling) when fonts are increased (1.4.6), also allows users to narrow pages (and have text reflow) allowing users to have shorter line lengths.
We have added advisory techniques to improve the legibility of text:
Document: WCAG 2.0 Guidelines
Submitter:
Monica Løland, The Danish Council of Organisations of Disabled
People (DSI) <mol@handicap.dk> Affiliation:
The Danish Council of Organisations of Disabled People
(DSI)
Location: meaning-supplements
Comment:
Comment (including rationale for
proposed change):
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”.
Proposed Change:
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”.
The working group agrees that writing as clearly and simply as possible is highly desirable, but could not find a way to test whether this had been achieved. We have added the following sentence to the Intent Section of SC 3.1.5, and have also added it as an Advisory Technique:
"Content should be written as clearly and simply as possible."
The description of conformance levels in WCAG 2 has been rewritten to clarify the levels:
The word "levels" does not mean that some success criteria are more important than others. Each success criterion in WCAG 2.0 is essential to some users, and the levels build upon each other. However, even content that conforms at AAA (triple-A) may not be fully accessible to every person with a disability.
Because of the tighter limits that this success criterion places on content, we feel it is appropriate at level 3.
Document: Understanding WCAG 2.0
Submitter:
Gian Sampson-Wild <gian@tkh.com.au>
Location:
minimize-error-identified (Benefits)
Comment:
Benefits: Add that this benefits people with cognitive disabilities
Thank you for the suggestion, we have added the following to the benefits section of How to Meet Success Criterion 2.5.1:
"This success criterion may help people with cognitive, language, and learning disabilities who:
Document: Understanding WCAG 2.0
Submitter:
Gian Sampson-Wild <gian@tkh.com.au>
Location:
meaning-doc-lang-id (Benefits)
Comment:
Benefits: These SC do not assist people with cognitive disabilities
Proposed Change:
Remove from the Benefits section that these SC assist people with cogntive disabilities
We have revised the Benefits section to clarify how this success criterion assists people with certain classes of cognitive, learning, or language disabilities:
People who find it difficult to read written material with fluency and accuracy, such as recognizing characters and alphabets, sounding out words with correct pronunciation, and understanding words and phrases.
Document: WCAG 2.0 Guidelines
Submitter:
Greg Gay <g.gay@utoronto.ca> Affiliation:
ATRC UofT
Location: meaning-pronunciation
Comment:
Item Number: Success Criterion 3.1.6
Comment (Including rationale for any proposed change):
Is guideline 3.1.6 relevant to alphabetic langauges. I was unable to determine the meaning of this guideline as it applies to English, or other alphabetic languages. If it is relevant to alphabetic languages, examples should be provided, or it should be stated that it applies to syllabic, or orthographic languages.
Proposed Change:
Guideline 3.1.6 is indeed relevant to alphabetic languages. Examples have been added to the "Intent of this success criterion" section of "How to Meet 3.1.6" to illustrate this. The revised section reads as follows:
"For example, in the English language heteronyms are words that are spelled the same but have different pronunciations and meanings, such as the words desert (abandon) and desert (arid region). Additionally, in some languages certain characters can be pronounced in different ways. In Japanese, for example, there are characters like Han characters(Kanji) which have multiple pronunciations. Screen readers may speak the characters incorrectly without the information on pronunciation. When read incorrectly, the content will not make sense to users."
Document: WCAG 2.0 Guidelines
Submitter:
Roger Hudson <rhudson@usability.com.au>
Location:
minimize-error
Comment:
Comment (including rationale for
proposed change):
Guideline 2.5 states, "Help users avoid mistakes and make it easy to correct mistakes that do occur." The Level 1 and Level 2 Success Criteria for this Guideline all appear to be concerned helping people recover from mistakes. The only SC that relates to avoiding mistakes in the first place is a Level 3 criterion.
Proposed Change:
I suggest the Working Group consider including more information on how mistakes can be avoided. At the least, Success Criteria 2.5.4 should be a Level 2 criterion.
We have created a new Level 2 success criterion intended to help users avoid errors: "Information or cues are provided when content requires user input".
Document: WCAG 2.0 Guidelines
Submitter:
Gian Sampson-Wild <gian@tkh.com.au>
Location:
minimize-error
Comment:
2.5: There should be a Level 1 SC which requires error prevention techniques, such as providing instructions at the beginning of a form
Proposed Change:
Create a new SC. I am happy to help with this
We have created a new Level 2 success criterion intended to help users avoid errors: "Information or cues are provided when content requires user input".
Document: WCAG 2.0 Guidelines
Submitter:
Lisa Seeman <lisa@ubaccess.com> Affiliation:
Invited expert at W3C, UB access
Location:
ensure-compat (Support
compatibility with current and future user agents (including
assistive technologies))
Comment:
Comment (including rationale for
proposed change):
two questions we need to know for interface components
But what I am not sure is mentioned is make sure each element exists in the first place - and is not color across a screen. or letters in no logical order but that are absolutely positioned. A ball is a ball, a word is a word. Things need to know who they are and to what they belong.
Proposed Change:
Add at level one
All objects and components that can be visual perceived can be programmatically identified thought its life cycle.
We have revised SC 1.3.1 ("Information and relationships conveyed through presentation can be programmatically determined or are available in text, and notification of changes to these is available to user agents, including assistive technologies.") and SC 4.1.2 ("For all user interface components, the name and role can be programmatically determined, states, properties, and values that can be set by the user can be programmatically determined and programmatically set, and notification of changes to these items is available to user agents, including assistive technologies.") so that this is now required.
If objects and components can be visually perceived, SC 1.3.1 requires that they be programmatically determined or described by text. Changes to the object also need to be notified.
Document: WCAG 2.0 Guidelines
Submitter:
Robert C. Baker <<Robert.C.Baker@ssa.gov>> Affiliation:
Social Security Administration
Location: meaning
Comment:
Comment (including rationale for
proposed change):
The guidelines do not address the following:
§Guidelines for creating HTML documentation and Help must be stated and Help using navigational techniques must also be documented for accessibility.
Proposed Change:
We agree that Help and documentation that is available *on the web* is web content and hence that it should conform to these Guidelines. Note that although the same issues appear for documentation and Help files for desktop applications, these guidelines do not address that content. However, we feel that attempting to single out specific examples of Web content is likely to lead people to believe that only the listed examples are covered.
Document: WCAG 2.0 Guidelines
Submitter:
M.F. Laughton <adio@crc.ca> Affiliation:
Government of Canada
Location: meaning
Comment:
The document lacks any reference to dealing with "unusual user interface features or behaviours" that are likely to confuse the first-time/novice user. We feel that such should be described to the user before they are encountered.
Proposed Change:
Add a level 3 (at least) success criterion - perhaps to Guideline 3.1 - requiring that "Explain/describe/warn about the existence of unusual user interface features or behaviours before they are encountered.
We've tried to address this type of scenario in the Guidelines as "predictable" behaviour and is covered under Guideline 3.2 "Make the placement and functionality of content predictable." We've tried to further supplement it with Guideline 2.4 "Provide mechanisms to help users find content, orient themselves within it, and navigate through it".
The Success criteria need to be testable and it would be difficult to test for an "unusual interface." However we have added a sentence to the intent section of 2.4 that says:
"Unusual user interface features or behaviors may confuse people with cognitive disabilities."
Document: WCAG 2.0 Guidelines
Submitter:
Gian Sampson-Wild <gian@tkh.com.au>
Location:
meaning-located
Comment:
3.1.4: If information is provided in an abbreviated form without expansion, then the content is essentially inaccessible to people that cannot interpret the abbreviation. People who use screen readers and people with cognitive disabilities often have difficulties interpreting abbreviations.
Proposed Change:
There should be a Level 1 version of this SC which requires that important abbreviated information is marked up, or expanded the first time it is used in a page
As outlined by the different situations in SC 3.1.4, providing the expansion for the first use of an abbreviation is only a sufficient technique when the abbreviation only has one expansion on that web page, e.g., Dr. is only used as an abbreviation for doctor or for drive, but not for both. Otherwise, providing the expansion on the first use will be more confusing for users with cognitive disabilities.
Document: WCAG 2.0 Guidelines
Submitter:
Henny Swan <henny.swan@rnib.org.uk> Affiliation:
Royal National Institute of the Blind
Location:
meaning
Comment:
Comment: No mention is made of presentation of text i.e. left aligned vs. justified/right aligned text, long lines, multiple columns, overuse of different styles etc.
Proposed Change:
Add in.
Since these are all design decisions related to visual presentation, the working group believes that this issue is covered under "Principle 1: Content must be perceivable: Guideline 1.3 Ensure that information and structure can be separated from presentation." Satisfying these success criteria should let the user control the style of presentation of text, possibly via assistive technology.
We have also added the following advisory techniques to GL 3.1:
Document: WCAG 2.0 Guidelines
Submitter:
Takayuki Watanabe, Makoto Ueki, and Masahiro Umegaki
<nabe@lab.twcu.ac.jp> Affiliation:
JIS WG2
Location: time-limits (2.2
/ 3.1)
Comment:
Comment: WCAG 2.0 doesn't mention about the speed of text which is moving on the page. It is hard for people with visual disabilities and cognitive limitations to read and understand the text. Can the author use the fast scrolling text?
Text that is being scrolled automatically would be covered by SC 2.2.3 and F16:
SC 2.2.3 Content can be paused by the user unless the timing or movement is part of an activity where timing or movement is essential.
F16: Failure of SC 2.2.3 due to including scrolling content where there is not a mechanism to pause and restart the content
If an author uses scrolling text, there must be a way to pause the text to give the person time to read and understand it.
Document: WCAG 2.0 Guidelines
Submitter:
Chris Ridpath <chris.ridpath@utoronto.ca> Affiliation:
ATRC University of Toronto
Location:
navigation-mechanisms-refs
Comment:
Comment (including rationale for
proposed change):
Success Criterion 2.4.4 should be at level 1 and is currently at level 2. Good link text is very important for people with visual impairments as well as people with cognitive impairments. Poor link text was identified as a key problem in the DRC report (http://www.drc-gb.org/PDF/2.pdf). Good link text is at least as important as skip-navigation links which is at level 1.
This SC has been moved to level 1 because without it, it requires significantly greater effort (and keystrokes) for assistive technology users to determine link context.
Document: WCAG 2.0 Guidelines
Submitter:
Gian Sampson-Wild <gian@tkh.com.au>
Location:
navigation-mechanisms-descriptive
Comment:
2.4.5: This should be at Level 1. Descriptions, headings, labels etc are very important for both people who use screen readers and people with cognitive disabilities. Equivalent checkpoints in WCAG 1.0 are at Level AA
Proposed Change:
Move to Level 1
We have added "descriptive" to SC 2.4.3 and moved it to level 1.
SC 2.4.5 has been moved to Level 2. It addresses descriptive headings and labels, which may need to be understood in context. While headings may not have sufficient descriptive power in isolation, when viewed in the context of a structured document, they do have sufficient descriptive power.
Document: WCAG 2.0 Guidelines
Submitter:
Gian Sampson-Wild <gian@tkh.com.au>
Location:
navigation-mechanisms-location
Comment:
2.4.7: This should be at Level 1. Determining the current location is sometimes very difficult for both people who use screen readers and people with cognitive disabilities
Proposed Change:
Move to Level 1
This success criterion is at level 3 because not all web pages are part of a set of web pages to which this success criterion can be applied. The working group agrees that when it does apply, it is very important for people with these disabilities.
Document: WCAG 2.0 Guidelines
Submitter:
Gian Sampson-Wild <gian@tkh.com.au>
Location:
minimize-error-context-help
Comment:
2.5.4: This should be Level 1. Context sensitive help is very important to people who use screen readers and people with cognitive disabilities.
Proposed Change:
Move to Level 1
While context sensitive help is useful and sometimes necessary for people with disabilities, the type and level of detail for context sensitive help varies greatly depending upon the type and functions of the site. Requirements must be applicable to all Web sites in order to qualify as Level 1 or Level 2 in WCAG 2.0.
Document: WCAG 2.0 Guidelines
Submitter:
Lisa Seeman <lisa@ubaccess.com> Affiliation:
Invited expert at W3C, UB access
Location:
conformance
Comment:
Comment (including rationale for any
proposed change):
Level 3 success criteria:
I object to definition. Because many criteria are level 3 only because they are considered too hard to do on all web content does not mean that level 1 and two achieve minimal and enhanced accessibility.
Level 3 is also minimal accessibility
Proposed Change:
change of wording
Level 3 success criteria:
We have completely rewritten this section of the guidelines:
The word "levels" does not mean that some success criteria are more important than others. Each success criterion in WCAG 2.0 is essential to some users, and the levels build upon each other. However, even content that conforms at AAA (triple-A) may not be fully accessible to every person with a disability.
Document: WCAG 2.0 Guidelines
Submitter:
Charles McCathieNevile <chaals@opera.com>
Location:
Comment:
The guidelines place in level 3 very many of the requirements necessary to help people with cognitive and reading disabilities access the web. Since only 50% of level 3 requirements (as chosen by content authors) need to be met in order to claim confomance to the guidelines, it is quite possible to conform to the guidelines at triple-A level while doing very little (and clearly not enough) to address the needs of these user groups.
I propose either that this be explicitly and clearly explained in the introductory and conformance sections, or that the levels system be reworked as per my last call comment on them.
cheers
Chaals
We have changed the definition of Triple-A conformance so that all level 3 success criteria must be satisfied.
Also see Proposed Resolution on new cognitive items and limitations of WCAG above.
This next block of issues all call for clarifying WCAG's level of support for people with cognitive, language, and learning disabilities. We will be adding language to WCAG based on the text from our meetings on cognitive issues.
The comments in this section have the same proposed resolution so it is listed here once, to avoid repetition. It is also used in responding to some other comments below.
We have added language to the Introduction, the Conformance section, and the Quick Reference to highlight the fact that WCAG 2 only addresses some of the needs of people with cognitive, learning, and language disabilities, and to call out the need for more research in this area. WAI is exploring ways in which to support and encourage work in this important area.
We have added some best practices for cognitive, learning, and language disabilities as advisory techniques, and we have proposed 2 new success criteria in this area.
Document: WCAG 2.0 Guidelines
Submitter:
Roger Hudson <rhudson@usability.com.au>
Location:
intro
Comment:
Comment (Including rationale for any
proposed change):
Currently the introduction identifies cognitive limitations as one of the disabilities that WCAG 2 addresses. Unlike WCAG 1.0, WCAG 2 gives only scant recognition to the needs of people with disabilities.
Proposed Change:
Either improve WCAG 2.0 or remove the suggestion that the needs of people with cognitive limitations (or difficulties) will be met.
Document: WCAG 2.0 Guidelines
Submitter:
Roger Hudson <rhudson@usability.com.au>
Location:
accessible-alternatives
Comment:
Comment (including rationale for
proposed change):
Guideline 4.2 relates to the need to ensure content is accessible or provide an accessible alternative. I am concerned that overall, WCAG 2.0 does not sufficiently recognise the needs of people with cognitive disabilities or limitations and this guideline in particular does not appear to specifically address these needs.
In my country (and I imagine in most others) people with cognitive disabilities and learning disorders represent the largest proportion of the population with disabilities. In its current state, WCAG 2.0 could leave a site developer, who is keen to improve the accessibility of a site for people with cognitive disabilities, with the incorrect impression that all they need to do is ensure the content is at an appropriate reading level.
WCAG 2.0 should not avoid addressing the needs of people with cognitive disabilities with the vague excuse that it is not immediately possible because today\'s technologies and user agents do not adequately support content negotiation.
Proposed Change:
I strongly urge the Working Group to provide more comprehensive guidance in how to improve the accessibility of web sites for people with cognitive disabilities and learning disorders in WCAG 2.0.
I suggest Guideline 4.2 (and the associated documents) should specify different ways of improving the accessibility of content for people with cognitive disabilities and learning disorders. Also, the Guideline should clearly indicate appropriate ways of providing accessible alternative content.
Guideline 4.2 (which has been incorporated into the Conformance section) permits multiple versions of content, so that specialized presentations for people with cognitive, learning, and language can be provided..
Document: WCAG 2.0 Guidelines
Submitter:
Lisa Seeman <lisa@ubaccess.com> Affiliation:
Invited expert at W3C, UB access
Location:
intro (Introduction)
Comment:
Comment (including rationale for any
proposed change):
The claim in http://www.w3.org/TR/WCAG20/Overview.html learning difficulties, cognitive limitations,
However the checkpoints towards understandability even at level 3 addresses only secondary education level – in other word usable for mainstream people without these disabilities. The basic mechanism for simplifications have not been included, or use of symbols or conversion to symbols. Also left out are use for controlled languages
The result: I read a lot of complex specification. I am even writing W3C specifications, but WXAG is the only on that I can not follow though because of my disability. I can understand the concepts, but the presentation requires remembering what technique 3.1.3 was for, and then (if I forgot what 3.2.3 stood for, going back to the original guidelines finding it, hopefully not confusing it with 1..3.2 etc – why because WCAG are following there own specifications, so I, as a person with a disability, can not use their material.
To say “this document contains principles, guidelines, and success criteria that define and explain the requirements for making Web-based information and applications accessible” and to include learning difficulties, cognitive limitations is an insult to anyone with learning memory or cognitive impairments. there are many clear sets of guidelines that do that. WCAG is not one of them.
Proposed Change:
Practical proposal – state clearly that learning difficulties, cognitive limitations are not fully addressed beyond a very limited way. Then work on a extended guideline, be it optional and untestable, success criteria that does the job.
Document: WCAG 2.0 Guidelines
Submitter:
Lisa Seeman <lisa@ubaccess.com> Affiliation:
Invited expert at W3C, UB access
Location: intro
Comment:
Comment (including rationale for any
proposed change):
This document contains principles, guidelines, and success criteria that define and explain the requirements for making Web-based information and applications accessible. "Accessible" means usable to a wide range of people with disabilities, including blindness and low vision, deafness and hearing loss, learning difficulties, cognitive limitations...
I am not sure that if pages are fixed to comply to WCAG they will be more accessible to LD
Proposed Change:
Change to exclude Learning disabilities.
Document: WCAG 2.0 Guidelines
Submitter:
Lisa Seeman <lisa@ubaccess.com> Affiliation:
Invited expert at W3C, UB access
Location:
minimize-error
Comment:
Comment (including rationale for any
proposed change):
Most of this (at least at the higher levels) helps blind folks access error information. That is good. Clearly what is missing hear is a game plan for helping people with a learning disability , who have trouble filling in forms.
Forms are real nightmares for a lot of us. In fact I often do not deposit checks and perform other tasks because of the barrier that form filling presents.
Things that make it harder include short labels that do not explain what they are, coping numbers, Non expandable, small fonts. Too much information on one page. Information not being well grouped such as user information, payment information. Then with the short labels I get confused what is what. Server time outs. Asking a lot of information to make forms simpler to process but make form filling much harder and more complex.
For example on this form on line it is much simpler (but PF preferred this table .. oh well) .... the options could be in a combo box as filled out meaningfully text...
Proposed Change:
Perform user testing with different groups of people with learning disabilities and cognitive limitations - including age related.
Identify what techniques help
Add them
Document: WCAG 2.0 Guidelines
Submitter:
Lars Ballieu Christensen <lbc@sensus.dk> Affiliation:
Sensus ApS - European Accessibility Consultants
Comment:
Comment (including rationale for
proposed change):
As a practitioner with 10 years experince in advising site owners and developers on how to develop web sites that are accessible to the widest range of users using the widest range of technilogies, I find the following the following issues in WCAG2 highly problematic:
The introduction of a technology baseline; the concept of a baseline is in my opinion in itself in direct conflict with the idea of creating inclusive solutions; I fear that the baseline will be used widely to formally pass accessbility tests by omitting all potentially tricky technologies from the baseline. In my opinion, the baseline is a mistake that should be removed from the document. If the aim is to promote an inclusive envisonment, the whole notion of accepting lower standards in, say, private intranets is absurd as it will preent people with special needs to work in these environments.
The document is still heavily biased towards the visually impaired. By and large, other groups of people with special needs are in practice omitted from the substance of the guidelines. These include, but are not limited to, the deaf, dyslexic, people with reading difficulties, and the cognitively disabled. The standard remedy of demanding that all non-textual information also be represented as textual information is simply not enough.
The idea of granting triple-A conformance status to a web site if it passes half (randomly selected?) the level 3 success criteria does not make sense. It suggests either that the level 3 success criteria are irrelevant to the general accessibilily or that it is more important to be able to pass the test than to comply with the level 3 success criteria.
Proposed Change:
Also See Proposed Resolution on new cognitive items and limitations of WCAG above.
Document: WCAG 2.0 Guidelines
Submitter:
Bruno von Niman <ANEC_W3CRep_Bruno@vonniman.com> Affiliation:
ANEC (ANEC-ICT-2006-W3C-006)
Comment:
Comment (including rationale for any
proposed change):
Learning disabilities and cognitive limitations are not addressed! This may be perceived as usability issues but we believe the consumer should not have to know the difference between usability and accessibility! Older consumers, a numerous part of the EU population, will face severe problems!
Proposed Change:
Should be covered by the WCAG 2.0 documents. Otherwise, the opposite must be explicitely claimed, to avoid misunderstandings. Another option would be to continue work on a set of extension guidelines to address these needs.
Document: WCAG 2.0 Guidelines
Submitter:
Gian Sampson-Wild <gian@tkh.com.au>
Location:
Comment:
Cognitive disabilities - People with cognitive disabilities are unfairly discriminated against within WCAG2. I believe this is due to the usability and testability requirements. It is generally accepted (and one chair has said so explicitly) that requirements that assist people with cognitive disabilities are often general usability techniques. Criteria that assist people with cognitive disabilities is more likely to fall foul of the requirement for testability than other criteria, simply because these criteria recommend changes to the way content is written, not how a site is coded. For example, in WCAG1 Checkpoint 14.1 - Use the clearest and simplest language appropriate for a site's content - still has no clear equivalent in WCAG2 and partiallymaps to Level 3success criteria.
Proposed Change:
Set up a specific taskforce within WCAG WG to identify success criteria that should be added to ensure WCAG2 addresses the needs of people with cognitive disabilities (I volunteer to be a part of, or to head up, this taskforce), or comply with Lisa Seeman's suggestions in her formal objection (which I have cosigned)
Document: WCAG 2.0 Guidelines
Submitter:
Lisa Seeman <lisa@ubaccess.com>
Location:
Comment:
WCAG 2.0 claims to define and address
the requirements for making Web content accessible to those with
learning difficulties, cognitive limitations and others. We object to
that claim.
Specifically, the success criteria requirements for making content understandable largly ignore the needs of people with learning difficulties and cognitive limitations. Please note that there are guidelines published by other groups that will make content much more accessible to these users. However, with the WCAG claim to address learning difficulties and cognitive limitations, people will not know that they need to look further.
We would like to see continued work in this field and a statement in the WCAG 2.0 abstract and introduction modifying the claim that they currently address accessibility for learning disabilities. Specifically, we recommend removing learning difficulties and cognitive limitations from the list of supported disabilities. A sentence may be added later in the abstract that "these guidelines may also provide some benefits for people with learning difficulties and cognitive limitations". We would then like to see a statement of intent such as: "the working group intends to build additional success criteria to address accessibility for learning disabilities and cognitive limitations."
All the best,
Lisa Seeman, www.ubaccess.com
Jonathan Chetwynd, Accessible
Solutions
Andy Heath, Axelrod Research and Computing
Gez
Lemon, www.juicystudio.com
Roberto Scano
Gian Sampson-Wild
Dr. Andy Judson
Yvette Hoitink
Marc Walraven
Fred
Heddell MBE, Inclusion International
Mrs. Zoe Apostolopoulou
e-ISOTIS
Andrew Arch Vision Australia
Sofia Celic Vision
Australia
Keith Smith, BILD (British Institute of Learning
Disabilities)
Peter Rainger
Erlend Øverby
William
Loughborough
Geert Freyhoff Inclusion Europe
Better Days
advocacy group
Mencap Accessibility Unit
The Rix Centre (for
Innovation and Learning disability)
Antonia Hyde, United Response
Diane Lightfoot, United Response
Jo Kidd, The Skillnet Group
Dan Edney The Skillnet Group
United Response (UR)
Liddy
Nevile, La Trobe University
Andy Minnion, The Rix Centre
Simon
Evans, The Rix Centre
Jim Byrne, GAWDS
Mel Pedley
Pamela
E Berman
Caroline Lambie, Mencap Web Communications Manager.
Andrew Holman, Inspired Services
Robert Hubbert, Ubisan
John
Nissen, Cloudworld Ltd
Paul Williams
Roger Hudson
Janine
Ness
Zoe Porter, Valuing People
Sue Carmichael, Valuing
People
Geoff Stead
David Sloan, Digital Media Access Group
Simon Cramp
Ann Fergusson
Dr. Robin Boast
Matthew
Smith
Neel Shearer, CALL (Communication Aids for Language and
Learning) Centre
Paul Brown, The Scottish Disability Team
Jim
Ley
Sally Cooper
TechDis
Katarina Mühlenbock, Dart
Emmanuelle Gutiérrez y Restrepo, Sidar
Mats Lundälv
Dart
Sari Follansbee
Sarah Riley
Sally Paveley, Advisory
Unit
Document: WCAG 2.0 Guidelines
Submitter:
Andrew Arch <andrew.arch@visionaustralia.org> Affiliation:
Vision Australia
Location: intro (Opening)
Comment:
Comment: Para 1 says that WCAG 2.0 makes web content available to a wide range of disabilities, including "blindness and low vision, deafness and hearing loss, learning difficulties, cognitive limitations, limited movement, speech difficulties, and others". It seems that learning difficulties and cognitive limitations are not addressed to any significant extent, in fact even less than WCAG 1.0. It seems the emphasis is even more on 'blindness and low vision' and 'limited movement'. THis may be becasue the strong move to testability, but given that this is the case, then let's not kid everyone (or no-one) that WCAG 2.0 address all disabilities.
Proposed Change:
Change wording to leave these out at this stage. Seriously consider the next task for the working group to be to properly address the needs of these groups with supplement or addenda to WCAG 2.0 (or release as a WCAG 2.1)
Document: WCAG 2.0 Guidelines
Submitter:
British Standards Instution, London, UK <> Affiliation:
British Standards Instution, London, UK
Comment:
Addressing Cognitive and Learning Disability
WCAG 2.0 claims to define and address the requirements for making Web content accessible to those with learning difficulties, cognitive limitations and others. We do not accept that claim.
Specifically, the success criteria requirements for making content understandable largely ignore the needs of people with learning difficulties and cognitive limitations. Please note that there are guidelines published by other groups that will make content much more accessible to these users. However, with the WCAG claim to address learning difficulties and cognitive limitations, people will not know that they need to look further.
We would like to see continued work in this field and a statement in the WCAG 2.0 abstract and introduction modifying the claim that they currently address accessibility for learning disabilities. Specifically, we recommend removing learning difficulties and cognitive limitations from the list of supported disabilities. A sentence may be added later in the abstract that "these guidelines may also provide some benefits for people with learning difficulties and cognitive limitations". We would then like to see a statement of intent such as:"the working group intends to build additional success criteria to address accessibility for learning disabilities and cognitive limitations."
Document: WCAG 2.0 Guidelines
Submitter:
Roger Hudson <rhudson@usability.com.au>
Location:
meaning
Comment:
Comment (Including rationale for any
proposed change):
Guideline 3.1 is concerned with the need to make text readable and understandable. In general WCAG 2.0 contains very few provisions for improving the accessibility of web content for people with cognitive disabilities or learning difficulties. There is the level 3 SC 3.1.5, which is concerned with the reading level of text, however it is a fallacy to assume all cognitive disabilities somehow relate to a persons ability to read.
WCAG 1.0 contained the Priority 1 Checkpoint 14.1 (Use the Clearest and simplest language appropriate for a site's content). It also contained the Priority 2 Checkpoint 12.3 (Divide large blocks of information into more manageable groups where natural and appropriate). Combined these two checkpoints communicated the desirability of preparing content that could be accessed by people with a range of cognitive and intellectual abilities and suggestions for how this could be achieved. Unfortunately, WCAG 2.0 does not appear to contain a similar commitment or guidance to these issues.
Proposed Change:
Guideline 3.1 should contain two new Level 2 success criteria, which read:
The working group was unable to come up with a testable equivalent of WCAG1 14.1. However, we have added an advisory technique to guideline 3.1 and SC 3.1.5 that reads, "Using the clearest and simplest language appropriate for the content."
We have also added a new Success Criterion to GL 3.1, "Pages are organized into sub-sections with titles", to address some of the properties covered by Checkpoint 12.3.
Also See Proposed Resolution on new cognitive items and limitations of WCAG above.Document: WCAG 2.0 Guidelines
Submitter:
Gian Sampson-Wild <gian@tkh.com.au>
Location:
mapping (Checkpoint
10.2)
Comment:
Properly positioned labels: 10.2 no longer maps to any particular SC. Although this checkpoint was included in WCAG1 to assist people who use screen readers, prior to the uptake of explicit labelling, this is still a very important SC for people who use magnifiers and people with cognitive disabilities.
Proposed Change:
Create a new SC the equivalent of 10.2 (I am happy to write this)
Assistive technology has advanced since the WCAG 1.0 guidelines were released. As long as the label is explicitly associated with a field, assistive technologies can present the information to the user in an understandable manner. However, since visual positioning can be important, especially for pages translated into other languages, we have added an advisory technique to Success Criterion 1.3.1 and Guideline 3.2 titled "Positioning labels to maximize predictability of relationships."
Note: The mapping has been removed from the WCAG document itself. The working group will work in coordination with the EOWG WCAG 2.0 Materials Support Task Force in the creation of transition materials and will consider these comments when the mapping is updated.
Document: WCAG 2.0 Guidelines
Submitter:
Henny Swan <henny.swan@rnib.org.uk> Affiliation:
Royal National Institute of the Blind
Location:
meaning (Success
Criteria)
Comment:
Comment: WCAG1 14.1 is not represented in this guideline or any other. This is quite a major omission and one that is important for not only users with cognitive and reading problems but also browsing in a second language; a strange omission given W3C's Internationalisation WG.
Proposed Change:
Add in
The working group was unable to come up with a testable equivalent of WCAG1 14.1. However, we have added an advisory technique to guideline 3.1 and SC 3.1.5 that reads, "Using the clearest and simplest language appropriate for the content."
We have added language to the Introduction, the Conformance section, and the Quick Reference to highlight the fact that WCAG 2 only addresses some of the needs of people with cognitive, learning, and language disabilities, and calls out the need for more research in this area. WAI is exploring ways in which to support and encourage work in this important area.
Document: WCAG 2.0 Guidelines
Submitter:
Henny Swan <henny.swan@rnib.org.uk> Affiliation:
Royal National Institute of the Blind
Location:
Comment:
Comment: WCAG1, checkpoint 14.2 is not reflected in WCAG 2. The WCAG 2 checklist states that this is because it is reflected in the techniques rather than the Success Criteria which are normative. Can be argued that 14.2 is as important to people with cognitive problems as 1.1 and alt text are to VI users. In WCAG one the former was a P3 that later a P1. It may be that because it is not testable that 14.2 hasn't carried over into WCAG 2 but it shouldn't be excluded because it is not testable as it is still a fundamental guideline for this user group. In the Introduction it states that WCAG2 is for people with cognitive and learning problems so therefore this checkpoint should be in WCAG 2.
The working group was unable to come up with a testable version of WCAG1 14.2, so that authors could determine when the supplements were needed and how to ensure that the supplements actually addressed the needs of people with cognitive disabilities. Graphic or auditory supplements are listed as sufficient techniques for SC 3.1.5.
Also See Proposed Resolution on new cognitive items and limitations of WCAG above.Document: WCAG 2.0 Guidelines
Submitter:
Andrew Arch <andrew.arch@visionaustralia.org> Affiliation:
Vision Australia
Location: mapping
Comment:
Comment: Several WCAG 1.0 checkpoints that are still very important for some people with disabilities are missing from WCAG 2.0:-
I acknowledge that some of these may not be machine testable, but they are human (consensus) testable.
Proposed Change:
Add these Checkpoints back in as WCAG 2.0 SC.
Response: Image maps are non-text content and they are links. Therefore, this requirment is covered under Success Criteria 1.1.1, 2.4.4, and 2.4.5. HTML technique H24 "Providing text alternatives for the area elements of image maps" is a sufficient technique for these success criteria.
Response: We have added two new success criterion to address these concerns:
SC 1.4.5: Visually rendered text can be resized without assistive technology up to 200 per cent without loss of content or functionality.
SC 1.4.6: Visually rendered text can be resized without assistive technology up to 200 per cent without loss of content or functionality in a way that does not require the user to scroll horizontally.
Response: This is addressed by Success Criterion 1.3.1 and technique H73.
Response: We have added an advisory technique to GL 3.1, 1.3 and 2.4 titled "Making links visually distinct."
Response: This is addressed by an advisory technique listed under SC 2.4.5 (Starting section headings with unique information).
Response: A characteristic that is important to WCAG 2.0 is the testability of each Success Criteria. We have not been able to create a testable description of "clear language." We have tried to cover this in some of the success criteria and advisory techniques in Guideline 3.1. However, there is no direct mapping.
Response: Aspects of WCAG 1.0 Checkpoint 14.3 are required by WCAG 2.0 Guideline SC 3.2.3 and SC 3.2.4. There is no Success Criterion in WCAG 2.0 that is as broad as WCAG 1.0 Checkpoint 14.3, so aspects of it do not relate.
Document: WCAG 2.0 Guidelines
Submitter:
lisa seeman <lisa@ubaccess.com> Affiliation:
UB access
Comment:
Comment (including rationale for
proposed change):
The success criteria are not stable in the future, and do not capture everything that you need to do. They are the testable aspects of current conformance
I think this limitation needs to be emphasized. Specifically, success criteria by themselves do not necessarily mean that the point of the guideline was achieved.
Proposed Change:
Why not putting rules of thumb in the guidelines themselves? Success criteria are only measurable aspects of a rule of thumb. People should not turn success criteria into a checklist whilst ignoring that.
The success criteria need to be testable or else people cannot tell when they have conformed to the success criteria and thus WCAG 2.0. The document states that more can be done than the SC and provides advisory techniques to that end. We have added more advisory techniques to cover recommendations for which we have not been able to develop testable success criteria. We have also clarified in the introduction that even satisfying all success criteria will not meet the needs of all people with all disabilities.
Document: WCAG 2.0 Guidelines
Submitter:
Gian Sampson-Wild <gian@tkh.com.au>
Location:
Comment:
Testability - The decision to comply with the testability requirement has outlawed some very important success criteria. This requirement has also not been applied fairly to all success criteria. Some current success criteria do not comply with the 8 out of 10 rule - for example 1.1.1. This SC requires that alternatives to non-text content "serve the same purpose and present the same information". One basic example of this is to require equivalent ALT attributes for images, but I do not believe that 8 out of 10 people would agree on the same ALT attribute for an image. For instance, in the Live in Victoria site (www.liveinvictoria.vic.gov.au) there is an image under the heading "Business Migrants". When I worked on this site, several people said this image should have a null ALT attribute as it conveyed no information. Several other people suggested ALT attributes of "A couple of business migrants chatting at work" or "Guys chatting at work". Whereas the ALT attribute that I recommended was "There is a wealth of opportunities for Business Migrants in Victoria."
Proposed Change:
Remove the requirement for testability and set up a taskforce (I volunteer to work on or head up this taskforce) to identify criteria that should be included in WCAG2. Alternatively, develop a set of supplementary guidelines that are non-testable to be used in conjunction with WCAG2.
The success criteria need to be testable or else people cannot tell when they have conformed to the success criteria and thus WCAG 2.0.
With regard to SC 1.1.1 the success criterion does not require that ALT text provided by different people be the same. WCAG 2.0 categorizes different classes of alt text and provides test procedures to help humans evaluate whether alt text satisfies the success criterion. But it does not require 'good' alt text. Only that it be alt text and not placeholders (e.g. "picture")
Advisory techniques are used to provide supplemental materials that are non-testable that can be used in conjunction with WCAG 2.0. They provide additional guidance on what can be done beyond the requirements of WCAG.
Document: WCAG 2.0 Guidelines
Submitter:
Lisa Seeman <lisa@ubaccess.com> Affiliation:
Invited expert at W3C, UB access
Location:
media-equiv
Comment:
Comment (including rationale for any
proposed change):
I am concerned that the requirement for real time synchronization put a lot of extra work on authors who would like to provide short animations or clips that help people with learning disabilities fulfill a task. On the whole, a lot of multi media, especially in education, is good for many learning disabilities, and these requirements may act as a step backwards for learning disabilities.
Proposed Change:
Make an exception in SC 1.2 for any content provides extra help visual for tasks and information that has been described in text else wear.
Document: WCAG 2.0 Guidelines
Submitter:
Ulrike Peter <upeter@ifib.de>
Comment:
Comment (including rationale for
proposed change):
We are concerned about Principle 3 “Content and controls must be understandable”.
Restructuring
We appreciate the restructuring of WCAG2 into four general principles allowing more independence of technology. But we fear that in practice the focus will be exclusively on the success criteria. This risk should be countered.
We demand that the principles and the guidelines of WCAG2 are given more importance and value. The success criteria should be defined as one (of several) possibilities to secure the WCAG2. The limitations of the success criteria have to be pointed out. The focus should be laid on the assurance of the principles and guidelines.
Criticism on the success criteria of the third principle
In the more general formulations of the revised WCAG2, also those checkpoints of WCAG1 can be found which have already become law in many European countries. Comparing the concrete implementation recommendations of WCAG2 (the success criteria) with those of WCAG1 (the checkpoints), it shows for the area of understandability that the aspects relating to the contents have got lost: In WCAG1, the requirement 14.1 „Use the clearest and simplest language appropriate for a site\'s content“ has the highest priority. In WCAG2, the guideline 3.1 includes content aspects of readability and text understanding. In the success criteria for 3.1, however, these requirements are missing. The success criteria included in WCAG2 now represent only side aspects of understandability which can be technologically checked. The much more important aspects in the area of understandability can only be submitted to standardized tests on the basis of expertise and considering the specific target groups of the web offer. In Germany, this is established practice, and know-how is available. The certification procedure based on the BITV, the German adoption of WCAG1, as well as the BIENE Award procedure follow these requirements on the basis of German law demanding not only the implementation of the „conditions“ (corresponding to the checkpoints of WCAG1), but also the implementation of the „requirements“ (corresponding to the guidelines of WCAG1).
The certification procedure of DIN CERTCO has been developed by leading representatives of science, practice and associations of people with disabilities. Beside the product quality of the web offer, also the process quality of the content tendance is evaluated. The BIENE Award is a competition carried out since 4 years awarding prizes to the best accessible German-language web offers which thus become models for the discussion. Besides expert tests, the test procedure also includes tests with people with different disabilities.
Exclusion of people with learning difficulties and cognitive limitations
The definition of target groups in the WCAG2 explicitly refers to people with learning difficulties and cognitive limitations. On the level of principles and guidelines we find the requirements of this target group, but not on the level of success criteria. This is where the exclusion takes place. Though the success criterium 3.1.5 demands that additional contents is offered if the language level of the texts is above the secondary education level, this does not mean that the requirements of the target group with learning difficulties and cognitive limitations are met. Further, it remains unclear how it is made sure that the texts keep the required level.
Proposed Change:
Document: WCAG 2.0 Guidelines
Submitter:
lisa seeman <lisa@ubaccess.com> Affiliation:
UB access
Location: text-equiv-all
Comment:
Comment (including rationale for
proposed change):
Text equivalents for struggling students and people with LD are often of a very different nature to the SC described.
They would typically not have all included text, point out the key detail that someone needs to understand
Alt tags are often verbose, such as explaining or giving a sentence of context to a diagram. We often have multiple prodnotes (using HTML with Daisy XML as a base) for a single picture often linked to different regions
descriptive alt tags would be omitted – they would just confuse the user who we are trying to help identify key content and concepts.
Would such a page be conformant?
Note there are many more people with these needs than who are blind. And blind users are getting all the key information anyway.
Also note: Alt tags and prodnotes are a great way to put info in a page for LD without changing the general use
Proposed Change:
Create an alternative SC set for pages for people with LD.
Document: WCAG 2.0 Guidelines
Submitter:
lisa seeman <lisa@ubaccess.com> Affiliation:
UB access
Location:
Comment:
Comment (including rationale for
proposed change):
I think WCAG itself (agendas forms etc) need to be more usable for people with Cognitive Imparments like impaired short term /visual / auditory memory
If we can not make our own system usable then people with these impairments can not comment and affect the guidelines
It also clearly shows a lack of understanding of how to make content accessible for people with LD and Cognitive limitations
As a side note I have participated in a few W3C groups and I find WCAG the hardest for people with LD to participate in.
If anyone thinks I am unable to understand the concepts they should refer to http://www.w3.org/WAI/PF/GUI/roleTaxonomy-20060508.html
It is the presention that makes it inaccessible not the content
Proposed Change:
Document: WCAG 2.0 Guidelines
Submitter:
Gian Sampson-Wild <gian@tkh.com.au>
Location:
navigation-mechanisms-focus
Comment:
2.4.6: This should be at Level 1. Order of information is very important to both people who use screen readers and people with cognitive disabilities.
Proposed Change:
Move to Level 1