RE: CFC - Publish WCAG2ICT First Public Working Draft

Hi Andrew,

Please correct me if I’m wrong but I think the current APCA-W3 is limited to web content only (and on self-illuminated displays only), and WCAG2ICT is specifically intended for other contexts – apart from the fact that we can’t have WCAG2ICT deviate from WCAG itself, your suggestion does not seem workable to me.

Also, I believe the APCA-W3 license only covers use in WCAG and not in other documents (including other technical standards that adopt WCAG2ICT, such as EN301549) but I guess that is more of a logistical question on licensing terms and agreements.

Best,
  Shadi

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Shadi Abou-Zahra
Amazon Devices and Services
Principal Accessibility Standards and Policy Manager
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From: Andrew Somers <Andy@GeneralTitles.com>
Sent: Thursday, 3 August, 2023 10:34 AM
To: WCAG list (w3c-wai-gl@w3.org) <w3c-wai-gl@w3.org>; public-silver@w3.org
Cc: Chuck Adams <charles.adams@oracle.com>
Subject: RE: [EXTERNAL] CFC - Publish WCAG2ICT First Public Working Draft


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-1
Objection.

This is the first opportunity I’ve seen to weigh in on this.

SUMMARY

While it has been established that WCAG 2.x is bound to require a certain backwards compatibility, that does not mean we must promote SCs that are unsupported by modern science into yet another new document, to continue to wreak havoc and misunderstanding in the accessibility and designer/developer communities regarding this important topic.

Thank you,

Andy

Additional Reading For a Deeper Dive:
_____________________
BACKGROUND

My objection is rooted in my long-standing objections¹ to certain WCAG 2.x SCs which can be harmful to readability, as well as being confusing, not aligning with human perception, and resulting in unintended consequences²⁻³. For WCAG those include 1.4.3 and 1.4.11, regarding the present document, these are 6.1.5.4 and 6.1.5.8

6.1.5.4 (1.4.3) does not predict nor align with the human perception of contrast on self illuminated displays, and in fact the values it generates can create conditions that are harmful to readability, particularly for those with color vision deficiencies such as protanopia⁴. 6.1.5.8 (1.4.11) also ignores the primary drivers of contrast perception, the spatial characteristics⁵, which arguably are most important for non-text. 1.4.11 reuses the faulty math and an arbitrary threshold from 1.4.3, citing an unpublished self-referential document for support. (The cited informal email actually implies the importance of spatial characteristics, but not otherwise recognized/developed in that SC.)


NOT JUST ME

Independent peer review demonstrates that with a set of thousands of random color pairs, 47% that “pass” WCAG2 should instead be rejected. Paradoxically, ~22% that are rejected should pass⁶, and in fact are demonstrably better for color vision deficiencies than the related colors that were incorrectly passed.

And no peer review is required to see that 1.4.3 does not properly calculate nor predict useful colors for the increasingly popular dark mode—in this use case adhering to the WCAG2.x contrast results creates an unreadably poor contrast value for all users, not even considering impairments⁷. This becomes important for automation.⁸




AUTOMATION

Of course, no designer or developer would intentionally use such poor colors (this being one big reason the design community has disregarded WCAG 2.x), but the need for and push for automated color adjustment demands a functional replacement for WCAG 2.x contrast, referred to as "not-fit-for-purpose” as one peer reviewer stated.⁹

Automation or automated color selection, such as that envisioned by the CSS color-contrast() function, absolutely requires a perceptually uniform prediction method. Without it, automated color adjustment becomes meaningless and unreliable.

One example is that of spreadsheet automatic text color, flipping from black to white, depending on the background cell color in a spreadsheet. WCAG 2.x contrast puts that flip point at a significantly incorrect value, resulting in poor to unreadable combinations. And here is an example of an unintended consequence: an application that is doing the color flip accurately will degrade the user experience if the app is modified to instead use the invalid flip point resulting from WCAG 2.x


HOW TO CORRECT

There are other methods¹⁰ and guidelines written¹¹ which have been subject to public testing for years, and have ample third party and peer review, including a recent journal-published review.¹²

At this point, there is no valid reason to create new documents that cite obsolete methods, nor is there a reason to demand backwards compatibility here.

A “simple” replacement method is the Bronze Simple Mode<https://readtech.org/ARC/tests/bronze-simple-mode/?tn=intro>¹³, developed as a way to use perceptually uniform contrast prediction methods, with a guideline of simple thresholds similar to the WCAG 2.x SCs (no lookup table). This is a criterion that echos the simplicity of WCAG 1.4.3 but is, at the very least, using perceptually uniform math/methods.


References:
1. https://github.com/w3c/wcag/issues/695

2. https://tangledweb.xyz/please-stop-using-grey-text-3d3e71acfca8?sk=7caf4a84900aec25cfec31bf6fa996af

3. https://uxdesign.cc/better-reading-on-the-web-c943c4cfc91a?sk=f84c349a331d0290028cb76cca36615e

4. https://tangledweb.xyz/whats-red-black-also-not-read-573b9c0a97ed

5. https://www.smashingmagazine.com/2022/09/realities-myths-contrast-color/

6. https://www.cedc.tools/article.html

7. https://github.com/Myndex/SAPC-APCA/discussions/30#discussioncomment-1888870

8. https://github.com/w3c/csswg-drafts/issues/7310#issuecomment-1145775322

9. https://github.com/w3c/low-vision-a11y-tf/discussions/131#discussioncomment-1553545

10. https://apcacontrast.com

11. https://readtech.org/ARC/

12. https://git.myndex.com/#apca-peer-review--third-party-discussion

13. https://readtech.org/ARC/tests/bronze-simple-mode/?tn=intro




Andrew Somers

Senior Color Science Researcher

PerceptEx Perception Research Project<https://www.myndex.com/perceptex/>

redacted for public list



On Aug 1, 2023, at 1:05 PM, Chuck Adams <charles.adams@oracle.com<mailto:charles.adams@oracle.com>> wrote:

Call For Consensus — ends Monday August 7th at midday Boston time.

We previously agreed upon accepting the First Public Working Draft of WCAG2ICT.  No concerns were raised in our pre-cfc email.

This call is to approve publishing the First Public Working Draft of WCAG2ICT.  The draft document can be viewed here:  https://w3c.github.io/wcag2ict/


Kind regards,
Charles Adams



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