Edit comment LC-2673 for Accessibility Guidelines Working Group

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Comment LC-2673: Comment Shortname:; Commenter: Duff Johnson <djohnson@commonlook.com>; Message-id:; Section of the document concerned:

or; Refinement of the section concerned:; Status:
assigned to; Type:; Comment:
CONCLUSION

WCAG 2.0 is useful in the web context precisely because it’s web-centric. HTML developers can arrive at a reasonable understanding of how to apply WCAG 2.0 concepts more-or-less directly to the explicit structures of the HTML language and functional parameters of media files and JavaScript.

The WCAG2ICT is replete with unsubstantiated claims together with (seemingly) casual and ill-considered assumptions. Given that the document offers the wholesale application of technical concepts to technologies and contexts never envisioned by WCAG 2.0’s authors, these failures are catastrophic with respect to the current draft. This document cannot be regarded as a serious attempt to address accessibility specifications in non-web content and ICT.

This is simply the wrong mission for W3C and WAI, whose concerns are (rightly) web content.

Further development of the WCAG2ICT along the current lines will bring disrepute to W3C since this project falls so far out of W3C’s scope and expertise, and meshes so poorly with the subject at hand.

Accordingly, the WCAG2ICT should be entirely re-scoped and revised, moved to an appropriate body for further development, or terminated.; Related issues: LC-2663
(space separated ids); WG Notes: Previous proposed resolution: The W3C did not initiate the concept of applying WCAG outside of Web Content. Rather it was the US Access Board who noted that the guidelines for electronic documents and software in the TEITAC report paralleled WCAG 2.0. The Access Board has proposed that WCAG 2.0 be used as the standard for non-web content and software in the Section 508 refresh process. Current drafts of European Mandate 376 (M376) standards are following the US lead. The W3C is simply providing information about a W3C standard in response to the actions of the US Access Board and EU M376 standards development team. The task force work statement is consistent with the WCAG working group charter that includes the following under its scope: "Coordinating with other entities adopting and using WCAG 2.0." If you feel that WCAG 2.0 should not be used for non-web content and software, then we would suggest that you address your comments to the U.S. Access Board and EU M376 standards development team. RE PDF: PDF documents are web-content, and according to WCAG working group members PDF was always envisioned as being covered by WCAG 2.0 during its development -- and techniques have been documented for PDF. Earlier notes: Duff Johnson has been a public critic of WCAG for quite some time. He has posted on LinkedIN groups and tried to initiate momentum against WCAG 2 ... he is CEO of the company Netcentric which specializes in PDF accessibility. He is the chair of the PDF Achieving WCAG 2.0 with PDF/UA v1.01, and the ISO PDF accessibility standard PDF/UA v1.01, which he advances in place of WCAG for PDF, it has several significant deviations from WCAG including prescribed hierarchical headings. This response from him is totally predictable. (DM); Proposed Resolution: The W3C did not initiate the concept of applying WCAG outside of Web Content. Rather it was the US Access Board who noted that the guidelines for electronic documents and software in the TEITAC report paralleled WCAG 2.0. The Access Board has proposed that WCAG 2.0 be used as the standard for non-web content and software in the Section 508 refresh process. Current drafts of European Mandate 376 (M376) standards are following the US lead. Through this task force, the W3C is developing a common understanding of how WCAG 2.0 might apply to non-web ICT for organizations and entities who are already seeking to so adopt and apply WCAG 2.0. By doing this we increase the likelihood that these applications of WCAG 2.0 will be consistent, and in keeping with the Principles, Guidelines, and Intent of WCAG 2.0. If you feel that WCAG 2.0 should not be used for non-web content and software, then we would suggest that you address your comments to the U.S. Access Board and EU M376 standards development team. Comments on the use WCAG 2.0 for non-web content and software, can be sent to the U.S. Access Board and/or submitted as part of the EU M376 review process. RE: PDF; PDF documents are web-content, and according to WCAG working group members PDF were always envisioned as being covered by WCAG 2.0 during its development -- and techniques have been documented for PDF. ================== [WCAG WG] Comments ============== change the last sentence of the first paragraph The W3C created a task force that brought in ICT companies, and the M376 committee, and Access Board to join with WCAG member to create this guidance because it would both identify specific issues in apply WCAG 2.0 to ICT (documents and software) and increase the likelihood that these applications of WCAG 2.0 will be consistent, and in keeping with the Principles, Guidelines, and Intent of WCAG 2.0. and a NEW second paragraph Please note that the introduction points out (in paragraphs 7 and 2) that " This document does not seek to determine which WCAG 2.0 provisions (principles, guidelines, or success criteria) should or should not apply to non-web ICT, but rather how they would apply, if applied." also that " Although this document covers a wide range of issues, it is not able to address all the needs of all people with disabilities. Because WCAG 2.0 was developed for the Web, addressing accessibility for non-Web documents and software may involve provisions beyond those included in this document. Authors and developers are encouraged to seek relevant advice about current best practices to ensure that non-Web documents and software are accessible, as far as possible, to people with disabilities." change the last paragraph to If by "technologies and contexts never envisioned by WCAG 2.0’s authors" you are referring to PDF; PDF documents are web-content, and according to WCAG working group members, PDF were always envisioned as being covered by WCAG 2.0 during its development -- and techniques have been documented for PDF. However the Access Board is now considering applying them beyond the web which is why additional review and guidance was needed - which is what the WCAG2ICT was formed to provide.; (Please make sure the resolution is adapted for public consumption)