Disposition of Comments from WCAG WG Review

Website Accessibility Conformance Evaluation Methodology (WCAG-EM),
Editor Draft, 30 July 2012, 30 August 2012, 4 September 2012 and 10 September 2012

This is a disposition of comments recevied from the WCAG WG publication approval survey on the Website Accessibility Conformance Evaluation Methodology (WCAG-EM), Editor Draft 30 July 2012. This page is intended for internal discussion by the WCAG 2.0 Evaluation Methodology Task Force (Eval TF).

A new Editor Draft was proposed in an answer to the comments by WCAG WG. As a result of the new editor draft, (WCAG-EM), Editor Draft 27 August 2012, WCAG WG did a new WCAG WG publication approval survey. At the 30 August Telco of WCAG WG discussion we discussed 4 open comments that needed further attention and discussion (Comment #5, Comment #7, Comment #12 and Comment #13). Subsequent changes have been made to the (WCAG-EM), Editor Draft 3 September 2012. After the 6 September Telco of WCAG WG, a number of comments and proposed solutions were discussed. We have tried to address these comments in the new Editor Draft of 10 September 2012 and subsequently in the Editor Draft of 15 September 2012.

Open Comments

All comments have been addressed

Comments from WCAG WG

Listing of the comments from WCAG WG- and their proposed resolutions
ID Commenter Location Status Priority Current Text Suggested Change Rationale Resolution
1 Michael Cooper (in questionnaire) General Closed Medium Editor notes "Will editors' notes be kept or removed for publication? They seem mostly internal comments, not public, so suggest remove." They seem mostly internal comments, not public

Resolution: Editor notes not intended for the public have been removed in the 27 August 2012 Editor Draft

Rationale: Some editor notes are intended for the public while others are intended for internal discussion; the latter will be removed

2 Michael Cooper (in questionnaire) General Closed Medium Comments that indicate "needs approval" in the Editor Draft Will everything that says "needs approval" be approved or removed before publication?  

Resolution: Most removed in the 27 August 2012 Editor Draft. Rest will be removed before publication.

Rationale: These Editor Notes are intended for internal discussion and will be removed before publication

3 Michael Cooper (in questionnaire) 2.1 Scope of Applicability Closed Medium "However, this methodology may not be applied to a website excluding any of its parts." [...] Instead of saying "don't exclude parts of a site" I think it would be better to go into more detail about why we want people to be careful to include everything [...] The following section "2.1.1 Particular Types of Websites" helps with the above, so maybe they just need to tie in better.

Resolution: Editorial changes made in the 4 September 2012 Editor Draft.

Rationale: Editorial refinements to provide better clarity

Note: See also Comment #31

4 Michael Cooper (in questionnaire) Sections 1.3, 2 introduction and 4.1 Closed Medium Throughout I'm unclear on the relationship between this document and http://www.w3.org/WAI/eval/ [...] if the content there is so important, it should be incorporated into the main document [...] these two resources should merge, or the distinctions between them made much more clear

It keeps pointing out to that document for more detail [...] if the external document is valuable because it's easier to organize and maintain.

Comment repeated after 30 August Editor draft.

Resolution: No change

Rationale: The W3C/WAI Evaluation Resource Suite provides complementary background and guidance for other types of evaluation (especially "Preliminary Reviews"). All references to that suite are in optional sections of the document or made in other ways that do not cause direct dependencies on these resources. W3C/WAI guarantees persistency of these resources though the detailed content of these resources may be updated with time to better reflect current paractices.

5 Michael Cooper (in questionnaire) Diagrams Closed Medium content-bearing diagrams need longdesc or text conveying their information right by them content is not adequately covered by alt text

Resolution: Changes made by adding text conveying their information right by them and adding alt-attribute referring to text that is directly next to the image.

Rationale: Very relevant comment

6 Michael Cooper (in questionnaire) "Requirements" throughout Closed Medium example: Requirement 1 don't think it is meaningful to have a requirement that says "follow other requirements", and it makes it harder to understand what that requirement requires, if anything If requirements are broken into sub-steps, then only the sub-steps need to be presented as requirements.

Resolution: No change

Rationale: This hierarchy of requirements helps emphasize the required and optional steps of the evaluation procedure; Eval TF will consider editorial improvements to achieve this goal in future drafts

7 Michael Cooper, Loretta Guarino Reid, David MacDonald, and Gregg Vanderheiden (in questionnaire) "Requirements" throughout Updated High term "requirements" renaming requirements as recommendations would be good

[...] use of "requirements" is a bit strong for a non-normative document [...] If we were to keep them as requirements, I would push back on a number of them as going too far for a resource that will be used in so many different scenarios

I find the use of the work "requirement" odd. It makes it feel like the focus is on whether you are applying this methodology correctly, rather than whether the methodology is effective for evaluating web sites.

It is an informative document but there is normative language "must, Requirements #" etc...

This is being released as a NOTE but it is written like a "STANDARD PROCEDURE" with requirements etc. it should be either changed to a standard and processed as such -- or rewritten to be more notelike (informative but not requiring anything)

Resolution: Changed to Methodology Requirement and made substantial changes to the Abstract and Introduction sections in the 4 September 2012 Editor Draft to better clarify that these are not normative, nor additional WCAG 2.0 requirements (as suggested during the WCAG WG Telco of 30 August 2012)

Rationale: Re-emphasizes that these requirements are only for the methodology and not additional WCAG 2.0 requirements

Note: See also Comment #12

8 Michael Cooper (in questionnaire) Introduction of section 3 Closed Low     I like the depth of detail this document now has, it seems much more useful than previous versions

Resolution: Thanks for the positive feedback

Rationale: N/A

9 Michael Cooper (in questionnaire) Introduction of section 3 Closed Medium   add a flowchart or process diagram that shows the steps of the methodology (with appropriate longdesc of course) It's hard to envision and comment on the methodology as a whole with just a linear text version. I wouldn't say this is a requirement before the next TR publication, would like it on the radar. Consider that it may help reviewers out and facilitate collecting more substantive comments.

Resolution: No change

Rationale: A provisional diagram is provided in intro of section 3; we will consider improvements to this diagram in future drafts; we welcome specific comments on refining it for future publications. Help is proposed by WCAG WG

10 Michael Cooper (in questionnaire) Section 3.4.3 Step 4.c Closed Medium "3.4.3 Step 4.c: Assess Accessibility Support for Technologies" this section needs to provide more guidance, hopefully including references to planned resources like accessibility support database I know this is a tough one, but the note that this section is complete concerns me

Resolution: No change

Rationale: This guidance goes beyond the scope of this document, as it is applicable to many situations rather than post-development conformance evaluation alone; we recommend this guidance be developed as additional WCAG 2.0 guidance, ideally as part of Understanding WCAG 2.0 or similar supporting materials so that we can reference it from this document

Note: The editor note that "this section has been completed" is purely for internal review, to help Eval TF participants quickly identify the changes made between drafts; it will not remain in the document and is not to be interpreted as an absolute statement (hence "completed" rather than "complete")

11 Michael Cooper (in questionnaire) 3.5.3. Step 5.c Closed Medium "The score is the ratio of the Success Criteria met over all applicable Success Criteria" What is "applicable" needs to be defined. Is it all SC for a given conformance level? Or can you exclude e.g., 1.2.x SC if you don't use media? Since many of the SC are worded so they are met if they are what I would call "not applicable", the definition of applicable has to be very clear if it is to be used in a calculation.

Resolution: No change

Rationale: The corresponding sections always start with "applicable as per 3.1.3 Step 1.c. Define the Conformance Target"; repeating this at the end of the same paragraph adds unnecessary redundancy and complexity. A note on the test result "not applicable" is provided in section 3.4.1

12 Michael Cooper and Loretta Guarino Reid (in questionnaire) Section 5 Closed High  

Need to find some other term than "conformance"

I agree with Michael's discomfort with the use of the term conformance. If nothing else, there seems to be potential confusion between evaluating whether a web site conforms to WCAG via this methodology, vs whether the methodology used to evaluate the web site conforms to this methodology. If the focus is on the latter, the introductory material need to be very clear that this is one approach to evaluating conformance, rather than general guidance about conformance evaluation methodology. The current document title is ambiguous.

Section "5. Conformance with this Methodology" implies there is a conformance model. That is by definition not true, since this is a non-normative document.

Resolution: Changed to "Application of this Methodology"

Rationale: Replace the word conformance.

Note: See also Comment #7

13 Bruce Bailey (in questionnaire) Section 1.4 Terms and Definitions Closed Medium "Template: A specific page that provides a more or less fixed framework for content. Templates are mostly used to provide the basic components of a web page (logo, menu, layout, skip links etc.). Templates are often filled with content." Please coordinate definition of “template” with ATAG.  

Resolution: We used definition from ATAG

Rationale: Important to seek alignment with other WAI resources

14 Andrew Kirkpatrick (in questionnaire) 3.1.5 Step 1.e: Define the Techniques to be Used (Optional) Closed Medium  

I can't review this whole document now, but I went looking for this and liked this section - we need more clear statements like this

 

Resolution: Thanks for the positive feedback

Rationale: N/A

Note: This section in 27 August 2012 Editor Draft has been further refined

15 Loretta Guarino Reid (in questionnaire) Section 1.2 Closed Medium  

Nit: why is Methodology capitalized in "People who want to use the Methodology for ..."

 

Resolution: Changed to lower case in the 27 August 2012 Editor Draft

Rationale: Typo

16 Loretta Guarino Reid (in questionnaire) Section 2.1 Scope of Applicability Closed Medium   I don't understand the importance of requiring a full, self-enclosed website. I'm not even sure what self-enclosed means - no links to any external web pages? This seems pretty restrictive. Why is any additional constraint required beyond WCAG's conformance claim?  

Resolution: No change

Rationale: As per section 1.1 Scope of this Document, this methodology "focuses on only one aspect of evaluation within the development process, which is the accessibility evaluation of an already existing website"

Note: Some editorial updates have been made to the Abstract and Introduction sections in the 27 August 2012 Editor Draft

17 Loretta Guarino Reid (in questionnaire) Section 2.1 Scope of Applicability Closed Medium "Note: According to WCAG 2.0 it is possible to make a "Statement of Partial Conformance" for third-party content and languages lacking accessibility support. However, these parts must still be included in the scope of evaluation [..]". I don't understand the note about partial conformance. If you include these in the pages covered by a conformance claim, nothing can conform. Partial conformance claims are just advisory information about pages that do not conform to WCAG 2.  

Resolution: Changed to "Note: WCAG 2.0 defines "Statement of Partial Conformance" for individual web pages that are known not to conform with WCAG 2.0 due to third-party content and/or languages lacking accessibility support. Such web pages may not be excluded from the scope of evaluation according to this methodology. In some cases this means that the website as a whole does not conform with WCAG 2.0 due to only partially conforming web pages. Section 3.5 Step 5: Report the Evaluation Findings provides more guidance on reporting evaluation results and making accessibility statements for entire websites." in the 27 August 2012 Editor Draft and changed to only due to in 3 september 2012 Editor Draft

Rationale: Agree that this section needs further clarification. We mean that one cannot claim conformance over a website by out-scoping part of a website or a webpage, especially parts that are known not to conform. Many people misunderstand the concept of "statement of partial conformance" in this context hence we felt it needs to be explained in this section

18 Loretta Guarino Reid (in questionnaire) Section 3.3.2 Step 3.b. Closed Medium "select at least two distinct web pages with the following features each (where applicable and available)"

3.3.2 Requirement 3b - what if there are not two distinct web pages for some feature?

 

Resolution: No change

Rationale: The text says "where applicable and available"

19 Loretta Guarino Reid (in questionnaire) Section 3.4.1 Closed Medium "Note: According to WCAG 2.0, Success Criteria that do not apply to the content are deemed to have been met."

The note in 3.4.1 is confusing. "do not apply" is an ambiguous term.

 

Resolution: Changed to ""Note: According to WCAG 2.0, Success Criteria to which there is no matching content are deemed to have been satisfied. An outcome such as 'Not Applicable' may be used to denote the particular situation where Success Criteria were satisfied because no relevant content was applicable", and added link to the definition of "satisfy" in WCAG2.0 in the 27 August 2012 Editor Draft

Rationale: "do not apply" has been changed to "no matching content", and further refinements have been made in response to Eval TF Comment #22

20 Loretta Guarino Reid (in questionnaire) Section 3.4.1 in final Note Closed Medium  

3.4.1

Typos: "parts a website" -> "parts of a website" , "on on" -> "on"

 

Resolution: Changed as suggested in the 27 August 2012 Editor Draft

Rationale: Typos

21 Loretta Guarino Reid (in questionnaire) Section 3.4.2 Closed Medium  

3.4.2 Requirement 4.b seems like it is addressed to the developer rather than the evaluator. What are you trying to say here?

 

Resolution: Changes to this section in 27 August 2012 Editor Draft have been made have been in response to Eval TF Comment #29

Rationale: This section tries to explain the use of WCAG 2.0 techniques by evaluators. Making improvements to the guidance in Understanding WCAG 2.0 and How to Meet WCAG 2.0, in particular with regard to "common failures", would benefit readers of this document as well as many more situations.

22 Loretta Guarino Reid (in questionnaire) Section 3.4.3 Closed Medium  

3.4.3, Step 4.c: Accessibility Support applies to techniques, not technologies. Please edit this section title so it doesn't reinforce the idea that entire technologies should be rejected on accessibility support grounds.

 

Resolution: Changed to "accessibility features"; This section in 27 August 2012 Editor Draft has been further refined accordingly

Rationale: WCAG 2.0 refers to "Web content technology (or feature of a technology)" in the definition for "accessibility supported" and elsewhere.

23 Loretta Guarino Reid (in questionnaire) Section 3.4.4 Closed Medium  

3.4.4 Requirement 4.d seems both onerous and not well motivated. Where must such copies live? for how long must they be saved? etc. Particularly when a web site is updated to address problems found, do copies need to be made every time there is a change anywhere?

 

Resolution: No change

Rationale: This section is optional and provides guidance on good practice. Where the copies live and for how long is irrelevant to the methodology; it help an evaluator in case of disputes. Copies do not need to be updated because they only need to backup statements made by the evaluator at the time of evaluation. We may consider editorial improvements to this section in future drafts.

24 Loretta Guarino Reid (in questionnaire) Section 3.5.3 Closed Medium  

it isn't clear to me how useful this sort of score is. A few very minor errors can produce a low score by this metric.

 

Resolution: No change

Rationale: We are particularly looking for public comments and input on this section. This optional section is included due to numerous requests and as per scope of the Eval TF Work Statement

25 Loretta Guarino Reid (in questionnaire) Section 3.5.4 Closed Medium  

Requirement 5f: If the methodology requires machine-readable reports, it seems like there should be something in the methodology that uses these reports.

 

Resolution: No change

Rationale: This section is optional and provides guidance on good practice. Reports are the output of an evaluation methodology rather than input. We could decide to add more information for this in a later draft.

26 Loretta Guarino Reid (in questionnaire) Sections 1.3, 2 introduction and 4.1 Closed Medium  

For the purposes of the methodology, what is the distinction between preliminary reviews and other reviews? It feels like there is some tensions between using the methodology as a way to assess the status of a web site and a way to report the status of a web site.

 

Resolution: No change

Rationale: This methodology is a way to assess the conformance of entire websites and report their status. Preliminary evaluations are coarse assessments to get an initial impression of the status. It specifically states "A preliminary review does not check every accessibility issue and will not catch all of the problems on a site. Thus the method described in this page is not sufficient to determine if a Web site conforms to Web accessibility guidelines."

27 Loretta Guarino Reid (in questionnaire) throughout Closed Medium  

Formatting issue: I'm finding many of the lists of steps very hard to read, since the names of the steps themselves contain complex numbers and colons. Perhaps such lists should be enumerated instead of inline.

 

Resolution: No change for this publication

Rationale: We plan to work with EOWG to refine the formatting for the next publication

28 David MacDonald (in questionnaire) Requiremetnt 1.e Closed Medium   Not sure I understand this [...]  

Resolution: Changes to this section in 27 August 2012 Editor Draft have been made in response to Eval TF Comment #29

Rationale: This section tries to explain the use of WCAG 2.0 techniques by evaluators. Making improvements to the guidance in Understanding WCAG 2.0 and How to Meet WCAG 2.0, in particular with regard to "common failures", would benefit readers of this document as well as many more situations.

29 Gregg Vanderheiden (in questionnaire) Abstract Closed Medium "This document specifies an internationally harmonized methodology for evaluating the accessibility conformance of websites to the Web Content Accessibility Guidelines (WCAG) 2.0." this has to be reworded.

1. WCAG conformance is page by page -- which is specifically forbidden by this document/method.

2. Addition in Survey 30 August 2012: "Can you include something that states clearly that WCAG does *not require* conformance of whole websites -- but conformance can be for independent pages of independent processes?"

Resolution: Significant changes have been made to the Abstract and Introduction section in the 4 September 2012 Editor Draft (as suggested during the WCAG WG Telco of 30 August 2012)

Rationale: This methodology is intended to provide guidance on evaluating the conformance of entire websites rather than individual web pages (which is already covered by WCAG 2.0), and making WCAG 2.0 Conformance Claims on such (typcially large) collections of web pages (as defined by WCAG 2.0); clarification of this seem necessary to avoid confusion

30 Gregg Vanderheiden (in questionnaire) 3.2.2 Step 2.b Identify Key Functionalities of the Website Closed Medium Key Functionality and even worse "Primary Functionality" sampling should probably happen based on usage-weighted pages

sounds like very dangerous Concepts - and are often used to limit what needs to be made accessible [...] predetermination of what is important is dangerous.

Added comment to this one in the WCAG WG survey of the 27 August Editor Draft.

Resolution:

1) Changed "Key Functionality" to "Common Functionality" in Changes to 27 August 2012 Editor Draft

2) Open issue to further discuss the definition or use of "Common Functionality" for future publications

Rationale: It was not the intent to limit the usability of a website for people with disabilities but in many situations sampling is necessary to manage the evaluation of many web pages and theor states. Unfortunately usage-weighting alone seems insufficient to select representative sample. This issue needs more discussion to improve the concept in future drafts. Due to comments from WCAG survey of 27 August Editor Draft, we will discuss other better terminology after this draft.

Note: See also Comment #34

31 Gregg Vanderheiden (in questionnaire) 2.1 Scope of Applicability Closed Medium However, this methodology may not be applied to a website excluding any of its parts.   Why? you can claim conformance to part of a web site.. so why not evaluate that.

Resolution: Editorial changes made in the 4 September 2012 Editor Draft

Rationale: Editorial refinements to provide better clarity

Note: See also Comment #3

32 Gregg Vanderheiden (in questionnaire) 2.1 Scope of applicability Closed Medium "Release version 1.5.3 of Online Reservations System (ORS) application" Does this have an http:// address? if not is it a web page?  

Resolution: No change

Rationale: It could several web pages or a web application in a single webpage (with a single URI). All parts of this web application are seen to be a single entity, defined as a website for the purpose of this methodology

33 Gregg Vanderheiden (in questionnaire) Section 2.1.1 Closed Medium "Such website versions can be considered as individual websites rather than sub-sites for the purpose of this document."

Website in Multiple Versions
... Such website versions can be considered ... [CAN or SHOULD or ???]

 

Resolution: No change

Rationale: Can be. It is a choice. This could mean that a commissioner will ask the evaluator to look at only one version. That would then be possible

34 Gregg Vanderheiden (in questionnaire) Section 3.2.1 Step 2.a Closed Medium "3.2.1 Step 2.a: Identify Key Web Pages of the Website"


should be RETITLED as 3.2.1 Step 2.a: Identify COMMON Web Pages of the Website

 

Resolution: Changed in 27 August 2012 Editor Draft

Rationale: This is more inline with the intended meaning

Note: See also Comment #30

35 Gregg Vanderheiden (in questionnaire) Section 3.2.2 Step 2.b Closed Medium 3.2.2 Step 2.b: Identify Key Functionalities of the Website What about all the other functionalities of the site? not important? Suggest they change this to just 3.2.2 Step 2.b: Identify Functionalities of the Website" and have it identify all of the functions that the web site offers to the public/user -- to ensure all functionalities are accessible. We don't say "ensure that the KEY or PRIMARY rooms in a building are accessible."

Resolution: No change; See also Comment #34

Rationale: For many websites, especially complex web applications, it is not manageable (nor necessary) to identify every function and corresponding code path; The intent of this section is to ensure adequately representative coverage of the functionality. This needs more discussion as per Comment #34.

36 Gregg Vanderheiden (in questionnaire) Section 3.2.3 Step 2.c Closed Medium 3.2.3 Step 2.c: Identify the Variety of Web Page Types and 3.2.4 Step 2.d: Identify Web Technologies Relied Upon Excellent  

Resolution: Thanks for the positive feedback

Rationale: N/A

37 Gregg Vanderheiden (in questionnaire) Section 3.3 Step 3 Updated Medium "3.3 Step 3: Select a Representative Sample" change it to "3.3 Step 3: Select a Sample that is Representative of the Range of content and format" you have a constructed or structured sample -- so it will not be representative.

Resolution:Add to review note in section 3.3 Step 3 about sampling that we are planning to add a random sampling approach to the next version

Rationale: We plan to discuss sampling in much more detail for the next version of the document.