Part of Item:
Comment Type: TE
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?
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.
The description of conformance levels in WCAG 2 has been rewritten to clarify the levels ( see http://www.w3.org/TR/2007/WD-WCAG20-20070517/#overview-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.
*In general, Level A success criteria achieve accessibility by supporting assistive technology while putting the fewest possible limits on presentation. Thus people with a wide range of disabilities using a wide range of assistive technologies, from voice input and eye-tracking devices to screen readers and screen magnifiers, are able to access content in different ways. In other words, Level A success criteria support the ability of both mainstream and specialized user agents to adapt content to formats that meet their users' needs.
* The success criteria in Level AA provide additional support for assistive technology. At the same time, they also support direct access to content by the many people who use conventional user agents without assistive technology. In general, Level AA success criteria place more limits on visual presentation and other aspects of content than the success criteria in Level A.
*Level AAA success criteria increase both direct access and access through assistive technology. They place tighter limits on both presentation and content.
Because of the tighter limits that this success criterion places on content, we feel it is appropriate at level AAA.
We have added new success criteria addressing scalability of text:
Level AA: Visually rendered text can be resized without assistive technology up to 200 percent and down to 50 percent without loss of content or functionality.
Level AAA: Visually rendered text can be resized without assistive technology up to 200 percent and down to 50 percent without loss of content or functionality and in a way that does not require the user to scroll horizontally.
In addition, we have added advisory techniques to improve the legibility of text:
- Avoiding justified text
- Providing sufficient inter-line and inter-column spacing