Part of Item:
Comment Type: GE
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.
1. Omit the concept of a baseline from the document.
2. Accommodate other - and in many cases much larger - user groups than merely the visually disabled. Complement the text alternative requirement with requirements for other alternatives including simplified text and sign language.
3. Decide whether and which of the level 3 success criteria are important. Leave out the unimportant and make the rest mandatory for gaining triple-A conformance status.
1. The notion of baseline (now referred to as "accessibility-supported Web technologies") is not an attempt to weaken the guidelines or create less inclusive environments. It is a recognition that the level of support in browsers and assistive technology is constantly changing, and that any attempt to define "accessible technologies" based on the support available at the current time will deprive people with disabilities from the benefits of on-going innovation on the internet. For instance, we want all users to benefit from the use of CSS. At the time that WCAG1 was published, user agent support was not sufficient to include CSS in acceptable technologies.
2. We believe the guidelines address a wide range of physical disabilities, including deafness, hearing impairments, mobility impairment, and seizure disorders. The reliance on text is because it is the format that lends itself best to rendering in a wide variety of modalities. Text can be converted to speech, rendered on braille displays, or displayed visually. It may facilitate translation of text into different language levels at some point. This does not mean that providing a text representation solves all accessibility problems.
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 3 new success criteria in this area.
3. The definition of triple-A conformance has been changed to require all level AAA success criteria.