Part of Item:
Comment Type: general comment
Comment (including rationale for proposed change):
We are concerned about Principle 3 â€śContent and controls must be understandableâ€?.
We appreciate the restructuring of WCAG2 into four general principles allowing more independence of technology. But we fear that in practice the focus will be exclusively on the success criteria. This risk should be countered.
We demand that the principles and the guidelines of WCAG2 are given more importance and value. The success criteria should be defined as one (of several) possibilities to secure the WCAG2. The limitations of the success criteria have to be pointed out. The focus should be laid on the assurance of the principles and guidelines.
Criticism on the success criteria of the third principle
In the more general formulations of the revised WCAG2, also those checkpoints of WCAG1 can be found which have already become law in many European countries. Comparing the concrete implementation recommendations of WCAG2 (the success criteria) with those of WCAG1 (the checkpoints), it shows for the area of understandability that the aspects relating to the contents have got lost: In WCAG1, the requirement 14.1 â€žUse the clearest and simplest language appropriate for a site\'s contentâ€ś has the highest priority. In WCAG2, the guideline 3.1 includes content aspects of readability and text understanding. In the success criteria for 3.1, however, these requirements are missing. The success criteria included in WCAG2 now represent only side aspects of understandability which can be technologically checked. The much more important aspects in the area of understandability can only be submitted to standardized tests on the basis of expertise and considering the specific target groups of the web offer. In Germany, this is established practice, and know-how is available. The certification procedure based on the BITV, the German adoption of WCAG1, as well as the BIENE Award procedure follow these requirements on the basis of German law demanding not only the implementation of the â€žconditionsâ€ś (corresponding to the checkpoints of WCAG1), but also the implementation of the â€žrequirementsâ€ś (corresponding to the guidelines of WCAG1).
The certification procedure of DIN CERTCO has been developed by leading representatives of science, practice and associations of people with disabilities. Beside the product quality of the web offer, also the process quality of the content tendance is evaluated. The BIENE Award is a competition carried out since 4 years awarding prizes to the best accessible German-language web offers which thus become models for the discussion. Besides expert tests, the test procedure also includes tests with people with different disabilities.
Exclusion of people with learning difficulties and cognitive limitations
The definition of target groups in the WCAG2 explicitly refers to people with learning difficulties and cognitive limitations. On the level of principles and guidelines we find the requirements of this target group, but not on the level of success criteria. This is where the exclusion takes place. Though the success criterium 3.1.5 demands that additional contents is offered if the language level of the texts is above the secondary education level, this does not mean that the requirements of the target group with learning difficulties and cognitive limitations are met. Further, it remains unclear how it is made sure that the texts keep the required level.
Thank you for the reference to the DIN CERTCO certification process and to the BIENE Award.
The working group has had difficulty developing success criteria for Principle 3 that are testable, human-language independent and that apply to all web pages, and that address the needs of people with different cognitive, language, and learning disabilities.
We have added language to the Introduction to highlight the fact that WCAG 2 only addresses some of the needs of people with cognitive, learning, and language disabilities, and calls 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. Since advisory techniques do not need to be testable or universal, we have been able to include techniques based on some of the BIENE requirements, as well as best practices suggested by researchers on cognitive, learning, and language disabilities. The new advisory techniques include:
*Using the clearest and simplest language appropriate for the content
*Avoiding centrally aligned text
*Avoiding text that is fully justified (to both left and right margins) in a way that causes poor spacing between words or characters
*Using left-justified text for languages that are written left to right
*Using appropriate justification for languages that are written right-to-left
*Limiting text column width
*Avoiding chunks of italic text
*Avoiding overuse of different styles on individual pages and in sites
*Making links visually distinct
*Using images, illustrations, video, audio, or symbols to clarify meaning
*Providing practical examples to clarify content
*Using a light pastel background rather than a white background behind black text
*Highlighting a link or control when the mouse hovers over it
*Avoiding the use of unique interface controls unnecessarily
*Using upper and lower case according to the spelling rules of the text language
*Avoiding unusual foreign words