Template for comments on WCAG 2.0 Last Call Draft and Support Documents

Commenter: Lisa seeman

Email: lisa@ubaccess.com

Affiliation: Invited expert at W3C, UB access

Date: May 17 2006


Please ensure that the comments submitted are as complete and "resolvable" as possible. Thank you.

Document Abbv. (W2/UW/TD)

Item Number (e.g. 1.1)

Part of Item (Heading)
Comment Type (G/T/E/Q)
(Including rationale for any proposed change)
Proposed Change (Be specific)
 W2 3.2.2

Level 1 Success Criteria for Guideline 3.2

Some widgets - such as a tree, the tab order will and should change when a component is expanded. It make no sense to say that that is not OK unless it is not predicable.
As AT becomes used to these widgets, instruction will not be required
Changing the setting of any form control or field does not automatically cause a change of context (beyond moving to the next field in tab order or behavior for a progamaticly determinable widget type.), unless the authored unit contains instructions before the control that describe the behavior
 W2 3.2.

Level 1 Success Criteria for Guideline 3.2

I am concerned that level 1 SC will act against automatic help and combined with information hiding. For example when  information is hidden unless you  focus on the element in question, and then all the sub information about it is given.

If you do not hide the information then the page becomes busy and you can not see what the main points are. If the user has a two strep process to access the information, then they may never receive it.

As with many SC, they are OK if you read the definition, but if you just read the text it is misleading
change the term "change of  context" to "confusing change in context"
the definition can remain the same
 W2 1.2

I am concerned that the requirement for real time synrcrization put a lot of extra work on authors who would like to provide short animations or clips that help people with learning disabilities fulfill a task.
On the whole, a lot of  multi media, especially in education,  is good for many learning disabilities, and these requirements may act as a step backwards for learning disabilities.

Make an exception in  1.2 for any content provides extra help visual  for  tasks and information that has been described in text else wear.
 W2 3.2.
to my mind the most important aspect if predictability is exposing to the user agent what each thing is.  That way the interface can be tailored to the user's access strategy.
 If XHTML 2 roles are known - what is main and what is secondary navigation, then  the order becomes less important
add success criteria

Terms in the document often seem to mean something a bit different, until you read the definitions. As WCAG is often quoted the terms themselves should be as close to clear language as the can be without viewing the definitions.
change the term "programticly determined", to "supported by Assistive technology".
 W2 3.2.3

. Adaptive interfaces are a good thing. sometimes change is because we know more about what the user likes ..change the wording
...occur in the same relative order each time they are repeated, unless a change is initiated by the user or may  benifit the user
 W2 http://www.w3.org/TR/WCAG20/Overview.html
To get to CR (candidate recommendation we believe two things are required.
1, Concrete checkpoints or list of requirements
2, Tests that completion of the minimum requirements of  success criteria at each level will make sites  progressively usable for people with disabilities listed in the overview.
Create a list of "what to do" checkpoint


·         Level 3 success criteria:

1.      Achieve additional accessibility enhancements.

2.      Can not necessarily be applied to all Web content.

I object to definition . Because many criteria are level 3 only because they are considered too hard to do on all web content does not mean that level 1 and two achieve minimal and enhanced accessibility.
Level 3 is also minimal accessibility

 change of wording
Level 3 success criteria:

1.      Achieve minimal accessibility ,   or, if the Success criteria can be applied to all Web content, achieves additional accessibility enhancements.

2.      Can not necessarily be applied to all Web content.

 W2 http://www.w3.org/TR/WCAG20/Overview.html introduction

The claim in http://www.w3.org/TR/WCAG20/Overview.html learning difficulties, cognitive limitations,

However the checkpoints towards understandability  even at level 3 addresses only secondary education level – in other word usable for mainstream people without these  disabilities. The basic mechanism for simplifications have not been included, or use of symbols or conversion to symbols. Also left out are  use for  controlled languages

The result: I read a lot of complex specification. I am even writing W3C specifications, but WXAG is the only on that I can not follow though because of my  disability. I ca understand the concepts, but the presentation requires remembering  what technique 3.1.3 was for, and then (if I forgot what 3.2.3 stood for, going back to the original guidelines finding it, hopefully not confusing it with 1..3.2  etc – why because WCAG are following there own specifications, so I, as a person with a disability ,  can not use their material.

 to say “this document contains principles, guidelines, and success criteria that define and explain the requirements for making Web-based information and applications accessible” and to include learning difficulties, cognitive limitations  is  an insult to anyone with learning memory or cognitive impairments. there are many clear sets of guidelines that do that. WCAG is not one of them.

Practical proposal – state clearly that learning difficulties, cognitive limitations are not fully addressed beyond a very limited way.  Then work on a extended guideline, be it optional and untestable, success criteria that does the job.   


1.       Identifying changes in natural languages USING a technology-specific technique listed below AND Identifying text direction of passages and phrases USING a technology-specific technique listed below (for a technology in your baseline) "


The example is an odd one because always, when changing direction, you are changing characters and there for  it is , by definition programticly determined


More over bILI languages change direction all the times whenever numbers are used. Are you really expecting each number to be in it’s own span? Why not follow the standard  BILI algorithms

Remove this paragraph