Email: IBM Comments on WCAG 3.0 Draft (9 - Requirements)

[cwadamsoforacle]

Comment from email:
Requirements
The following comments have to do with the Guidelines and outcomes, and methods:
• We support the incorporation of ATAG and UAAG methods, provided the applicability to user agent vs authoring tool vs author is crisp and clear. This helps provide a bigger picture of how all of the accessibility pieces fit together, so a reader can get an understanding of how all of the parts need to be in place for the accessibility to work properly. However, in the current examples it isn’t clear what aspects of the requirements are the responsibility of content/application owner vs. browser/user agent owners.
• Flattening the hierarchy of Levels (A, AA, AAA) into single set of requirements is contradictory to previous WCAG 2.x conformance level guidance that says: “It is not recommended that Level AAA conformance be required as a general policy for entire sites because it is not possible to satisfy all Level AAA Success Criteria for some content.”

In addition, not having a hierarchy of Levels (A, AA, AAA) for guidelines or outcomes gives them all equal weight in the scoring system, and it shouldn’t. This means that teams won't know what criteria are most impactful, which to implement first, etc. that are implied by having the levels. It may cause adoption of AAA success criteria to the detriment of other important criteria to try to score well in certain functional categories to obtain a Bronze level.
• In response to the questions regarding captions:
o Should the scoring of essential videos have more important/higher weight than captions on advertising and promotional videos?
Response: There is some concern whether everyone viewing or testing a site would deem the same videos as essential. In addition, many advertising or promotional videos are 3rd party content that are not controlled by content authors of a web page or site. It seems unfair that the site or service be held accountable for the potential score of such content.
o Are burned-in captions equivalent to closed captions or should they be scored lower?
Response: Burned-in captions, if they are of high quality, are nearly equivalent for the requirement of having captions, so should be scored either the same or slightly lower (as they are not available to users who are deaf-blind). Other requirements for being able to adjust the font, color, or placement should be separately judged and reported. Obviously, burned-in captions wouldn’t support any user adjustments for captions. One way to handle this is to have Bronze level be provision of accurate captions, in whatever form. Silver and/or Gold support for this requirement could be providing the personalization.
• Structured content: Structured content is helpful to everyone, but not all content lends itself to having headings. For example, dialogs, forms, etc. In such cases, headings aren't needed so requiring all content to be organized into headings is not always a desired direction. When there are application controls, these also don’t need to have a heading. As an example, if the controls are grouped into a UI Control (e.g., menus or toolbars) a heading isn’t necessary. However, we do agree that where larger quantities of information are contained in the view, headings are one good way to visually and programmatically organize the content. Be careful that the standard doesn’t require headings everywhere, when there are clearly situations that are perfectly accessible and understandable without their presence. Also, technically the example shows menu “headings” but, in reality, it’s a structure of menu with sub-menus where the higher level menu is a higher level “category” of the sub-menus. There may also be “categories” or “sub-categories" used in lists of items, but these aren’t technically called “headings”.
IBM comments on the WCAG 3 FPWD -March 2.docx

[cwadamsoforacle]

Thank you for your comment. Project members are working on your comment. You may see discussion in the comment thread and we may ask for additional information as we work on it. We will mark the official response when we are finished and close the issue.

[SuzanneTaylor]

@cwadamsoforacle should the comments here on captions and headings be moved into separate issues?

[cwadamsoforacle]

@SuzanneTaylor, that is most likely what we will do with this and other issues. When we received feedback in the form of a document, we took steps to get that feedback transferred from the document into github. Now that we have the issue in github, this is likely best addressed by splitting this into more specific and targeted issues.