The following is the text of an E-mail dated 2006.11.22 from WCAG Working Group cochair Gregg Vanderheiden to various parties interested in cognitive disability under WCAG 2. The document has been converted from “HTML” E-mail to real HTML. It is provided here for criticism and review.
A number of comments have been filed as well as a formal objection regarding the coverage (or lack of coverage) of cognitive, language and learning accessibilities issues in the 27 April 2006 draft of W3C Web Content Accessibility Guidelines version 2.0 (WCAG 2.0). There was also a concern that developers might make a WCAG 2.0 conformance claim and believe that all of the requirements for cognitive disabilities have been covered, and that no additional support is needed beyond the guidelines.
This letter is to provide some background information on what we have done so far to address these and to invite you to a meeting with us to discuss this topic, concerns that have been raised, and ideas for what we can do in both the WCAG guidelines themselves and in the related support and application materials. We are inviting representatives of the group that signed the formal objection, as well as additional people with expertise in the area of cognitive disabilities including members of the working group.
The Working Group recognizes that the guidelines do not address all the needs of cognitive (or any other) disabilities. However, we feel that the current draft of WCAG 2.0 includes success criteria that do address many aspects of cognitive disabilities directly or via assistive technology. Given this, we believe it would be inaccurate to remove any claim of addressing cognitive, language and learning disabilities (CLL), but we certainly agree that it should be clear that the guidelines do not cover all access issues for any disability – including cognitive, language and learning. The Working Group has been reviewing the ways in which WCAG 2.0 addresses different types of CLL disability so that we can characterize more carefully which requirements are addressed and which are not.
We wish to work together with people inside and outside of the working group with expertise in this area
- to be sure that WCAG describes its reach accurately,
- to explore whether we can increase the scope of WCAG’s coverage, and
- to encourage additional work on guidance that would not be bound by the constraints that exist for WCAG.
As background, we would like to review some of the principles guiding our work on WCAG. It is the expectation of the W3C that WCAG will be used as a primary international accessibility standard. Therefore, it must be applicable to all Web content and achievable on all sites. This is particularly true for levels 1 or 2. Furthermore, it must be possible to verify a site’s conformance to WCAG, so WCAG requirements must be testable. In WCAG 1.0, provisions that could not be verified were largely ignored.
These constraints have certainly impacted WCAG 2.0 as it exists today. Many success criteria have been proposed that the Working Group agreed were important principles of accessibility, but could not think of ways to reliably verify their conformance and therefore could not include them in the guidelines. This was true across all disabilities.
In spite of this, in a close review of the needs of cognitive accessibility and the provisions of WCAG, we have come to the conclusion that there is substantial support for cognitive accessibility in the WCAG success criteria. This support is detailed in the attached draft of a companion document A, “Cognitive or learning disability” [also Microsoft Word original]. Much of the support comes from features that support assistive technologies specialized to the needs of people with cognitive disabilities. (The difference between direct access and access via assistive technology is described in the draft companion document B, “Direct Access and Special UA” [also Microsoft Word original].) Other support comes from requirements to provide a consistent design on the site and to relieve time limits on activities, distraction, etc.
We have also been careful to structure the success criteria so they don’t prevent authors from following additional cognitive-specific accessibility guidelines. Where possible, we provide our own additional recommendations in the form of advisory techniques that go beyond the WCAG success criteria and often include important but not testable advice. (Note: Most advisory techniques [for all disabilities] exist only as titles and [Future Links] in the current draft. We are getting to these support documents as quickly as we can given our small group. We are always interested in others who would like to help.)
In addition to these features of WCAG 2.0, we plan to provide some additional resources to support understanding of the relationship of WCAG to cognitive accessibility. A number of subject-specific “Application Notes” are planned, and an Application Note about cognitive accessibility is an opportunity to detail the special issues involved, describe how authors should implement their WCAG conformance with cognitive accessibility in mind, and point out additional techniques, ideas and resources. (See attachment C, “Going Beyond WCAG 2” [also Microsoft Word original].) We also believe there is need for further research into effective means of addressing the needs of individuals with cognitive disabilities. Eventually we would expect to incorporate this research into future accessibility guidelines. We would like your ideas and help with these two documents as well.
Moving forward we would like to schedule a meeting on the topic. The purpose would be:
- to review the attached materials (including additions or corrections)
- to identify any additional measures that can be taken with WCAG2.0 itself (given its constraints)
- to identify other ways to advance cognitive, language and learning access beyond that which can go into WCAG 2.0.
We are hoping to meet via teleconference on December 5[, 2006] from 20:00 til 22:00 UTC, with a follow-up meeting on December 19 at that same time. We know the time is a bit early or late for some of you but it is the only time the spans Europe to Australia and doesn’t hit anyone at 1:00 to 6:00 in the morning. We hope that you will be able to join us for these meetings. Could you advise us if you would be available?
Thanks much
- – Gregg Vanderheiden & Loretta Guarino Reid, WCAG Co-Chairs
- – Michael Cooper, WCAG Staff Contact
- – Judy Brewer, WAI Director
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Updated 2006.11.26