Lisa Seeman's objection to WCAG's claim that WCAG 2.0 will address requirements for people with learning disabilities and cognitive limitations.
Author: Gez Lemon
The abstract of the Last Call working draft of the Web Content Accessibility Guidelines (WCAG) 2.0 contains the following in the abstract:
This document contains principles, guidelines, and success criteria that define and explain the requirements for making Web-based information and applications accessible.
The abstract continues to define accessible as:
"Accessible" means usable to a wide range of people with disabilities, including blindness and low vision, deafness and hearing loss, learning difficulties, cognitive limitations, limited movement, speech difficulties, photosensitivity and combinations of these.
If people with learning difficulties and cognitive limitations were directly addressed by the guidelines, they would be included under principle 3: Content and controls must be understandable; or more precisely, under guideline 3.1: Make text content readable and understandable. This guideline contains one Level 1 success criterion about the primary natural language, and one level 2 success criterion about the natural language of each passage or phrase. Level 3 has some success criteria about jargon, idioms, abbreviations, pronunciation, and a reading ability above lower secondary education. Not only does this dramatically fail to address an area of accessibility as complex as learning difficulties and cognitive limitations, but it doesn't even make sense against the proposed conformance scheme. If the natural language is required to be identified at level 1 (a minimum level of accessibility that is applicable to all web content), how come the way the language is used is at level 3 (additional accessibility enhancements that are not necessarily applicable to all web content)?
Lisa Seeman intends to make a formal objection about WCAG 2.0's claim that they address all requirements for learning difficulties and cognitive limitations, as they do not have the success criteria to back up their claim. Moreover, there are known techniques that WCAG have not included, and people who do intend to cater for people with learning difficulties and cognitive limitations would benefit from knowing of these techniques. If WCAG accept the objection, Lisa has kindly volunteered to help compile a list of "how to" documents and work on extensions for guideline 3 for understandable content. Lisa intends to submit the following letter of complaint:
WCAG 2.0 claims to define and address the requirements for making Web content accessible to people with learning difficulties, cognitive limitations and others. We object to that claim.
Specifically, the requirements for making content understandable ignore the needs of people with learning difficulties and cognitive limitations. Please note that there are guidelines published by other groups that will make content much more accessible to these users.
We would like to see continued work in this field and a statement in WCAG 2.0 abstract and introduction modifying the claim that they currently address accessibility for learning disabilities. Specifically we recommend removing learning difficulties, and cognitive limitations from the list of supported disabilities.
If you would like to support Lisa's objection, either leave your name in a comment, or contact me and I will pass your contact details on to Lisa. The more people that sign the objection, the more seriously the objection will be taken.