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Re: EC proposes rules to make government websites accessible for all

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From: Duff Johnson
Date: Dec 4, 2012 8:34AM


On Dec 4, 2012, at 5:01 AM, Mark Magennis wrote:

> My take on WCAG is that other documents are definitely covered by it as it clearly encompasses Web Content in any format, so it DOES indicate that any documents downloaded from websites need to be compliant.

Why do you feel WCAG 2.0 encompasses "any format" including documents downloaded from websites? And if you think it encompasses "any format" then what do websites have to do with it at all? Why not just call it "CAG 2.0" and drop the "W"?

WCAG 2.0 only claims to cover "web content" but leaves the definition of web content vague. It's a big stretch to assume that WCAG 2.0 can adequately cover any content that can be transmitted electronically (i.e., downloaded from a website). That's a far more expansive claim, as the (almost entirely negative) feedback on the WCAG2ICT draft made clear.

WCAG 2.0 is about "web pages". Are non-web formats the same as "web pages" for accessibility purposes?
The answer is, at least, not obvious. Many have noted that WCAG 2.0 does not provide sufficient technical guidance on non-web formats as it does with HTML/CSS/JavaScript. If other standards are critical, then WCAG 2.0 can't be the whole story, can it?

> The tricky bit when determining whether a PDF (or Word doc or anything else) is 'accessible' is the concept of Accessibility Support which is pretty much left to the website owners, format providers, assistive technology vendors and users to argue about in the pub isn't it?

The reason it's "tricky" is because WCAG 2.0 offers no technical or operational guidance on the many questions that arise when "non-web content" (anything other than HTML/CSS/JavaScript) needs to be accessible.

The rush to re-define all content as "web content" in order to have WCAG 2.0 "apply" to it is understandable, because regulators want "a single standard". I sympathize. Regardless, wanting something does not make it so.

Best regards,

Duff Johnson

President, NetCentric US (creators of CommonLook)
ISO 32000 Intl. Project Co-Leader, US Chair
ISO 14289 US Chair
PDF Association Vice-Chair

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