During the consultation phase of WCAG 2, Inclusive New Media Design researcher Simon Evans, together with several other interest groups, lodged a formal objection to WCAG 2. This centred on the assertion early in the guidance that compliance with WCAG 2 would ensure that web site developers met the needs of many people with disabilities including those with cognitive / learning / intellectual disabilities. The text of the objection was as follows:
‘WCAG 2.0 claims to define and address the requirements for making Web content accessible to those with learning difficulties, cognitive limitations and others. We object to that claim. Specifically, the success criteria requirements for making content understandable largely ignore the needs of people with learning difficulties and cognitive limitations. […]
We would like to see continued work in this field and a statement in the 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. A sentence may be added later in the abstract that “these guidelines may also provide some benefits for people with learning difficulties and cognitive limitations”. We would then like to see a statement of intent such as: “the working group intends to build additional success criteria to address accessibility for learning disabilities and cognitive limitations.”'
The Working Group modified the introduction of WCAG2.0 as a result which now includes the following text:
‘Although some of the accessibility issues of people with cognitive, language, and learning disabilities are addressed by WCAG 2.0, either directly or through assistive technologies, the WCAG 2.0 guidelines do not address many areas of need for people with these disabilities. There is a need for more research and development in this important area.'
In specific response to the formal objection the Working Group also wrote:
‘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……… 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.doc". Much of the support comes from features that support assistive technologies specialized to the needs of people with cognitive disabilities. 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.'
Copy of Letter of invitation - Re Cognitive Language and Learning aspects of WCAG 2.0
After the objection was lodged, WAI arranged a teleconference between some of the signatories and committee members to discuss potential action. The meeting was not formally minuted but some details have emerged including the suggestion that a task force be created to produce additional supplementary guidance for developers. The assertion of WAI at this time was that no research in regard of the web access needs for these various groups (viewed by the working group as a constituency) existed.
In response to the criticism Gregg Vanderheiden (co-chair WCAG WG) also produced a ‘Cognitive and Learning Disability Matrix' mapping WCAG 2.0 success criteria to the perceived needs of the ‘CLL' group.
In the ‘Going Beyond WCAG2.0 Document' there is a call for assistance in creating:
Some accessibility sites are downright ugly, but the problem lies with those sites’ designers and not with accessibility, which carries no visual penalty.
Jeffrey Zeldman, Designing with Web Standards, 2003
Although serving the needs of people with disabilities should of course be a concern, the far wider issue – that accessibility is a matter of usability – has rarely been discussed. As designer professionals, we should be designing our content so it is globally accessible and meets the needs of as many people as is possible and practical given our specific circumstances, regardless of their abilities or the type of device they choose to access the Web
Andy Clarke, Transcending CSS: the fine art of web design, 2006