Inclusive Communications Working Document

General Discussions, Comments and Recommendations

6.0 Introduction

This chapter gathers together all those important elements which do not readily fit into other chapters. Particularly important is section 7.2 which assembles a vital set of general principles which should inform all matters of policy concerning ICT and elderly and disabled people.

6.1 Discussion issues

The following issues have been raised in the INCOM discussions and need to be further explored and analysed.

a) Follow-up

INCOM is of the view that the observations and suggestions of this report should be followed up in a concrete and measurable way.

Given the important role of COCOM in the implementation of the Electronic Communications Framework package and the demographic trends in Europe, COCOM should take advantage of the information in this report and an effort should be made to consider accessibility in future undertakings. This report should be as widely disseminated as possible.

Given the demographic changes in the near future, Member States would benefit from following the developments in other countries and from exchanging information, experience and follow up progress.

For topics and areas where development and research is needed, the Sixth Framework Programme offers possibilities and budgetary resources.

A new working group with a mandate to follow up and monitor in a concrete way the suggestions of INCOM and address new developments in the electronic communication sector could be created. This becomes crucial in view of the accelerated pace of technological developments.

b) Mainstreaming

The demographic trends reported in 1.5 indicate that there is a strong market case for providing goods and services for disabled people and this goes on to describe the principles of Design For All which would make this possible but so far disabled people have suffered severely in the ICT context from market failure. The reason for this may partly be connected with the degree to which ICT design is a function of lifestyle and fashion rather than utility but it is important to note that the pure demographic argument for the market case does not deliver accessibility unless it is subjected to opportunity cost analysis, i.e. what alternative uses of capital are available to the supplier?

Experience would indicate that although including the needs of disabled and elderly people in general provisions might be difficult and time-consuming it provides much greater long term benefits than seeking highly specific provisions.

There will always be a tension between mainstreaming and special provision but it is important that more work is undertaken on opportunity cost as the demographic profile of the EU moves ever more towards older people.

c) Standards

One critical area of mainstreaming is in the use of standards applied to generic technologies to make them accessible. In the area of ICT this is important for two special reasons:

ICT is subject to detailed standards much more than many other products
Such standards frequently apply to publicly funded and/or essential services.

As the role of legislation and regulation decreases the role of standard setting will increase and it needs to be subjected to the kind of democratic balance which applies to governmental and legislative processes. Specifically, this means that disabled people and/or their representatives should be an integral part of all standard setting that affects them.

Both industry and users benefit from such standards to be made international. Thus, participation in international standardisation with European requirements should be strongly encouraged. That creates larger markets and better interoperability.

d) Harmonised action across Member States

Harmonised action across Member States should be based upon the promotion of good practice so that where one Member State has established a 'lead position' it should seek to widen its application until such time as it naturally becomes material for EU-wide implementation.

e) User involvement

User involvement has been a central theme of this report. It is a vital element of the first general recommendation in section 6.2, reflecting a common theme across many issues and technologies. Although representational mechanisms will vary between Member States, the Commission should issue guidelines on best practice, particularly in respect of Member State Representation on Commission bodies.

6.2 General principles and recommendations

The following general principles and recommendations have been brought forward in the INCOM discussions as worthy of further consideration.

All ICT, broadcasting and telecommunications Directives, Regulations, Resolutions, Codes of Practice, guidelines and policy statements should take account of the needs of older and disabled people through consultations with the organisations which represent them.
Design for All principles should be followed in all areas of the production of goods, services and information but they should be particularly applied by the public sector and its agencies and licensees and in public procurement.
Following the good practice from some Member States, it is recommended to consult with users with disabilities and publish accessibility policies in respect of ICT, broadcasting and telecommunications and to monitor progress.
As identified in the eEurope 2002 and 2005 Action Plans, several benchmarks have been adopted for general progress in ICT and should be extended to encompass accessibility.
Accessibility in the context of Design for All should be integrated into initial product design; in the case of digital information this means that multimedia should be multi-modal.
Where general production cannot facilitate universal access, manufacturers should ensure standardised, simple connectivity between their products and assistive technologies.
Accessibility should be regarded as a European-wide, integrated challenge and should be based on the twin strategies of the Commission's mandate to promote production based on economies of scale, particularly important for national benchmarks which produce accessibility goods and services, and on communications interoperability across Member State borders.
Standards bodies should be encouraged to comply with CEN/CENELEC guide 6 in their standardisation work, to improve the likelihood that the needs of elderly people and disabled people are taken into account.

6.3 Public policy issues

The following is a list of public policy issues, with short comments, which may need to be taken forward:

Digital Copyright. Some multinational companies have already indicated that they wish either to charge additional royalties for the right to produce enriched, accessible programming from their original material (signing, sub-titling, audio description) or they wish to ban it on aesthetic grounds.
Levers for Accessibility in Deregulated Markets. This Report has frequently referred to problems of accessible hardware/user interface design in deregulated markets. This needs to be considered alongside deregulated digital production in such areas as satellite television.
Encryption, Privacy and Accessibility. Particular problems for people with disabilities may emerge with the growth of Registered Electronic Signatures and encrypted documents. This will become vital if Government uses encrypted systems for funds transfers for benefits payments.
Transatlantic Reciprocity Agreements. A good deal of information and literature on disability and accessibility originates in the United States of America. There are transatlantic problems over copyright and other instruments; these need to be studied, in particular for entertainment on demand and DVD accessibility
“Pay-as-you-go” Radio. The accessibility of television is of primary importance to people with disabilities but many also rely heavily upon radio. The first generation of digital radios have screens which present difficulty for partially sighted people but subscription radio, in parallel with subscription television, is already on the horizon and this will present its own problems.
Internet Streaming Standards. Member States may find it difficult to determine whether media streaming is publishing or broadcasting. Either way, it is important to establish that accessibility standards should apply to it.
e-Citizenship and Voting. This is largely a matter for Member States but common safeguards should be developed to underpin the European Convention on Human Rights and Article 13[1] of the Treaty of Amsterdam.
Information for Carers. This report has largely concentrated on the needs of elderly people and those with disabilities but accessible information for carers is a necessary component of civilised living for many households.
Electronic Funds Transfers to Private Citizens. Transfers may be of immense use to disabled and elderly people who do not wish to leave home on a regular basis to collect funds and who cannot handle printed material. Conversely, if such systems are inaccessible they will create new barriers.

[1] Article 13; Without prejudice to other provisions of this Treaty and within the limits of the powers conferred by it upon the Community, the Council, acting unanimously on a proposal from the Commission and after consulting the European Parliament, may take appropriate action to combat discrimination based on sex, racial or ethnic origin, religion or belief, disability, age or sexual orientation.