Inclusive Communications Working Document
Key Urgent Topics: Access to Telecommunication Services
Introduction
This chapter covers topics which have been identified by INCOM as having high importance for users, where users have encountered serious problems and with a connection to articles in the Directives, in particular the Universal Service Directive and the Framework Directive. However, some solutions go beyond the scope of the Directives.
Following the INCOM Terms of Reference, each topic includes:
- descriptions of the constraints experienced by people with various disabilities in gaining access to and using electronic communications services
- solutions, actions, measures, approaches in Member States and sometimes outside Europe
- suggested ways to overcome the constraints.
3.1 Access to national emergency services [1]
Constraints experienced by people with disabilities
Rapid and effective communication with emergency services can be a matter of life and death. Currently, a significant number of persons with disabilities, in particular persons with deafness, hearing impairment, speech impairment and deaf-blindness have difficulties connecting to and communicating with emergency services either directly or indirectly (e.g. through a relay service).
Given the seriousness of this issue, equal access for disabled persons to emergency services must be given top priority.
Deaf persons using text telephones in particular report problems with connecting to emergency services. The emergency centre may lack the equipment to be able to receive the call or it may not be able to identify the calling equipment as a text telephone, since certain types of text telephones are silent when calling up. For others, the operator must listen to the tone to distinguish it from a fax.
In the UK and Norway, special emergency numbers for text telephones are used. In Sweden the number is 112, and calling text telephones send a signal that is easy for an automatic system to distinguish from that of a fax, but hard for the human ear.
The text relay services described in the next section can connect to public emergency services in all eleven countries where they exist, with the exception of France, where there is a limited direct access through Minitel terminal.
Users find it unacceptable to have different emergency numbers in different countries for different types of disabled-users telephones. It is the opinion of INCOM, that the “112” number should be available to persons with disabilities with the equipment they use for telephone communication and that efforts should be made to remove existing technical difficulties, e.g. by replacing old terminals.
Deaf, hard-of-hearing and some speech-impaired persons are increasingly using mobile phones to send SMS and MMS messages as well as videophones and other messaging systems. However, these present considerable problems when trying to connect to emergency services. If the caller cannot speak intelligibly, the nature of the emergency and the location cannot be communicated quickly.
Blind persons may also have a problem to communicate their location when using a mobile phone.
The localisation problem is shared with other, non-disabled users who cannot describe their location for various reasons. It is expected that future generations of mobile telephones will be able to provide possibilities for accurate localisation.
A pilot trial of SMS for emergency calls by deaf persons in Sweden concluded that SMS can be an adequate method of communication with emergency services, provided that certain technical adaptations are made. However, the user representatives in INCOM have expressed a strong concern about the reliability and dependability of such solutions. The current store and forward technique does not support an appropriate and reliable solution for emergency calls. However, given the increasing use of SMS by deaf persons, it is the only system currently available and needs major modification and movement to other, real-time interactive systems to be suitable for an emergency situation.
SMS was not designed to be used for emergency communications but as a commercial messaging service with all the inherent attributes. There needs to be more study of the use of SMS for emergency communications about its practicality both from a user and emergency services side.
As long as the emergency services do not accept these communication methods directly, gateways to text telephony should be established and used.
Users with disabilities are not considered in current mainstream standardisation work on emergency services.
Access to emergency numbers for persons with disabilities belongs naturally in the new European forum on public safety and emergency communications, to be launched in 2004.
According to the draft Commission Recommendation on the processing of caller location information[2], “Member States should require their national authorities to report to the Commission on the situation of E112 implementation by the end of 2004” (Article 13) and “When reporting on the situation of E112 implementation, national authorities should address any relevant technical feasibility issue that hinders the introduction of E112 for specific categories of end-users” (Recital 14).
Suggestions to overcome the constraints
In order to enable users with disabilities to have equal access to emergency services, INCOM suggests the following ways to contribute to overcoming the constraints described above:
- it is desirable that persons with disabilities are able to call the emergency services free of charge using their ordinary communication equipment, by using the single European emergency call number ‘112’; the call may be handled in text or voice or video or a combination of these media;
- that manufacturers are encouraged to include technical facilities to facilitate a dialogue with callers with disabilities in emergency situations, such as pre-programmed emergency messages with easy access;
- that new call centre equipment be defined to address accessibility by handling interaction with mobile telephones, SMS messages, videophones, Internet messages etc; call centres personnel should be appropriately trained on accessibility matters;
- that standardisation organisations are encouraged to include the requirements of callers with disabilities in mainstream standards for emergency calls and emergency call handling; the EC could issue standardisation mandates in order to address these issues;
- that the preferred set of standards defined in section 3.2 are included among the methods to access emergency services in text, voice and video;
- that working groups and co-ordination groups on emergency services, such as the new European Forum on Public Safety and Emergency Communications, should consider accessibility issues in their work and consult with representative organisations of disabled people;
- that national authorities in their reporting on the situation of E112 implementation address issues regarding users with disabilities.
3.2 Access to telephone services for persons with deafness/severe hearing impairment/speech impairment/deaf-blindness[3]
Constraints experienced by people with disabilities
Not everyone can use voice telephony. People who are deaf, have severe hearing impairment or severe speech impairment cannot make use of these everyday services that most people take for granted. According to the COST 219 group[4], the number of persons in those groups in the European Union are respectively two million, four million and two million.
For those who can read and write, text telephony can be a good way to communicate. For those who have sign language as their mode of communication, video telephony is needed to provide a conversational communication connection.
However, when text telephony was introduced in Europe there was no standardisation process in place. Consequently, there are at present at least seven different incompatible systems in different European countries. This means that the users can not make calls to other countries and sometimes not directly to other text telephones with a different standard in the same country. Text telephones are widely spread today in Europe. For example, COST 219 estimated in 2001 that the total number of text telephones in Scandinavia was 19.000[5].
An international standard for text telephones[6], which is backwards compatible with all existing equipment has been adopted by ITU, but has not yet been widely implemented.
In order to enable text telephone users to communicate with voice telephones, relay services where a person provides the link between a text call and a voice call are important. The COST 219 group reported in 2001 that Denmark, Finland, France, Greece, Netherlands, Norway, Portugal, Sweden, Switzerland and the United Kingdom provided such services. Since then, Spain and Ireland have started national services. In most of them, the user pays the same cost as for a call without relay service. Almost all can be reached via direct dialling from abroad. The volume varies between countries from a few calls to thousands of calls per week. In France, however, the wide availability of Minitel terminals has in many cases superseded the need for text relay services.
Two Member States provide video relay services for sign language users. In Sweden, the national regulator PTS procures the service from a county council and in The Netherlands it is provided by the TC Visinet foundation.
Speech-to-speech relay services for persons whose speech is hard to understand are available in The Netherlands and Sweden.
Guidelines for text telephony and for relay services have been issued by ETSI[7] and The Nordic Forum for Telecommunication and Disability[8].
The introduction of IP networks should take care not to introduce degradation of text telephone communication.
It should also be pointed out that a text message takes about five times as long as the same voice message. In Sweden, this is taken into account in a fixed compensation for extra costs paid by the government to persons with disabilities. France has a monthly social rental fee for persons that fulfil some appropriate conditions. Persons with disabilities can also benefit from this. In Ireland, text telephone users can get a rebate of up to 70% on text phone charges per bill. In UK there is a rebate system for text phone users. In Norway it is an obligation for the universal service provider to give deaf, hearing-impaired people and speech impaired people a reduction of their telephone costs when using text phones and this could also include video phones or related equipment.
For sign language users, the quality of video telephony is sometimes unsatisfactory, although there now exist good possibilities to meet their requirements using broadband networks.
International standards for text, voice and video communication have been established but the market has been slow to adopt them. The favoured solution is to adopt a single, IP-based set of preferred standards for all modes of accessible conversation facilitation. The set of preferred standards are IETF SIP for call control, ITU-T H.263 for video, ITU-T T.140 with transmission as specified in IETF RFC 2793 for text and ITU-T G.723.1 for audio. Nothing prevents implementations to include other coding standards, but the preferred ones should be maintained for interoperability.
By specifying this set of preferred standards within reach of mainstream implementers, the users can have their terminal design of choice, and still reach all services that need to be accessible to them, such as text relay service, video relay service, speech-to-speech service, emergency service and services for interoperability with voice and text telephony in the telephone network. This is a practical response on the requirement from the European Parliament in resolution B4-0985/98 that requires us to ensure compatibility of telecommunications text and videophone equipment for deaf people across Europe.
Suggestions to overcome the constraints experienced
In order to enable users with disabilities to have equal access to telephone services, INCOM suggests the following ways to overcome the constraints described above:
- that a set of standards[9] for all modes of accessible conversation facilitation be endorsed, possibly following the procedure in Article 17 of the Framework Directive;
- that manufacturers be encouraged to provide products that comply with the preferred set of standards;
- that manufacturers be encouraged to develop and provide products that are suitable for deaf-blind persons. Member States could study how these products could be made affordable for the users;
- that active steps are taken to ensure that communication costs are as affordable for users with disabilities as for other users;
- that the need for a high speed transmission capacity (broadband) is endorsed for those disabled users who need to communicate in sign language and lip reading;
- that relay services are made available to ensure communication with voice telephones and with those services which do not have their own compatibility by text or sign language, also across Member States;
- that the development and deployment of network gateways and standardised text transmission be supported to allow interoperability of installed text telephones with new services and new transmission methods.
3.3 Access to public pay telephones
Constraints experienced by people with disabilities
On the topic of public pay telephones, two issues are vital: ensuring a sufficient number of payphones and accessibility of the telephones. Disabled people are hampered due to the placing of equipment in inaccessible places. Blind and partially sighted people may have difficulty reading usage instructions. People with cognitive impairments may have difficulty using public phones. These are some examples of difficulties encountered:
- Kiosk doors may be too heavy and doorways too narrow for wheelchair users
- Appliances may be at the wrong height for wheelchair users
- Instructions may be inaccessible for blind and partially sighted people
- Appropriate facilities such as sound amplification and text communication may not be available for deaf and hearing impaired people
- Operating instructions may be difficult for people with cognitive difficulties
- Poor or inconsistent design of key pads, or reliance on touch screens can render payphones inaccessible to blind and partially sighted people.
These constraints have been addressed in various ways in the Member States. For example, in the UK, it is ensured that a proportion of public call boxes have text and amplification facilities and are “wheelchair accessible”. The UK regulatory framework also requires 70% of public payphones to incorporate additional receiving amplification and 75% of them to be accessible by wheelchairs.
However, mobile phone trends and the decline in the use of payphones need to be considered. Evaluations have begun with a view to assessing alternative possibilities for public pay phones (or public phones at private places like restaurant, cinema). Some countries (e.g., Denmark and Finland) suggest that mobile communications will lead to pay phones becoming less used. Following the same trend, the mobile phone base in Poland, Hungry, Slovakia and the Czech Republic exceeds the fixed line base and there is no expectation of significant fixed telephony roll-out. Some other countries, such as Norway, have stressed that small remote places where mobile coverage may be poor will require that public telephones are accessible there.
The issue of access to machine readable cards, and therefore public fix payphones, is also dealt with by standards such as CEN/TC 224/WG6 on human-machine interface. This group elaborated in particular a draft Technical Specification “Guidance on design for accessible card-activated devices” which addressed the problems of physical accessibility of machine-readable cards and their keyboard. For example, these documents recommend that the access route to the machine shall be flat, without steps, stairs or unevenness and shall not present barriers or hazards to people.
Suggestions to overcome the constraints experienced
Drawing on some known good practices, in order to enable users with disabilities to have equal access to public pay telephones, INCOM suggests the following ways to contribute to overcoming the constraints described above:
- Member States should encourage that national authorities fully exploit the possibilities for providing access by disabled persons to all publicly available telephone services, through appropriate means, such as by payphone or an alternative technological platform, such as mobile communications;
- Member States are invited to draw up a score card of measures taken, measures that will be taken together with time frame for implementation and results achieved;
- it is also desirable if Member States:
- actively work with representatives of their national disability groups in order to identify the needs and the measures needed for achieving them
- develop an action plan as to how these measures will be implemented
- share best practice in relation to payphone accessibility
- continue to review best practice in relation to alternative platform accessibility.
- the use of standardised layout of the keypad, of the area around the phone box and of the information displayed should be pursued; ensuring effective access to emergency services should facilitate free movement across Europe of disabled citizens;
- Member States should, where appropriate, consider further analysis on better design or design-for-all to improve payphone accessibility through benchmarking of best practices;
- local users with disabilities and/or representative disability organisations should be used systematically as part of the feedback process in order to assess the accessibility of publicly available telephone services;
- Member States should monitor the implementation of all relevant standardisation specifications.
3.4 Access to mobile telephones [10]
Constraints experienced by people with disabilities
Ever since the introduction of GSM-based mobile telephones, the more than ten million hearing aid users in Europe[11] have been affected by interfering noise from such telephones. This circumstance makes it impossible for some hearing aids users to use mobile phones together with their hearing aids and causes unwanted noise in the hearing aids from telephones nearby.
The European hearing aid industry has addressed the problem by increasing the immunity to such interference, which diminishes the inconvenience but does not eliminate it. According to EHIMA, the hearing aid manufacturers’ association, the technical limit for such immunity in the hearing aids has been reached and it is up to the telephone manufacturers and operators to make a contribution to a solution.
The EMC Directive[12] requires apparatus to be so constructed that any disturbance it produces is at a level which allows radio, telecommunications and other apparatus to operate as intended, and to have a sufficient degree of immunity to disturbance so that it too can operate as intended, in normal environments.
Setting the limits on emissions and the immunity levels is done through the medium of standards. Standards for electrically powered equipment, including hearing aids and other active medical devices, are produced by the IEC and CENELEC while telecommunications matters are handled in the ITU and ETSI.
Hearing aids, therefore, will be designed to meet the harmonised EMC standards listed against the Medical Devices Directive[13], while mobile phones will be subject to those cited alongside the RTTE Directive[14]. The situation that a hearing impaired person wants to listen to a mobile phone through the hearing aid has not been foreseen in the drafting of the relevant standards and it may be expected that interference problems will continue unless the standards are amended.
In the United States, the Federal Communications Commission (FCC) adopted a Report and Order in July 2003[15] requiring all operators and manufacturers of mobile telephones to provide within two years at least two models of telephones without the disturbing interference of hearing aids.
As mobile telephone services are being increasingly developed and common, the access by users with disabilities should be considered. This relates both to access to the telephone terminal and to the services provided.
Mobile platforms also have a strong potential for providing special services for disabled people. One example is the WISDOM project with participants from the United Kingdom, Sweden, Spain and Germany, aiming to realise mobile video telecommunications services for deaf people with access to a video server through text/graphic menus and directly through sign language recognition and personal communication. Other examples concern navigation, localisation and call for assistance.
Suggestions to overcome the constraints experienced
In order to enable users with disabilities to have an equal access to mobile telephone services, INCOM suggests the following ways to contribute to overcoming the constraints described above:
- voluntary or mandatory requirements on the suppliers and producers of mobile phones in Europe to provide some mobile phones with reduced interference, like the U.S. requirement, would give hearing aid users an equal opportunity with other users to use mobile services;
- manufacturers are encouraged to identify which mobile phones have reduced interference to their customers;
- continued pilot trials with new services for users with disabilities as in some Member States will show new potential ways of providing valuable services;
- when creating mobile personal communication services, interoperability should be arrange with corresponding services in fixed and wireless services. (see section 3.2);
- accessibility should always be considered in the design of new mobile terminals and services
- standardisation organisations are encouraged to consider the interference between mobile phones and hearing aids in developing the respective future standards.
3.5 Access to directory services [16]
Constraints experienced by people with disabilities
Persons who are blind or who have strongly reduced vision, as well as some persons without adequate hand function cannot use ordinary printed free telephone directories. In order to find a telephone number, they must contact the directory service call centres. As a result, these users with disabilities will have higher costs for the directory information than other users.
Some countrieshave adopted measures to provide compensation for such extra costs, for example:
- In Ireland, the universal service provider Eircom provides special directory enquiries which allows those unable to use the phone book because of a disability to use a directory enquiry service free of charge.
- In the Netherlands, KPN offers a helpdesk and a free number for people unable to use the directory.
- In Sweden, following procurement from the National Regulating Authority PTS, the operator Telia provides a free directory service for people unable to use the paper directory.
- In the United Kingdom there is an obligation on service providers to have a free directory enquiry service and through connection for customers not able to use a printed phone directory
- In Norway there is an obligation for the universal service provider to give a discount for blind and weak sighted people when using directory services.
Suggestions to overcome the constraints experienced
In order to enable users with disabilities to have an equal access to directory services, INCOM has the following suggestions to contribute to overcoming the problems described above:
- following the examples of some Member States, a system in all Member States for compensation of extra costs caused by a personal disability for finding telephone directory information would create equality between users with and without disabilities in all of Europe.
[1] See Article 7 and Article 26 of the Universal Service Directive, as referred to above in Section 2.
[2] COCOM03-03REV2 Draft Commission Recommendation on the processing of caller location information in electronic communication networks for the purpose of location-enhanced emergency call services, 14 April 2003
[3] See Article 7 of the Universal Service Directive as referred to above in Section 2.
[4] Bridging the Gap? Access to telecommunications for all people. Edited by Patrick R.W. Roe. COST 219 (2001). Published by the European Commission.
[5] http://www.stakes.fi/cost219/Texttelephony.htm
[6] ITU-T V.18 Operational and interworking requirements for DCEs operating in the text telephone mode and ITU-T T. 140 Text conversation protocol for multimedia application
[7] ETSI TR 101 806, Human Factors (HF); Guidelines for Telecommunication Relay Services for Text Telephones (2000) http://www.etsi.org
[8] Nordic Guidelines for Telecommunication Relay Services for Text Telephones, NFTH 4/1998; Nordic Guide to Text Telephony, NFTH 2/2002; Nordic Guide to Video Telephony and Video Relay Service - for persons with impairments, NFTH 3/2002 http://www.nsh.se/nfth.htm
[9] IETF SIP for call control, ITU-T H.263 for video, ITU-T T.140 with transmission as specified in IETF RFC 2793 for text and ITU-T G.723.1 for audio
[10] See Article 8(2) of the Framework Directive as referred to above in Section 2.
[11] http://www.interconnectionconsulting.com/english/marketingindex_js.html?hoergeraeteE.htm
[12] Council Directive 89/336/EEC of 3 May 1989 on the approximation of the laws of the Member States relating to electromagnetic compatibility. OJ L 139, 23.5.1989, p.19
[13] Council Directive 93/42/EEC of 14 June 1993 in relation to medical devices. OJ L 169, 12.7.1993, p.1
[14] Directive 1999/5/EC of the European Parliament and of the Council of 9 March 1999 on radio equipment and telecommunications terminal equipment and the mutual recognition of their conformity, OJ L 91, 7.4.1999, p.10
[15] Federal Communications Commission FCC 03-168 Report and Order adopted July 10, 2003; http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-03-168A1.pdf
[16] See Article 5 and Article 7 of the Universal Service Directive as referred to above in Section 2.