Inclusive Communications Working Document

Key Urgent Topics: Access to Broadcasting, Digital Television and Related Services

Constraints experienced by people with disabilities

4.1 Introduction

Like all other citizens, people with disabilities enjoy watching television but their access to it can be restricted: deaf and hearing impaired persons have problems with the audio and blind and partially sighted people have problems with the visual material, pictures as well as text on the screen. There are more than 80 million people in Europe[1], 22 million living in the European Union[2], with a significant hearing impairment and eight million with a serious sight impairment. Furthermore an increasing number of older persons with experience of multiple disabilities, cognitive and sensory disabilities, face access barriers to television viewing.

Most deaf and hearing impaired people can benefit from subtitling but some require signing as this is their first language and they have difficulties in reading the text.

Blind and partially sighted people can benefit from audio description (an additional narration that fits between the existing dialog and that describes action, body language and facial expressions).

Both of these groups within the population face additional problems where this additional information is not in their first language. When it is a foreign language programme that uses subtitles as the medium for translation or programmes that use alternative access methods for on-screen displays e.g. on-screen navigation menu’s it is possible to use 'audio-subtitling' (a voice output created by using speech synthesis technology to convert the subtitles into speech). In all these cases additional information is added to the original programme and provided to supplement the standard content.

Deaf people are assisted with their understanding of dialogue and verbal presentation and blind people learn about action, body language and facial expression.

It is important to note that audio description can also help non-disabled people enjoy television while they are performing other tasks and that subtitles benefit non-disabled people for example by helping increase literacy levels.

The provision of both analogue and digital subtitles has been available for some time but audio description and ‘closed’ signing need further development. The manner in which these services are produced also needs consideration. A common approach is needed as recommended in the final report of the study of CENELEC ‘TV for All’[3]. In the absence of European standards some countries like Spain are developing their own national standards for instance for authoring subtitles[4].

Elderly people and many viewers with cognitive problems find channel navigation and programme viewing too complex and accessible electronic programme guides (EPG), is a preliminary requirement to be able even to select a programme. High quality audio description and clear subtitling can both help in a variety of ways, for example facilitating understanding of the programme. The needs of the users should be taken into account; they should also be consulted. Media should be customisable to facilitate accessibility. These features need to be considered from the outset rather than as modifications to be implemented at a later date.

4.2 Remote controllers and EPGs

A new element of complexity has been introduced with the indispensable use of remote controllers and electronic programme guides.

Remote controllers frequently have small, near identical keys which do not conform to a common operational pattern which presents difficulties for blind and partially sighted people and those with cognitive problems. Manufacturers claim that the detailed standardisation of user interface features could be restricting the development of better solutions in the market, whilst people with disabilities claim that standardisation is essential to increase accessibility and ease of use. Some standardisation done in other ICT domains, for example the raised dot on key 5 in numerical key pads, has proven to be very useful.

An alternative would be to discuss with manufacturers the possibility of creating a specialised market for accessible remote controls. Manufacturers would need to make their remote control codes available to third parties on fair, reasonable and non-discriminatory terms.

Electronic Programme Guides (EPG) for digital television now provide programme listings up to 400 channels for seven days; but, more significantly, many EPGs are now the sole route of access to programmes and the sole source of accessibility sign posting. EPG's and navigational menus currently have a very complex user interface only available in a visual format. Therefore, they present problems for old, blind and partially sighted people. Also, they do not possess signing capacity. It is difficult not only to find and select accessibility support services but also to find and select a programme. Connections to assistive devices might be a solution as might alternative voice input/output interfaces.

4.3 Other services

Tele-shopping and interactive services present an extra layer of difficulty because they combine some of the inaccessibility problems of broadcasting with those of Internet publishing. Community law makes a clear difference between television broadcasting services, submitted to the TWF directive, and services provided on individual demand, which constitute Information Society services.

4.4 Digital radio

As digital radio expands there is a strong possibility that broadcasters will increasingly use receiver screens to display information. These are typically small to reduce cost which presents difficulties to many people in addition to blind, partially sighted and older persons.

4.5 The place of television

Access to television means access to leisure, information, education among other things. It is therefore crucial for disabled and elderly people to be full and equal citizens. Unlike the use of computer-based services, many television services are directly or indirectly paid for by citizens through licence fees or taxation. In some countries this has already led to certain accessibility obligations being made conditions of licence to broadcast. In the UK and Portugal[5], for example, the accessibility obligations on subtitling are being implemented but the ones on EPGs are actually ahead of the ability of the technology to deliver. The recent study "Digital television for all"[6] completed by the DTI in the UK provides a good overview of the matter.

Making content accessible, however, is only part of the solution: the transmission channel must have the capacity to carry the enriched assistive services such as audio description, subtitling and signing and this may have to be required as a 'must carry' obligation. Finally, even if the information is accessible and transmitted, the receiver TV set or set top box may not be able to decode the enriched assistive services, if manufacturers have no economic incentive to include the relevant functionality. Furthermore recording equipment should be able to record these accessibility features. This requires a holistic strategy for equivalent service which includes stated targets for all special access services, including subtitling, signing and audio description in the context of content creation, transmission and reception. All enriched assistive services should be represented on EPGs by common symbols and all enriched assistive services should be easily accessible on standard receivers and recorders. There should be greater co-ordination between Member States in order to ensure that the equipment manufacturers have the correct incentives to include the relevant functionality.

4.6 Digital switchover

The e-Europe 2005 Action Plan[7] requires Member States to publish their plans for the switchover from analogue to digital television. This is important for disabled and elderly people in two inter-connected ways:

Because digital information is more flexible than analogue it is cheaper to produce at every phase (excluding its creation) - collection, editing/production, re-purposing - and so accessibility targets for digital television should be radically higher than for analogue, moving towards 100% accessibility in appropriate genres
Conversely, where EPGs are inaccessible and where they provide the only route of access to digital programmes, users may lose all access to some channels enjoyed in analogue. Access through use of an agreed set of icons would do much to resolve this.

4.7 Design for All

Underlying all accessibility the Design for All principle should be applied in initial production so that information is created in parallel in all three primary modes, audio, text and pictorial.

Suggestions to overcome the constraints experienced

The following actions will contribute to improving the accessibility to broadcasting services:

Member States should be invited to set and publish targets for the provision of accessibility features for digital television for appropriate genres respectively specifying content creation, transmission and reception. Some countries like UK are already having some targets quoted in legislation;
On the basis of best practice accessibility/ enriched assistive services should reach a target of 80% in appropriate genres by 2015;
Broadcasting regulators and broadcasters should agree codes of practice or other regulatory instruments to specify accessibility requirements, notably provision of accessibility/ enriched assistive services;
On the basis that there is not yet a technical solution for full EPG accessibility, there needs to be an urgent, Europe-wide initiative to solve this problem before analogue switch-off and digital switchover, aiming at a common standardised solution for accessibility;
Strategies and measures about analogue switch-off and digital switchover should take account of the needs of older and disabled people. Public consultation with users and their organisations will contribute to this goal;
Accessibility to be progressively integrated into all standards, guidelines and the establishment of future deliverables for digital broadcasting in accordance with the recommendations in the CENELEC "TV For All" Report in order to promote European accessibility solutions;
A dialogue between manufacturers, users, broadcasters and regulators should be initiated regarding standardisation and promotion of accessibility features of remote controller devices, recorders and receivers and its impact on competitiveness and on ease of use, taking into account the need to achieve economies of scale across the Single Market in order to achieve affordable prices;
A closer co-operation to be established between COCOM and the Contact Committee established under the “Television Without Frontiers” Directive;
Studies and research should be undertaken to assess the market for additional accessibility features, easy to use products and the commercial benefits of inclusive design principles;
Action to be taken by broadcasters and manufacturers to raise awareness amongst consumers about the availability of assistive products and services and how access them.

[1] Institute of Hearing Research (IHR): people aged 18 and over with bilateral hearing impairment at 25 dB hearing level and above in EU and other European countries (as defined by UN/WHO). CENELEC TV for all report p. 5

[2] Eurostat- Behindertenstatistik,Zweite Ausgabe 1993 Office for official Publications of the European Community Brussels/luxemburg 1995 ISBN 92-826-9651-0

[3] http://www.cenelec.org/Cenelec/CENELEC+in+action/Horizontal+areas/ICT/e-Accessibility.htm

[4] "NORMA UNE 153010", on subtitling for people who are deaf or hering impaired, through teletext,

[5] http://www.aacs.pt/bd/Deliberacoes/20010328a.htm

http://www.hmso.gov.uk/acts/acts1990/Ukpga_19900042_en_1.htm The Broadcasting acts 1990

http://www.communicationsbill.gov.uk

[6] www.digitaltelevision.gov.uk/dtv_for_all.html

[7] COM (2002) 263final, eEurope 2005: An information society for all.