[ebu response 4 September 2008] Public consultation on web accessibility and other e-accessibility issues
Accompanying measures of Member States could include
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Accompanying measures of Member States could include:
Question 12a: Do you agree with the following accompanying measures of Member States? Please note that for each accompanying measures you have to choose between I strongly agree, I agree, I disagree, I strongly disagree or I don't know. Simply delete the answers as appropriate. Accompanying measure 1: Supporting training schemes for relevant actors involved in web accessibility, whenever possible with a direct involvement of persons with disabilities [I strongly agree - it will be equally important for Member States to put in place measures to train disabled people in local communities to use specialist software and equipment so that they are able to provide support in their community.] Accompanying measure 2: Providing information and guidance to persons with disabilities on accessibility of websites [and web applications] and, where relevant, about assistive technologies [I strongly agree] Accompanying measure 3: Supporting exchange and publication of best practices for the various stakeholders [I strongly agree] Accompanying measure 4: Collecting input from users, including through surveys, about their experience of accessibility [I strongly agree] Question, 12b: Do you think other accompanying measures of Member States than the above-referred one should be foreseen? [EBU strongly recommends the use of functionality testing and certification schemes, which should include automated testing and, most importantly, user evaluation. Although we do not recommend them to be mandatory because they can be costly, these schemes are very useful in providing technology developers and web designers with reference points, ensuring the visibility of accessibility features for customers, and most importantly ensuring the products and services developed do meet the accessibility needs of users - particularly where they are going to be used on a daily basis. Euracert (www.euracert.org), for instance, is the first European quality label for accessible websites. It has been set up on the basis of common references (the WAI guidelines, an evaluation methodology and a conformity assessment scheme) in order to allow recognition of labels issued to websites in different European countries. It is also important these schemes are carried out by independent bodies in order to ensure that conformance claims are realistic and not subject to the same limitations as self-assessed conformance levels. Such functionality testing should aim to ensure websites, applications and tools are accessible by all by: identifying issues and who is responsible for them (developers, designers, content producers etc.), outlining issues in accordance to priority levels and tracking progress in the (re)building process.7 It is important that legislation makes reference to these issues as they help interpret how WCAG should be implemented.] Question 13: Do you support the creation of a national web accessibility contact point? [Yes] G - Cooperation between Member States and other stakeholders Cooperation between Member States and other stakeholders could include:
Question 14: Do you agree that cooperation between Member States and other stakeholders should address these tasks? [I strongly agree]
E-accessibility challenges go beyond web accessibility. Disabled persons have reported difficulties in accessing and using television, mobile or fixed phones, public announcement systems, self-service terminals such as cash-dispensing and ticketing machines, health monitoring devices, and more. European legislation contains some provisions on e-accessibility, but it does not deal with the issue in a comprehensive way. Europe is also supporting research and innovation, promoting best practices, and stakeholder cooperation. E-accessibility is also dealt with by some ICT providers who have taken action to include accessibility features early in the ICT design process through inclusive universal design or 'design for all' approaches. Notwithstanding these actions, a recent European Commission study8 reported that the overall level of e-accessibility in Europe remains relatively poor and progress is rather limited, as analysed in the recent European Communication on e-Inclusion9. Given these observations, and taking into account the recent United Nations Convention on the rights of persons with disabilities and the proposals of the European Commission for a Renewed Social Agenda, this part of the consultation explores the need for further EU level action on e-accessibility in general (beyond web accessibility as covered in the first part of this consultation). The purpose of this part of the consultation is NOT to review the existing European activities, but rather to explore the possibilities to complement them in order to better promote general e-accessibility (while taking into account that further EU action on e-accessibility may be constrained by existing obligations, for instance, legal obligations on copyright). A - Your experience of e-accessibility
Question 15a: What are the main barriers to e-accessibility? Please note that for each of the proposed barrier, you have to choose between I strongly agree, I agree, I disagree, I strongly disagree or I don't know. Simply delete the answers as appropriate. Proposed barrier 1: The ICT does not have features to deal with accessibility challenges [I strongly agree] Proposed barrier 2: Lack of interoperability with assistive technologies [I strongly agree] Proposed barrier 3: Lack of information about the availability of accessible ICTs [I strongly agree] Proposed barrier 4: Lack of instructions about how to use accessibility features [I agree] Proposed barrier 5: Extra cost of accessible ICT is a concern for the user [I strongly agree] Proposed barrier 6: Little awareness of ICT providers on accessibility [I strongly agree] Question 15b: Are there any other barrier(s) to e-accessibility? Please specify. [Another barrier to e-accessibility is the fragmentation of actions at EU level: if each European country chooses its own way of working towards accessibility in the ICT field, it will hinder the definition and creation of clear and measurable targets for accessibility for commercial players. It will also confuse ICT providers as to which rules they are supposed to follow. A second barrier we have identified is the lack of awareness of existing standards among web technology providers and understanding of how they apply - for instance ISO-9241-171 for software accessibility. It follows from this that developers do not consider accessibility as a fundamental integral element in the design process and do not carry it through in upgrades and new releases. But the main barrier to accessibility is affordability. For example, voice output on mobile phones is available but costs a lot more than a "standard" phone. Legislation should strongly support affordable accessible technology and explore the introduction of specific funding mechanisms for products and services that cannot be provided and sustained in a competitive market (such as refreshable Braille display or sign relay services).]
Question 16: Do you provide accessible technologies/do you include accessibility in your services? - Yes, we always propose it to our clients - Yes, when the clients request it - No, because there are few requests from the clients - No, we don't have accessible solutions - I am not concerned Question 17: What are the main barriers for you when dealing with e-accessibility? - The lack of technical specifications - The difficulty to implement technical specifications - The lack of harmonised approach at European level - The lack of demand - The extra cost - I am not concerned - Other, please specify.
Question 18: Are you aware of the issue of e-accessibility and of the implications for persons with disabilities using your goods/services? - Yes, I am fully aware - Yes, I am partially aware - No, I am not aware - I am not concerned
- Lack of availability of accessible ICT - Cost of accessible ICT - Lack of interoperability of accessible ICT with other technologies - Other, please specify. - I am not concerned B - Priority areas for EU action There are many ICT-enabled products and services that may pose accessibility challenges for disabled persons. Question 20a: For which technologies/equipment should possible further action at European level be a priority and why? Please note that for each of the proposed technology/equipment, you have to choose between High priority, Relevant priority, Low priority, No priority, I don't know. Simply delete the answers as appropriate. Proposed technology/equipment 1: Digital TV [High priority] [Despite years of discussion between industry and user groups, there is still no digital TV equipment on the market that is accessible to blind and partially sighted people. Without TV equipment that provides a spoken interpretation of the plethora of on-screen, visual information that digital TV uses, digital switchover will mean "digital switch-off" for the 30 million blind and partially sighted citizens of the EU when the digital switchover is completed in 2012. A general requirement under European e-Accessibility legislation would ensure that a manufacturer who provides accessible TV equipment is not at a competitive disadvantage vis-à-vis other suppliers into the EU market, and thereby create a level-playing field. Furthermore, as TV broadcast can be accessed through more and more devices, it will become more important to ensure accessibility of a variety of interfaces, including online broadcasting, for instance using the i-player.] Proposed technology/equipment 2: Mobile communications [High priority] [Access to mobile phone for disabled people is not currently covered by any legislation, and blind and partially sighted people continue to face severe usability and access problems. Indeed, the scope of the Directive 2002/22/EC on universal service and users' rights relating to electronic communications networks does not include mobile communications. The Radiocommunications and Telecommunications Terminal Equipment Directive 1999/5/EC does cover mobile phones and refers to the need for equipment to be designed accessibly for disabled people (article 15), but provisions for the Commission to apply 'essential requirements' have never been used. European legislation is therefore needed to ensure mobile communication services and equipment are accessible and affordable to disabled people.] Proposed technology/equipment 3: Fixed communications [High priority] [As stated in the previous question, accessibility issues with regard to electronic communications are addressed in very patchy way: network and services are covered by the electronic communication framework (currently under review), but accessibility requirements are limited to fixed-line telephony. Equipment is covered by the Radiocommunications and Telecommunications Terminal Equipment (RTTE) Directive, but the Commission has never used the accessibility provisions and the RTTE Directive does not cover the issue of affordability of accessible equipment. E-Accessibility legislation would therefore be a welcome framework to ensure that we move to technology-neutral policy on electronic communications, that user equipment such as mobile phones is covered by accessibility requirements, and that affordability issues are addressed.] Proposed technology/equipment 4: Self-service terminals [High priority] [The MeAC study found that self-service terminals are rarely made accessible to disabled people, in particular highlighting the fact that "on average just 8% of all ATMs that have been installed by the two main retail banks in the EU 25 countries provide 'talking' output to ensure accessibility for people with visual impairments, with most of these to be found in just three countries." This finding shows that service providers in this field are not convinced that it is worth their while to make these services accessible for disabled people. We therefore believe, e-Accessibility legislation should formulate functionality requirements so as to allow and encourage technology progress with regard to accessibility in every ICT sector. For instance, although WCAG 2.0 applies to web accessibility, its core principles could be used to develop generic e-accessibility requirements. There also needs to be a mechanism for disseminating existing standards and guidelines and clarifying which ones apply when, as there are already international, Europe and national standards that apply to public access terminals. The key issue is to ensure that these standards are actually applied and that whatever research and technology development carried out do result in accessible public access terminals. At the moment, for instance, self-service terminals in the health sector are being rolled out that are not accessible to blind and partially sighted users.] Proposed technology/equipment 5: Personal computers [High priority] The use of ICTs, and personal computers in particular, is now prevalent in most workplaces. This has the potential to offer many more job opportunities for blind and partially sighted people, but only if personal computers and intranets are accessible. A recent study carried out by the Centre for the Economics Education in the UK "Use IT or Lose IT? The impact of computers on earnings" (2007) even estimates the wage premium for being able to use the internet and the email to be around 10 per cent - it is essential blind and partially sighted people, and other disabled people, are not put at an economic disadvantage because of e-Accessibility issues. The accessibility of software applications is also often overlooked, yet it is a barrier to people using personal computers, in particular for work or study. EBU therefore believes it is equally important that core business systems, e.g. finance and HR, are developed to be accessible by all users. With the increasing use of web-based applications, it is important that software accessibility is promoted and that emerging standards (ARIA) are brought to the attention of developers.] Proposed technology/equipment 6: Internet / web [High priority] [EBU strongly believes that since more and more services are delivered online - from access to public information and health services, to education and training activities in schools and colleges, to commercial transactions - a rapid improvement in levels of web accessibility is needed, starting with websites providing information to the public, i.e. public services and services of general public interest, such as financial services. Websites should be accessible to all European citizens, whether disabled or not. Of particular concern to blind and partially sighted people is the increasing use of the PDF document format, which is not always accessible to screenreader users - for instance tables and empty lines cannot be read. EBU understand such a format is necessary to protect documents but believes it should be made accessible.] Proposed technology/equipment 7: Domestic equipment [High priority] [Many domestic appliances, such as kettles, can be used by blind and partially sighted people without any adaptations. However, items using digital displays or touch screen input, such as washing machines, can be impossible for a blind person to use unless there is a speech output and clear tactile controls. Focus group research carried out by RNIB in the UK identified domestic equipment as one area of key concern as people were afraid of not being able to carry out domestic chores independently.] Proposed technology/equipment 8: ICT in general [High priority] [As information and communication technologies converge, there is an opportunity to introduce accessibility from the start into converged platforms - as well as a danger not to. There is also a danger that the convergence of technologies may lead to confusion over user requirements and relevant guidelines and standards. The increasing use of touch screen interface, for instance in in-flight entertainment, public access terminals and mobile communication devices, is a problem for blind and partially sighted people. It is important that accessibility is considered as technology develops and is included in new products.] Question 20b: Are there any other ICT that should be a priority at EU level? Please specify. [E-books and e-readers: The rapidly increasing number of books and journals available in electronic format, including in the academic and education fields, offers a great opportunity for blind, partially-sighted and other print-disabled people to access more books, more quickly, more cheaply and to be able to adapt them to formats which suit their individual needs. However, it is vital accessibility is built in from the start and/or to remove any existing barriers: at the moment, people trying to access these electronic books and journals have to negotiate a number of layers of search engines, websites and catalogues before they can access the products they need, all of which need to be accessible. This assumes at least a reasonable level of computer literacy. They also need to download special software packages to enable them to download and access electronic books and journals. Finally, once readers get to the book, there may be digital rights management "wrapping" which make access very difficult. The book/software/hardware then needs to be compatible with the assistive technology software which the people use, whether text-to-speech, large print or Braille.] Question 21a: For which services that are based on ICT should possible further action at European level be a priority and why? Please note that for each of the proposed services, you have to choose between High priority, Relevant priority, Low priority, No priority, I don't know. Simply delete the answers as appropriate. Proposed services 1: Consumer banking, financial services [High priority]
Proposed services 2: Consumer retail services [High priority]
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