[ebu response 4 September 2008] Public consultation on web accessibility and other e-accessibility issues
Availability of product information, particularly from mainstream suppliers/retailers
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Availability of product information, particularly from mainstream suppliers/retailers Proposed services 3: Travel, tourism services [High priority]
Proposed services 4: Audio-visual content services [High priority] [The Audiovisual Media Services (AVMS) Directive does now include the accessibility of audiovisual services within its scope (article 3c). However, it does not impose mandatory obligations on Member States to make TV broadcasts accessible, nor does it establish specific targets. This is a serious failing. The MeAC study has shown that there is little subtitling for deaf and hard of hearing people and almost no audio description for blind and partially sighted people in EU countries, including spoken subtitles of foreign language programmes. The market alone has clearly not delivered these access services in the many years since they first became technologically feasible. E-accessibility legislation would therefore be welcome to encourage broadcasters to explore solutions.] Proposed services 5: Services in general (that use ICT) [High priority]
Question 21b: Are there any other services that should be a priority at EU level? Please specify. [Inaccessible education services, particularly where web and software are used to deliver learning and assessment tools and exams, can hinder the achievement of educational qualifications by disabled people. Educational publishers produce more and more mixed media publications (for instance a booklet with a multimedia CD and a website database) which are mostly mouse-based and therefore rarely accessible to screenreader users. Internet and computer use are also now essential to the completion of most degree courses, while many third-level institutions now have intranet or internet-based communication networks that enable social communication between students, provide university news broadcasts, and ensure course-related communication between teachers and students. A student unable to access the internet would thus find it virtually impossible to fully participate in third-level education. In terms of tangible educational impacts, there is evidence that being able to avail of e-learning can impact positively on the achievement of qualifications. A case study in the UK found that students in lower education attainment groups achieved nearly half a grade higher on their GCSE’s when they had more than 10 hours of e-learning13. Where e-learning is inaccessible to people with disabilities, this will add to the educational disadvantages that they already face in comparison to their peers.] C - Preferred approach Explanation: Action at European level to promote e-accessibility can take many forms. It is necessary to define which actions would be more effective or necessary. Possibilities include: binding legislation; non-binding legislation (recommendations); standardisation and reference technical specifications; enhanced benchmarking and good practice exchange; increased R&D and innovation support. Question 22a: What should be included in possible future EU action for e-accessibility? Please note that for each of the proposals below, you have to choose between High priority, Relevant priority, Low priority, No priority, I don't know. Simply delete the answers as appropriate. Proposal 1: Binding legislation [High priority] Proposal 2: Non-binding legislation such as recommendations [Low priority] Proposal 3: Standardisation; technical specifications [High priority] Proposal 4: Benchmarking and good practice reporting [Relevant priority] Proposal 5: Increased research support [Relevant priority] Proposal 6: Increased innovation / deployment support [High priority] Question 22b: Please provide details in terms of the way the modalities for possible EU action should be implemented. [EBU strongly believes a European approach to e-accessibility is needed in the minimum form of a directive to overcome fragmentation and drive coordination and set a clear deadline for implementation. A European approach should also drive the creation of a market in accessible tools and support services and ensure a level-playing field for all stakeholders. We want to stress that a recommendation will not be enough. Member States have already shown their commitment to encourage the development of e- accessibility, but have not been able to deliver. Experience in the Netherlands, for instance, shows that self-declarations of web accessibility do not work. We therefore believe binding European regulation is the only way to ensure Member States enforce e-accessibility measures in a coordinated way. These measures should make use of standards and guidelines, where they exist, or seek to develop new ones, in particular using the Design for All principles.] D - Legislative action Explanation: A number of countries have legislation in place to promote e-accessibility. Some legal provisions on e-accessibility also exist already at EU level. If further legislation is considered at EU level, without prejudice to the current acquis communautaire, several questions must be addressed amongst which the foremost are about which e-accessibility requirements to comply with and the criteria for selecting the ICT technologies and services concerned. Question 23a: Which types of e-accessibility requirements are most relevant? Please note that for each of the requirements below, you have to choose between Very relevant, Relevant, Somewhat relevant, Irrelevant, I don't know. Simply delete the answers as appropriate. Requirement 1: Offering an alternative solution to the product/service (e.g. operator assistance) [Very relevant] Requirement 2: Offering alternative ways of user interaction (e.g. audio output next to text). [Very relevant] Requirement 3: Offering at least one accessible model within the product range [Very relevant] Requirement 4: Providing information on the e-accessibility features [Very relevant] Requirement 5: Compliance with e-accessibility standards, where these exist [Very relevant] Requirement 6: Interoperability with assistive technologies [Very relevant] Requirement 7: Interoperability with other ICTs to ensure end-to-end accessibility. [Very relevant] Question 23b: You may wish to quality your answer by referring to the technologies, equipment or services that you selected before as a priority for action. Please specify. [It is important that whatever alternative product or service is developed actually corresponds to what users want, and is not a poor alternative. Overall, it would be preferable to develop an accessible product/service in the first place - alternatives should not be used to avoid developing such accessible products or services.] Question 24a: Which criteria are relevant to guide the selection of products and services that need to comply with e-accessibility requirements? Please note that for each of the criteria below, you have to choose between Very relevant, Relevant, Somewhat relevant, Irrelevant, I don't know. Simply delete the answers as appropriate. Criteria 1: Product/service is important for participation in society and economy [Very relevant] Criteria 2: Product/service is essential for the personal safety of the user [Very relevant] Criteria 3: Service is of public interest [Very relevant] Criteria 4: Product or service is widely spread amongst the population in general [Relevant] Criteria 5: Development and deployment cost or sales prices of the product or service are much higher than the cost of the e-accessibility features. [Relevant] Criteria 6: Novelty of product or service, e.g. imposing accessibility requirements on new models only. [Relevant] Criteria 7: Expected lifetime of the product or service is much longer than the time needed to add the e-accessibility features [Somewhat relevant] Question 24a: You may wish to qualify below your answers by referring to the technologies, equipment, or services that you selected before as a priority for action. [EBU believes that ideally all products and services should be accessible - this means ensuring that mainstream products and services are accessible by all and allow add-on software and hardware for disabled users requiring further accessibility. For instance, it should be possible to use a PC without a mouse and to magnify and use self-voicing, and to add assistive technology such as screen reader and refreshable Braille display for blind and partially sighted users. ] Question 25: If you consider further legal action would be appropriate at EU level to improve e-accessibility in general, please provide further details on your views. [Legislation requiring software and other ICT to incorporate compliance with accessibility standards throughout their development would lead to accessibility for all and improve access for people in all aspects of their life, not just education and employment. Supporting public sector procurement of accessible ICT is just a first step towards this broader goal. When considering future legislation, it is important to look at precedents and at what is being devised elsewhere in the world. We therefore urge the Commission to examine the approach being taken in the USA to legislate on accessible telecommunications and ICT. The "21st Century Communications and Video Accessibility Act" which was tabled in the USA on 19th June 2008, is intended as a joined-up legislative approach to ensuring the accessibility of ICT and telecommunications systems. The very fact of its being tabled recognises the need to address some of the problems of inaccessibility through the legislative route, and the failure of "market forces" to provide full accessibility voluntarily. The bill covers a large range of areas. As an overview these are:
E - Expected impact of action at EU level Question 26: What could be the costs (for individuals, companies, or other concerned parties) of a possible more general EU approach on e-accessibility? These could be costs related to adaptation of the technology, verification of compliance with requirements, information provision to disabled users, etc. Please elaborate your response and relate to the priorities for technologies or services identified before. Please provide evidence of expected costs as available. [It is undeniable that there will be costs associated with introducing e-accessibility, but there are already heavy costs associated with inaccessibility - the exclusion of more than 10 per cent of the EU population from participating in the European Information Society - getting access to knowledge, education and information - and thereby from contributing fully to the EU social and economic development. Experience also suggests that where companies invest in developing accessible solutions, the costs are more than compensated by the benefits both in social and economic terms. A clear example of a company that has been able to monitor the benefits of making its website accessible is that of Legal & General, a FTSE 50 financial services company providing products such as pensions, life assurance and investments in the UK. Legal & General re-launched its main website in July 2005 to improve usability and accessibility and ensure it would be used on mobile devices. The benefits were tremendous14:
EU-level legislation also reduces the cost at national level by ensuring there is no unfair treatment or additional requirement.] Question 27: What could be the benefits (for individuals, companies, or other concerned parties) of a possible more general EU approach on e-accessibility? These could be benefits relating to competitiveness, innovation, participation in the labour market, etc. Please elaborate your response and relate to the priorities for technologies or services identified before. Please provide evidence of expected benefits as available. [Every European citizen, whether disabled or not, has a right to access information and ICT products. This right has now been enshrined in the UN Convention on the Rights of People with Disabilities (Articles 9 - Accessibility and 21- Access to Information). However, the benefits of ensuring that blind and partially sighted people are able to access ICT (e-Accessibility) should be seen in the context not just of social but also economic benefits. EBU believes that ensuring that blind and partially sighted people have full access to ICT is a prerequisite for ensuring that they are well educated and able to contribute fully to the EU economy. This is crucial if the EU is to meet its Lisbon Strategy objectives. As public services and information are increasingly delivered online, it is essential to ensure that these are accessible to blind and partially sighted people. Similarly, as more and more commercial transactions are delivered online, it is essential that the ICT products and services that support them are accessible. To start with, there are quantifiable benefits for the broader economy simply from getting individuals to be digitally-engaged. A UK report, for example, has estimated that each additional digitally-engaged citizen adds more than £200 (€252) to GDP over three years.15 Blind and partially sighted people can benefit from ICT as much as, or in some cases even more than, others. For instance, whereas a blind person would once have required someone to read their correspondence to them, they can now benefit from the increased autonomy provided by text-to-speech output on computers. Such access technology is often very expensive. However, if design-for-all principles are used, the cost of accessible technology can be kept to a minimum. For ICT manufacturers and service providers, e-Accessibility of products and services means a larger potential market and a reduced need for support calls and alternative service delivery routes. Research carried out by Microsoft and Forrester Research, Inc in 2003 suggested that up to 60 per cent of the working age population would be likely to benefit from accessibility because of minor disabilities or other usability difficulties.16 Quite simply, there is a much wider potential market for accessibility features such as adjustability of displays and alternative output modes for anyone using ICT in particular circumstances (noisy/silent environment, poor lighting, hands-free situations etc.). For employers, it means the possibility of greater workforce productivity, the retention of older and disabled workers, and a larger labour pool to draw upon. Indeed, greater overall accessibility can help companies retain staff who have deteriorating vision, thereby avoiding job loss and moving someone onto benefits while spending time and money recruiting and training someone new. It has been estimated that an increase of just 1 per cent in the employment rate of people with disabilities in Ireland would results in savings of €20 million per annum based on avoidance of disability payments and increased tax take and depending on whether the employment is in a minimum- or average-wage job.17 This, in turns, means greater efficiency savings for government. So does accessible e-government. In Ireland, for instance, the Revenue Commissions have estimated that they have saved €10.5 million in 2005 from their online filing and payment system. If the barriers to internet access were removed for just 20 per cent of disabled people, there could be many more efficiency savings. Furthermore, EBU wants to point out that many innovations to provide accessibility have subsequently proven to have much wider value and appeal.18 For example, audio-books were first developed for blind people but the general market for audio-books now exceeds blind readers. Closed captioning of broadcasting is also widely cited as an innovation which, though originally designed specifically for people with hearing impairments, has found wide application for language students as well as viewers in public spaces such as pubs and restaurants. EBU therefore strongly believes that a joined-up EU approach to e-accessibility will strengthen the case for companies to embrace accessibility as an integral part of their product and service development and reduce the need for costly add-ons and re-design at a later stage. It will also allow them to export their products and services abroad, thereby ensuring that accessible products and services become a mainstream, rather than a niche market.]
For statistical purposes, this section seeks to gather information concerning key characteristics of individuals and organisations responding to this consultation. Please note that the Commission may publish the contributions received on its website. A. You are Please delete the answers as appropriate. [an organisation of users with disability] B. In case the Commission decides to publish the contributions received on its website, do you agree that your contribution is published? [Yes] If yes, do you agree that your response is published with your name (or the name of your organisation)? [Yes] C. If you wish, please provide your name and/or organisation and email address. [European Blind Union 58 avenue Bosquet 75007 PARIS (France) www.euroblind.org Contact details: Anne Spinali, European Campaigns Officer, EBU c/o RNIB anne.spinali@rnib.org.uk ] D. The Commission invites respondents to provide position papers. These should be sent to the following email address: einclusion@ec.europa.eu [About EBU The European Blind Union (EBU) is a non-governmental and non profit-making European organisation. It is one of the six regional bodies of the World Blind Union, and it is the only organisation representing the interests of blind or partially sighted people in Europe. EBU aims to protect and promote the interests of blind or partially sighted people in Europe. EBU currently has 45 member countries, each represented by a national delegation. We are happy for our contribution to be made public. For further information or clarification, and to arrange future discussions, please contact in the first instance Anne Spinali, European Campaigns Officer, anne.spinali@rnib.org.uk, +44 (0)207 391 2087.] 1 Commission Communication on web accessibility (COM(2000)284); Council Resolution on a European Action Plan for accessibility of public websites (2002/C 86/02); Council Resolution on eAccessibility (2003/C 39/03); European Parliament Resolution on accessibility of public websites (C5-0074/2002-2002/2032(COS)); Commission Communication on eAccessibility (COM(2005) 425); Ministerial Declaration on an inclusive information society (Riga, June 2006); Commission Communication on e-Inclusion (COM(2007) 694). References in this document are available at www.ec.europa.eu/einclusion 2 See "Measuring progress of e-accessibility" study, available at: http://ec.europa.eu/information_society/activities/einclusion/library/studies/meac_study/index_en.htm 3 The World Wide Web Consortium is preparing to adopt internationally recognised specifications for web accessibility in 2008, i.e. the new version of the Web Accessibility Initiative guidelines. They also inspire ongoing work by European Standardisation Organisations on public procurement of accessible Information and Communication Technologies (work on Mandate 376). See: www.w3.org and http://www.econformance.eu 4 Commission Communication on e-Inclusion (COM(2007)694). 5 See Commission Communication on Services of general interest (COM(2007) 725). 6 User agents are any software that retrieves and renders web content for users. This includes web browsers, media players, plug-ins, and other programs, which help in retrieving and rendering web content, possibly in combination with assistive technologies (definition from the World Wide Web Consortium). 7 RNIB has developed such functionality testing: the See it Right guidelines, http://www.rnib.org.uk/xpedio/groups/public/documents/publicwebsite/public_seeitright.hcsp The cost of the audit depends on the size of the websites (less or more than 50 pages), the degree of conformance that the client is aiming to achieve (See it Right, See it Right plus WCAG AA etc.). RNIB also provides assessment of pages/templates, consultancy sessions, rechecks, maintenance packages and training for web designers. 9 COM(2007)694. 10 Work Research Centre (2008) ‘ICT accessibility and social inclusion of people with disabilities and older people in Ireland: The economic and business dimensions’. Report commissioned by the NCBI Centre for Inclusive Technology (CFIT). 11 FreshMinds/UK online centres (2008) ‘Economic benefits of digital inclusion: building the evidence’, available at http://www.ukonlinecentres.com/corporate/content/view/11/112/lang,en/ 12 Dobransky, K. & Hargittai, E. (2006) ‘The Disability Divide in Internet Access and Use’, Information, Communication & Society: 9:3:313-334. 13 FreshMinds/UK online centres (2008) ‘Economic benefits of digital inclusion: building the evidence’, available at http://www.ukonlinecentres.com/corporate/content/view/11/112/lang,en/ 14 http://icant.co.uk/webstandardsforbusiness/pmwiki.php/Main/LegalAmpGeneral 15 Gov3 (2007) ‘Building a Business Case for Digital Inclusion’, report for UK online centres ltd., 23 February 2007, cited in FreshMinds/UK online centres (2007) ‘Understanding digital inclusion – A research summary’, available at www.uknolinecentres.com/corporate/images/stories/downloads/uk_online_digitalinclusion.pdf 16 Microsoft/Forrester Research, Inc. (2003) ‘The Market for Accessible Technology—The Wide Range of Abilities and Its Impact on Computer Use’ available at http://www.microsoft.com/enable/research/phase1.aspx 17 Work Research Centre (2008) ‘ICT accessibility and social inclusion of people with disabilities and older people in Ireland: The economic and business dimensions’. Report commissioned by the NCBI Centre for Inclusive Technology (CFIT). 18 National Council on Disability (NCD) (2005) ‘Information Technology and Americans with Disabilities: An Overview of Innovation, Laws, Progress and Challenges’ available at http://www.ncd.gov/newsroom/publications/2005/innovation.htm Directory: media -> position-papers media -> Unicef voices of Youth Chat Theme: Children and aids nigeria and Zimbabwe 13 October 2006 Background media -> Tsunami Terror Alert: Voices of Youth media -> Biblical Eschatology Presentation by: D. Paul Beck May 4, 2016 Ground Rules media -> Guide to completing the collection using the Omnibus system media -> The milk carton kids media -> Events Date and Location media -> The Gilded Age: The First Generation of Historians by H. Wayne Morgan University of Oklahoma, April 18, 1997 media -> Analysis of Law in the United Kingdom pertaining to Cross-Border Disaster Relief Prepared by: For the 30 June 2010 Foreword media -> Cuba fieldcourse 2010 position-papers -> July 2012 ebu response to ec consultation How would you envisage the "governance" of such an "Internet of Things" (IoT)? Download 148.78 Kb. Share with your friends:
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