Introduction
The Department of Communications, Marine and natural Resources have produced a draft Sectoral Plan in response to requirements under the Disability Act, 2005. The process of producing the draft Plan included consultation both internally and with organisations of and for people with disabilities.
The draft Plan was put out for public comment on June 8th 2006, with views to be returned to the Department no later than noon on June 20th 2006.
The visually Impaired computer society is a self-help group whose aims include the promotion of technologies that facilitate greater inclusion into society of its members. We have over 100 members on the island of Ireland, and have been in existence since 1986. VICS is a subgroup of the Irish computer Society. This document outlines the response of VICS to the proposed sectoral plan.
Principles of Design For All
VICS recommends that the plan should stipulate that all public procurement tenders include a requirement, that the principles of Design For All should be followed in the planning, development and maintenance of all products and services. An important element of this is that people with disabilities are involved from the beginning in the development of these products and services. This ensures that any accessibility problems can be identified and solved at an early stage in the product life cycle. If barriers to people with disabilities are found once the product or service is complete, it is often both expensive and time consuming to rectify the situation.
VICS notes that Design for All is a requirement of two European Directives on Public Procurement that came into force earlier this year.
Telecommunications
VICS believes that the Universal Service Provider (currently eircom) should be required to provide copies of the complete telephone directory in a range of alternative formats to people with disabilities, including electronically via a medium suchas CD. At present every household in the country receives a printed copy of the telephone directory free of charge. This service should also be provided to people with disabilities. VICS is aware that directory enquiry request via telephone is already available for no cost. However, this facility only allows a user to make a limited number of requests at a given time. In addition, any information acquired in this way must either be remembered or written down for future use.
Indeed, VICS believes that ComReg already has powers to enforce such a requirement by means of the European Communities (Electronic Communications Networks and Services)(Universal Service and Users' Rights) Regulations 2003 (S.I. 308 of 2003).
Section 6 of the regulations states:
(1)The Regulator may with the consent of the Minister, specify obligations applicable to designated undertakings, designated for the purpose of ensuring that disabled end-users can enjoy access to and affordability of publicly available telephone services, including access to emergency services, directory inquiry services and directories, equivalent to that enjoyed by other end-users.
Broadcasting
VICS feels that a target of 1 percent of Irish television programmes to be audio described in the next few years falls far short of an acceptable level. The plan should specify a goal of audio description reaching an equivalent point of that of subtitling as soon as is technically feasible. Further more, this requirement must apply to home produced programmes and not just to those purchased from other producers.
Technology Ireland
The recent announcement of a large fund to be made available for research in the areas of Science and Technology included reference to the establishment of Technology Ireland. VICS recognises and welcomes the upcoming establishment of the Centre of Excellence in Universal Design under the National Disability Authority as a result of the Disability Act 2005. However, VICS believes that Technology Ireland should also address the issue of Universal Design or Design for All. Such an approach to technology development includes the needs of all members of society, nut just those with disabilities.
Documentation in Alternative Formats
VICS believes that all two-way communication with the Department and organisations under its aegis should be possible using alternative formats that suit the user on request. These should include large print, Braille and electronically. This should include access to all billing information.
VICS particularly draws the Department’s attention to the use of documents in PDF format. These are frequently unusable by blind people. All documents that are made available in PDF format should also be available in alternative formats, particularly on web sites. This is in line with requirements of the Worldwide Consortium’s Web Content Accessibility Guidelines.
Copyright
It is unclear if the Department is responsible for policy regarding Copyright, however it seems appropriate to comment here on the subject.
VICS recommends that the Plan specifies that all efforts will be made to ensure that Copyright is not a barrier to visually impaired people having access to written material in formats that suit their needs. This includes access to electronic versions of written books. It also means access to information stored electronically in proprietary formats such as PDF or various electronic book formats.
Contacting VICS
Tony Murray:
Chairperson, Visually Impaired Computer Society
Email: tony.murray at vicsireland.org
Phone: 01-6413801
Tim Culhane:
Deputy Chairperson - Visually Impaired Computer Society
Email: tim.culhane at vicsireland.org
Phone: 01-2415107
