Select Committee on Culture, Media and Sport Appendices to the Minutes of Evidence


Memorandum submitted by Royal National Institute for the Blind


  RNIB is concerned that:

    —  The Government has not given any priority to the needs of visually impaired people in either the development of communications policy or in pre-legislative consultation.

    —  Two million visually impaired people in the UK remain largely excluded from ICT and digital broadcasting, with the situation deteriorating.

    —  OFCOM must be fully representative of disability and visual impairment issues and invested with a more proactive role as advocate for excluded consumers.

    —  The market has produced ICT equipment and services that are not usable for blind and partially sighted people.

    —  Legislation and regulation must ensure enforceable industry standards and license conditions as opposed to the currently envisaged emphasis on voluntary codes of practice and general authorisations.

    —  Digital switch-over will immediately exclude between one and two million people from digital television various potentially beneficial interactive citizenship services at a stroke.

  RNIB offers:

    —  To give expert technical and evidential policy testimony to the Committee on these issues.

    —  Examples of services and equipment which blatantly exclude people with sight difficulties.

    —  Design and up-stream solutions.


  The Royal National Institute for the Blind (RNIB) is the largest organisation representing the interests of the almost two million visually impaired people in the UK. RNIB offers a wide range of direct and indirect services in many sectors. Our mission is to challenge the disabling effects of sight loss. RNIB challenges all barriers in the path of blind and partially sighted people and works to ensure their access to services and information on an equitable basis.

  RNIB is in touch with thousands of blind and partially sighted individuals and local groups who have been expressing increasing alarm about being excluded from the digital revolution, with specific concern being expressed around digital broadcasting and internet access.

ICT, broadcasting and visually impaired people

    —  Two million people in the UK have a serious sight problem which cannot be corrected by glasses.

    —  A further nine million people would struggle to read standard 12 point print on a LCD display.

  RNIB uniquely understands that the enormous growth of screen based technologies threatens to deny blind and partially sighted people the benefits of the communications revolution. Digital television and radio, EPGs, WAP mobile telephones, PDAs, the internet, public information kiosks and ATMs could all easily be made accessible to blind and partially sighted people but overwhelmingly are not.

  Future converging technologies will have even greater capacity for screens or other visual data output devices and therefore there will be an even greater danger that they will exclude people who have restricted sight.

  The relevant industries have demonstrated, by and large, that despite intense lobbying they are not prepared to put the research and development resources into designing inclusively, and they feel that there is no statutory regulatory requirement for them to do so, or even standards for them to follow. The previous propensity of markets in the medium to long-term to develop common standards is rendered obsolete by the pace of change. In this context public sector leadership is vital, especially as people are being excluded now.


  RNIB supports the creation of a single regulator for the converging information, communication and broadcasting industries. We recognise the huge potential of convergence for deepening and extending the social, economic and cultural inclusion of disabled people but caution that many are in danger of being excluded from the benefits altogether.


  It is RNIB's contention that the paving Bill should spell out the principal objective and general duties of the Secretary of State and the new regulator. We would want something akin to the principal objective set out in the Utilities Act 2000 which marries protection for consumers with the promotion of effective competition and includes specific reference to the Secretary of State and the regulator's duty to have regard to the interests of disabled people, pensioners, people on low incomes and individuals living in rural areas. Visually impaired people fall under each of these categories with, for example, 90 per cent being over the age of 65 of whom nine in 10 live on an income of less than half of the national average. Ideally we would want reference to promoting full access to communication services for all disabled people.

  As we understand it the plan is to have a Chairman and the rest of the board in place by next spring—before any principal objective and general duties have been established and before the detail of the Communications Bill has received any scrutiny. Key appointments will be made without reference to any principal objective. Unless it is clear what the primary objective of the new regulator is we fail to see how the right appointments can be made. It is essential that the board know at least in essence what their overarching purpose is and how consumer protection features. In any case, a commitment to disability equality and a real understanding of the access issues for disabled people in relation to the different technologies should certainly figure among the criteria for appointments. RNIB would argue that one member of the board should be required to have personal experience of disability and hold a brief to represent the interests of disabled people.


  We are concerned that there is no reference in this paving Bill to the principal objective of the new regulator, no intention to create a shadow consumer structure and no provision for disability access or representation.

  These omissions reinforce our concerns that the digital communications agenda is being driven forward with a lack of practical commitment to securing the full inclusion of visually impaired people.

  Now is the time to make that commitment. The White Paper indicated that OFCOM would be required to give due weight to the need for improved access to communications services for people with disabilities. Rather than take this on trust, Parliament should ensure that it is built into the new regulatory framework from the outset.

  Since the board is apparently to play a key role in setting the vision for OFCOM we think it essential that Parliament gives them a clear steer in this Bill. As things stand parliamentarians are effectively being asked to entrust appointees with the vision for OFCOM.

  Furthermore if there is going to be an argument about the principal objective, and in particular what giving "due weight" to the need for improved access to communication services for people with disabilities means it should be had now before we get into the detail promised in the draft Communications Bill. There is a pressing need to ensure the shadow framework has a clear overall purpose if the needs of visually impaired and other disabled people are not to be an afterthought.

Shadow consumer structure

  It is perfectly sensible to set up OFCOM in a shadow form and make arrangements for a smooth transfer to the new regime once the main Communications Bill has been enacted. However, the same principle should have been applied to the consumer structure. Energywatch was set up in shadow form and overlapped with the outgoing gas and energy consumer structures. There is no reason why the same approach should not have been used here, especially in view of the pressing need to put disabled people in the picture. Our fear is that the absence of such a structure for communications signals a relatively weak consumer regime. We would argue for a shadow, independent consumer panel—with appropriate representation for visually impaired and other disabled people and strong powers—to be put in place sooner rather than later.


  RNIB has many current concerns about the course of consultation and legislation. We would like to know

    —  What high-level discussions Ministers and officials are planning to initiate with disability organisations on the scope and detail of the draft Bill?

    —  Will arrangements be put in place for ensuring alternative format versions of the draft bill and any accompanying consultation papers are readily available and effectively publicised to individual visually impaired people and other disabled people and their organisations? What is the communications strategy?

    —  Will the consultation process involve proactively seeking out the views of visually impaired people and other disabled people across the UK?

    —  Are there plans to organise fully accessible regional meetings/focus groups to discuss the proposals with stakeholder groups?

  Full parliamentary scrutiny will be vital. We welcome the fact that the Culture, Media and Sport Committee is already launching a further inquiry on the issue and see a vital role for a Joint Committee of both houses to subject a draft bill to rigorous pre-legislative scrutiny. The more the Joint Committee can engage with stakeholder groups during its consideration of a draft bill the better. This of course will have implications for the length of the consultation period.

Government's overall objectives

  RNIB welcomes the prospect of swift legislation and the opportunity for consultation, and urges the Government to continue to make contact with us on the technical issues around visual impairment and converging technologies.

  RNIB feels that the Government is in grave danger of failing to ensure that services are accessible to visually impaired and other disabled people. RNIB wants universal design standards for service providers (eg EPGs) and manufacturers (equipment) to be included in license conditions. We also want government to specify short-term measures to ensure access if full access is technically not feasible.

  The promotion of inclusion can only be achieved if it is evidentially based. The regulator must prioritise studies of the user profiles of disabled and older people who are currently excluded, examine future demographic change and put the business case to suppliers and service providers.

Public service broadcasting

  The market alone will not provide a universally accessible and affordable system of PSB, especially to visually impaired people. The White Paper recognised this, but failed to suggest a solution. Access to public service channels is a key concern for visually impaired people, and should be central to OFCOM's activities.

Digital broadcasting

  RNIB is extremely concerned that digital broadcasting is leaving blind and partially sighted people behind. The two chief ways that people with sight impairments could enjoy TV programmes are audio description and text manipulation. Yet

    —  Only 45 blind households have been given the equipment that can receive audio-description.

    —  There are currently no plans to produce any more of this equipment.

    —  The government is using the fact that there will be no equipment as a reason not to require more programmes to be audio described.

    —  The number of audio described programmes is pitifully small compared to those that are sub-titled for deaf people.

    —  At present blind viewers cannot use digital television because of the inaccessibility of on-screen menus.

    —  There is no requirement that future digital television sets include equipment for audio description or accessible navigation features.

    —  Many of the people who could benefit the most from shopping, voting or communicating through interactive television could be deprived of the opportunity.

Analogue TV switch-off

  Unless action is taken now the switching off of analogue television will force the 94 per cent of blind and partially sighted people for whom TV is the major information and entertainment conduit to struggle with:

    —  unfriendly navigation;

    —  small print and poor contrast screen menus;

    —  audio-description which is either rare, expensive or non-existent;

    —  and interactive features for which they have already paid financially (by purchasing the set, or package) but cannot use.

  The Government has announced plans to launch small-scale pilot projects offering free conversion to digital television, including access to free-to-air digital channels and interactive services, including the internet. However, none of these trials include people with sight problems.

  Clearly there is much pressure on the government to provide incentives to encourage people to switchover. The Government is keen to discourage speculation that it will give away free set top boxes for fear of damage to the market and will need to provide other incentives. However, people with sight problems face a huge disincentive that not only will they not be able to benefit from opportunities that digital TV brings but will find it harder to change channel and find out what is on next.

  The government could provide incentives for people with sight problems by ensuring access to audio described TV programmes and access to interactive services like the internet. The internet is a powerful gateway to the world of communication and information, and if people with sight problems could access information about health, benefits and other services this would increase their independence.


  Internet access for blind and partially sighted people is contingent on website accessibility, screen readers, access software, training and affordability.

  The internet promises the ability to receive health and emotional support without having to travel to be in the same room as the professional. These services delivered cheaply and quickly could enormously benefit the section of the community that is less mobile and less independent. It also has very pertinent applications for those without useful sight.

  The ability to shop, talk to a care worker, vote, check the TV listings, book a taxi, pay bills, or write to a relative through a digital television would revolutionise the lives of hundreds of thousands of citizens who are currently unable to easily undertake these tasks on their own without added cost.

  RNIB wants clarification that "universal access to the Internet by 2005" will mean access for everyone, not just those who (feel confident that they) want it. Blind and partially sighted people are largely technologically disenfranchised and have the right to be sold the benefits of getting online and to be aware of how they will be excluded if they are not online.

  Legislation must not overlook the crucial aspects of training and on-going support. Visually impaired users must also be helped to upgrade their equipment so they stay connected.


  RNIB believes that access to higher bandwidth services will be crucial for blind and partially sighted people and calls for representation on the group looking at future strategy.

  RNIB agrees that the market will not deliver universal affordable high speed connections, and that older visually impaired people in rural communities will be particularly excluded. Note that high-speed access is still very limited (and expensive at £40 per month). Many rural areas not yet covered. The availability of equitable and accessible library services for blind and partially sighted is crucial to countering this excluding tendency.


  RNIB respects the moral and economic elements of copyright, and the entitlement of creative artists and of those who add value to creative material to be fairly rewarded for their endeavours. However, we see it as an abuse of copyright to use it in any way that denies print disabled people, including visually impaired people, equitable access to information.

  For this reason we welcome the Government's commitment in principle to introduce an exception in copyright law for the benefit of blind and partially sighted people. We very much hope to see legislation passed during the current session of Parliament, and trust enough parliamentary time can be made available. While it is the DTI which leads on copyright legislation, the support of members of the Culture, Media and Sport Select Committee would be most valuable.

  The proposed legislation would eliminate the need for permission to be sought prior to the production of alternative formats, but would not deal with technical blocks to access, as explained below.

  Technological developments mean that copyright-protected material is increasingly presented on the Internet. Various rights management systems are employed to regulate access to this material. Unfortunately, they are often designed (no doubt inadvertently) in such a way as to render the material inaccessible to blind and partially sighted people. The display cannot be enlarged or transposed into synthetic speech. The fundamental answer to this problem lies in better design, and RNIB is actively involved in influencing bodies such as the Open Electronic Book Forum.

  However, blind and partially sighted people also need a legislative framework which guarantees them alternative means of access to material which is technologically blocked. It is therefore essential that the European Copyright Directive (Article 6.4.) is effectively implemented and that rights holders are obliged to co-operate in overcoming these barriers. A draft statutory instrument on the implementation of the directive will be published by DTI this Spring. We hope it will face the issue squarely.


  RNIB believes that the current enquiry would benefit hugely from the evidence of an organisation representing the interests of a large section of the community whose sensory impairment present particular ineluctable structural challenges to communications legislation and regulation. We remain hopeful that the Committee call upon us to give oral testimony.

January 2002

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