Memorandum submitted by the Royal National
Institute of the Blind
1. INTRODUCTION
1.1 Royal National Institute of the Blind
(RNIB) is the leading organisation representing the needs and
interests of the two million people in the UK with a sight problem.
The organisation provides over 60 services. It works directly
and indirectly with blind and partially sighted people, representative
organisations, visual impairment professionals, national and local
government, the broadcasting and entertainment sector, and a range
of public and private organisations.
1.2 Since its Needs Survey* in 1991 showed
that 94% of blind and partially sighted people watch television
RNIB has taken an active role in highlighting access issues. It
has worked to try to ensure access to programmes, services and
equipment, both by direct work with broadcasters and manufacturers
and by influencing legislation. RNIB's role has become particularly
important since the introduction of digital television, which
provides considerable opportunities with the availability of more
channels and services, and better picture and sound quality. However,
for the majority of blind and partially sighted people these advantages
are offset by the problems in accessing services and equipment.
1.3 RNIB has recognised the access issues
related to digital television and through previous consultations
and direct working with service providers (including the BBC)
and manufacturers has ensured that some of these issues have been,
and continue to be, addressed. However, it is essential to have
relevant legislative and regulatory frameworks to ensure that
all issues are addressed, particularly to ensure that access issues
are automatically included in any future technology developments.
The BBC Charter is, therefore, a key part of this future framework.
1.4 RNIB was pleased that its campaigning
on the 2003 Communications Act resulted in Ofcom having the responsibility
for ensuring that many access measures would be covered by codes
of practice or an appropriate regulatory framework. It is essential
for the broadcasting industry to recognise and address the problems
caused by digital technology. Many of the issues covered by the
Communications Act are relevant to the BBC through its Royal Charter.
1.5 RNIB has worked with many BBC departments
to raise awareness of the needs and interests of blind and partially
sighted people, and to try to develop good practice guidelines.
RNIB, therefore, welcomes the opportunity to have input into the
Committee's inquiry in order to contribute to the debate about
the future of the BBC, and has responded where issues specifically
impact on the lives of people with a sight problem.
2. WHAT SCOPE
AND REMIT
SHOULD THE
BBC HAVE IN
THE DIGITAL
FUTURE?
2.1 Public Service Broadcasting: As
the UK's major public service broadcasting organisation, and one
that is publicly funded, the BBC has a responsibility to adopt
and implement good practice. Public Service Broadcasting plays
an important role in the provision of television programmes in
the UK by ensuring there is a variety of high quality programming
across a range of channels. Public service broadcasters have a
significant role to play in developing access services for sensory
impaired viewers on all television platforms. They should take
the lead, and have an on-going role, in providing the high quality
audio described programmes that blind and partially sighted people
expect. RNIB recognises that the BBC is now operating in an increasingly
fragmented market and that it needs to ensure that it can remain
competitive without losing its ability to provide a unique contribution
to the life of the UK and the wider world. However, development
within the new broadcasting environment must not mean a lowering
of standards.
2.2 AUDIO DESCRIPTION
2.2.1 RNIB recognises that the BBC has been
in the forefront of developing access services for blind and partially
sighted people, particularly since the launch of digital television.
The work it has done on technical solutions for the delivery of
terrestrial audio description has been invaluable. In addition
the BBC started providing audio description at the same time as
other digital terrestrial broadcasters, although it was not covered
by the relevant legislation. Although the BBC has given the commitment
to match such services it is essential for access provision, including
targets, to be included in the new Charter.
2.2.2 However, RNIB does want to ensure
that in the future the BBC does meet the spirit of its Charter,
and the aims of public service broadcasting. This is not currently
the case with the audio description digital satellite. Unfortunately
it took from 2001 until December 2003 for one channel (Five) to
transmit its audio description via satellite as well as terrestrial.
As at April 2004 the other broadcasters have not made this provision.
It is bad enough that these are all public service broadcasters
(BBC, ITV and Channel 4), but worse that they include the only
publicly funded broadcaster. The BBC has deliberately chosen to
withhold a service that would considerably enhance the viewing
experience for satellite viewers with a sight problem. The lack
of this audio description has been made worse for blind and partially
sighted satellite viewers by the fact that from mid-2001 until
late-2003 this was the only way of receiving audio description.
The first terrestrial receiver with audio description capability
only became available in December 2003, despite the terrestrial
broadcasters transmitting a description service since mid-2000.
(As at April 2004 there is no audio description on digital cable
television.)
2.2.3 It is important to understand how
audio description makes a programme more informative and/or entertaining.
It enables blind and partially sighted people to enjoy a much
wider range of material, including some that is difficult to follow
without it (eg complex series such as Waking the Dead and Silent
Witness). It enables independent viewing and, thereby, takes away
the dependence of relying on someone else to fill in the key gaps
(or missing the end of a story because there is no-one to ask).
Blind and partially sighted people will not get the most enjoyment
from and access to television programmes until Government and
industry recognise that adequate provision is essential. More
audio description of a wider range of programmes would be an incentive
for people to move from analogue to digital television.
2.2.4 Although RNIB concentrates on the
needs of blind and partially sighted people in this response it
is important to understand how audio description can benefit much
larger numbers of people.
The cognitive benefits to older people
were covered in the European AUDETEL Research from the early 1990s.
Comparison tests were done that showed that people remembered
more about storylines and characters after watching programmes
that were described.**
It is felt that description helps
people with learning difficulties and people for whom English
is not their first language.
In addition audio description is
beneficial to sighted people whilst their attention is not fully
on the television (eg when ironing, cooking, or when watching
television in a cara new development currently being promoted).
Audio description can, therefore, enhance the viewing experience
for most people, at different times under different circumstances.
2.2.5 As the only public funded, and the
major UK public service broadcaster, the BBC should:
provide more audio description than
other broadcastersaim for 50%, at least, irrespective of
the targets outlined in the Communications Act 2003, which are
totally inadequate;
provide audio description on all
digital platforms;
ensure the widest range of programming,
on all its channels, is described;
increase audio description output
on analogue television in order to raise awareness amongst the
general public as well as blind and partially sighted people.
(The current transmission of a described programme on analogue
is a good step but most blind and partially sighted people will
not be aware of a broadcast as part of the Sign Zone, in the early
hours of the morning);
ensure that when described programmes
are released on DVD the audio description is included.
2.3 Older people: The BBC must be
in a position to recognise and reflect social and demographic
change, particularly as current forecasting indicates that older
people will be the majority by the year 2025. It is worth noting
that the majority of blind and partially sighted people are over
the age of 65. Sight loss (along with hearing loss and certain
other disabilities) is related to ageing so inevitably the number
of older blind and partially sighted people will increase. It
is, therefore, essential to ensure that current planning for audio
description, and other access measures, provides a solid basis
for the future development of services.
2.4 Educational programmes: The BBC
has provided an invaluable range of educational programmes throughout
its history, for schools, through the Open University, and for
general viewing. The BBC of the future should continue to provide
this essential access to and opportunity for greater social inclusion
through its education and learning services, as well as its mainstream
programming. It has to ensure that some of its services are reaching
everyone at some time, and that it plays a role in the wider Government
aspiration of lifelong learning for all.
2.5 Films: As a result of its history
of encouraging and developing drama and films the future investment
in British films is another key role for the BBC. It should be
able to provide the infrastructure to:
ensure training and encouragement
for young, or new, writers and directors;
encourage the creative talents of
people with disabilities;
contribute to the mixed cultural
life of the UK; and
provide opportunities for greater
social inclusion.
2.6 RADIO
2.6.1 As well as access to digital television
it is important that Digital Audio Broadcasting is not overlooked
as radio is an essential medium for blind and partially sighted
people. DAB offers the benefit of a wider range of channels but
listeners still have to cope with displays of text. This will
increase when digital text services are offered and these will
be inaccessible to people with a sight problem unless leading
broadcasters and manufacturers ensure that they can be accessed
in alternative ways. The BBC has been in the forefront of DAB
development and should use its influence to ensure that these
services are actually accessible.
2.6.2 The BBC is in a unique position of
providing a wide range of radio channels, enabling it to plan
strategically to ensure that all tastes and interests are covered.
Both through network and local radio the BBC must be able to provide
the type of specialist programming that is not available from
other broadcasters (eg Radio 4's In Touch).
2.6.3 In the past local radio stations have
been in the forefront of developing programming for people with
a visual impairment. However, in recent years this situation has
changed with fewer opportunities for specialist programming. In
addition the areas covered by local radio stations are getting
larger, thereby destroying much of the benefit they brought in
their early days. Real local news is essential for those people
who cannot access their local newspaper. With the possibility
of more community radio in the future the BBC has role to play
in ensuring that its local provision really does reach out to
and involve the community, in order to meet the needs of the whole
audience.
2.7 DIGITAL TECHNOLOGY
2.7.1 The BBC has always been in the forefront
of broadcasting technology developments, and has been able to
use its research and development resources to ensure that good
quality standards are developed and adopted by broadcasters, both
in the UK and overseas. The BBC should be able to continue this
role, ensuring priority for the access needs of people with disabilities.
2.7.2 Digital broadcasting offers many opportunities
for viewers and listeners but is more complex, and therefore more
daunting, for many people. It is even more daunting for people
who cannot see on-screen menu information and remote controls/keyboards
and read instruction manuals. The BBC should be able to use its
unique position in the UK broadcasting world to ensure universal
design principles are adopted so that both broadcasters and the
public can benefit from the changes that are happening now and
that will continue for many years.
2.7.3 Many blind and partially sighted people
are apprehensive of the move to digital television, for a number
of reasons but most importantly complexity of equipment, lack
of understanding of the need to change, and cost. It is, therefore,
essential that digital television and radio services and equipment
are fully accessible to people with a sight problem prior to the
switch from analogue to digital. All sectors of the broadcasting
industry, Ofcom, and the Government have a role to play in ensuring
that outstanding access issues are addressed and resolved urgently.
2.8 INFORMATION
The broadcasting industry (under the auspices
of the Government's Digital Action Plan) has identified the need
for clear information about digital (multi-channel) television.
As a lead digital player, particularly for Freeview, the BBC has
a vital role to play in providing information about digital television
and radio. As part of its information provision it is essential
for the BBC to ensure that access services are included.
2.9 INTERACTIVE
2.9.1 As one of the benefits of digital
television is the provision of interactive (enhanced) services
it is essential to ensure that these services are accessible to
blind and partially sighted people. Any additional programming
that is accessed via an enhanced option should be assessed for
audio description in the same way as the main programme. In addition
description must be considered for the additional services that
can be accessed via an interactive operator, such as NHS Direct.
2.9.2 It must be noted that at present the
access technology that enables blind and partially sighted people
to work with computers is not transferable to digital television
platforms. It is important to recognise that television interactive
services are not generally accessible to blind and partially sighted
people. To address all interactive access issues guidelines can
be drawn up along the lines of the world wide web accessibility
initiative. The Government should be encouraging service providers
and manufacturers to work together on the development of such
accessible services and equipment, particularly as its agenda
includes the delivery of public services via digital terrestrial
television. This will not be achievable until all services and
equipment are accessible and affordable.
2.10 Websites have become another tool of
broadcasters to deliver information. RNIB welcomed working with
the BBC to ensure that its website is accessible to people who
use access technology. However, it is essential that the BBC ensures
continued commitment to this access, in its desire to extend audience
reach and services in an increasingly competitive marketplace.
RNIB recommends that people with disabilities are consulted prior
to the conception of any new online service to ensure best use
of the medium, and to avoid fundamental design errors that might
be expensive to correct retrospectively.
3. IN THE
CONTEXT OF
SCOPE AND
REMIT, HOW
SHOULD THE
BBC BE FUNDED?
Whilst RNIB does not feel that it can contribute
to the debate about the funding of the BBC it feels it is important
to make the following points:
the licence fee ensures that the
BBC is accountable to the public, not to commercial interests.
This ensures that the needs and interests of viewers and listeners
are paramount. This should ensure also that issues such as access
services for people with sensory impairments are fundamental to
the organisation.
it is important to note that if alternative
funding methods are introduced in the future that blind and partially
sighted people are not disadvantaged. Currently registered blind
people have a 50% reduction in their licence fee. This type of
measure must be available also in any future funding scheme, particularly
if full access measures are not in place.
4. HOW SHOULD
THE BBC BE
GOVERNED AND/OR
REGULATED; ROLE
FOR OFCOM?
4.1 The BBC can sometimes seem a cumbersome
organisation because of its size and complexity. However, the
BBC's ability to provide technical research and development, along
with other service functions has enabled it to become established
as a leading broadcaster worldwide. Its present structure enables
the organisation to offer integrated planning and service delivery.
Whatever structure is put in place to regulate the BBC in the
future the organisation must be able to maintain and build on
its successes and reputation, and ensure that the needs of all
consumers are paramount.
4.2 In order to ensure that the needs of
people with disabilities and older people are fully covered the
following measures should be put in place:
all BBC Advisory Councils to contain
representatives with disabilities, or with knowledge and experience
of people with disabilities;
a BBC Advisory Committee on Elderly
and Disabled People in order to reflect changing needs, in the
light of technological developments and demographic forecasts.
This committee would have a responsibility to cover the BBC as
both programme/service provider and employer and should work closely
with Ofcom's own Committee;
all Statements of Policy to contain
specific targets for people with disabilities and the provision
of access services, with clear indications of whether or not they
have been met and what resources have been allocated.
5. CONCLUSION
5.1 RNIB recognises that the BBC has introduced
a number of initiatives over the years to reflect the needs of
people with disabilities, such as the transmission of specialist
television and radio programmes, the appointment of a Disability
Correspondent and membership of the Broadcasters and Creative
Industries Disability Network.
5.2 RNIB recognises also that the broadcasting
world that will be covered by the new BBC Charter will be very
different from that of the past and that the BBC needs to adapt
to ensure its future. However, RNIB feels that it is essential
for the BBC to remain in the forefront of broadcasting in the
UK and as such it has a real role to play in ensuring that older
people and those with disabilities are not disadvantaged in the
future. A strong, independent BBC is essential for the future
of digital broadcasting in the UK.
5.3 RNIB would welcome the opportunity to
discuss the issues further with the Committee to ensure that the
new BBC Charter provides the right framework to ensure that people
with a sight problem are not disadvantaged in the broadcasting
world of the future.
* Blind and Partially Sighted Adults in
Britain: the RNIB Survey, Volume One (1991).
** The European AUDETEL Project: Final Report
(TIDE 1994).
14th April 2004
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