APPENDIX 52
Memorandum submitted by The Royal National
Institute of the Blind
1. INTRODUCTION
1.1 The Royal National Institute of the
Blind represents the interests of 2 million blind and partially
sighted people in the UK. The Draft Communications Bill is of
vital importance to this hugely disadvantaged consumer group for
upon it depends their future inclusion in the Information Society.
1.2 Blind and partially sighted people form
a highly significant stakeholder group for the new regulator in
terms of numbers and needs. The number of people with sight problems
is set to increase with the ageing of the general population.
By 2031 at least 2.5 million people in the UK will be living with
a sight problem. Ensuring the needs of this group are promoted
and met by the regulator will benefit the interest of a wider
group of consumers—the one in seven of the British public,
for instance, who say they cannot easily read television captions.
1.3 Digital TV, convergence and new communications
technologies could bring huge advantages to this growing section
of society. For example, 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 could revolutionise
the lives of hundreds of thousands of citizens who are currently
unable to easily undertake these tasks on their own without added
cost. Yet, the enormous growth of screen based technologies threatens
to deny blind and partially sighted people these benefits. Digital
television and radio, EPGs, WAP mobile telephones, the Internet
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.
1.4 RNIB is extremely concerned that developments
in digital broadcasting, radio and telecommunications are already
leaving blind and partially sighted people out in the cold. A
robust new regulatory and legislative framework is needed to counter
this. Yet we can find little in the Draft Communications Bill
to reassure us. This is all the more frustrating since there is
so much that could be done, even in the face of rapid technological
change, to use legislation and regulation to bring about vital
social change.
1.5 Our written evidence focuses on how
the Bill might be strengthened to achieve the Government's stated
objectives of broadening access to cultural and recreational resources
through services such as audio description for blind and partially
sighted people and delivering universal access to a choice of
high quality services for all disabled people. It is vital the
Joint Committee devotes some attention to the issues raised here,
otherwise the Bill will simply not be fit for purpose.
2. THE GENERAL
DUTIES AND
POWERS OF
OFCOM
The need for a primary objective: universal access
2.1 We acknowledge that an attempt has been
made to give OFCOM something approaching a reasonable general
remit—for example, at least there is the suggestion of promoting
customers interests as opposed to just protecting them and there
is a subsidiary reference to having regard to the needs of disabled
people. But the jumbled list of general, competing duties fails
to hit the mark. The Government is wrong not to establish a hierarchy
of priorities. Competition is never an end in itself it is only
one of the means by which consumers gain better services and a
flawed one at that.
2.2 Of the Government's three original objectives
outlined in the White Paper by far the most compelling was that
of "ensuring universal access to a choice of diverse services
of the highest quality". This we would submit should be the
primary objective of the new regulator and indeed should be applied
equally to the Secretary of State. It puts the consumer and citizen
centre stage where they should be. Utilities legislation imposed
a primary objective on both regulators and Ministers alike to
look after the consumer, yet this Bill gives Government no steer
at all on where its priorities should lie.
Serving the customer or the consumer?
2.3 The use of the term "customer"
as opposed to "consumer" in the first Part of the Bill
and elsewhere is also worrying. Using the term consumer wherever
possible would offer better protection to the rights of disabled
end-users of communications services. In a household of more than
one, only one person will be the "customer", the person
named on the bill or the TV licence. Yet a disabled person in
that household is no less entitled to priority fault repair, a
bill in braille, text users' rebate, free directory enquiry service,
etc for not being the "customer". Using the term consumer
wherever possible would offer better protection to the rights
of disabled end-users of communications services.
Inclusive Design and Access for Disabled People
2.4 Furthermore the requirement to merely
"have regard to" the needs of disabled people where
it appears relevant is no guarantee at all that OFCOM will robustly
challenge their growing exclusion. OFCOM should have duties to
— secure that inclusive design principles
inform the development of all future digital communication technologies,
facilities, services and equipment;
— promote the need for disability awareness
and equality training throughout the communications industries;
and
— secure that accessible communications
services, equipment and facilities, including training and on-going
support in their use, are made readily available to consumers
who are disabled at no extra cost.
2.5 Inclusive Design (also referred to as
"Design for all" or "Universal design") ought
to be a major driver of change in the new communications framework
and yet there is no reference to it in the current Draft Bill
or in the accompanying policy documents. It means in essence that
all services and equipment should be designed taking the needs
of disabled and older users right from the design phase. If this
has not been done they should be adapted, where possible, to meet
the required needs. In the cases where neither of these scenarios
can be achieved, appropriate supplementary equipment and services
should be proposed. Promoting disability awareness and equality
training should happen in tandem with the promotion of inclusive
design principles throughout the industries.
2.6 OFCOM might also usefully be given a
specific role in promoting Web Accessibility and the benefits
of getting on line. The growth of the World Wide Web means that
people with serious sight problems now have the opportunity to
enjoy a wealth of information and services that was previously
unavailable to them, from up-to-the-minute news and travel timetables
to online shopping and banking. With the help of synthesised speech
and braille display technology, even completely blind people can
use the Web. For these access technologies to work properly, web
pages must be appropriately designed and must be written in valid
hypertext mark-up language (HTML). Many sites are unusable by
visually impaired people simply because they are poorly designed
and are written in invalid HTML. People with disabilities have
as much of a right to be able to access websites as anyone else,
but many designers fail to recognise this. The Web is an information
medium, but too many web designers still think of it as a purely
visual medium, and are unaware even that visually impaired people
can access the web. Access to websites is covered by Part 3 of
the Disability Discrimination Act, yet there remains a chronic
lack of awareness on the part of service providers. OFCOM should
work with the DRC and disability groups like RNIB to proactively
raise awareness of and promote compliance with the Web Content
Accessibility Guidelines (WCAG) published by the Web Accessibility
Initiative (WAI).
2.7 But promoting inclusive design is not
enough on its own. It is one thing to design a universally accessible
system or a piece of assistive technology and another thing to
bring it to market. The case of the audio-description module developed
by the Digital Network is a case in point. It works beautifully
when inserted into a common interface slot. It delivers high quality
reception of audio description. It is the gold standard. Only
45 households will have access to it because the broadcasters,
the multiplex operators, the equipment providers and the government
are not prepared to make the additional investment to mass-produce
it. Also, it is essential that the audio description software
is built into future receiving equipment so that an additional
(costly) piece of equipment is not a permanent requirement. Likewise
someone may yet develop a fully accessible, interactive mobile
phone system, yet there would be nothing in the Bill to ensure
it reaches its intended consumer group. Access to the Internet
similarly depends on being able to afford the appropriate access
technology.
2.8 Hence the regulator must have a concomitant
duty to ensure accessible services, equipment and facilities are
made available. A further issue is the need to ensure training
and ongoing support to disabled end-users is provided so that
they are enabled to make the most of all digital developments.
2.9 Such duties would we believe be entirely
consistent with the "future proofing" requirement. The
legislation should also impose similar duties upon the Secretary
of State because Government must also offer political leadership
here. We would also want conditions relating to access imposed
through the new regulatory framework in Part 2 of the Bill. This
will happen to an extent in respect of telecommunications but
will not happen in respect of access to other communication technologies
unless Parliament insists on it.
Duty to promote equal treatment in employment
for disabled people
2.10 The omission of any duty to promote
inclusive design or equal access to communications services for
disabled people is all the more bizarre given that the Bill rightly
concerns itself with promoting employment opportunities for disabled
people in the broadcasting industry. Access to communications
services is at least as essential to the employment prospects
of disabled people as action to extend opportunities within one
industry.
2.11 That said, RNIB strongly welcomes the
duties upon OFCOM to promote equal treatment for disabled people
in broadcasting and the corresponding requirements to be placed
on broadcasters through their licences. Positive action in relation
to employment opportunities for disabled people is desperately
needed to make inroads into what remain appalling and unacceptable
levels of exclusion from the labour market. Disabled people in
general are over twice as likely to be unemployed as those who
are not disabled For blind and partially sighted people the situation
is particularly acute. Every year 4,000 people leave work when
they lose their sight. Of these around 25 per cent are quickly
forced out of work even though most could continue to work with
the right support, adjustments and commitment. Overall three out
of four blind and partially sighted people are unemployed—a
figure which has barely changed in ten years. At least 25 per
cent of unemployed blind and partially sighted people would like
to work if the opportunities and support systems were in place.
One of the major barriers they face is employer attitudes with
half of all employers say they will not employ someone who has
"difficulty seeing".
2.12 There are, of course, some examples
of blind and partially sighted people forging successful careers
in the TV and radio industries, albeit far too few. Progress here
would not only contribute to wider employment opportunities for
those we represent, it might also help ensure that tomorrow's
communications policies are not as blinkered when it comes to
access and inclusion for disabled people in relation to communications
services and equipment as they are today.
2.13 But the scale of disabled people's labour
market exclusion is such that we believe the provisions must be
taken further.
— First, both OFCOM's duty to promote fair
treatment of disabled people and the licensing requirements only
apply to the TV and radio industries. We strongly believe they
should be applied to the telecommunications and Internet industries
and work connected with those services too. There is no logical
reason why these industries should be excluded, indeed it will
create exactly the sort of regulatory gap the Bill is supposed
to close.
— Second, the proposed thresholds in
Clause 224 are not compatible with current Government policy to
end discrimination against disabled people in employment and go
against the principle of full and comprehensive civil rights.
The Government rightly intends to abolish the small employer threshold
in the DDA 1995 in line with the EU Directive on Equal Treatment
in employment and occupation by 2004. Future civil rights legislation
will allow coverage of both businesses with one employee and businesses
seeking to recruit and hold their first employee. For the provisions
in the Communications Bill to reinforce the notion that firms
can discriminate below a certain threshold is nonsensical and
not a message the Government should want to send out.
— Third, a job retention strategy for
disabled employees should be required of the relevant industries—making
available opportunities for retraining is a key part of that but
so are a range of other policies such as time off for rehabilitation
and to put "reasonable adjustments" in place in the
workplace (ie a Disability Leave policy).
— Fourth, companies should be given
a steer to raise awareness of the Access to Work Scheme for disabled
employees while publicising their equal opportunities and training
arrangements.
— Fifth, the principle of equal treatment
of disabled people should be extended to disabled people seeking
work experience. Companies should be required to show how they
make the process of applying for work experience fully accessible
to disabled applicants and demonstrate that they have the necessary
policies and practices in place to properly support disabled people
on work placements, especially since they may not be eligible
for support through Access to Work. The EU Directive on Equal
Treatment in Employment and Occupation specifies that vocational
training should be covered by anti-discrimination legislation—OFCOM's
duty and those of the broadcasters should mirror this.
2.14 Finally, there is no reference to the
need for OFCOM to collaborate with the Disability Rights Commission
in relation to its duty in this area. If, as envisaged, OFCOM
may disseminate information and advice or even guidance/Codes
of Practice in this area such collaboration would seem essential
and ideally would be written into the Bill.
The need for an advisory committee on disability
access issues
2.15 If OFCOM is to make a useful contribution
to opening up the Information Society to blind, partially sighted
and other disabled people by promoting Inclusive Design and effecting
solutions to key access problems, expertise and commitment in
this area must built into the governance structure of the regulator
itself. The Office of Communications Bill 2002 provides that OFCOM
may establish advisory committees as it sees fit. Since there
is no requirement to ensure there is disability expertise on the
Board, the need for a high level advisory committee bringing together
representatives of disabled people and experts in the field of
inclusive communications design is even greater. The Committee
should be charged with helping to steer OFCOM's work on disability
access and feed into the work of the different sectoral groups.
A member of the Board could take on the role as "Champion"
of the work of the Committee so that issues raised by it are fed
in and heard at the highest level.
3. CONSUMER REPRESENTATION
IN THE
NEW REGIME
Consumer Panel
3.1 The Consumer Panel must be an independent
advocate of consumer's interests with a clear remit to promote
universal access and champion the needs and interests of disabled
people in particular. The Bill does not reflect this at present.
The legislation should spell out a robust mission for the Panel
To deliver a one-stop service providing advocacy,
dealing with complaints as well as providing clear and accessible
information and advice;
To foster confident and assertive consumers
who know their rights and to help them put pressure on the companies
to help them get better deals and improved services;
To campaign for the full inclusion of—and
the delivery of real benefits for—disabled, elderly and
low-income consumers in the digital communication revolution.
3.2 This is the kind of mission EnergyWatch,
for example, works to. The Consumer Panel will be but a pale shadow
of consumer bodies in other areas unless these parts of the Bill
are significantly beefed up.
3.3 Key to the Panel's effectiveness will
also be its resourcing, its independence and its ability to represent
the full range of consumer interests. Absolutely nothing is said
about how large the Panel will be or to what extent the Panel
will be resourced, what powers it will have to employ staff, or
to generate income. It will undoubtedly need its own Secretariat
and sufficient funding from the Treasury to employ administrative
and specialist staff and policy researchers if it is to have real
clout.
3.4 Nor will the Panel have sufficient independence
of the regulator. All members are appointed by OFCOM and may at
any time be removed. In addition OFCOM appears to retain the right
to withhold from it any information it chooses (96.6). In Utilities
regulation it is the Secretary of State who appoints the consumer
council. We call for the Panel to be completely independent of
the regulator. A memorandum of understanding could spell out how
they can work together with OFCOM to promote the consumer interest.
Members should be appointed by the Secretary of State with more
limited and explicit criteria for dismissal. Additionally, the
Panel should be directly accountable to the Secretary of State
and to Parliament for the work it does and the money it spends.
3.5 We welcome the fact that there will
be Panel members representing the nations and that appointments
must secure, as far as possible that the Panel are able to give
informed advice about the interests of disabled people among other
disadvantaged groups. This is rather limited, however. We would
argue strongly that there must be room for representatives of
visually impaired people and other groups of disabled people on
the panel. Disabled people are not a homogenous group; they have
different access requirements. A wide range of consumer voices
must therefore be supported and heard in the Panel Structure.
We would suggest a structure of consumer interest group fora feeding
into the main panel to accommodate this. All too often "representatives"
of disabled people on quangos are not supported in consulting
the constituencies they represent—the onus ends up being
with the individual or a sponsoring voluntary organisations. If
the consumer structure is to have credibility and deliver the
goods it will need to be set up and resourced to facilitate wider
engagement with disabled people.
4. OFCOM'S INTERACTION
WITH DISABLED
CONSUMERS
4.1 Direct service of customer needs will
dominate a large part of OFCOM's operations and will require substantial
ongoing resource and senior management attention. Yet no attention
has yet been given to addressing how disabled people are to be
able to interact with the single regulator on a par with non-disabled
people for advice, information, to use complaints procedures or
participate in consultation processes. Crucial to that is being
able to expect to have information and communications needs fully
met.
4.2 Disabled people have a great variety
of information needs—from braille, large print and tape
for visually impaired people through to textphone access for deaf
and deafblind people and plain easy to read English for anyone
with learning difficulties. Catering effectively for these needs
will only be possible if OFCOM, and indeed the Panel are required
to develop and implement an accessible information policy to ensure
disabled consumers can interact with both bodies using their preferred
format or means of communication. Unless there is a clear policy
comprising clear guidelines for staff and an action plan there
is a very real risk that OFCOM's systems will not be designed
or operate in an inclusive way. Building such provision in from
the outset eliminates that risk, will save money in the long run
and ensure OFCOM takes a best practice approach.
5. THE NEW
REGULATORY FRAMEWORK
AND PROVISIONS
5.1 Current areas of exclusion for blind
and partially sighted people which we want explicitly addressed
by the legislation are set out below followed by our assessment
of what action may be possible within the scope of the Bill as
currently drafted and what additional provisions might be needed
to the draft legislation.
Exclusion from Digital TV
5.2 The two chief ways that people with
sight problems could enjoy television programmes are audio description
and text manipulation. Audio description is an additional narration
that fits between dialogue and describes action, body language,
facial expressions—anything that will help people follow
what is happening on screen. Audio describing television programmes,
films, plays, sporting events and even an exhibition of paintings
is now technically relatively easy especially with digital technology.
While it is available at a number of theatres and cinemas in the
UK, and RNIB has run a described home video service since 1994,
there is still no openly available audio description television
service that can be received by everyone.
5.3 Text manipulation is the key to dealing
with written information on the television screen necessary to
find your way or "navigate" around digital television.
Changing channels, controlling volume, finding out programme information
and setting a recording are impossible if they are dependent on
being able to read relatively small written information on the
television screen. So far nobody is making televisions with a
screen reader or a way to manipulate on-screen text. Yet technology
has existed for years, which enables text manipulation on screen—it
is how partially sighted people use computers at work and in school.
Regulation of Electronic Programme Guides and
APIs
5.4 RNIB welcomes the fact that OFCOM has
the power to regulate Electronic Programme Guides and Application
programme interfaces. This must be used to require EPG providers
and set top box manufacturers, whether through general conditions
or universal service conditions, to supply blind and partially
sighted end-users with EPGs and APIs with access features to meet
their needs:
— The majority of visually impaired
viewers have some useful sight and could read on screen text provided
their EPG and specifications within their set top box enables
them to change the size, shape, shade and colour of the text and
background to meet their individual needs;
— For those without any useful sight,
a screen reader providing synthesised speech output would be the
only practical way to navigate around digital television;
— A significant minority of blind and
deafblind people will require EVPGs and APIs which support connection
to an electronic braille display.
5.5 If these options are not feasible in
the short-term, providers should be required to make available
information via alternative methods such as telephone helpline
services or email.
5.6 There must also be regulation of handsets/remote
controls to enable people with sight problems and reduced manual
dexterity to operate them easily. The VISTA (Virtual Interface
for a Set-Top box Agent) project, led by the ITC, will examine
the potential use of technologies that allow a viewer to "speak"
commands to the TV as well as have the TV "talk" back,
to select programmes from the hundreds of digital channels now
available. This project is aimed to improve access for visually
impaired people but clearly could have benefits for people with
physical disabilities who would simply be unable to manipulate
a remote control themselves. OFCOM must champion this project
when it takes over from the ITC and ensure the technology is made
widely available.
5.7 If such regulation is not forthcoming
soon, the consequences will be extremely damaging, with blind
and partially sighted people facing a huge deterrent to "going
digital" faced with the impossibility of navigating the different
channels.
Regulating the transmission and reception of audio
description services
5.8 It is not immediately apparent that
OFCOM necessarily has any power under the proposed regulatory
framework to require equipment for receiving audio description
to be made available to blind and partially sighted people. It
certainly has powers over spectrum and it will be vital to use
these to ensure sufficient spectrum is reserved for the transmission
of audio description services.
5.9 Yet it is also vital that OFCOM acts
to plug the gap left by the Broadcasting Act 1996 which legislated
for audio description targets for DTT broadcasters but failed
to address the means of reception. Hence six years on, just 45
households are able to view audio described programmes on digital
terrestrial as part of a trial of a new module. Neither the industry,
the existing regulators, nor the Government have accepted responsibility
for ensuring the module is supplied to blind and partially sighted
customers on DTT. Similarly digital cable companies are holding
out against supplying their blind and partially sighted customers
with a means of receiving audio description. Only Skydigital has
made its (very) limited audio description service available to
visually impaired customers.
5.10 The one aspect the Bill does deal with
clearly is the retention of the audio description targets for
digital broadcasters and their extension to digital cable and
satellite, with corresponding amendments proposed to the BBC Agreement.
The Policy paper and Regulatory Impact Assessment accompanying
the Bill trumpet the fact that audio description, sub-titling
and signing requirements are in the first tier of broadcasting
regulation. The RIA argues that this is justified because in this
case the public interest outweighs any potential impact on the
industry. "Whilst there are costs to industry, particularly
as regards subtitling, signing and audio description, these have
to be set against the resulting considerable social benefits."
But owing to the low level at which the audio description targets
are set and the fact that the reception issue is not even referred
to, let alone addressed blind and partially sighted people are
not rejoicing.
5.11 Instead there is deep disappointment
that broadcasters" targets for audio-description have been
frozen at 10 per cent over 10 years. RNIB has long called for
audio description targets of 50 per cent to reflect the huge importance
of this service for blind and partially sighted people's enjoyment
of digital TV. People with sight problems compare the importance
of audio description to sub-titling for people with hearing problems
where the targets are 80 per cent. They simply do not understand
why they are getting such a bad deal by comparison. The key excuse
the Government used in freezing the targets, following its review
last year, was that they were not prepared to "extend and
improve" the audio description service until the question
of receiving transmission had been resolved. Hence blind and partially
sighted people are caught in a "chicken and egg" situation.
5.12 There is in fact no coherent Government
policy or strategy on how they intend to expand access to audio
description on digital TV. There is goodwill on the part of the
Broadcasting Minister but no firm commitment to do anything in
particular other than talk. We think there should be a clear strategy,
that now is the time to put it together and that DCMS/DTI should
clearly set out what they intend to do via licensing conditions,
using provisions in the new regulatory framework set out in Part
2 of the Bill or other legislative or non-legislative means to
sort the reception issue out. Options we would want to put forward
(which are not necessarily mutually exclusive) include:
— Approving the use of general conditions
or universal service conditions at an early stage to insist that
Digital TV providers supply blind and partially sighted customers
with set top boxes which are capable of receiving Audio Description
and which support accessible Electronic Programme Guides at no
extra cost. Skydigital has already commissioned set top boxes
from manufacturers which have the capability to receive audio
description making satellite the only option currently (and a
pricey one at that) for a blind or partially sighted person wanting
to access audio described programmes. There is no practical reason
why the cable companies and the new DTT Multiplex Licence holders
should not be required to do likewise when they commission set
top boxes from manufacturers—they simply need to write these
access requirements into the equipment specifications. The technology
is not a problem—it exists and it works, what is lacking
is any regulatory requirement;
— Bring forward the "must offer must
carry" obligations and provision for free access to PSBs
from other platforms at the earliest possible opportunity. Ensuring
this happens to coincide with analogue switch off is far too late.
Although it is not clear on the face of the Bill that audio description
services are covered by these obligations, the EU directives indicate
that this is the case. If that alone was accomplished visually
impaired viewers would at least have one viable AD receiving option
in the shape of Skydigital, and could opt for a free to air package
which offered a far wider range of audio-described programmes
than they can access on Sky at the moment;
— The Government must invest £3
million in bringing the audio-description module developed for
use in the common interface slot of set top boxes for DTT to market.
This would extend access to some 20,000 visually impaired viewers.
The module is the "gold-standard" in terms of quality
for the viewer with sight problems (the weakness of the DTT signal
notwithstanding) since it uses the "closed" method of
receiving audio description. This is the preferred option for
accessing audio description as it allows much more flexibility
to the user. An individual can listen to the audio described version
with headphones whilst other viewers can watch the programme without
audio description. It is also possible to change the volume of
both the original programme and the audio described soundtrack,
which may be especially beneficial to people with hearing problems.
Skydigital operates an "open" method which means everyone
in the room has to listen to the audio description whether they
want to or not;
— Legislate to require all televisions
or set-top boxes manufactured in the UK after a certain date to
be designed to be compatible with audio-description signals (this
can be done without falling within Article 28 of the European
Treaty so long as non-compliant imports can come into the UK).
Many of the leading television suppliers in the UK manufacture
in the UK, so such a measure would have the desired effect;
— The Government should robustly pursue
a harmonising measure or standard setting at EU level to ensure
future generations of set top boxes and digital TVs have a second
sound channel built in and support other key access features.
Exclusion from Digital Radio
5.13 There is no mention in the Bill of
radio receiving equipment and indeed this was excluded from the
scope of the recent EU Directives and indeed a previous Directive
on terminal equipment. Digital audio broadcasting could offer
considerable benefits to visually impaired people, in particular
better sound quality and stability of signal. However, there are
two potential threats to them being able to take advantage of
this new service in the foreseeable future—the use of digital
displays on sets, and the cost of receivers. Digital radio receivers
present huge access problems. On-screen menu systems are used
for tuning and programme choice; they also identify upcoming programmes
of interest, or alert the listener to new programmes just starting.
Apart from these obvious problems, already additional data is
being transmitted—what piece of music is playing, weather,
traffic, and so on. These systems are also set to become interactive.
In all likelihood these developments will simply make the radio—once
the mainstay of visually impaired people's access to the Information
Society—more inaccessible than ever before.
5.14 If there is any scope for using the
new regulatory framework or other legislation to ensure blind
and partially sighted people are provided with accessible digital
radio receivers the opportunity must be seized. Otherwise OFCOM
and the Government should at least promote the need for action
by manufacturers and lobby for standards for accessible radio
receiving equipment at EU level.
6. NEED FOR
A DISABILITY
ACCESS FUND
6.1 Finally, one specific new provision
we want written into the Bill is for the Secretary of State to
have a grant making power, similar to that enshrined in Section
93 of the Telecommunications Act 1984 to defray or contribute
towards expenses incurred in supporting research into, developing
and providing accessible communications apparatus and technologies
in the interests of disabled people. Funding to bring the DTT
audio description module to market should be a top priority in
this respect.
7. ACCESS RADIO
7.1 RNIB strongly welcomes provisions in
the Bill on "access radio" which have the potential
to increase access to broadcasting resources for blind and partially
sighted people. We are concerned, however, that limitations on
sponsorship and advertising might make such stations difficult
to sustain.
8. PROGRAMME
STANDARDS
8.1 There are many misconceptions and inaccurate
characterisations of blindness and partially sighted people, not
to mention other disabilities, which have contributed to the stigmatisation
of visual disability and to lower expectations of quality of life.
These stereotypes have clearly played a part in building up the
social exclusion of blind and partially sighted people in employment,
education and cultural life. For the one in five of us who will
develop an un-correctable sight problem if we live to the age
of 75, these myths and misconceptions may lead to emotional isolation
and a lack of engagement with the many practicable rehabilitation
strategies available.
8.2 OFCOM must have a duty to ensure licensed
public service broadcasting avoids these inaccurate depictions.
RNIB calls for a further objective to be added to the objectives
for OFCOM's standards code for television and radio services,
namely "that material likely to lead to the stigmatisation
of disabled people is not included in television and radio services."
9. CONCLUSION
9.1 Blind and partially sighted people are
increasingly excluded from many developments in digital technology
through exclusive design, the cost or technical difficulty of
access, the absence of suitable equipment and the lack of training.
We hope the Joint Committee agrees that the legislation must contribute
much more to the task of combating this growing exclusion and
will reflect the importance of regulating for genuinely universal
access in its recommendations on the Bill.
June 2002
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