Accessible future for end users with disabilities - 11th BEREC Stakeholder Forum
Thank you. Thank you. Welcome to all. So I'm delighted to have on this panel Lise Fuhr, the Director General of ETNO that probably many of you know already, Donal Fitzpatrick, who is Senior ICT Design Advisor at the National Disability Authority.
Forgive me, Donald. National disability authority. In Ireland, and Wouter Bolier, who is today representing the European Disability Forum but works as a policy officer at IderIn in the Netherlands. Thank you. Thank you all three for joining us. And thank you for Ramon for your help here on stage.
I'll just say three words to sort of set a little bit the scene for this panel. I mean, in this room, you've already read the code many times from the beginning to the end and back to the beginning. You know that these issues of user with disability, we were discussing it with Tonko yesterday.
Provisions on users with disabilities have been in EU law, telecom law since the mid ninety's. I see, will I'm nodding and agreeing that I've got a good memories. And when you look at the code, it starts with Article One.
When you look at the scope and the aim of the code, the aim of this directive is to ensure good quality, affordable services, including for those with disabilities. And then you move to the second article, which sets the mission letter for NRAS BEREC, the Commission Member States, and it's to have high level of protection for end users, in particular end users with disabilities. And then as you read through the directive, whether it's about consultation, about helplines, about information requirements, transparency, quality of measure, measurement, there is always some provisions on users with disabilities.
Next to that, there is another piece of EU law that is one year younger than the code 2019, which is the European Accessibility Act. We'll discuss it with Wouter a bit later. But there is a bit of overlap between the code and the European Accessibility Act in the sense that the European Accessibility Act also covers in its scope the act. The Accessibility Act is very much about condition for placing on the market product and services suitable for users with disabilities. But it covers also telephony services and related equipment in addition to a broader scope of services, including computers, ATM, but also smartphone and telephony equipment. Okay, so in terms of transposition, we'll discuss later the code.
Last time I checked, member state didn't do too well. I think there were a couple of laggers, but otherwise everybody had transposed the code. When it comes to the European Accessibility Act, the picture Wouter is not as nice.
We will discuss it later. Anyway, without further ado, I suggest that we first go to you Lise to take stock of what some telecom operators have done in that space, and then we'll move to Donal and Wouter. Yeah, thank you, thank you. And thank you for inviting ETNO to speak in this distinguished panel.
And I often have the honour and privilege to speak about the promise and the potential of digital transformation. And of course, I think it's extremely fascinating to see how our members are rolling out next generations connectivity all over Europe. But it's also extremely good to see how digital technologies are playing a major role in things like sustainability, the impact on climate change, and transforming Europe into a sustainable economy. But one thing that makes me even more proud, and it has been mentioned earlier today, is that in EU and also in our member companies of ETNO, we put citizens at the forefront of what we do.
So if we look at privacy, we look at data protection, child protection, but also when it comes to providing quality services for end users with disabilities. And if you look at the numbers in the UN, they estimate 50% of the world's population have some sort of disability. That's almost 1 billion. And the European Commission estimates 87 million people in the EU have a form of disability. So, of course, it's key that we have access to the digital society also for people with disabilities.
And there are, as you're saying, several rules that are regulating this. Another one is the UN Convention on the Rights of Persons with Disabilities. But I also want to take your attention to the Global Digital Compact, which is now in the making and which is also important for me because I work on the IGF leadership Panel and we're looking into this. And this is actually a topic we should have also as a priority for digital policy making.
So if we look at you talked about the European Digital Accessibility Act, and they set out a number of features, and I'll go through some of them very quickly, and then I'll go over to my members. But we have real time text and high fidelity audio. You have video where the resolution should be high enough so you can enable sign language communication. You should ensure wireless coupling to hearing technologies, and also, of course, capacity to avoid interference with assistive devices.
And as you were saying, you also have the code that are coupling this. So we think it's important you have this robust set of rules. But what is even more important is, of course, how we implement it, how we innovate it, and also the technological solutions for all of this.
So there I look forward to hear two experts coming up with your views on how this is working. So if I take it from the ETNO members, we are trying now to have accessibility by design as a key principle, which is to me important because you take it as a baseline instead of an add on to the products. So we have some of our members who are providing tailored services for people with disabilities, such as information in Braille and large print of accessible electronic formats.
We also try to ensure that end users have the necessary digital skills to use crucial communications technology, and not only in order to have their communication and entertainment needs, but also to be fully integrated into a job market. If I am to bring a few examples, you have Telefonica offers, subtitles, audio descriptions on its TV offers. That's more on the entertainment side.
But we also have BT allowing to register specific needs and tailor specific offers to suggest technology and gadgets to help end users on a daily basis. So with that being said, I think it's great that our services are tailored and to the end users with disabilities, but I also think it's important we look at the physical part. So access to stores, to customer service, et cetera, we cannot only have it in our services, we also need to live it in a fully fledged way. So let me end by saying I know many of our members are very keen on diversity and have it high on their priority. So to give people equal access to work in their companies is also high on the agenda. Thank you. Thank you very much, Lise.
Let's move to you, Donal, and before diving into the conversation on the regulatory part itself, could you tell us a few words of the misadventure in a way that you encountered with your PowerPoint to bring a bit of reality in this conversation? Thank you very much indeed. It's wonderful to be here and great to be back in person in such a lovely room. My goodness, the acoustics in here are wonderful. The misadventure, or the adventure we'll call it, was interesting because as many of you, those of you who can see, will realise, on my knee I have a small device. I'm now holding it up, which is a Braille device. So I have some notes here in Braille that I'm able to read as we proceed.
And this is what we know of as assistive technology. And my laptop is equipped with assistive technology called a screen reader, which anything I type is spoken to me. Anything that comes up on the screen is spoken, et cetera.
And when I was discussing with the organisers the possibility of using that instead of the provided laptop in the venue, we weren't sure it was going to work. And I do want to commend the organizers for their offers to do whatever it took to actually get that to work. I think it was very much appreciated, but I made the decision not to take a chance. And my basic logic was, well, if I can't hear the PowerPoint, they're not going to see it.
So that's what we decided to do, was just to turn this into a conversation, which I think is really important when it comes to matters such as this. But for yourselves, as a moment, it's important to realise that when people with disabilities are included in events, that to make accommodations available to enable us to use the devices and the technologies that we need to use. As I said, the organizers here were perfectly happy to go the extra kilometer to make sure that was possible, but we chose not to trust the technology. Thank you, Donal. Thank you very much for your testimony. Let's move into the heart of the matter, starting with the organisation, your employer, the National Disability Authority.
Later we'll go to Wouter, who works for an NGO. But you work for an authority. You're a regulator, actually.
So explain us that. Is it common in Europe to have a disability authority? I have to correct that slightly. We're not a regulator. We were established following the Disability Act in Ireland and our function is to offer advice and guidance to government and other public sector organisation in respect of disability. We also fullfill the function of monitoring various aspects of the Irish Disability Act. For example, one of the requirements is that public sector organisations has and aims for a minimum of 3% of all employees to be people with disabilities.
This is moving to 6% in 2024. So we monitor that. We also now monitor things like the recently adopted Web Accessibility Directive. But as well as that, we also have the center for Excellence in Universal Design, which promotes the adoption of universal design. And for those who are not familiar with that particular term, universal design, we define as the design and composition of an environment such that it can be used to the greatest extent possible by everybody irrespective of age, size, ability or disability. Which very much ties in with what we're talking about here today in the context of communications, universally designed and universally available.
Communications really does make the window in the world very wide open for people with disabilities. And we'll get on to some more of that in a few moments. Yeah. No, thank you, Donal. So you're not a regulator, but at least you use some soft regulation. Perhaps we could settle with that.
A question which I would really like to discuss with you. Ireland is telecom operators. Like any other country.
Ireland is also the home to many large ICT companies, at least the European home of many large ICT companies. What can you say about the dialogue that your organisation is having with, let's put it, the ICT telecom community? Is this a very structured dialogue where you guys meet every month and go through the outstanding problem? Or do you meet at the invitation of the Irish government? Or how does it take place, this dialogue? We all meet in Brussels, perhaps? We love meeting in Brussels, it's a lovely city. We would tend to engage with people like the Irish communications regulator COMREG. As I said, our remit is very much through public sector organisations. I think the question of structured dialogue is really, really interesting.
Universal design promotes is based on seven principles, one of which is equity of use. So it is really important from an end user with disability the perspective of an end user with disabilities that equity of use is built into everything that is done in the communications space that guarantees. For example, I was struck last night as I was walking through Brussels by the fact that changes in regulations, as I landed on the plane, I got a text from my home provider saying, you can use your data allowance as you would if you were at home.
Now, this is wonderful because for people with disabilities, a lot of the technology that we use, mainstream technology for sure. Let's give you a hypothetical. I can't look at street signs as a blind person, so when I want to navigate from point A to point B, I use one of the navigation apps on the phone produced by the major providers. We all know who they are that relies on data. And before a lot of this happened, you were constantly thinking, oh gosh, I can only use this navigation app for certain length of time, for short journeys.
What's it going to cost me if I go over my data allowance? So there's now a freedom about this. There's a freedom now that actually exists that one can actually do this and really engage. You can use video communications if you need to ring somebody and say, can you see where I am? I've also done this.
But to facilitate this I totally agree, Philippe. It requires very much a lot of dialogue to make sure that that equity of use carries on and continues into the future. We're talking about the future here. I should explain that I've only recently, in the last year and a half, joined the center for Excellence in Universal Design.
So I personally am not as aware of what I would call structured dialogue forums for structured dialogue. I do know that in some of the standards bodies, CEN/CENELEC, et cetera, and the preparation of standards, for example, EN 301549 comes to mind. There is conversation between some of the people with disabilities who are on that and some of the major companies, et cetera. But I think with the arrival of things like the European Accessibility Act has been referenced several times, we have a situation where that, as we're going to find out, creates very much a market for accessible products and services. And to ensure that equity of use is going to require significant consultation and dialogue in very formal, semiformal and indeed, informal settings to ensure that equity of use.
And I'll just qualify a reference to the UNCRPD Convention on the Rights of Persons with Disabilities that the previous speaker made, which very much mandates the consultation and inclusion of people with disabilities from the earliest opportunities possible in the design of products and services. So that dialogue is very, very important and will become even more so as new legislation promulgates over the next number of years. Yeah. Thank you. Before moving to Wouter. Donal if you, as a blind person, if you had a magic wand and you could sort of make any of the existing technologies I'm not talking about science fiction.
The thing that, you know, exists in labs and so on, and you would want this to be sort of widely available for the blind people community, what would it be? Thank you for that one. I think we've moved the technology has really moved on in the last number of years. I mean, we don't always want to talk back to the COVID time when we were all in lockdowns and everything else, but that really has jumped things forward.
Video communication platforms are now very much in evidence. We're using one for online participants today. I think for me, what's very important is that the technology I'll give you four words: perceivable, operable, usable and robust.
And they very much follow the principles there. You see those regularly in things like the Web Content Accessibility guidelines. So whatever happens, I think those four words have to be at the forefront. Perceivable, operable, usable and robust.
So that if the latest technology comes down, possibly powered by artificial intelligence, that those four words are the guiding principles that enable everybody, including people with disabilities, to actually use it. Thank you. Thank you very much. Donal, let's move to you Wouter, but with Wouter we have agreed to ask your question.
So please take your phone, reach out for your phone. The slido, I hope is still otherwise you risk on your badge. Can you see the question? Question is simple. In my short words of introduction, I alluded to two legislation, the Code and the European Accessibility Act. Both somewhat somewhat overlapping.
Wouter will qualify that in a minute, but somewhat overlapping. And the question that with Wouter we are asking you, do you think that the community of people with disabilities is better served by two legislation, somewhat overlapping? Or would we live in a better world if we had a single legislation addressing in a holistic way all the problems to address the needs of the community of people with disabilities? I'm talking and I see the results already there. So, Wouter, do you want to commend what do we see there on the graph? Who is winning? Well, it is very interesting to see that provisions gathered in a single act have about 67% and provisions in both the code and the Accessibility Act 33%. So it's one third against two third.
Now, you're going to explain why they are wrong, of course. Well, I can understand this number. It's not necessarily wrong.
I can understand it. But the way I see it, the Accessibility Act and the electronic communication code, they do not necessarily overlap each other, but they complement each other. So the Accessibility Act focus on accessibility of products and services and the electronic communication code focus on network infrastructure and also the universal services and accessibility of emergency number 112, and together combined they say the World Telecommunication chain.
Everyone there has a responsibility for accessibility. So for example, the manufacturers of a smartphone from the Accessibility Act have to make it accessible following the accessibility requirements. So it need to be able to run, for instance, real time text and total conversation. It was already mentioned by Lise. These are two interoperable international standards. So the smartphone has to be able to run it, the surfaces need to carry it, and the infrastructure, the network infrastructure, has to be able to support it.
So combined, this is the world Telecommunication chain. Everyone in this chain has to do their part in accessibility, and that's why we believe they are both stronger together. Thank you.
Thank you, Wouter Voila. So I hope perhaps that will change some people's mind by now. We won't take another vote to see whether Wouter plea was successful. Talking about the European Accessibility Act, I said in my introduction that on the code, members say they've done a good job of implementing it. When you look at the Accessibility Act, the picture is less perfect. Can you give us an idea of where things stand? This is an act from 2018 which should have been transposed by the last summer.
Well, there are several member states that haven't finished the transposition of the act yet. So, for instance, in the Netherlands, we are not ready yet. We should be ready a year ago in June 22. 2022. We are now in the end of the legislation process. So the proposals to implement and transpose the Accessibility Act in Dutch legislation will be discussed, debated in the House of Representatives, probably in May this year, and then the General orders in Councils will follow soon after that.
And then probably in summer, the Senate will have a final decision about it. So we are facing, let's say, well after summer, later this year, that we will be ready with the transportation. And that's just an example from the Netherlands that are seven member states who are not ready yet. The deadline of 2025 still stands strong.
So the member states who are not finished yet, have to hurry up. 2022 was the deadline for transposition into law, and 2025, as you indicated, is the deadline for actually putting into application those rules. And do we have some visibility already on what the pictures look like for what really matters at the end, which is the practical implementation of the rules? Well, Lise was telling what ETNO and ETNO members are doing, and I think it are very good points you mentioned. What I miss, however, is the mention of what you are doing to make networks ready to carry, for instance, real time text and total conversation. These are two accessibility requirements from the Accessibility Act and the electronic Communication code. So the network infrastructure has to be ready by 2025 as well.
It is not only the finances and the services, but the network infrastructure too. That was my question to Lise, but are you working on that already? Because it has to be there in 2025. So if you haven't started yet, you should start now. In the long list of articles in the code touching about users with disabilities, there is one that is you told me particularly important is article 85 on real time text.
To use the vocabulary of the code, it's the total conversation services and when you read the article, it is subsidiary pushed to the extreme if national circumstances allow and as if human beings were different from one country to another. But anyway, that's another. What do you think of this article on total conversation services? Can we register some real progress there? Well, it is there in the legislation, so it has to be there. But for instance, for the emergency number 112 in Europe we have agreed that it should be accessible for everyone. So a deaf person needs to be able to contact 112 and the emergency service, for instance, in sign language. And to do so, you would need a standard like total conversation or a person who cannot speak because they have a speech impairment or because you are in a situation when you are under a terrorist attack and you have to contact image services quietly.
You would want to use text communication and that is real time text. So emergency number 112 needs to be accessible with total conversation and real time text for everyone. And it also could be beneficial for you when you are in that situation where you have to contact 112 quietly.
The way it is going. Well, it depends on what country or what member you state you are asking. But for instance, in the Netherlands we have 112 app since last year and this supports real time text and we are very happy with that. Also, mobile application for 112 we consider as an interim solution for accessible 112. What we want is that construction, real time text become the mainstream ways of contacting 112, just like we use, for instance, voice telephony. Yes, just on my side because you asked if my members were ready and the true answer is I have no overview, but I actually got inspired to do a small survey on this internally.
So I think we will look into how ready we are for this. I also get very inspired by Donal saying universal design instead of accessibility by design. I actually think it should be universal and I think this is the baseline I get from this conversation is whenever we deliver services, we should do it as universal as possible for everyone. So it's not only disability and ability, but also age and other things. And I know we are working on many of these things, but it's interesting to get feedback. Donal, on this crucial issue of access to 112.
What does the picture look like in Ireland? The picture in Ireland is again very similar to the rest of Europe in the sense that we are working through transposition activities across the board. 112 at the moment is, as far to the best of my knowledge, I don't think we have text based services, but we're working closely with government colleagues to actually ensure that as close to 2025 as possible, these things are actually available. Sorry, Donal. Yeah. I'm very happy with your suggestion to ask the members how they are ready or not, it might be of interest for all of you that in the United States they are already there. What concerns real time text. So the devices, the Android or iPhone that are delivered on the market in the United States are already ready for real time text.
It is built in in the smartphones and also the network infrastructure already supported. So in the United States, you can contact the 9112 of the United States with real time text already it is there and we are behind them. So we have to hurry up at the catch up before the Americans with total conversation too.
But that's interesting to have a talk with the Federal Communication Commission, the FCC in the United States, how they are doing that work. It's very interesting point. Can you just reexplaining so you say on the latest iPhone, did you say? Yes. So the end user wishing to contact emergency can do it with real time text. I'm sorry, I'm going to display my full ignorant. Maybe Lis e can explain it.
What does it require? Network level? I am not a technical person, but I am a policy officer that the network should be ready and they are supported by the Americans. We should be able to do it. No doubt about that.
I don't know who I'm committing here. Well, on the 911 or 112, it's also a matter of if the emergency service are able to receive it. So it's a two part that needs to talk on the real time text and the networks, that's a different thing. But exactly.
The 112 has a little hook to it that it needs to be also received in the other end at the level of the calling centers receiving the calls. So it's not the telcos is what you're saying? No, I'm not saying it's not. I'm saying it's one with many parts that needs to work together also because a lot of 112 calls have a service where they can see where you are. So it's a location service that needs to work together with this. I'm looking at the room to see whether there are people who want to pitch in with a complement of information, if there are experts of these matters or with naive questions like mine. Don't see anyone.
And Wouter, on this question that we discussed with Lise and Donal already for the Netherlands, is there a structured debate between either in your organisation and other similar organisation representing users with disabilities and the ICT players, telecom operators and other members of the ICT sector. We just started some informal talks with one of the bigger telecom companies in the Netherlands. They are aware of the deadlines and the accessibility requirements of the Accessibility Act. They are thinking about how to implement this together with other telecom companies in the Netherlands, which is the informal first talks we had just recently. Not on a formal level, but I would like to invite ETNO on behalf of European Disability Forum to have a chat as well for my colleagues of EDF with you how we can work together on this matter.
Because we have to do this together. We all have the same goal to make the telecommunications and 112 accessible. So that's my invitation to you and I'll accept it. Thank you. Donal was alluding earlier to the importance of bringing users with disabilities early in the design of product and services. So is this something that is irrespective of this one one two issue in the Netherlands, as far as you know? Is there some sort of a structured dialogue for places where you guys talk to each other or is it more on a haphazard basis? Well, we have structural meetings with Ministry of Economic Affairs, for instance.
We are in good contact. We are still transposition of the Accessibility Act has to be finished first before we can really talk about implementation of it. We are already preparing for that with the Ministry of the Coordinating Ministry of Healthcare. So we are in talks with the government for the implementation part, but we are not that far because we have to wait till it is finished for the legislation part and then we are ready to talk. And we know each other, we can find each other, we have good contacts. So I trust that in the Netherlands this will happen.
I'm not sure in other member states, but in the Netherlands we are ready for that to meet with everyone involved, including the telecom companies. Changing completely the conversation now and looking at the business side, you guys are also an attractive market, I realise. I was reading some information published by the European Commission around the European Accessibility Act and they talked about addressing a market of 18 million customers. I mean, this is roughly the population of the Netherlands also. So that's quite a nice do you believe that there is enough awareness in the ICT business community that there is the equivalent of a medium sized European country to be conquered there or not? Well, it is improving. The awareness is improving and that is mainly because of the legislation that is already here.
So we have the Web Accessibility Directive, for instance, for accessibility of websites and apps and the new Accessibility Act that's coming into force in 2025. And what I see happening here. But also in the Netherlands is that companies, bigger, smaller ones are getting aware of all the deadline is coming, we have to be prepared.
What does it mean for our production lines, what does it mean for the way we operate and conduct business? So I see it is going I'm not sure if everyone is ready on time, but I see it is very much going rapidly since we are getting very close to the deadline. In the Netherlands, the Ministry of Economic Affairs also will do something of an information tour for the companies, the bigger and the smaller ones, to inform them what the accessibility requirements will be for them. There will also be something of an portal or a website where business can check, okay, this is my kind of product or service. What kind of accessibility requirements do I have to abide to? And that is what we are working on right now as we speak, or the government is working on. Thank you. Donal, on this question over his business, sufficiently aware of the business opportunity, I guess.
I think it's a really interesting one because for many years in the US. Things like the Americans with Disabilities Act, which mandates that anything that used in a federal context is actually accessible, has played a huge part in things like procurement. I think procurement is going to play a really important part going forward in all of this because of the fact that a lot of, for example, our technology manufacturers at large scale technology manufacturers do come from that. I think there's an awareness there of the needs both from a business sense, if you like, a large scale procurement factor, but equally, then I think we've seen it mainstreaming of disability is happening.
It'd be very interesting. And we should possibly have done this to find out how many people in this room have things like smart home devices, smart speakers, how many people we were talking about this at lunch, how many people use voice recognition or other forms of technology which started off life as assistive technologies for people with disabilities. So I think there's an awareness of the fact that designing from the start of the process to include people with disabilities will bring a business case and a business bonus.
I'm not quite so sure that it's there yet in smaller enterprises. And I think that's really where we need to focus. Our effort is to highlight the benefits and as you say, the increased market that's actually available to people and businesses if they engage with and ensure that the products are actually accessible. Thank you. Thank you, Donal. Lise. Well, on the business case, on this, we have sometimes an issue with that.
The problem might be global, but the solution is local. And when it comes to networks, every member states have their own specificities, et cetera. Of course, there are global standards, and if we can have some standards on much of this, I think it would be perfect because that's what we need in order to actually unfold it in the European Union. Absolutely. We have perhaps time for one question. Still no volunteer, then? I was thinking Wouter.
I could perhaps put you on the spot, as I did unfairly with Donal earlier, and ask him if he had a magic wand to make available something that already exists in the labs or perhaps in small industrial production. As a representative of the deaf and hard of hearing community. What would you say? Yeah, well, it's quite simple to make it personal.
I am a father of two deaf children and I want them to be able to contact 112 24/7 in sign language, and that is not possible yet. For instance, in the Netherlands, we have a sign relay service that is only open between 07:00 in the morning and 08:00 in the evening. So deaf persons in the Netherlands, please plan your emergency during the day. But that's my dream.
24/7 112 sign language and not only in the Netherlands, but in all member states. Thank you. That will be very nice. Yes. Thank you. I think that's a very good one.
That's a very good one. On this, I would like to thank our panelists. Thank you.
2023-04-29 22:37
