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Best practice in telecommunications for people with a disability in Australia

(Please note that this document may link to web pages that have moved or no longer exist, or may refer to other documents that are no longer available.)

by TEDICORE (Telecommunications and Disability Consumer Representation)

Gunela Astbrink
TEDICORE Policy Adviser

March 2002

Contents

Executive Summary

The purpose of this document is to outline best practice for government, industry and the community sector in order for people with a disability to achieve access to and equity in telecommunications products and services in Australia.

This document has been produced by TEDICORE (Telecommunications and Disability Consumer Representation). TEDICORE represents the interests of Australian telecommunications consumers with disability, seeking to promote equity and accessibility. It is therefore in an excellent position to understand the needs of people with a disability in relation to telecommunications and thus to present the case for best practice in this area. TEDICORE has been active for the past four years with its involvement in industry and government working groups, advisory bodies, public inquiries and fora. It has also published research articles and developed discussion papers and position papers on topics of importance to the disability community. This Best Practice document therefore represents these activities and the collected information and experience in terms of access to telecommunications for people with a disability.

The document outlines key aspects of the Australian legislative and regulatory environment in relation to people with a disability. Examples of mechanisms aiming at best practice in Australia in the regulatory and legislative arena are detailed. Practical applications of these mechanisms through TEDICORE's work are outlined. An example of international best practice is related back to and adapted for the Australian situation.

Finally, and most importantly, the Best Practice Guidelines have been developed to highlight the many areas which still need addressing. These form a set of recommendations which are listed below. The recommendations are listed under key principles adapted from the European COST 219 Telecommunications Charter. The recommendations reflect issues such as legislation and regulation, telecommunications equipment, universal design, accessible network services, public procurement, a range of Internet access issues, pricing, consumer consultation processes and the promotion of accessible products and services.

It is likely that the Best Practice Guidelines and recommendations will be revised as needed.

Recommendations

Principle 1

Telecommunications facilities and services are accessible to all.

  1. The definition of the Universal Service Obligations in the Telecommunications (Customer Protection and Service Standards) Act should be expanded to include universal accessibility reflecting ability and ease of use, quality of the service and the needs of consumers for affordable and appropriate services and products.
  2. All carriers and carriage service providers offering retail services shall develop Disability Action Plans, lodge these with the Human Rights and Equal Opportunity Commission and review them regularly.
  3. The federal, state and territory governments should incorporate accessibility to telecommunications products and services in their procurement policies.

Principle 2

The needs of people with disabilities are taken into account in the design of any telecommunications equipment or service. Terminal equipment is designed for the widest possible market.

  1. The Department of Communications, Information Technology and the Arts together with the Australian Communications Authority should exert more pressure on carriers to initiate research and development relating to people with a disability and report this in their Industry Development Plans and Disability Action Plans.
  2. Corporations should adopt the principles of universal design in the development of new products and services.
  3. Corporations should include the needs of people with a disability in the beginning of the design process of new products and services and incorporate a Disability Impact Statement through the various stages of the design process.

Principle 3

Network services adequately support relevant special terminal functions so that all users experience equivalent end-to-end service.

  1. Networks must be designed to incorporate accessibility and be tested prior to implementation of any new network service. The testing must be in a real-life situation.
  2. Changes to existing or adoption of new network services should involve in-depth consultation with consumers to ensure there is no impact on people with disabilities. If there is an impact, a solution shall be found which meets the needs of all parties.

Principle 4

When mainstream products and services cannot be used, provision is made for people with a disability to access the telecommunications service by means of additional and/or alternative equipment and services.

  1. An independent and consumer-based Telecommunications Disability Program should be established to give people with disabilities the freedom of choice of carriage service provider and equip them with the hardware and/or software to equitably access the telecommunications network.
  2. A nationwide video relay interpreting program should be implemented.

Principle 5

The Internet and related digital technologies are accessible, available and affordable by people with a disability.

  1. A national Internet Scheme for People with Disabilities should be established and have the following components:
    • Creation of a pool of assistive devices to facilitate access in community-based centres.
    • Low interest loan program for purchase of computer and printer.
    • Development of a national clearinghouse and network of regionally-based PC recycling programs for people with disabilities.
    • IT and T-based assistive devices provided as needed through a federal government program and upgrades to equipment are provided upon application.
  2. A national Internet Training Partnership Scheme should be established with the following components:
    • A multi-tiered training program to support people with disabilities in their use of the Internet.
    • Delivery of training will be provided at the local level by people trained through regional Train the Trainer programs.
    • Development of a national clearinghouse and network of regionally-based PC recycling programs for people with disabilities.
    • People with disabilities are included in the Government-sponsored Telstra Internet Assistance Programme.
  3. An Internet Access Allowance should be implemented.
  4. A Government IT and T Disability Centre of Excellence should be established.
  5. An Assistive Technology Research and Development Corporation should be established.
  6. Organisations providing online information to consumers should comply with all three levels of the W3C Web Content Accessibility Guidelines.

Principle 6

People with disabilities should, as far as possible, be able to use telecommunications services at prices equivalent to those without disabilities. Most of the additional costs of providing access to all should be met by dedicated funds or absorbed within general operating costs.

  1. Any new service or changes to an existing service should not result in additional costs to a person with a disability.

Principle 7

Providers of telecommunications equipment and services and regulatory authorities consult regularly with people with disabilities about their access requirements and take appropriate action. Equally, organisations representing people with disabilities contribute their knowledge and expertise.

  1. The Department of Communications, Information Technology and the Arts should offer three year grants for consumer representation with yearly performance measures in order to maintain continuity of representational activities.
  2. All carriers and carriage service providers offering retail services should incorporate direct consumer consultation in its operations.
  3. Consultation with people with a disability should incorporate best practice guidelines as outlined by the Department of Family and Community Services.
  4. ACIF processes should ensure that consumer participation in all ACIF fora including Working Committees and Reference Panels is supported in such a way as to offer a level playing field between industry and consumer representatives.
  5. A training and mentoring program should be implemented to increase understanding by consumer representatives of the complexities of the telecommunications regulatory regime to assist in their representation activities.

Principle 8

Telecommunications products and services that improve and increase access for people with disabilities are actively advertised and promoted, with information also available in accessible formats.

  1. Products and services for people with disabilities should be promoted in both the disability and general media.
  2. Information about products and services should be made available in Braille, large print and electronic formats and be written in plain English.

Background

TEDICORE has been working for the past four years on improving equity to and accessibility in telecommunications for people with a disability. There have been many issues which TEDICORE has dealt with over these years which are reflected in this document. However, there is still a large amount of work to be done. Thus the importance of establishing a Best Practice model in telecommunications for people with a disability in Australia is timely and important in order to highlight the issues of concern and to work towards solutions.

TEDICORE

TEDICORE (Telecommunications and Disability Consumer Representation) represents the interests of Australian telecommunications consumers with disability, seeking to promote equity and accessibility.

TEDICORE's work focuses on bringing key organisational representatives from the Australian disability community together to consider telecommunications issues and to communicate effectively with the telecommunications, information technology and communications industry, as well as with relevant regulators and researchers. Particular engagement includes such regulatory bodies such as ACIF (Australian Communications Industry Forum) and the Australian Communications Authority (ACA), and by giving people with disabilities a further opportunity to raise concerns in public, government and industry fora.

TEDICORE can funnel many logistical and technically complex issues from government and industry directly to self-advocacy representatives of people with disabilities. It aims to provide support for people with disabilities to raise concerns which can be effectively heard and dealt with by government and industry.

TEDICORE is funded by the Commonwealth through the Grants to Fund Telecommunications Consumer Representations program of the Department of Communications, Information Technology and the Arts and is now in its fourth year of operation. TEDICORE's Project Advisory Body consists of peak disability organisations such as Australian Association of the Deaf, Deafness Forum, Blind Citizens Australia, Women with Disabilities Australia, Communication Aid Users Society and the Physical Disability Council of Australia as well as Christopher Newell who is recognised as an expert in the field.

TEDICORE has been actively involved in the majority of the activities discussed in these Best Practice Guidelines.

TEDICORE, through its Policy Adviser, also has links with telecommunications activities in a variety of other countries. In Europe, there has been a considerable focus on telecommunications for people with a disability by the European Commission, as well as regional and national bodies.

COST 219 Telecommunications Charter

COST 219, a European Union Action Project on telecommunications and disability has worked for the past 15 years to achieve more accessible telecommunications. It has produced the Telecommunications Charter setting out a statement of principles for improving access and equity in telecommunications. These principles are an excellent benchmark on which to set Australian best practice guidelines. The principles in the TEDICORE Best Practice Guidelines adapts and adds to the principles of the COST 219 Telecommunications Charter to identify the progress made in some areas and to highlight the work still required to achieve real equity.

TEDICORE Best Practice Guidelines

TEDICORE has been active for the past four years with its involvement in industry and government working groups, advisory bodies, public inquiries and fora. It has published research articles and developed discussion papers and position papers on topics of importance to the disability community. These Best Practice Guidelines therefore represent these activities and the collected information and experience in terms of access to telecommunications for people with a disability.

The Best Practice Guidelines focus on eight major principles. Each principle is used as a major heading with a discussion of issues and activities followed by relevant recommendations on further work that needs to be done by government and industry to achieve equity in telecommunications.

These Guidelines reflect the current situation in Australia and as new issues emerge, it is expected that revisions will be made.

1. Telecommunications facilities and services are accessible to all.

This principle is the broadest and encompasses the key element that TEDICORE strives for. More specific issues are discussed under other sections.

Legislation and regulation are the cornerstone in making telecommunications accessible to all. However, there are limitations in the current legislative and regulatory environment which reflect in the facilities and services offered.

1.1 Legislation

The Disability Discrimination Act 1992 and the Telecommunications Act 1997 and the Telecommunications (Consumer Protection and Service Standards) Act 1999 are inextricably linked in a number of ways. Complaints of discrimination under the Disability Discrimination Act 1992 (DDA) influenced the insertion of particular clauses in the Telecommunications Act relating to people with disabilities. Complaints under the DDA have also led to public inquiries on telecommunications issues. The DDA is being referred to in current moves to make significant changes in the method that telecommunications equipment is provided to customers with a disability.

1.1.1 Universal Service Obligations

Central to achieving access to telecommunications are the Universal Service Obligations (USO) in the Telecommunications (Consumer Protection and Service Standards) Act 1999. The USOis governed by the following policy principles:

"(a) all people in Australia, wherever they reside or carry on business, should have reasonable access, on an equitable basis, to:

(i) standard telephone services; and

(ii) payphones; and

(iii) prescribed carriage services; and digital data services;"
(Section 9, TCPSS Act).

While this sounds commendable, there are limitations to the extent which the USOcan benefit people with a disability. For example, Wilson and Goggin (1993, p. xii) stated that universal service should include

To date, only geographical availability has been implemented in the Act. Wilson and Goggin explain that universal accessibility on the other hand relates to the social nature of telecommunications and that the success of it as a service requires assessing factors such as "ability and ease of use, quality of the service and the needs of the consumers for affordable and appropriate services and products." (p. 31) Certainly, to include universal accessibility as part of the Universal Service Obligations would mean that people with a disability actually would be closer to equity in access to telecommunications.

1.1.2 Standard Telephone Service

It is important to note that, under the Universal Service Obligations, the supply of a standard telephone service does not limit itself to a voice-based service but includes customer equipment needed by people with disabilities. The standard telephone service is defined in the Telecommunications (Customer Protection and Service Standards) Act 1999 as "a carriage service for each of the following purposes:

(a) the purpose of voice telephony;

(b) if:

(i) voice telephony is not practical for a particular end-user

with a disability (for example, because the user has a hearing impairment); and

(ii) another form of communication that is equivalent to

voice telephony (for example, communication by means of a Teletypewriter) would be required to be supplied to the end-user in order to comply with the Disability Discrimination Act 1992;

the purpose of that form of communication;

(c) a purpose declared by the regulations to be a designated purpose for the purposes of that provision;" (Section 6)

The reference to the DDA as a compliance measure is significant. The 1995 Scott vs Telstra case would have had a distinct influence on this inclusion in the Telecommunications Act. This was a historic case where a Deaf person stated that he was being discriminated against due to Telstra failing to supply a TTY for him to make use of the telecommunications network. At the time, most residential telephone users had a telephone handset which was rented from Telstra as part of the line access fee. However, TTY's were not available under the same rental scheme as a standard handset. In a landmark decision, the Human Rights and Equal Opportunity Commission found that Scott had been discriminated against, leading to Telstra initiating an expanded TTY provision program. This has benefited Deaf, hearing and speech impaired people.

1.2 Regulation

Since the deregulation of the telecommunications market in the 1990's, the federal government has adopted the policy of a light regulatory approach to the industry. The Australian Communications Industry Forum (ACIF) was established in 1997 as an industry self-regulatory organisation. ACIF's main role is to develop codes and standards and to drive widespread compliance. It also facilitates or coordinates discussion on industry-wide strategic issues. One of the major challenges is industry compliance to the codes and standards. If a code or standard is registered with the Australian Communications Authority (ACA), the government regulator, it has to be complied with. However, codes and standards that are not registered may have a lower compliance rate.

The codes and standards developed by ACIF Working Committees have to be finally approved by consensus. Therefore, the process is quite slow and pain-staking at times and may result in an outcome which is considerably below the expectations of some of the members of the Working Committees.

The Australian Standard AS/ACIF S040:2001 (Requirements for Customer Equipment for use with the Standard Telephone Service - Features for special needs of persons with disabilities) commonly called the Disability Standard was developed in 1999 by an ACIF Working Committee. This was after a directive by the Australian Communications Authority to develop such a Standard. The Working Committee comprised consumer and industry representatives and unfortunately, much of what consumers with disabilities had hoped to achieve with the Standard was not included. The process was frustrating to consumer representatives. It took 18 months to finalise the Standard and the two main features, a raised dot on the 5 key of the keypad and inductive coupling were already listed in the Telecommunications Act (S. 380) as examples of what to include in a Disability Standard.

On a more positive note, ACIF's Disability Advisory Body has developed Guidelines (ACIF G586) to assist ACIF Reference Panels and Working Committees in meeting the needs of people with a disability when developing codes and standards (Appendix 1). This should mean that particular issues of accessibility are incorporated into codes and standards at an earlier stage. It should also help to create awareness on accessibility amongst industry participants in the standards-making arena.

1.3 Public Procurement

Governments are very large purchasers of goods and services and thus have the power to strongly influence the market. An excellent example is the approach taken by the U.S. federal government in its requirement based on amended legislation (Section 508 of the Rehabilitation Act) that all federal government employees including those with a disability should have the same opportunity to use hardware and software in the workplace. This means that the U.S. federal government requires in its procurement policy that only hardware and software which is accessible shall be purchased.

This has had a tremendous effect as major hardware and software companies have had to ensure that accessibility is now incorporated into their products in order to supply to the U.S. Government. Section 508 Accessibility Guidelines have been developed and are used to assess whether a variety of products including telephones and web sites are accessible. This is a growing international trend with countries such as Japan, Ireland and Sweden working towards accessible procurement policies. In fact, a European Commission project entitled ACCENT studied accessibility in information and communications technology procurement resulting in a number of set of guidelines including accessibility of telephone systems and services.

In Australia, the Department of Finance and Administration revised the Commonwealth Procurement Guidelines in September 2001. In a section outside the guidelines themselves but which is intended to assist officials in their procurement decisions, disability considerations are mentioned in reference to the Commonwealth Disability Strategy. The Commonwealth Disability Strategy states that "purchasing specifications and contract requirements for the purchase of goods and services are consistent with the requirements of the Disability Discrimination Act 1992." (p. 11, A guide to the performance reporting framework, Commonwealth Disability Strategy) It is unclear how this is implemented in government department and agency purchasing decisions.

While the impact in Australia would be different to USA as telecommunications products are often not manufactured in this country, it would encourage those that are manufactured in Australia and those that are imported to also be accessible. A procurement policy incorporating accessibility for telecommunications by federal, state and territory governments will have a strong impact on improving the working environment for government employees with disabilities and because of market pressures, the rest of the community.

Recommendations

1. The definition of the Universal Service Obligations in the Telecommunications (Customer Protection and Service Standards) Act should be expanded to include universal accessibility reflecting ability and ease of use, quality of the service and the needs of consumers for affordable and appropriate services and products.

2. All carriers and carriage service providers offering retail services should develop Disability Action Plans, lodge these with the Human Rights and Equal Opportunity Commission and review them regularly.

3. The federal, state and territory governments should incorporate accessibility to telecommunications products and services in their procurement policies.

2. The needs of people with disabilities are taken into account in the design of any telecommunications equipment or service. Terminal equipment is designed for the widest possible market.

Often products and services are developed and user testing is only done at the final prototype stage. This means that if there are products which then are discovered to have serious problems for accessibility, it is often too expensive to make adequate adjustments and changes. People with disabilities have the capability of providing vital input into applications which are workable and useful. People with disabilities have to strive harder to do things in the way our community is currently constructed - these things often are what other people take for granted. This striving sometimes leads to clever solutions which often have broader applications. Typical examples of products initially designed for people with disabilities are the telephone, the scanner and voice recognition. This is why it is important to include people with disabilities early on in the development of new products and services.

2.1 Cooperative Research Centre on Smart Internet Technology

The Smart Internet Technology Cooperative Research Centre (SITCRC) has, in Australia, a unique approach to addressing this issue. The SITCRC, formally established in late 2001, is partially funded by the federal government and comprises nine universities and major industry partners such as Telstra, Motorola and Hewlett-Packard as well as many smaller companies. There are technology programs and a user requirements program.

The user program undertakes its own research as well as working with the technology programs so that any project includes the needs of users right from the beginning of the project. The main three user groups are small and medium enterprises, young people and people with a disability. An expert panel of people with a disability will be set up to advise on methodology and provide ideas and links into the disability community. The SITCRC has contracted a specialist in disability and technology issues to ensure that the interests of people with a disability are incorporated in the technology programs. It is anticipated that inclusive design will feature strongly as the work of the SITCRC ramps up. The type of approach taken by the SITCRC should set an example for other corporations.

2.2 Disability Impact Statements

Corporations developing new products and services could use international guidelines such as the U.S. Section 508 Guidelines to check whether a product was accessible at various stages of the design and implementation process. In fact, the use of a "Disability Impact Statement" is a useful tool to achieve this and unambiguously declares the corporation's intentions in working towards accessibility.

2.3 Universal design

Universal design can be defined as helping: "to simplify life for everyone by making products, communications, and the built environment more useable by more people at little or no extra cost." (Center for Universal Design, http://www.design.ncsu.edu/cud) There are two parts to universal design. The first is to design products which are flexible enough, as is commercially practical, to be directly used by people with the widest range of abilities. The second is to design products so that they are compatible with the broadest range of assistive technologies for people who can not use or efficiently access the products directly. However, there still needs to be a recognition that, in some cases, provision should be made for people with a disability to access additional equipment and services. This has been the case with the cochlear ear implant adaptor. The importance of universal design is that a product is designed in a flexible manner to accommodate more people than previously. TEDICORE has given seminars on universal design to Telstra and ATLINKS, a telephone design company.

One day, there will be a reduced need for specialised equipment when more products are developed using universal design principles. This, in future, should reduce costs for consumers and increase the market share of suppliers.

2.4 Industry Development Plans

Many new carrier licenses have been granted over the past few years. Amongst the conditions for the granting of a license is the provision of an industry development plan under the Act. This specifically mentions the requirement for the reporting of a carrier's activities in connection with the production and supply of equipment for use by people with disabilities and the reporting of research and development to address the needs of people with disabilities. There is much more that could be done in this area as research and development impacting on people with disabilities has been quite limited over many years.

Recommendations

4. The Department of Communications, Information Technology and the Arts together with the Australian Communications Authority should exert more pressure on carriers to initiate research and development relating to people with a disability and report this in their Industry Development Plans and Disability Action Plans.

5. Corporations should adopt the principles of universal design in the development of new products and services.

6. Corporations should include the needs of people with a disability in the beginning of the design process of new products and services and incorporate a Disability Impact Statement through the various stages of the design process.

3. Network services adequately support relevant special terminal functions so that all users experience equivalent end-to-end service.

Network services are not an obvious feature of telecommunications services to the average consumer. However, it has a huge impact on how the consumer is able to use applications and equipment. For example, the effects of the changeover from analogue to digital networks for mobile phone users with a hearing aid or cochlear implant were profound. It is vital that future changes to network services incorporate consumer consultation to take into account and find solutions to potential problems.

3.1 GSM mobile phones and hearing aids

A representative complaint was lodged in 1999 with the Human Rights and Equal Opportunity Commission (HREOC) by the Deafness Council of New South Wales. This related to the electromagnetic interference caused to hearing aids and cochlear implants by GSM mobile phones. Due to the representative nature of the complaint and the implications for broad policy change, the Commissioner decided to hold a public inquiry and call for submissions from consumers and industry. Based on these submissions, HREOC's final report and a conciliation process, an agreement was reached by Telstra, Optus and Vodafone to assist people with hearing impairments. The schemes offered by the three carriers varied somewhat but they all offered consumers free or discounts on accessories to facilitate usage of the GSM handsets. The schemes in some cases also offered the possibility of swapping to the CDMA system, which while still a digitally-based system, has been found to interfere less with hearing aids. All carriers have provided brochures and other information material on choosing mobile phones for people using hearing aids. It should be pointed out that the conciliated agreement was made in 2001 and the opportunities for consumers to swap to CDMA, for example, had a number of restrictions and was for a limited period of time.

The initial problem was that GSM was instituted without consultation with disability organisations and thus a major network was in place together with the associated problem when it was not possible to make a change as huge investments had been made in the new infrastructure. There is a danger that this could happen again.

3.2 CDMA and the wireless local loop

CDMA and wireless local loop could be used in remote locations as an alternative to laying copper cable. It is based on CDMA mobile phone technology and the consumer is supplied with a mobile phone handset from which extensions can be cabled to other parts of a consumer's residence. However, TTY's do not work with the CDMA technology. Telstra is planning to introduce this technology based on pilot studies conducted on islands in the Bass Strait.

There are a number of issues of concern with the introduction of this technology. For example, a TTY user may visit and not be able to connect his/her TTY which means that not only would the visiting TTY user not be able to contact family and friends but emergency services would be inaccessible. Another concern is that businesses may find it a disincentive to employ people with a disability if they need to make changes to their telephone system due to the potential high cost.

It is understood that Telstra has a number of strategies to deal with these issues including surveying potential installation areas and the trialing of alternative technologies for TTY users.

However, consumers feel that new types of network services (i.e. CDMA and wireless local loop) must be designed to incorporate accessibility and tested prior to implementation. The testing must be in a real-life situation. This should avoid the need for stop-gap measures at the last minute.

3.3 Future network services

Consumers are concerned about potential development of inaccessible network services and need to feel assured that alternative technologies will meet their needs. Equitable access to network services should mean that a person with a disability can plug terminal equipment into the existing network just as an able-bodied person. Regrettably, this is often not the case.

Future technologies such as Voice over IP will potentially offer other challenges for people with disabilities. However, this still needs investigation.

Recommendations

7. Networks must be designed to incorporate accessibility and be tested prior to implementation of any new network service. The testing must be in a real-life situation.

8. Changes to existing or adoption of new network services should involve in-depth consultation with consumers to ensure there is no impact on people with disabilities. If there is an impact, a solution shall be found which meets the needs of all parties.

4.When mainstream products and services cannot be used, provision is made for people with a disability to access the telecommunications service by means of additional and/or alternative equipment and services.

4.1 Disability Equipment Program

The Disability Standard (AS/ACIF S040:2001) discussed in Section 1.2 refers to customer equipment for use with the Standard Telephone Service. Because it is accepted in the legislation that a consumer needs the supply of equipment in order to use the standard telephone service and that the Act further specifies that this applies to equipment by people with a disability, people with a disability are supplied with equipment such as TTY's to meet their needs by Telstra. Telstra has the responsibility as the Universal Service Provider to supply equipment if needed under the Universal Service Obligations (USO).

As part of its USO role, Telstra is required to provide a Disability Equipment Program. The Program provides specialised phone equipment at the same cost as a standard phone handset for people with a disability who are Telstra local call customers after they have fulfilled eligibility criteria qualifying them for the Program.

The Telecommunications (Equipment for the Disabled) Regulations 1998 gives examples of the type of equipment to be made available by Telstra in order for it to meet its Universal Service Obligations. Disability equipment listed in the Regulations includes TTY's, volume control phone, a phone with speech amplification, a handsfree phone and various ancillary products. This is reflected closely in what Telstra currently provides through its Program. However, Telstra may consider expanding its Program in the near future.

As technologies change, there should be the facility for people with a disability to have access to equipment for those technologies on an equitable basis.

People with a disability have limited freedom of choice in choosing another provider based on price and service. Optus has recently introduced a limited TTY program for Optus customers with a disability who use particular Optus services. The smaller providers have no equipment program.

This has become a contentious issue with consumers. ACIF has held two forums on the topic. One positive outcome has been that the Department of Communications, Information Technology and the Arts, the Australian Communications Authority and the Human Rights and Equal Opportunity Commission have agreed to an interpretation of the DDA and the Telecommunications Act with regard to the obligations of carriage service providers. For example, if providers offer equipment as part of their telephone service, they are required to also provide some accessible equipment. This applies to mobile phones as well as fixed phones. This has been an emerging issue in the past year and it is likely that further developments will occur in this area in 2002. TEDICORE has developed a Position Paper on this issue and is lobbying for changes to ensure that an independent and consumer-managed Telecommunications Program be established. (Appendix 2)

4.2 National Relay Service

The National Relay Service for TTY users is outlined in the Telecommunications Act. This is a twenty-four hour service funded by the federal government and run by an independent organisation, the Australian Communication Exchange (ACE) with carefully constructed performance measures. The government regulator, the Australian Communications Authority oversees the National Relay Service and holds an annual Consumer Forum to ensure that ACE is delivering the service as required.

People with speech impairments are offered a national speech-to-speech relay service which operates 18 hours per day. Other services offered by the National Relay Service include Voice Carry Over and Hearing Carry Over. Voice Carry Over offers the facility for the caller to converse on the phone but to receive the reply as written text on their TTY.

It is believed that the National Relay Service has facilitated the world's first text-based emergency call service using the short dial number of 106. It means that people with hearing or speech impairments or Deaf people can now use TTY, telephone, modem, Voice Carry Over or Hearing Carry Over to contact emergency services. Over the first year of operation, 350 calls were made to this service proving its value.

Two contentious issues regarding the need for a PIN to call long-distance within Australia and TTY training are expected to be resolved later in 2002.

4.3 Video communication for Deaf people

Deaf people who have AUSLAN as their first language have expressed enthusiasm in using sign language via telecommunications. This has many advantages over the use of a TTY especially for those whose literacy skills are not as well developed in their second language of English. The DCITA-funded AccessAbility project Deaf Australia Online II studied Deaf people's current use of online technologies as well as their preferences for new technologies. Video communication was recognised as being a valuable tool. This could be through existing videoconferencing facilities. However, the facility of video relay interpreting extends the function of a relay service beyond that of a TTY and was very well received by those involved in the trial. To set up such a system requires a considerable investment in technology and expertise so to date it has not been implemented.

4.4 Specialised equipment and compliance testing

An issue which TEDICORE has been involved with the ACA for the past two years relates to the concern that specialised telecommunications equipment for people with disabilities which may be imported into Australia or manufactured here in small numbers is very expensive and therefore sometimes not made available. The telebraille for people who are Deaf and blind as well as some specialised switching devices are examples of this type of equipment. One of the ways to reduce the cost and time delays has been to re-examine the compliance testing which is mandatory for mainstream consumer products. TEDICORE initiated an approach to ACA and through the process of a working group with both industry and disability representatives, agreement was reached about a reduced regime of compliance testing for this type of specialised equipment. This will be put into practice in 2002.

Recommendations

9. An independent and consumer-based Telecommunications Disability Program should be established to give people with disabilities the freedom of choice of carriage service provider and equip them with the hardware and/or software to equitably access the telecommunications network.

10. A nationwide video relay interpreting program should be implemented.

5. The Internet and related digital technologies are ccessible, available and affordable by people with a disability

Access to computers and online services by people with a disability can be decisive to their quality of life and independence. It will define their opportunities to participate with other members of the community in the information age.

5.1 Outcomes from the AccessAbility Workshop

Five main elements were identified as major issues for people with disabilities to participate in the Information Economy:

These include the need to:

  1. Increase access to computer equipment and appropriate assistive devices for accessing online services
  2. Provide appropriate training and ongoing support
  3. Reduce cost barriers to accessing the Internet
  4. Monitor government IT and T decisions to ensure disability issues are incorporated
  5. Fund future research in assistive technology for online access and to promote product development in Australia.

These issues were identified at the final panel session of the AccessAbility workshop held on 14-15 May 2001 which was organised by the Department of Communications, Information Technology and the Arts. They are further supported by information from the AccessAbility workshop papers and from studies and surveys conducted by disability organisations such as Women with Disabilities Australia. As the AccessAbility funding program was not extended, it is important that the findings from some of the projects are implemented so that the knowledge gained is not wasted.

Recommendations were developed to reflect avenues and actions to address the issues.

5.1.1 National Internet Scheme for People with Disabilities

It is vital that people with a disability and especially those on low incomes have options of accessing the Internet in an affordable manner. This can be achieved in a number of different ways depending on the circumstances of the individual. For example, people with a disability who require the use of assistive devices as part of their computer system to access the Internet may not be able to afford these devices themselves. They may prefer to incorporate their use of the Internet with a visit to the local library, community centre or disability organisation. Other people on low incomes may, for a variety of reasons, not be in a position to regularly visit an organisation and would find it most valuable to access the Internet from their home.

To meet these diverse needs, the establishment of a national Internet Scheme for people with disabilities should have the following components:

  1. Creation of a pool of assistive devices to facilitate access in community-based centres. This would be a national ongoing program and could be modelled on the Networking the Nation project in Tasmania entitled Tech Assist Online. Funds would be used to purchase assistive devices to facilitate public access in centres used by people with disabilities.
  2. Low interest loan program for purchase of computer and printer. This program would be directly available to people with disabilities on low incomes. Loan repayments would be administered through Centrelink.
  3. Development of a national clearinghouse and network of regionally-based PC recycling programs for people with disabilities. This network would build on existing expertise in administering such programs such as Rural & Peninsula Disability Support and Green PC and make use of computers surplus to requirements by the three levels of government and corporations. This computer equipment would be provided to people with disabilities meeting eligibility criteria.
  4. IT and T-based assistive devices provided as needed through a federal government program and upgrades to equipment are provided upon application.
5.1.2 Training Partnership Scheme

In order to increase the availability of computer training for people with disabilities, there should be a national Training Partnership Scheme with the following components:

  1. A multi-tiered training program to support people with disabilities in their use of the Internet.
    It is important to have a multi-tiered training program in order to cater for the differing requirements of people with disabilities. The expertise gained from the DCITA-funded AccessAbility projects can input into the development of a nationally coordinated program, funded both by government and corporations. Corporations could include telecommunications providers and Internet Service Providers, who have a direct interest in increasing the number of online clients. Partnerships between community organisations, universities and specialised companies will assist in a number of ways.
  2. Delivery of training will be provided at the local level by people trained through regional Train the Trainer programs. This is supported by online training as appropriate. Ongoing support is offered if required. Training is provided for paid carers of people with disabilities in the use of assistive devices for accessing online services.
  3. People with disabilities are included in the Government-sponsored Telstra Internet Assistance Programme. This Programme includes a national Online Help Service to assist people in connecting to the Internet by providing help in the configuration of PC's and modems for connection to the Internet. It is vital that strategies include assisting people with disabilities.
5.1.3 Internet Access Allowance

In order to increase the affordability of Internet access for people with disabilities, an Internet Access Allowance should be implemented.

This should be organised along similar lines to and in addition to the Telephone Allowance currently administered by Centrelink. This allowance will assist people with disabilities on pensions to cover the costs of connection fees to an Internet Service Provider.

5.1.4 Government IT and T Disability Centre of Excellence

To ensure that Government policies and activities in information technology and telecommunications take into account the needs of people with disabilities, a Government IT and T Disability Centre of Excellence should be established.

This Centre of Excellence will coordinate IT and telecommunications policies relevant for people with disabilities across federal government departments.

Activities include:

5.1.5 Assistive Technology Research and Development Corporation

In order to promote future research in the area of assistive technology, and to encourage the development of an effective assistive technology industry in Australia, an Assistive Technology Research and Development Corporation should be established.

This would enable the work initiated by DCITA's AccessAbility program, especially in terms of the encouragement of research, to continue. The Corporation would:

The work of this Corporation would foster the development of an Assistive Technology industry in Australia, with considerable export potential, especially in the Asia Pacific region.

5.2 Telstra Centre for Accessibility

Telstra set up a Centre for Accessibility in 2001 to assist the corporation's many web developers to design accessible web sites. The Centre is located within the Human Factors Group of the Telstra Research Laboratories. There are useful synergies as the Human Factors Group has conducted a number of projects on Telstra products and services to identify accessibility concerns. The Centre which includes a staff member with vision impairment has been in great demand and it is hoped that this initiative will lead to more useable Telstra web sites. This type of initiative should be developed by other major corporations.

5.3 Government Online Strategy

The federal government introduced its Government Online Strategy in 2000 to assist in improved interaction between the government and the public, to improve service quality and offer better coordinated services from a range of government departments and agencies. The Strategy's key component was to bring all public government information online. Priority Two is entitled "Ensuring the Enablers are in Place" and part of this Priority is accessibility. Interestingly, it discusses accessibility not only for people with a disability but also for people living in rural and remote parts of Australia where Internet access is slow and thus the downloading of graphics-intensive web sites is extremely time-consuming. Reference is made to the Disability Discrimination Act which requires federal government online information to be accessible and deadlines were specified by which all federal government departments and agencies were to have their web sites accessible.

Unfortunately, the deadline of 30th December, 2000 was not achieved by all agencies and there are still a few which need to make their web sites accessible based on level one of the W3C Web Content Accessibility Guidelines. In a regular online survey conducted by the National Office for the Information Economy, the majority of agencies reported that any web site development included accessibility as a key performance requirement.

Recommendations

11. A national Internet Scheme for People with Disabilities should be established and have the following components:

12. A national Internet Training Partnership Scheme should be established with the following components:

13. An Internet Access Allowance should be implemented.

14. A Government IT and T Disability Centre of Excellence should be established.

15. An Assistive Technology Research and Development Corporation should be established.

16.Organisations providing online information to consumers should comply with all three levels of the W3C Web Content Accessibility Guidelines.

6.People with disabilities should, as far as possible, be able to use telecommunications services at prices equivalent to those without disabilities. Most of the additional costs of providing access to all should be met by dedicated funds or absorbed within general operating costs.

Use of the telephone or a related device to communicate over distance is considered a basic right by the community. People with disabilities should not have to incur any additional costs to other members of the community to use telecommunications. Any new service or changes to an existing service should also not result in additional costs to a person with a disability.

Examples where people with a disability may incur additional costs to those people who do not have a disability are:

Recommendation

17. Any new service or changes to an existing service should not result in additional costs to a person with a disability.

7. Providers of telecommunications equipment and services and regulatory authorities consult regularly with people with disabilities about their access requirements and take appropriate action. Equally, organisations representing people with disabilities contribute their knowledge and expertise.

7.1 Consumer representation

The Telecommunications Act states that consumer representation may be funded by the federal government to ensure that consumers are informed about telecommunications developments and that consumer interests are clearly presented to government and industry. This has become particularly important with the deregulation of the market and the many changes occurring in the provision of products and services. Four organisations are currently funded to represent residential consumers (Consumers? Telecommunications Network), small business consumers (SETEL), people with disabilities (TEDICORE) and the Australian Association of the Deaf. Smaller amounts of funding have also been allocated to peak disability organisations to cover costs of representation activities.

TEDICORE (Telecommunications and Disability Consumer Representation) provides a mechanism for consumers to discuss pertinent issues and concerns and then for these concerns to be directly raised in the appropriate government and industry forums in order to achieve better access to products and services. In the past four years, TEDICORE has been involved in or initiated many of the strategies discussed in this document.

7.2 Carriers' consultative process

Through the Australian legislative process, the universal service provider is required to have formal avenues in place for consumer consultation. Telstra organises twice-yearly Disability Forums and has set up a consumer advisory group for its Disability Equipment Program. The consumer advisory group is required under the universal service obligations of the Telecommunications Act. It discusses issues such as procedures for eligibility of the disability equipment program, usage statistics, negotiations under way for updated products and recommendations for new items. However, it is clearly an advisory group and so Telstra need not move ahead with recommendations for new items if it is considered financially inappropriate to do so.

Optus has established a more broadly-based Consumer Liaison Forum comprising consumer representatives from a wide variety of consumer organisations.

Again, on a broader basis, Telstra has its Consumer Consultative Council with representatives from a wide range of organisations representing ethnic communities, isolated children in remote regions of Australia, financial counsellors, older people, women, people with disabilities, Indigenous people, internet users, small business consumers and young people. The Council is co-chaired by a senior manager of Telstra and a consumer representative. There is a separate secretariat to support the work of Telstra and one to support the work of consumers in the development of policy through the Council.

Unfortunately, the smaller carriers have no processes in place for consulting with people with a disability. This should be addressed so that consumers can feel confident that there is a good channel of formal communication in place for issues to be resolved.

7.3 ACIF's consultative processes

Based on consumer recommendations from an ACIF Disability Forum, ACIF established the Disability Advisory Body (DAB) in 1999 to provide advice and input on the implications for people with a disability of any ACIF proposed code or standard. This advice is provided at the project proposal stage and ongoing advice can also be provided to Working Committees. The Disability Advisory Body comprises representatives from peak disability organisations.

The processes for consumer participation particularly in Working Committees need to be altered by ACIF so that consumers feel that their knowledge is respected and that there is a more level playing field. Consumers may feel intimidated by the many facets of standards development meetings. A training and mentoring program where consumers are given structured information on the telecommunications regulatory environment, meeting procedures and other facets of consumer representation would be extremely valuable to consumers. It would also lead to more effective participation in the standards-making processes. The provision of a consumer mentor to new representatives would raise confidence and offer support in the initial stages of representative activities.

Many consumers attending ACIF and associated industry meetings do so in their own time with a subsequent loss of income. This is totally different from industry representatives whose job encompasses participating in ACIF meetings. Consumer representatives feel that their participation is not recognised or valued to the same extent if they are not compensated for their time.

Recommendations

18. The Department of Communications, Information Technology and the Arts should offer three year grants for consumer representation with yearly performance measures in order to maintain continuity of representational activities.

19. All carriers and carriage service providers offering retail services should incorporate direct consumer consultation in its operations.

20. Consultation with people with a disability should incorporate best practice guidelines as outlined by the Department of Family and Community Services.

21. ACIF processes should ensure that consumer participation in all ACIF fora including Working Committees and Reference Panels is supported in such a way as to offer a level playing field between industry and consumer representatives.

22. A training and mentoring program should be implemented to increase understanding by consumer representatives of the complexities of the telecommunications regulatory regime to assist in their representation activities.

8. Telecommunications products and services that improve and increase access for people with disabilities are actively advertised and promoted, with information also available in accessible formats.

There is considerable concern that products and services for people with a disability offered by the major carriers such as Telstra and Optus are not widely known. While Telstra has produced a Catalogue of Products and Services and advertised its services in disability media, there needs to be a more concerted effort. For example, leaflets could be included with a customer's phone bill outlining products and services. This would reach people who do not belong to disability organisations. Optus has recently established a TTY program to existing customers in certain areas but the plans for extension of this program are not well-known.

Any information should be prepared in plain English to accommodate many people who have learning or intellectual disabilities or may be from non-English speaking backgrounds. Naturally, information should be available in alternative formats such as Braille and large print and if on web sites, be accessible according to the W3C Web Content Accessibility Guidelines.

The project commissioned by the Communication Aid Users Society and conducted by Deakin University highlights many important issues in the way accessible information should be disseminated to people with speech and communication impairments. Many of the recommendations in the report especially with respect to the way information is provided have relevance for a broader audience and should be considered in this light.

8.1 Online database of telephones with accessible features

Australian manufacturers and importers of telecommunications equipment for use with the standard telephone service must demonstrate public compliance with the provisions of the Disability Standard. This is usually through labelling and a compliance folder. In a novel approach, the Australian Telecommunications Industry Association (ATIA) has initiated an instrument of public compliance to be a web site which lists all phones which meet the criteria of the Standard. The ATIA's Disability-Industry Partnership (an informal group representing disability organisations and industry) has formed a sub-committee comprising consumer representatives such as TEDICORE and industry members to develop an online database listing phones which meet other phone accessibility criteria. These criteria have been developed from international guidelines and adapted for the needs of the online database. It is believed that a national online database on phones with accessible features for consumers is a first of its kind in the world. This is a good example of best practice where consumers and industry have worked together to achieve an outcome beneficial to both parties.

Recommendations

23. Products and services for people with disabilities should be promoted in both the disability and general media.

24. Information about products and services should be made available in Braille, large print and electronic formats and be written in plain English.

Conclusion

The key principles and recommendations set out in this Best Practice document reflect the desired outcomes so that people with a disability can use such an essential service as telecommunications in a more equitable manner. These recommendations are based on TEDICORE's knowledge of the current environment and its work in achieving improved access in telecommunications products and services for people with a disability.

Some of the recommendations should be successfully resolved in the short-term while others may require considerable advocacy work and a number of years for satisfactory change to occur. For example, the need for an independent Telecommunications Disability Program is recognised as an issue by both industry and government and while there is considerable work to be done to achieve a Program which will meet consumer expectations, it may a reality within the next couple of years.

In contrast, some recommendations which involve major changes in legislative and regulatory processes or in policy may take considerably longer.

TEDICORE, as part of the disability community, looks forward to working on these issues with industry and government so that Best Practice in telecommunications for people with a disability will become a reality.

References

Astbrink, G. (1996) Everybody's business: Consumer information access for people who are blind or vision impaired. National Federation of Blind Citizens of Australia,Melbourne.

Australian Communications Industry Forum (2001) Industry Guidelines: Access to telecommunications for people with disabilities - ACIF G586. ACIF, Sydney.

Australian National Audit Office (2001) Better practice guide - Internet delivery decisions
http://www.anao.gov.au/

Center for Universal Design (1997) The principles of universal design. NC State University.
http://www.design.ncsu.edu:8120/cud/univ_design/principles/udprinciples.htm

(2000) Commonwealth Disability Strategy: A guide to the performance reporting framework. Department of Family and Community Services,Canberra.

(2001) Commonwealth procurement guidelines and best practice guidance. Department of Finance and Administration, Canberra.
http://www.finance.gov.au/ctc/docs/cpg.pdf

(2001) Communicating with customers who are disabled - A guide for telecoms companies. Oftel.
http://www.oftel.gov.uk/publications/consumer/gpm0901.htm

(1999) COST 219 bis Telecommunications Charter. http://www.stakes.fi/cost219/charter.htm

Egan, J. and Worrall, L. (2001) Internet training package for people with a communication disability. University of Queensland, Brisbane.

Goggin, G. and Newell, C. (2000) An end to disabling policies? Towards enlightened universal service in The Information Society, 16:127-133.

Goggin, G. and Newell, C. (2000) Twenty-five years of disabling technologies: The case of telecommunications in Promises, promises: Disability and terms of inclusion, edited by M. Clear. Federation Press, Sydney.

Hansen, B.F., Hansen, A.O. et al (1998) Accessibility of telephone systems and services - ACCENT deliverable 3.3.
http://www.statskontoret.se/english/accenteng.htm

(1999) Inclusive consultation: A practical guide to involving people with disabilities. Department of Family and Community Services, Canberra
http://www.facs.gov.au/disability/ood/consgide.htm

Knuckey, J. and Slegers, C. (2001) Deaf Australia Online II. http://www.circit.rmit.edu.au/projects/dao2/index.html

Owens, J. and Communication Aid Users Society (2002) Accessible information for people with speech and communication impairment.

(2001) Section 508 Standards.

http://www.section508.gov/index.cfm?FuseAction=Content&ID=12#Telecommunications

Stanzel, J. (2001) A matter of choice in AccessAbility Workshop papers, pp. 161-171. Department of Communications, Information Technology and the Arts, Canberra.

(1999) Telecommunications (Consumer Protection and Service Standards) Act 1999.

Wilson, I. and Goggin, G. (1993) Reforming universal service: The future of consumer access and equity in Australian telecommunications. Consumers' Telecommunications Network, Sydney

Worrall, L., Egan, J. and Schmidt, D. (2001) Barriers to learning the Internet for people with aphasia in AccessAbility Workshop papers, pp. 50-55. Department of Communications, Information Technology and the Arts,Canberra.

List of acronyms and web sites

Australasian Legal Information Institute - Commonwealth Consolidated Acts
http://www.austlii.edu.au/au/legis/cth/consol_act/

ABS - Australian Bankers' Association
http://www.bankers.asn.au/

ACE - Australian Communication Exchange
http://www.aceinfo.net.au/

ACA - Australian Communications Authority
http://www.aca.gov.au/

ACIF - Australian Telecommunications Industry Forum
http://www.acif.org.au/

COST 219 - European Co-operation in the field of Scientific and Technical research
http://www.stakes.fi/cost219

DDA - Disability Discrimination Act 1992
http://www.austlii.edu.au/au/legis/cth/consol_act/dda1992264/

DCITA - Department of Communications, Information Technology and the Arts
http://www.dcita.gov.au/

Government Online Strategy
http://www.govonline.gov.au/projects/strategy/GovOnlineStrategy.htm

HREOC - Human Rights and Equal Opportunity Commission
http://www.hreoc.gov.au/

IIA - Internet Industry Association
http://www.iia.net.au/

Optus - Disability Action Plan
http://www.cwo.com.au/content/1,1463,107,00.html

TCPSS - Telecommunications (Customer Protection and Service Standards) Act 1999

Telstra - Disability services
http://www.telstra.com/disability

Appendix 1

Extract from ACIF Guidelines (ACIF G586)

1.1.1 Because the provision of appropriate products and services for people with disabilities must be in accordance with the Disability Discrimination Act 1992, Codes and standards should be drafted and read with reference to the Disability Discrimination Act 1992.

1.1.2 The principles of universal design should be taken into account, where relevant, in the development of Codes and Standards.

1.1.3 Codes and Standards that impact on consumers should be written in plain English, or have available an explanation of the Code or Standard in plain English. This assists the general population, including people with learning disabilities, and people from non-English speaking backgrounds.

1.1.4 Any documentation should be made available in alternative formats upon request e.g. large print and Braille and electronic format. Electronic documentation should be created in such a way that it is accessible to people with disabilities and in particular people with vision impairments.

1.1.5 The ACIF web site should meet international web accessibility guidelines in a similar way as specified by the Government Online Strategy to ensure ACIF Working Committees and Working Groups can access material on the ACIF website relevant to their task, and to ensure people with disabilities can access ACIF documents which have been released for public comment.

1.1.6 Customer enquiry or assistance lines should include a TTY line for people who are Deaf, speech or hearing impaired, and customer enquiry or assistance service operators should receive regular training in the efficient use of a TTY.

1.1.7 Customer service staff should receive regular training in communicating with people with a range of communication needs, including speech impairments.

1.1.8 Customer enquiry or assistance service counters should provide:

(a) sign interpretation on request for deaf people;

(b) language assistance for community languages; and

(c) communication facilitators and a counter loop for the hearing impaired.

1.1.9 Carriers and carriage service providers should ensure that customers can be easily assisted by an advocate, if required, when communicating with a supplier. An advocate is defined by ACIF as ?an attendant care worker, family member, friend or other person nominated by a customer with a disability, non-English speaking background or other special need to assist the customer. An Advocate is not authorised to make changes to the customer?s account or telecommunications services unless they are also nominated by the customer as an Authorised Representative.

1.1.10 When ACIF Codes, Standards or Guidelines mention access to the Emergency ?000? number, the TTY Emergency number ?106? should also be mentioned.

Appendix 2

Key principles of proposed Disability Telecommunication Program