Hi all,
The Telecom Regulatory Authority of India (TRAI) has released a
consultation paper on "Making Information and Communication Technology
Accessible for Persons with Disabilities". Blind Graduates Forum of
India has prepared the first draft of the representation to make it
convenient for you to add your suggestions. This is one of the most
important aspect of accessibility and can have far reaching
implications for all of us. Therefore, we invite you to review the
below representation and send your suggestions latest by Saturday,
20th January. Especially request the experts working in the area of
technology, communication, accessibility, law, management and
organizations working for persons with disabilities to contribute with
your expertise.
The best approach to review would be to read the consultation paper
published by TRAI from the below link, and then read our
representation pasted below.
http://www.trai.gov.in/sites/default/files/CP_ICT_20122017.pdf
Representation from Blind Graduates Forum of India
Q1. Which are the disabilities, with specific accessibility
requirement, other than those mentioned in para 2.3 that require
consideration for preparing a framework?
Other than the ones mentioned in the paper, Persons with speech
impairment needs to be included.
Q2. Apart from the challenges enumerated in para 2.3, what other
challenges do PwDs face while accessing telecommunication and
broadcasting services?
• Websites, software and mobile apps from vendors and service
providers do not comply with accessibility guidelines which makes them
inaccessible for visually impaired persons who access them using
assistive technologies like screen reading software, brail displays,
etc.
• Most electronic hardware products like Set Top boxes, Smart home
solutions, etc are not usable for PwDs as they don’t comply with
international accessibility standards.
• For instance, the buttons on most of these devices do not possess
any tactile notations and audio feedback to allow visually impaired
users to interact with them.
Q3: In your opinion, what are the reasons for the desired benefits of
ICT (telecom and broadcasting) not reaching the PwDs despite several
policy measures and scheme being implemented?
• Most policies are guidelines and are not mandated. There is no
penalty for non-adherence. This leads to lesser efforts towards
compliance.
• Most guidelines are made applicable only for government entities and
not all establishments. However needs of PwDs in their day-to-day
lives span beyond services and products offered by government
entities.
• Financial mechanisms that would help products benefiting PwDs to
mature and survive in the market either do not exist or are very low
and ineffective.
• Mechanisms of communicating to each of the relevant entities,
monitoring adherence to the policies, notifying the specific actions
to be taken and auditing are insufficient.
Q4: What additional or corrective measures can be taken by the
Government to enable better access to telecommunication, broadcasting
services and devices to PwDs? Please give a rationale for your
response.
• All the provisions in the policies concerning access to PwDs must be
made applicable for “all establishments” (including government,
private, autonomous, non-government, etc.) and not just government
entities. The same should be communicated explicitly in opening
statements itself: This is in line with Rights of Persons with
Disabilities Act 2016.
• All the specified provisions must be made “mandatory” and legally
binding instead of mere guidelines. Moreover, clauses specifying
substantial penalties for non-adherence should be incorporated.
Consider the example of several international organizations which had
initially begun working in the interest of PwDs for the sake of
compliance mandates, but upon realizing the business benefits
gradually ended up integrating these efforts into mainstream business.
• To avoid ambiguity, the definition of “everyday use products” must
be clearly defined and detailed. It should include products used for
personal use, at home, office, public infrastructures, malls, etc as
elaborated in Q6. There is a possibility of misinterpretation or using
it as a loophole to justify non-compliance.
• TRAI should have a helpline where only complaints regarding
accessibility can be received. The complaints should be published on
the Internet along with corresponding actions taken. This would not
just encourage disabled persons highlight their problems, but also
would ensure that the manufacturers remain on guard to not get caught
in the wrong foot.
• on settop boxes, service portability can be effectively used to
shift operators who do not provide accessible services.
Q5: Apart from the measures suggested by ITU, what additional measures
can be taken by the TSPs and equipment Vendors/suppliers and other
stakeholders to address the Challenges faced by PwDs while accessing
telecom and Broadcasting services?
• The suggested measures are only for consideration of TSPs. These
provisions need to be mandated to ensure adoption. Earlier measures
have been guidelines and there has not been much of action by TSPs.
Further, A PWD consumer who is paying for these services must get
associated information in accessible formats.
• A team must be setup to communicate measures, monitor adherence,
establish reporting mechanisms, and notify entities highlighting gaps
and audits to increase compliance. Most organizations are unaware of
their responsibilities and its implications on the lives of PwDs.
• the user / manuals should be published on their online portals as
well as shipped within the product packaging. All the contents should
be accessible with assistive technologies used by the blind like
screen reading software.
Q6. What are the areas where collaboration between various stake
holders would be useful and how?
• Collaboration is needed for integrating accessibility in all
products that have a display screen and interactive touch screen. This
includes set top box, POS machines, scanners, everyday use products
such as washing machines, microwave, Air Conditioners, refrigerator,
all types of wending machines, self-service public devices used in
shopping malls, airports, railway ticketing, printers including 3D
printers, scanners, lifts, elevators, musical instruments such as
keyboard, rhythm pads, etc.
• Collaboration on integrating accessibility and setting standards for
platforms, operating systems and software for wearable devices,
Internet of Things and artificial intelligence based platforms /
products.
• Collaboration on imparting necessary training and awareness
regarding accessibility standards to manufacturers, professionals
working in relevant fields and students studying in engineering
fields. If all stake holders are educated about the use case for
accessibility, it would become a part of the design instead of an
afterthought for compliance.
• Collaboration for implementing accessibility in platforms like
operating systems at a lower level as well as promoting the
development of common assistive technologies that can work with myriad
of devices can significantly reduce the cost and effort for all the
stake holders. For instance, "Talk Back" a built-in screen reading
software provided by Google Inc. allows a blind user to not just
access apps from Google but any other android app with equal ease.
• Hardware devices can be made accessible by either factoring
accessibility to the product or exposing the controls to an accessible
device like accessible mobiles. The latter can be an alternative
approach in making even devices with low computation capabilities
accessible. For this proper standards and security should be in place.
Q7. Should the Government/TRAI direct the telecom and broadcasting
service providers to provide information pertaining to billing, usage,
pricing and contracts in the form accessible to PwDs? Please provide a
rationale for your response.
• Yes, A PWD consumer is paying the same amount for the services
provided by these providers as any other consumer, and therefore must
have equal access to all the pertinent information for the services he
has availed.
• Every consumer regardless of disability must have an opportunity to
choose from the available options which can only become possible if
the mentioned information is provided in accessible formats.
• For instance, The service contracts though available in electronic
formats are not prepared while keeping accessibility in mind and hence
are inaccessible to screen reading software.
Q8: Should the Government/TRAI mandate that the devices used for
watching television provided through cable, satellite/DTH, fiber, etc.
should be made accessible to PwDs?
• Yes, in fact currently there is not a single service provider that
enables a visually impaired person to access a basic facility like
watching television independently.
• Therefore, there is an urgent need for producing accessible
broadcasting devices i.e. Television, Set top boxes and more because
even though the content is produced while keeping accessibility in
focus it doesn’t reach the targeted audience.
• Citing a recent example, Most of the visually impaired persons
couldn’t experience the audio described telecast of Dangal movie
because they didn’t have accessible Set top boxes and the audio
description service was not uniformly available with all the service
providers.
Q9. Should international accessibility standards be adopted for
telecommunication and broadcasting services and devices in India?
Please suggest steps required to ensure their adoption by the service
providers/device manufacturers.
• Yes, it will enable standardization and help in achieving economies of
scale.
• Mandating this policy is the most important measure to ensuring
adoption and compliance.
• Provisions can be made for providing first preference during
procurement to products and services from organizations complying with
international accessibility standards.
• Organize awareness campaigns and corporate round table conferences
on the topic of accessibility.
• Encourage hiring of PwDs who would act as key influencers for
adoption of accessibility standards in the organization.
Q10. What additional measures can be taken or technologies can be
deployed by service providers or equipment manufacturers to assist
PwDs?
• Enroll a team of beta testers representing different disability
groups to ensure that the technologies and equipments are accessible
and usable to all regardless of disabilities.
• The feedback obtained must be acted upon before the equipments are
brought to market.
• Make accessibility education a part of curriculum for courses in
relevant domains like engineering, design, management, medical.
Q11 Should device manufacturers be mandated to allow in their device’s
operating system those applications, which are meant to assist the
PwDs? Please justify your response.
• Mandating adoption of universal design for all platforms, operating
systems and products is a better approach considering cost and other
functional benefits.
• However wherever not feasible it is critical to mandate
organizations to allow external applications as many organizations
often do not allow proven technology to be integrated into their
products.
• This has led to inaccessible products and exclusion of PWD's access
to such equipment like in the case of set top boxes.
Q12. What measures can be taken in India so that emergency services
are made more accessible for PwDs? Should the implementation of these
measures by TSPs be made mandatory by the Government?
• Adopting a blend of international standards for emergency services
can go a long way towards making them reach PWD users.
• For instance, IVR enabled calling service can specifically prove
beneficial for visually impaired.
• The accessibility of emergency services is critical and hence the
guidelines should be legally enforceable for TSPs
Q13. Should the device/handset manufacturer be mandated to manufacture
at least one model of handsets for PwDs which is having accessibility
features and which are compatible with assistive technology features
such as hearing and visual aids including emergency buttons etc.
Mandatory incorporation of accessibility standards in all the products
is a better approach. Designing products exclusively for PwDs like
mobile handsets would not just require more cost and effort but would
also bring up the challenge of keeping them up-to-date with the other
main stream products available in the market.
Q15. Should any other funding mechanism for the development of
applications, devices and services meant for the PwDs be considered?
Please give a rationale for your response.
• Initiate interventions to reduce cost of all everyday use accessible
products and assistive tech products.
• Provide financial support through subsidies, tax exemption, zero
import duty, tax holiday, 100% foreign investment, etc. To encourage
organizations design, manufacture and sell accessible products.
• Disability and poverty goes hand in hand, and earning capacity of
PwDs cannot increase without an access to equal and accessible
environment.
• At the same time, it has been challenging for manufacturers and
sellers of accessible products to sustain their business due to low
demand and locating potential customers.
• This deadlock can be defused by interventions to reduce cost of
products and making it more affordable for PwDs through following
measures:
1. Deliver subsidies to PwDs directly with a provision for them to
avail it for products relevant for their needs. This will encourage
them reach out to sellers as per their needs and create demand. More
importantly, it will create a culture of buying among PWD that
currently is lacking.
2. Provide subsidies and tax benefits for sellers and manufacturers
based upon the revenue and no of units manufactured and sold. Most
startups working for PWD are unable to sustain. This will help them
survive and encourage new startups address their needs.
3. Open up to 100% FDI and eliminate all foreign investment
restrictions for funding on research, manufacturing and delivery of
accessible everyday use products and assistive tech products. This is
a highly underserved market. International expertise and resources
will enable addressing the needs of a fast growing market.
4. Encourage import of assistive tech products that are not available
in India through zero import duty and subsidy. There is very low local
expertise and awareness of business potential. This will avoid
duplication of investment on research and create awareness among local
players to speed up the process of making and selling in India.
• All procurement should prioritize on accessible products. Consider
other products only in case of non-availability of accessible products
with a mandatory clause on making them accessible in predefined
timelines.
• Similar to international trade fairs, there should be an annual
international trade fair of assistive technology of true international
standards. This should be a big awareness for local manufacturers and
sellers to showcase their products to international audience.
Q14. How should companies be encouraged to utilize their CSR funds for
development of applications, devices and services for the PwDs? What
kind of devices and applications can be envisaged/designed to make
achieve ICT accessibility for PwDs?
• They can be used for collaboration projects applicable for products
relevant for their industry elaborated in Q6.
The industry expertise and relevant infrastructures will enable
companies to foster integration of accessibility features into their
own products leading to direct business and social benefits.
Moreover, the focus should be on building demands for solutions with
accessibility features by empowering PwDs rather than CSR to create a
win-win situation for companies as well as PwDs.
Q16. How can effective campaigns be designed to create awareness
about use of ICT accessibility tools? Can such campaigns be funded by
CSR funds? If not, what other mechanisms can be used to fund such
campaigns?
• SMS / email alert service for new product / scheme launches can help
the campaigns reach wider audience.
• Collaboration with various organizations working in the interest of
PwDs can also help spread awareness to a larger audience.
• Conduct workshops and seminars for demonstration of accessibility tools.
Q17. Should the Government incentivize the manufacturing and
development of ICT tools and devices viz. tools for mobile
accessibility, TV accessibility or for web accessibility for PwDs?
Please give a rationale for your answer.
Yes. This should be applicable for all products that can be made
usable for PWD including the ones mentioned above for the reasons
mentioned in Q 15.
Regards,
Team Blind Graduates Forum of India.
Website: www.bgfi.in
Facebook: http://tinyurl.com/bgfifacebook
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