Now, in line with that I would like to invite the speaker from the European Disability Forum. He focuses on ICT. He is the ICT expert. Alejandro Moledo. He has been working with us for a long time. I’m delighted to welcome him to our stage. Thank you.
Thank you very much.
Thank you very much for the kind invitation. Thank you all of you for being here. Microsoft for hosting us. Great to be here with you.
Yes, most of you know about EDF, the European Disability Forum. We are the umbrella organisation representing the interest of persons, with disabilities at EU level through the active involvement in policy making. This afternoon we are focusing on policy.
Our mission is to make sure that the UNCRPD, the UN convention on the rights of persons with disabilities is fully implemented. As you may know, the UN convention is the first human rights treaty that recognizes access to ICT as one of the fundamental rights for persons with disabilities. Accessibility is one of the general principles of the convention. In order to enjoy the rest of the rights enshrined in the convention you need accessibility. Our motto in this regard is to make sure that accessibility is taken into account. It is mentioned in the article 9 on accessibility. And article 30 and 21 also mention access to the technology as we mention today.
This is why EDF is so focused on working on new technologies. In this regard, we are having a twintrack approach. On one hand, we focused on those legislation trackling the needs of persons with disabilities. And empowering them. Such as the web accessibility directive. That is very close to my heart. It was my first directive. And Accessibility Act. But it is also very important to mainstream accessibility in sectorial legislation that are very relevant to the everyday lives of persons, with disabilities. Our ultimate objective is to make sure accessibility is understood as a core aspect of ICT. When we talk about ICT, we tend to talk about privacy, data protection, security. But we also want as Jenny mentioned in her video message. We want to make sure accessibility is embedded in the design of any kind of technology. That’s what we try to achieve in our advocacy towards policy making.
So, what do we want? Simple. We want available, affordable and accessible technologies. These conditions are what guide us in our endeavours at EU level. And concerning this policies, what we are trying to ensure is that there is an end to end accessibility. When using technologies. What would be the point in having a tv that supports subtitling, if the service provider, the audio visual content doesn’t provide the subtitles? Same for telephony services. If my smartphone can support realtime text but the network operator doesn’t support it, there is no point in having this feature. It is important to keep in mind we need this end to end connectivity and interoperability throughout the whole chain.
That’s why we need an ambiguous requirement. If we leave the words accessibility in the legislation, we may not be ensuring that the technology includes those features that are necessary for us.
Ima mentioned that one of the challenges that we are facing recently. As you can imagine it is exciting moment for accessibility. It is being discussed in many different legislation. The Accessibility Act is a huge milestone for us. But we face with this challenge and question, what about, how this different legislation can complement each other? Our answer was, okay, we can keep the obligations in the sectorial legislation. For instance the public procurement that was mentioned by Ima as well. The public procurement directive. Accessibility criteria into account. But what does it mean in practice? How can we ensure that accessibility is actually a reality when public authorities buy products or services? That’s why we need the Accessibility Act. We need to mention how to achieve the accessibility. What accessibility features, requirements should be ensured to make sure that obligation is actually respected.
So, I don’t know if I… I can’t see the screen.
Am I in the right one?
– You are still in the first slide.
– Really? Sorry. I was pressing.
Sorry about that.
I didn’t notice. You could have stopped me.
So, briefly I will try to give you a quick overlook on 3 pieces of legislation. And our views and the views of our members with regards to these 3 EU directives.
The audio visual media directive. The European Accessibility Act.
Audiovisual services was mentioned by Liisa before. It is important that we need to ensure that audiovisual content is accessible to all of us.
Unfortunately the audiovisual media directive didn’t have an obligation to make those services accessible. It was an encouragement for member states to ensure that. Some did and some did not. In the end we saw that one of the main problems was that the implementation of this directive differs broadly across the EU. There are some countries that transpose the directive and went further. The UK, France, Spain, and actually have better access services in their tv programs. In public and in commercial. But still, some mostly commercial broadcasters are behind. Netflix or Hbo in Europe is lagging behind in terms of subtitling, audio description, sign language interpretation. And spoken subtitling. Which is not available. The implementation of the directive has been quite different, depending on the country we are talking about.
And still, there are some problems of access. Because for instance the electronic programming guide, the menu you open to see what content you want to watch is not accessible for blind users. Or doesn’t include whether a program has sign language interpretation or subtitles. It is very important for the enjoyment of the services itself as well.
So, the Commission… I am lost with the presentation.
– I’m going backwards?
– That one.
– Maybe I should stay here. Would be easier. Okay.
I’m very sorry.
As I was saying, the Commission presented an update of the audio media service directive and removed the encouragement to member states to encourage broadcasters to make their services more accessible. But, the Parliament and the Council both preferred to have the accessibility provisions in the sectorial legislation. And this is still not confirmed. As well, they are in trilogues in the negotiations about the audiovisual service directive. What we save so far, not confirmed, is an article that could look like this. This is a summary. We don’t have the text for the moment. We see that we finally got a mandatory provision to ensure audiovisual services would be accessible. This is important. What is the problem of this? Here we don’t have any explanation of how that can be achieved. Any accessibility requirements to include subtitles. Those should be personalized. We don’t have anything of that. That should have been placed in the Act. And this is not yet in the sectorial legislation. This is the obligation. This means, it is important, a take away for you. We will need to work a lot at national level to ensure that this is properly implemented. The main services are included. We prioritize the content that users… We need to work a lot on national level. This is an improvement. The broadcasters reporting every year, preparing action plans on accessibility, will also have emergency communication, for disasters and so forth. We hope the Commission and the national regulatory authorities will exchange information on quality aspects. Quality is very important in audiovisual services.
Let’s go to the electronic communications code.
Which is also an update of the telecoms package adopted in 2009 and mentioned before by Wouter.
Back in 2009 it was quite successful for the disability movement at the time. We managed to ensure equal access and choice for e end users with disabilities. The problem was again that the implementation of this directive differs, broadly across Europe and its countries. Implemented or interpreted this article very differently.
So, we still lack of interoperability. This is very important. We don’t have a harmonized approach on the services that could actually make the telephony services and emergency services accessible for persons with disabilities. Even though the sectorial legislation was good at that time and had what we wanted, it was not ensuring a harmonized approach and interoperability of the services across Europe. We saw and Wouter also presented in his presentation, different initiatives in different countries like an app here to contact 112. An initiative to support deafblind users. And provide them with equipment. There were different possibilities for member states to interpret this directive.
I don’t want to get into too many details. I want to talk about what we are advocating for now in the electronic communications code. We want to ensure the equal access and choice is respected. We still have that success that we achieved in 2009 in the legislation. We want to ensure there is availability and interoperability of total conversation. Now the Commission is proposing that voice communication will be one of the universal services. That’s very good. Because with that you can have affordability measures. If this is a universal service, even though you live in a rural area and cannot afford it there should be at national level to support it and you enjoy that universal service. Voice communication is not the only way to communicate. There is also text communicationt and sign language communication. And that’s why I really liked as well Markku’s presentation. We need to ensure total conversation. The combination of realtime text, voice and video in the same call. Of course, in the electronic communication’s code we can still ensure the provision and affordability of the assistive technology that is needed for some people with disabilities. And we also need to ensure that this, interpreting services, relay services are under the universal services obligations. If this is our right, the service that we all should enjoy, if I want to communicate with a deaf person or a deaf person wants to communicate with me those should be available as well. The relay services in the country. 112 is also an important area. I will talk about in a moment in the accessibility act. Information about 112. Just to enter a little bit in the accessibility act. Here is the comparison or difference how can this legislations can complement each other. As you can see, the availability, affordability of the special equipment that we need should fall into the definition of a universal service, provided by the member states. This will need to be arranged at national level and you need to lobby your national governments. But the minimum set of accessibility features of meanstream products, smartphones, should fall into the accessibility act. As Ima explained, the Accessibility Act adopt a set of requirements. In standards that industry can use. A minimum we should ensure in the mainstream market. I explained about the availability and affordability of the services. In which we include video and text relay services. 112, we pushed for having the advanced mobile location in the 112. Meaning, when you call or text your 112 service, it will immediately locate you and will send your location to the emergency center. This could save a lot of lives. So we also supported this proposal.
I don’t know if I forget anything else.
I will go to the Accessibility Act. I don’t want you to get you too bored about policies.
The Accessibility Act, Ima explained the aspects of the act.
And I just want to give you a brief overlook on what is going on. What is the position of the different institutions. And I will focus on audiovisual services and telecommunication and electronic communications.
So, from the Parliament side, unfortunately as I said, we were really unlucky with the policitians we got in the directive.
They didn’t listen to us in the sense that they did not understand and we tried very hard, with our members, to explain that we still needed some accessibility requirements for audiovisual services. Because we want to make sure that subtitles will be taken on board. That audiodescription will be taken on board. Spoken subtitles taken on board. Sign language interpretation. The Parliament proposal was to restrict the application of the act to only websites and mobile apps. That’s it. Nothing else. That was unfortunate. The funny thing was, they did include tv’s, which was in the scope of the Commission proposal. But with vague accessibility requirements. I will show you in a moment.
On the contrary, for telephony and emergency services they did well. They ensured that smartphones will support realtime text and total conversation. Perfect. And the service providers, meaning the network operators and the emergency communication as well, will support realtime text and total conversation. Fine.
But what’s the problem with the accessibility requirements? Why we were so picky and pushy on having comprehensive, sector specific requirements. Before if we only use functional performance criteria, then we will not be ensuring that the devices and service will have the feature that we are expecting.
So, I would read it if I can.
Usage with limited hearing. Where the product provides auditory modes of operation, it shall provide at least one mode of operation with enhanced audio features. What does it mean? Does it mean the device will be interoperable with assistive devices?
Will this mean that the device will have features such as high audio quality? High quality audio. We don’t know. That’s why we pushed when we discussed with the EU institutions, for having sector specific requirements in the products and services that were important for us. That’s why we push for realtime text and total conversation in the telephony services. What about the Council? The Council did also exclude the audio visual content of the act. But they were, they are a bit more ambitious in the approach to those aspects around the audiovisual content. Not only include websites and mobile apps, but also all kinds of apps, that you can ownload in your tv. Also the settopboxes. The Epd’s. The Council text is a bit more ambitious than the parliament. For the audiovisual products, the tv’s, the Council did ensure users will be able to personalize the accessibility features that you want in your tv. Enlarge the subtitles, whatever you need.
On telephony services. They did cover the sector specific requirement that we were pushing for. Total conversation and realtime text. But, this is something that we will need to push the governments at national level. They exclude the emergency centers. What happens? This is a funny thing. They will ensure that the device will support realtime text. That the network operator will carry the realtime text, also through the 112 number. But then when your text reaches the emergency centers, they cannot respond. Because they excluded the emergency centers.
In this regard we said that we want at least member states to ensure that the appropriate centers, we don’t need to have them all, but at least the appropriate ones, depending on the population etc, will be able to receive the realtime text and be able to respond and handle the call. Otherwise the end to end accessibility and interoperability won’t be possible.
Telephony productss as I said, include this accessibility sector specific requirements. There was no explicit mention of compatibility with assistive listening technologies. This is something we need. There are requirements that could be maybe interpreted in this regard. We will also talk, now talking with different member states and stressing that explicit mention of these technologies will be very much needed.
There is my last slide. I just want to quickly go through or mention the 7 priorities that we have ahead of us in 2018 for the Accessibility Act.
Basically, the Council excluded public procurement and structural funds. We believe it is important the public administrations have a set of requirements that they can follow in public procurement. We are grateful that Microsoft and Digital Europe are also supporting us on this. We actually published a joint statement with them in this regard. We need public procurement to be included in the Act.
Built environment. This is important for the members. The built environment, and for you as well. The built invironment should be included. What is the point for an ATM to be accessible if you can’t enter the bank. Micro enterprises were excluded completely in the Parliament. Don’t ask me why. In the Council they excluded micro enterprises for services. Our goal is to include it all. If they cannot afford accessibility, they will also have article 12.
On disproportionate burden. Self service terminals were restricted in the Council’s text. Emergency centers. Transport services in the Parliament’s position is well covered. Whereas in the Council is not great. Very vague.
And it doesn’t cover urban modes of transport, which is very important for all of us in everyday life. And audio visual services as I explained.
My take away for you would be, now we need really to contact our ministries, to try to convince them to be open to rediscuss some aspects of the Accessibility Act. And try to make sure that we, as I explained at the beginning, we have end to end accessibility in technologies. And the products and services in the Accessibility Act. Sorry, this has been a lot of information. I’ll be happy to answer any questions you have. Thank you very much. (applause)
Mark: Thank you very much, Alejandro.
We have had some incredibly beneficial and informative presentations.