Can accessibility be left to the marketplace?
Written by Mark Magennis Friday, 19 June 2009
Our recent experiences lobbying for the accessibility of Digital Terrestrial Television (DTT) after analogue switch-off in 2012 have raised questions of who is responsible for ensuring digital accessibility and digital inclusion. These questions have implications beyond DTT, for e-government, education and the information society as a whole.
The DTT issue has come up in discussions between the TV Access coalition and RTÉ concerning the minimum receiver requirements (PDF, 340Kb) for digital terrestrial television (DTT). The intention of RTÉ is to lay down an appropriate minimum functional standard for digital set top boxes.
However, this minimum standard doesn’t include much in the way of accessibility requirements. The only nod in the direction of accessibility is the requirement to provide access to subtitles via a dedicated button on the remote control. This is welcome, but blind viewers will need set top boxes with access to audio description as well as subtitles and text-to-speech capability so they can navigate the menus and EPGs. Many viewers with physical impairments will need remote controls that can be used easily with one hand or by someone with reduced motor control. Viewers with low vision would like to able to change the size and colours of menus and other on-screen text so that they can read it.
None of these features are contained within the minimum receiver specification. RTÉ’s argument is that the Government wants public free-to-air television to remain as affordable as possible. If the minimum spec is set too high, it pushes up the price of a basic set top box. We agree with that, so our lobbying concerns those accessibility features that are low-cost or no-cost to implement. The fact that DTT boxes with audio description can be bought from Argos in the UK for under £15 is evidence of how cheap some of these features now are.
But essentially the minimum receiver specification is there to ensure that receivers are available with a minimum set of functionality. So where is the parallel mechanism that will ensure that receivers are available with accessibility features, even if these cost a little more to implement and therefore command a higher price? And whose responsibility is it to ensure that people with disabilities do not become excluded from television due to the unavailability of accessible equipment? The responses we’ve received from RTÉ indicate that neither they nor the Government see this as their responsibility. They are leaving it to “market forces” to provide accessible digital equipment to consumers.
Sure, lots of things can justly be left to market forces. We wouldn’t expect the Government to intervene to guarantee the availability of accessible power tools for example. So what’s wrong with leaving it to market forces to provide accessible TV?
Firstly, market forces do not have a good track record of delivering accessibility in mainstream technologies. The EC Communication on e-Inclusion (November 2007) reported that: “Lack of e-Accessibility persists in many countries ... Mass-market technologies and services often continue to ignore inclusive design/ design for all.”. A follow-up study in November 2008 recognised: “a market failure to deliver eAccessibility in Europe which is linked to insufficient development of obligations and incentives for the supply side.”.
Secondly, and more importantly, what this all boils down to in the end is social inclusion. Unlike access to power tools, access to television is essential for social inclusion and protecting social inclusion is an essential function of government. With DTT, we have a situation where the actions that our Government is taking in switching off analogue TV will force people to switch to digital. If this introduces accessibility barriers, then the Government is, effectively, acting to reduce social inclusion for people with disabilities.
The same argument applies to e-government services. As the government switches its services (tax, social welfare, local government services, etc.) to digital channels, people who are unable to access those channels will become increasingly disadvantaged and increasingly excluded. The argument extends to education, employment, transport and any other aspects of society that will become ‘digitised’. Digital technologies are changing the way we carry out many of the activities required to take part in society. The way we communicate, work, learn, access information and services. To be able to continue to participate in all these activities is essential for social inclusion and democracy. When new digital technologies come in and change the playing field, it is therefore essential that the Government puts in place measures to level that playing field, by opening up access to all, otherwise social exclusion will result. What those measures should be is a much bigger discussion. Legislation, regulation, education, direct funding and procurement policy are just a few examples that may have a role in different areas.
The main point is that digital accessibility is too important to leave to the marketplace. CFIT calls on Government to recognise the threats to social inclusion created by the increasing use of digital technologies and work to ensure an inclusive digital future for all citizens, including older people and people with disabilities.