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Telecommunications Services: Access by Disabled People



1. Introduction

A number of organisations which represent the interests of disabled and elderly people in the UK are concerned at the lack of progress in making services more accessible. There are still many barriers that hinder access to telecommunication services by these users. These barriers frequently arise because a narrow view of consumer needs has been taken at the planning stage of products and networks. It is often difficult and expensive to rectify matters at a later date, when it has to be done due to pressures of altered market forces and anti-discrimination legislation. It is therefore most important to discuss these issues now, when wide-ranging changes in the structure of European telecommunications are being introduced. The introduction of 3G mobile services, the forward planning of 4G, convergence of the electronic communication technologies and the adoption of new Directives to facilitate the next stages of liberalisation all combine to produce an opportunity that, for the benefit of both providers and consumers, must not be missed.

For people who are disabled, barriers to telecommunications access may arise in the terminal equipment, in the network, or in both. The distinction between networks and terminals that was brought about in the previous stages of liberalisation makes it harder to resolve problems. In producing this paper, the authors ask that the matter be put to TCAM with the following objectives;

  • to enable discussion of the broader aspects of inaccessibility,
  • to identify any action in respect of terminals that might be taken under Article 3.3 of the RTTE Directive, and
  • to refer the issues that remain to appropriate sections of the Commission.


2. What is the Problem?

Although it has brought spectacular advances, liberalisation has also created very significant problems for users whose needs fall outside the mainstream market. Separation of networks from terminals means that there is no single responsibility for ensuring the end-to-end functionality by which users measure the quality of their service. The terminal is useless without the network, and vice versa. Disabled people in particular often require specific features simply to access basic telecommunication services. These features will vary according to the nature and extent of the disability and may be in the networks, or in the terminals, or both. Network features can be mandated through universal service obligations, or by national legislation, if operators exclude them from their commercial offerings. There is no equivalent mechanism applying to the provision of terminals. This problem becomes most difficult when accessibility is dependent upon corresponding features in both the network and the terminal. Neither operators nor equipment manufacturers will initiate action without a matching response from the other party, and there is no mechanism apart from commercial collaboration that would make them do so.


3. What has been promised?

Community policy statements on present and future electronic communications services have set out very clearly the principles of a barrier-free Europe. They speak of guaranteed access for all to electronic communications, of services available to all European citizens, and of avoiding division of the new Information Society into 'haves' and 'have nots'. These aims may be aspirational and not intended for immediate delivery, but disabled people - who often find themselves in the position of the 'have nots' - read these statements and they wonder why so little is done to eliminate well-documented existing barriers to access. Their frustration with this situation is leading to demands for more specific anti-discrimination legislation, based perhaps on the USA model. They also look at the practical effects of recently enacted human rights legislation in re-defining the ways in which minority groups are treated. Confrontations of this kind, which may create serious difficulties for manufacturers and operators in the telecommunications sector, could be avoided if there was evidence of more progress in achieving the EU policy aims. The industry could help by paying heed to the voices of its consumers and showing that it understands their problems, even if solving them takes a little longer.


4. Are Disabled People different?

Every European citizen is likely to be disabled at some time or other. Illness or accident can result in disability, which may be temporary or permanent. The process of ageing brings various impairments of function which often lead to permanent disability. The increase in the numbers of older people in Europe's population has emphasised the importance of viewing disability within the mainstream, and not as a fringe issue. To those who have experienced it from infancy or youth, disability is the normal state and not a barrier to participating actively in the life of the community. Others in the community may create barriers which exclude disabled people, but this can be corrected with proper understanding. Those who acquired disabilities later in life have also learned the value of asserting their independence. Even in their determination to press for respect and dignity, disabled people are behaving exactly as the rest of the population. Their numbers are very large and it makes no sense, commercially or socially, to disregard them.


5. Access to basic telecommunications services

Present and proposed EU Directives define a set of basic services that should be available to all users, either as users' rights to be observed by all operators or through the universal service obligations placed upon designated service providers. These basic services are, in practice, described in relation to a technology which has evolved from the 'plain old telephone system' (POTS), in which the fundamental modality was voice Telephony. Many people find this a curiously old-fashioned way of thinking in an age when data transmission is at least as important as voice Telephony, and convergence of communications technologies is causing networks to operate in multiple modes. The user to user real-time conversation which is the historic traffic of the POTS is no longer exclusively conducted with voice. In future, the expansion of broad-band services will make multi-media communication commonplace. Then, those people for whom voice is not their normal mode of face-to-face conversation will be enabled to use gesture (signing) or lip-reading, as well as text. They will have the opportunity as well as the expectation to use the telecommunications networks in a modality chosen by themselves - not by the operators. For the present, the necessity to define the 'native' modes of telecommunication networks is becoming apparent, so that users may know to which services they have an entitlement.

Defining 'native' modes which extend beyond voice cannot be separated from the issue of terminal equipment function. As soon as text or any other non-voice modality is enabled, the parameters applicable to the terminal need to be defined before the user can access any network services in these modes.


6. Problems faced by disabled users

The problems that disabled people experience in using telecommunications services are diverse, because disability is diverse. There may be problems in using the terminal, and problems in obtaining connections across the network. Problems with terminals include inability to see the markings and displays, inability to hear the ringer or the received speech, and inability to handle the instrument and its controls. All of these can be resolved, or at least lessened, with suitably designed terminal equipment. Frequently, however, no suitably designed equipment is available. This situation can be viewed as a failure of the market that would justify regulatory intervention. There are difficulties in defining the form of regulatory action that would be effective in these cases (see section 7), but that does not excuse inaction.

Problems in obtaining connections across the network frequently involve the terminal to some extent. For example, 'timing out' of dialling - because the user dials slowly due to memory or dexterity difficulties - can be overcome by having a buffer facility in the terminal. Network tone signals can be converted at the terminal to visual indications, for profoundly deaf users, although this cannot be done for spoken call progress announcements. Basic services on the POTS network can be accessed only by voice, so deaf people using text telephones need assistance from a third party in order to reach facilities which are part of the rights of every user. In the UK, British telecom has introduced its Text Direct service, which is responsive to text telephones once the user has dialled in to the facility. This has eased many of the difficulties encountered by this group of users, but this manual entry to a special service is necessary because the general networks cannot identify the presence of a text telephone on the line. This is a further instance where terminal characteristics and network services need to be considered together.

The area of added value services brings problems which effectively rule out these offerings for many disabled users. Typically each service is presented either in an audio mode or a visual one, without the user having the option to select. Some information can be converted at the terminal, for example CLI, but conversion from speech to text is much more difficult. These problems are likely to get worse as added value services develop.


7. Solutions that are exclusively RTTE matters

As shown in the previous section, the solutions to many accessibility problems require linked action associated with both the network and the terminals. Cross-sector action of this kind, although very necessary, requires special consideration and this needs to be put in hand without delay. Also, regulation under a Single Market Directive cannot lead to a situation where all terminals are suited to the needs of all users, for the diversity of needs is too great. An onus must rest upon the subscriber, as the person responsible for the installation outward of the NTP, for the selection and siting of terminals that are suited to the needs of the occupants of the premises. In disclaiming their own responsibilities in this respect, network operators and equipment manufacturers should provide as much information about accessibility as is reasonably possible to subscribers and purchasers, to facilitate informed choice. Additional mandatory requirements applied to terminal equipment under Article 3.3 will help in some particular instances, but they do not and cannot go far enough to address the great diversity of accessibility features needed to accommodate all forms of disability.

Three proposals for Article 3.3 action follow, relating to keypad layout, text telephone protocols and functioning of terminal equipment during periods of mains failure.

Keypad Layout

Use of a standard keypad layout, with the tactile identifier on the '5' key, ought to be mandatory in the interests of users with visual impairment. Given that the computer and telecommunications sectors are in the process of converging, the presence of divergent sector standards for keypad layout is a very serious embarrassment. If agreement on a single standard is not in prospect, then an additional tactile marking is needed to identify the version to visually-impaired users.

Text Telephone Protocols

Inter-working of text telephones is hampered by the variety of transmission protocols in use. At least 5 different systems are found in Europe. Difficulties arise with calls between Member States with differing local preferences, and text telephone users who travel in Europe may find that they cannot connect to relay services or make emergency calls. The ITU V18 protocol overcomes this difficulty without rendering the installed base of equipment obsolete. V18 terminals will select a default mode from several commonly used protocols, so that messaging proceeds using a mode that both terminals can recognise. An article 3.3 Essential Requirement that called for Text telephones to utilise the appropriate ITU transmission protocol would be a simple but effective measure. A regulatory definition of 'Text' suitable for this purpose is already available.

Mains Failure

Failure of the mains power supply, for example in adverse weather conditions, is a statistically predictable occurrence which, in a prolonged event, raises user dependence upon the telecommunications services in order to summon help. Users who are elderly, disabled or otherwise vulnerable will be at increased risk during an extended power failure and an inability to make even an emergency call can turn a distressing situation into a life-threatening one. Network operators go to considerable lengths to maintain service integrity whenever the public power supply fails and the conditions which caused the power failure do not necessarily interrupt telecommunications. This integrity is degraded - in terms of end-to-end operability - if the user's terminal cannot maintain a basic service without mains power. Users may not know, or may forget, that some types of terminal equipment will totally cease to function whenever the mains power supply fails. These terminals should be regarded as unreliable for use in emergencies, and should be identified as such.


8. Discrimination

Where there is a choice of modalities supported by a network, not all users will have that full range of choice. Some will have their choice restricted, for example, as a result of disabilities that effectively close off some options. Their restriction in choice is unfortunate, but recognised as inevitable. However, it is vital that the choices which are open do not exclude any of the basic services. Exclusion of that kind would be viewed as discrimination, in that a lower standard of service would be offered to people with disabilities. With the strong expectation of anti-discrimination legislation being extended in the EU, in line with the Community's declared policies, Member States as well as service providers will need to consider their position on these issues.


9. Conclusion

This paper has outlined problems which limit disabled users' access to services and can put service providers at risk of failing to meet legal obligations. Particular cases have been identified related to terminals, which could be addressed through the mechanisms of the RTTE Directive. It is not the purpose of this paper to propose detailed measures, but rather to initiate discussion aimed at resolving known problems and preventing future ones. This seems to be an appropriate time to ask TCAM to establish an Ad Hoc Group to consider the subject further. The Ad Hoc Groups on R&TTE-D Implementation, and in particular Ad Hoc Group D (Essential Requirements & User Information) would seem to be convenient models. There is unfinished business (particularly in respect of use of text terminals) from these earlier Ad Hoc Group Reports which TCAM could usefully return to. The contributors to the present paper express a strong wish that TCAM will act upon these suggestions. They confirm that they are willing to assist with help and advice in support of the objectives, which are:

  • to enable discussion of the broader aspects of inaccessibility,
  • to identify any action in respect of terminals that might be taken under Article 3.3 of the RTTE Directive, and
  • to refer the issues that remain to appropriate sections of the Commission.


Document status: REVISED VERSION 2 - 25 September 2001

Address for comments: Tony Shipley, on behalf of PhoneAbility/RNIB

Email: adcshipley@aol.com


ANNEX

UK ORGANISATIONS CONTRIBUTING TO THIS PAPER


DIEL

DIEL is an independent advisory committee established by Act of Parliament to advise Oftel, the telecoms industry regulator, on the interests and needs of consumers who happen to be either disabled or elderly, or both. Most members are themselves disabled or over age 60.


PhoneAbility

PhoneAbility is the independent UK focal point for telecommunications and the needs of disabled and elderly people. The group acts as a catalyst in this area by organising conferences and seminars on telecommunications and disability. It also acts as the UK reference group to the European project COST219bis.


RNIB

The Royal National Institute for Blind People (RNIB) is one of the UK's biggest and most diverse charities. It provides over 60 different services for over 2 million people with serious sight problems throughout the country, and lobbies on their behalf in the UK and with European organisations. It is an active participant in the development and application of Information and Communication Technologies (ICT).


TAG

The telecommunications Action Group (TAG) is an umbrella organisation of the main national voluntary organisations concerned with telecommunications and deaf, deafened, hard of hearing and deafblind people. It aims to arrive at a consensus viewpoint of deaf people to put to Government, Oftel, telecoms companies, local authorities and others.

 



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