Best Practice in Telecommunications for People with a - TEDICORE .rtf

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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 Advisor




                                    March 2002


                                                                                       1
                               CONTENTS



Executive Summary

Recommendations

Background

TEDICORE Best Practice Guidelines

1. Accessibility

2. Universal design

3. Network services

4. Additional equipment and services

5. The Internet

6. Prices

7. Consumer consultation

8. Promotion and information dissemination


References

List of acronyms and web sites

Appendix 1

                                       Appendix 2




                                                    2
 Best practice in telecommunications
for people with a disability in Australia


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.




                                                                                              3
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.

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.


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

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.


Principle 4


                                                                                                  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.

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.


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

11. 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&T-based assistive devices provided as needed through a federal government
            program and upgrades to equipment are provided upon application.

12. 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.

13. An Internet Access Allowance should be implemented.

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

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



                                                                                               5
16. 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.

17. 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.

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.


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.

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


                                                                                              6
print and electronic formats and be written in plain English.




                                                                7
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 Advisor, 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


                                                                                              8
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.




                                                                                          9
             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 USO is 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


                                                                                            10
      (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 USO can
benefit people with a disability. For example, Wilson and Goggin (1993, p. xii) stated that
universal service should include
"universal geographical availability
universal accessibility
universal affordability
universal technological standard
universal telecommunications and participation in society".

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,
TTYs 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 benefitted Deaf, hearing and speech impaired people.



                                                                                              11
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 is having a tremendous effect as major hardware and software companies have to
ensure that accessibility is now incorporated into their products in order to supply to the


                                                                                              12
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.

                                                                                             13
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 usable 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


                                                                                             14
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


                                                                                          15
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, TTYs 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 trialling of alternative technologies for TTY


                                                                                          16
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 TTYs
to meet their needs by Telstra. Telstra has the responsibility as the Universal Service


                                                                                             17
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 TTYs, 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.




                                                                                            18
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.




                                                                                          19
5. The Internet and related digital technologies are accessible,
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&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



                                                                                                 20
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:

(a) Creation of a pool of assistive devices to facilitate access in community-based centres.
This would be a national ongoing program and could be modeled 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.

(b) 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.

(c) 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.

(d) IT&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:

(a) 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.

(b) 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.

(c) 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 PCs and



                                                                                                 21
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&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&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:

    To  ensure that government web content is accessible.
    Strategies to ensure that Government funding of research projects includes provision
      for accessibility
    Development of a Federal Government procurement policy for IT&T products and
      services which includes accessibility (the current US Federal Government
      procurement policy could be used as a model)
    Close liaison with the Office of Disability to ensure that the Commonwealth Disability
      Strategy is adhered to with regard to IT and telecommunications
    Embedding the strategies for facilitating improved online access in a variety of life
      situations such as education and employment training and preparation programs by
      developing a close partnership between DCITA and DETYA to implement
      AccessAbility project results
    Information dissemination and coordination including assistance with documentation
      and publishing of AccessAbility project results such as training methodologies and
      incorporation of disability sessions in conferences such as the Communications
      Research Forum
    Promotion including best practice models and AccessAbility project results with the
      difference these projects have made to the lives of people with a disability
    Awareness-raising in IT&T industry for inclusive design
    Establishment of a Reference Group comprising government, industry and consumer
      representatives to further develop partnerships

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



                                                                                              22
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:

    Encourage   and fund future research into areas of IT &T and disability. This would
      include the hosting of regular workshops and conferences, and the development of
      research resources (such as the AccessAbility Database).
    Assess the marketability of new products and services, including (but not limited to)
      those arising from the research it sponsors.
    Provide long term loans and other partnership arrangements to enable the
      commercial development of those products and services deemed to be marketable.
    Receive income from these loans and partnerships to fund further research and
      cover its costs of operation.

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 usable 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


                                                                                               23
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:
        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&T-based assistive devices provided as needed through a federal government
            program and upgrades to equipment are provided upon application.

12. 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.

13. An Internet Access Allowance should be implemented.

14. A Government IT&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

                                                                                               24
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:
Need to use a more expensive carrier because that carrier offers equipment necessary to
  use the phone service or offers specialised services such as operator-assisted directory
  assistance
Additional repair and service costs for equipment
The number of SMS calls to make arrangements for a Deaf person when using a mobile
  phone and the consequent cost compared to a hearing person who chooses a voice call
  in such a situation.
The higher long-distance call costs due to the longer time taken to conduct a TTY to TTY
  call.


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.


                                                                                         25
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


                                                                                         26
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


                                                                                              27
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


                                                                                         28
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.




                                                                                       29
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/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. & Worrall, L. (2001) Internet training package for people with a communication
disability. University of Queensland, Brisbane.

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

Goggin, G. & 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. & Slegers, C. (2001) Deaf Australia Online II.
http://www.circit.rmit.edu.au/projects/dao2/index.html


                                                                                              30
Owens, J. & Communication Aid Users Society (2002) Accessible information for people
with speeech & 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. & Goggin, G. (1993) Reforming universal service: The future of consumer
access and equity in Australian telecommunications. Consumers' Telecommunications
Network, Sydney

Worrall, L., Egan, J. & 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


                                                                                           31
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.au/disability




                                                                                  32
Appendix 1

Extract from ACIF Guidelines (ACIF G586)




                                           33
1.1.1Because 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.


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


1.1.3Codes 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.


1.1.4Any 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.


1.1.5The 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.


1.1.6Customer 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.


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


1.1.8Customer 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



                                                                             34
                    impaired.

           1.1.9Carriers 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.”

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




                                                                                   35
Appendix 2

Key principles of proposed Disability Telecommunication
Program
The   new Program will be consumer-focussed

The   new Program will be consumer-managed

Consumer   experience will be used as the basis for telecommunications disability
  requirements. These requirements are based on what people with disabilities need to
  be able to function well when using telecommunications products and services

Equitableaccess to the Internet is considered an integral part of access to
  telecommunications and will be incorporated into the new Program

Peoplewith disabilities will be assured of equitable access to mobile telephony as this is
  now considered an essential component of telecommunications

User needs with regard to new telecommunications technologies will be taken into
  account and incorporated as required into the new Program

People with disabilities prefer that telecommunications products and services are based
  on the principles of inclusive design thus obviating the need for a large number of
  specialised products and services. However, when specialised products are needed,
  these should be compatible with and easily connected to mainstream products.

The  new Program will be based on principles of social justice from the Universal
  Declaration on Human Rights - 1948 and the United Nations Declaration on the Rights
  of Disabled Persons - 1975.

The new Program will adopt the Telecommunications Charter of COST 219bis, 1999
(Appendix 3) as general principles for improving equity and access in telecommunications
for people with disabilities.




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