Select Committee on Culture, Media and Sport Appendices to the Minutes of Evidence



APPENDIX 13


Memorandum submitted by the RNID

INTRODUCTION

About RNID

  RNID is the largest charity representing the 8.7 million deaf and hard of hearing people in the UK. As a membership charity, we aim to achieve a radically better quality of life for deaf and hard of hearing people. We do this by campaigning and lobbying vigorously, by raising awareness of deafness and hearing loss, by providing services and through social, medical and technical research.

Key response and recommendations

  1.  RNID welcomes the proposal for subtitling and signing to be in the first tier of broadcasting regulation under OFCOM. This will mean that subtitling regulations and targets for digital terrestrial television will be extended to cable and satellite channels.

  2.  RNID also welcomes the DCMS Review of the Statutory Requirements for the Provision of Subtitling, Sign Language and Audio Description Services (publishing on 29 January 2001), which extends subtitling targets on digital terrestrial television (DTT) from 50 per cent to 80 per cent by the tenth anniversary of the start of the DTT service.

  3.  It also welcomes the recommendation that these targets are extended to cable and satellite. This will ensure greater consistency in the regulation and provision of subtitling on digital TV, and make a real difference to the everyday lives of millions of deaf and hard of hearing people.

  4.  RNID calls for legislation to establish the principle of price equality between basic telephone terminal equipment needed by disabled people to access telephone services and a standard voice telephone.

  5.  RNID welcomes the proposal for a consumer panel and calls for full deaf and hard of hearing representation on it.

1.  VISION AND OBJECTIVES

  RNID welcomes the Government's firm commitment to universal access to high quality services and networks. RNID is committed to ensuring that the communications revolution has a positive impact on the lives of 8.7 million people[13] in the UK who are deaf or hard of hearing, and believes that many of the White Paper proposals go a long way towards helping to realise this vision. This response also highlights shortfalls in the White Paper, which could prevent universal access, particularly in relation to telecommunications.

  RNID believes that the proposed new regulatory framework will help to ensure that deaf and hard of hearing people will be at the heart of the broadcasting revolution and supports the following White Paper proposals:

    —  Subtitling and signing in first tier of regulation, ensuring all TV channels, including cable and satellite, have statutory obligations to provide these services. This will ensure a level playing field in the regulation of subtitling regulation. The revised target of 80 per cent subtitling on all digital channels[14] is a major improvement from 50 per cent, but to ensure equal access all broadcasters should aim to subtitle 100 per cent of output over 10 years—a target to which the BBC has already committed.

    —  The creation of a new representative consumers panel to advise OFCOM. Five million people use subtitles regularly, one million of whom depend on them[15]. Approximately two million people use hearing aids and therefore need telephones designed to be compatible with hearing aids; at least a further three million people do not use hearing aids but need adjustable amplification built into phones. More than 400,000 people do not have enough hearing to be able to use a voice telephone even with amplification, and therefore require facilities for text communication equivalent to voice telephony. It is essential that their views and concerns over access to broadcasting and telecommunications are integrated into ongoing and future developments in communications, by ensuring that they are fully represented on the panel.

  1.3.4  RNID acknowledges that "New technology, generational change and shifting consumer preferences are the key underlying drivers of the major changes [in the telecommunications industry]", but believes that market forces alone will not guarantee deaf and hard of hearing people equal access to telecommunications. There is a huge demand from the UK's 8.7 million deaf and hard of hearing people for industry to provide better and cheaper services and networks, but industry is failing to invest in the development of these products. Access should be built in at the design stage for new products and services. This is consistent with the Disability Discrimination Act which requires service providers to make "reasonable adjustments" to ensure that goods and services are accessible to all disabled people.

Recommendation

  RNID urges the Government to give OFCOM powers to take specific measures to ensure that disabled users, including deaf and hard of hearing people, have equal—and equally affordable—access to all telecommunications services that are used by the majority and are essential to full social and economic inclusion. For deaf and hard of hearing people this must include availability of equally affordable fixed-line and mobile phones that are compatible with hearing aids and have adjustable amplification, and availability of equally affordable text communication. This must include text equivalents of all voice message services on the networks. The cheapest text telephone is still about 10 times as expensive as a basic voice phone.

2.  CREATING A DYNAMIC ENVIRONMENT

2.6  Electronic Programme Guides

  It is important that these indicate whether a subtitling or signed service is available. RNID recommends new symbols for subtitling and signing be produced for promoting these services that correlate to a dedicated button on the digital receiver. This will make it easier for deaf and hard of hearing people to access these services, whilst also helping to promote these services to potential new users. RNID research has indicated that a considerable number of deaf and hard of hearing people—particularly those aged over 75—do not know how to access subtitling services. [16]

3.  ENSURING UNIVERSAL ACCESS

3.3  Access to Television

  RNID research indicates that 24 per cent of deaf and hard of hearing people currently subscribe to satellite or digital TV channels, and that a further 20 per cent are considering subscription. [17]When compared to latest research by ICM, this indicates that deaf and hard of hearing people currently subscribe to cable and satellite channels at half the rate of the general population (45 per cent). [18]This is largely due to the inaccessibility of the digital channels, which are failing to attract deaf and hard of hearing viewers because of their failure to provide an acceptable subtitling service. The provision and accessibility of subtitles and signing on all digital TV channels is the key to ensuring deaf and hard of hearing people can access digital TV.

3.3.3  Recommendation

  The increase in subtitling targets from 50 per cent to 80 per cent in the recent DCMS Review[19] will considerably help to ensure that deaf and hard of hearing people have greater access to digital TV by the time of analogue switch-off. Future reviews need to be built into the Communications legislative process to ensure that the views of deaf and hard of hearing people continue to be taken into account as we move towards analogue switchover.

3.7  Access to Telephone Services

  RNID does not believe that there are adequate guarantees in the White Paper "to ensure that those telephone services which are used by the majority, and are essential to full social and economic inclusion, are made available to everybody on reasonable request, at an affordable price".

  The cost of terminal equipment used by deaf and hard of hearing people, in particular textphones and videophones is significantly higher than for a standard telephone. Access to telephone services is denied, if the equipment is required to connect to the network is unaffordable.

  Mobile telephone services are also not accessible to many deaf and hard of hearing people. Two million people use hearing aids yet the majority is unable to use digital mobile telephones because of radio frequency interference. In addition, over 400,000 people are unable to use a voice telephone, even with amplification. For this group, only Short Messaging Service (SMS) is accessible to those who want an affordable form of mobile communication. Interactive real-time text communication, compatible with fixed line textphones, functions poorly or not at all over mobile networks and requires a high cost keyboard handset.

  3.7.1  There are no obligations, existing or planned, that provide a safety net for disabled people who require special equipment to access telephone services. Those on low incomes in particular are consigned to live in a communication ghetto, excluded from the services used by the majority, leading to social and economic isolation.

Recommendation

  RNID calls for legislation to establish the principle of price equality between basic telephone terminal equipment needed by disabled people to access telephone services and a standard voice telephone. This could be achieved in practice through extension of universal service obligations or introduction of a universal service fund.

3.8  Access to the Internet

  The Internet is a powerful communications tool for deaf and hard of hearing people, Not only is it a great leveller between deaf, hard of hearing and hearing people, it also offers improved opportunities for deaf and hard of hearing people to be fully included in society through equal access to information and services.

  RNID is therefore very encouraged by the Government's commitment to universal access to the Internet by 2005. RNID research indicates that 29 per cent of deaf and hard of hearing people currently use the Internet and 33 per cent currently use e-mail systems. This is considerably lower than that of the general population—ICM polling shows that 49 per cent of the population currently access the Internet[20]. Of those who are deaf and hard of hearing, 90 per cent said they access the Internet at home, 25 per cent at work and 7 per cent in public spaces[21]. This is partly due to the fact that many hard of hearing people are of retirement age, whilst the majority of Internet users are aged under 35.

  3.8.1  To ensure full access to deaf and hard of hearing people to the Internet via mobile connections, it is important that there is full convergence between telephone and Internet systems for deaf and hard of hearing people. One manifestation of this is compatibility between communications equipment and digital hearing aids.

  RNID made the recommendation during the last consultation that there should be low cost unmetered access for deaf and hard of hearing people to ensure that access is not denied on the basis of cost. 61 per cent of deaf and hard of hearing people surveyed by RNID said they would be more likely to use the Internet if there were a reduced or cheaper rate. Internet rates are the most important determinant of Internet use—higher than training (50 per cent), cheaper computer hardware (36 per cent) and wider availability of the Internet at public places (20 per cent). However, the cost of access is being left to the market to determine, and whilst RNID recognises that the cost of Internet access and access devices has also fallen, more radical steps need to be taken to implement unmetered access. Given that the majority of deaf and hard of hearing people access the Internet from home, this point is all the more salient and RNID urges the Government to adopt this recommendation in the proposed legislation.

3.10  Supporting Individuals in using the New Communications Technologies

  Fifty per cent of deaf and hard of hearing people surveyed by RNID said they want training in how to access the Internet. RNID welcomes the Government initiative to provide education and training programmes.

Recommendation

  In order to ensure 100 per cent access by deaf and hard of hearing people by 2005, specialised training programmes will need to be developed, particularly for those whose first language is British Sign Language. RNID is working with deaf and hard of hearing people to develop such training packages, and is happy to work with Government and learndirect to ensure that all training programmes are accessible to deaf and hard of hearing people.

4.  MAINTAINING DIVERSITY AND PLURALITY

  4.4.7  The Cultural Diversity Network—RNID believes that this is a welcome new initiative. In particular, this initiative could be important to help ensure that broadcasters are more aware of the language and culture of deaf British Sign Language users in the UK.

5.  SECURING QUALITY

5.4  A Flexible, Consistent Regulatory Framework

  RNID believes the proposed three-tier structure of regulation helps to create a level playing field in broadcasting, whilst also allowing for flexibility.

  5.6.2  The inclusion of subtitling and signing in the first tier of regulation, applying to all broadcasters—terrestrial, cable and satellite—is a major breakthrough for all deaf and hard of hearing people, and RNID particularly welcomes this initiative. The increase of subtitling targets from 50 per cent to 80 per cent on DTT services by the tenth anniversary of the start of the DTT service (as recommended in the January 2001 DCMS Review) makes the vision of accessible digital broadcasting for deaf and hard of hearing people a much closer reality.

  Public support by deaf and hard of hearing people for a level playing field in the regulation of subtitling is overwhelming and has been demonstrated by the RNID subtitling campaign. Tens of thousands of deaf and hard of hearing people, and other supporters, have sent RNID postcards to their Members of Parliament, calling for this regulation of subtitles. Over 150 MPs have since pledged their support for this campaign.

5.9  Broadcast Material on the Internet and via Telephony:

  Broadcast material on the Internet or via telephony should be subject to the same subtitling regulations as those in 5.6.2. Of particular concern is the growth of sites with only audio-format delivery. OFCOM must ensure that the flexibility of the new regulatory regime adopts standards that combine regulations such as subtitling and text versions of broadcast, video and audio transmissions and those recommended by the Web Access Initiative (WAI).

  5.11.3  Digital radio has the potential to provide greater access to radio for deaf and hard of hearing people. Hearing aid users, people who are hard of hearing and people with mild hearing loss find that background noise and sounds on radio programmes makes it impossible for them to enjoy or understand programmes. This is particularly an issue on Radio 4 and other speech based broadcasting, for radio plays and information programmes where voices can be masked by "sound effects". As well as offering the opportunity for clearer transmission, digital radio could, given the number of channels available, offer a simultaneous broadcast of programmes without the background sounds.

  Digital radio also provides the opportunity for deaf people to follow the radio for the first time ever, through the transmission of text messages and pictures. RNID agrees that the best regulatory approach is to retain flexibility until such time as there is a critical audience mass for switchover to a digital system.

6.  SAFEGUARDING THE INTERESTS OF CITIZENS

  6.8.2  Within the proposed regulation of advertising by OFCOM, RNID recommends that standards be set to ensure that all advertisers subtitle their programme content. It costs less than £500 to subtitle one advert, whilst the cost benefit is huge in terms of the potential additional viewers/consumers if the advert is subtitled.

Recommendation

  In the last year, a number of mainstream films have been released with subtitled versions available at a limited number of cinemas. RNID warmly welcomes this initiative, and urges it to be further developed. It is vital that the addition of subtitles to cinema films does not create a need for films to be resubmitted to the BBFC for classification as this presents a significant hindrance to the future development, production and distribution of mainstream subtitled films, We would urge a solution to be found to avoid the need for subtitled versions of a film having to be resubmitted to the BBFC. One possible solution would be for the film and written script to be submitted at the initial stage.

  6.11.3  Recommendation: Videos, DVDs and computer games—RNID recommends that statutory targets are set to guarantee subtitling of at least 75 per cent of all new videos and DVDs.

7.  PROTECTING THE INTERESTS OF CONSUMERS

7.3  ACTION ON SERVICE DELIVERY

  RNID joins Government in challenging industry to come forward, before legislation, with effective codes of practice for service delivery. RNID has consulted all major broadcasters over the last two years over the way forward for a better subtitling service for deaf and hard of hearing viewers. Their response has shown that they favour a statutory rather than voluntary approach, which has been adopted in the regulatory proposals of the White Paper.

Recommendation

  RNID urges all broadcasters—particularly cable and satellite—to take action now in implementing these proposals so that they can build their audience viewing figures amongst deaf and hard of hearing people, rather than wait for legislation to come into force. RNID is keen to work with broadcasters to help raise awareness of new subtitling services available to deaf and hard of hearing people.

  7.3.2  Many deaf and hard of hearing people have subscribed to digital cable and satellite channels because they have been misinformed about their level of subtitling provision.

Recommendation

  RNID calls for pre-contractual information from all broadcasters about the real levels of subtitling offered on each channel.

7.5  Consumer Representation

  RNID seeks a guarantee that deaf and hard of hearing people will be fully represented on the consumer panel. This is important given that there are 8.7 million deaf and hard of hearing people in the UK, and given that part of the remit of the panel will be to incorporate the views of consumers with special needs and disabilities.

7.6  Access for People with Disabilities

  7.6.1  RNID supports the view that "Access to communication services often poses particular difficulties for people with disabilities, even though such services may be more important to them than the population at large." However, existing legislation places only general duties on regulators and existing regulations do not cover all important terminal equipment or mobile telecommunications services. The stated intention of carrying forward existing provisions into the future regulatory framework is disappointing and inadequate.

  It is vital that a holistic approach is taken to ensure access to communication services for people with disabilities, without artificial demarcations. For example, provisions covering text communication should span fixed and mobile networks, and communication services should include the handset or terminal equipment. Access, in regulatory terms, should start from the individual seeking to communicate rather than a socket in the wall.

  7.6.2  RNID believes that the Government has taken important steps towards ensuring that deaf and hard of hearing people have equal access to television services, through the proposed new regulatory system whereby subtitling and signing will come under the first tier of regulation, which is applicable to all channels. It is also key that subtitling targets for digital terrestrial channels are extended to cable and satellite through the proposed new regulatory system, from 50 per cent to 80 per cent (by the tenth anniversary of the start of the service).

Recommendation

  However, RNID is concerned that Government "efforts to raise awareness of the needs of people with disabilities across the whole communications industry" does not go far enough to secure equal access to telecommunications for deaf and hard of hearing people. OFCOM should be given the powers to ensure, through regulation, equal access to rapidly developing telecommunications services—that are set to become universal—by obliging telecommunications companies to adopt inclusive design principles at the outset.

  7.6.3  RNID welcomes the Web Accessibility Initiative (WAI) and the guidance on website design that this offers.

7.8  Digital Standards

  Text telephony was developed for use by deaf people over 50 years ago and the core technology still has its roots in that era. As communication technology has developed, such text telephony systems have been left behind and ignored with no modern equivalent introduced. As a result, Internet Protocols, data communications, mobile standards and even text messaging systems such as SMS are all incompatible with the systems on which deaf people rely. As technologies converge, the obsolescence will increase leaving text telephony to become an expensive legacy system, with extremely limited functionality and compatibility, compared to mainstream contemporary communication systems.

Recommendation

  The interests of all customers will not be protected unless the "encouragement" of interoperability of communications equipment is backed by a mandatory requirement to guarantee compatibility with the special equipment and systems used by disabled people. OFCOM should encourage development of new standards and systems that harness new technologies for the benefit of disabled people. Committed application of inclusive design principles will ultimately reduce the need for special equipment, reduce cost and automatically ensure compatibility.

  1. THE NEW ORGANISATIONAL FRAMEWORK

8.9  Powers of OFCOM

  RNID welcomes the proposed creation of OFCOM as an important step towards establishing a level playing field in the regulation of subtitling and signing on TV.

Recommendation

  RNID would also urge the Government to ensure that OFCOM has the authority and remit to run spot checks on the level and quality of subtitled and signed output to ensure that broadcasters meet their targets and quality standards. This will help to enable OFCOM to carry out its enforcement powers over subtitling and signing on TV.

February 2001


13   MRC National Study of Hearing (Davis 1995). Back

14   DCMS Review of the Statutory Requirements for the Provision of Subtitling, Sign Language and Audio Description Services (January 2001). Back

15   Based on independent research by NOP and Broadcasting Audience Research Board (1999). Back

16   Subtitling for Deaf and Hard of Hearing People. RNID (June 1999). Back

17   RNID survey of over 3,000 deaf and hard of hearing members and RNID Typetalk Users (January 2001). Back

18   Guardian/ICM opinion poll (19-21 January 2001). Back

19   DCMS Review of the Statutory Requirements for the Provision of Subtitling. Sign Language and Audio Description Services (January 2001). Back

20   Guardian/ICM opinion poll (19-21 January 2001). Back

21   RNID survey of over 3,000 deaf and hard of hearing members and RNID Typetalk Users (January 2001). Back


 
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