Memorandum submitted by the 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
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
1. VISION AND
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
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
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 yearsa 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.
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.
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 equaland equally
affordableaccess 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
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 peopleparticularly those
aged over 75do not know how to access subtitling services.
3. ENSURING UNIVERSAL
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
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).
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.
The increase in subtitling targets from 50 per
cent to 80 per cent in the recent DCMS Review
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.
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
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
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 populationICM
polling shows that 49 per cent of the population currently access
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.
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 usehigher
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
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.
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
4.4.7 The Cultural Diversity NetworkRNID
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 broadcastersterrestrial,
cable and satelliteis 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
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
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
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.
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
6.11.3 Recommendation: Videos, DVDs and
computer gamesRNID recommends that statutory targets are
set to guarantee subtitling of at least 75 per cent of all new
videos and DVDs.
7.3 ACTION ON
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
RNID urges all broadcastersparticularly
cable and satelliteto 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.
RNID calls for pre-contractual information from
all broadcasters about the real levels of subtitling offered on
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
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).
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
servicesthat are set to become universalby 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
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.
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
- THE NEW
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.
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.
13 MRC National Study of Hearing (Davis 1995). Back
DCMS Review of the Statutory Requirements for the Provision of
Subtitling, Sign Language and Audio Description Services (January
Based on independent research by NOP and Broadcasting Audience
Research Board (1999). Back
Subtitling for Deaf and Hard of Hearing People. RNID (June 1999). Back
RNID survey of over 3,000 deaf and hard of hearing members and
RNID Typetalk Users (January 2001). Back
Guardian/ICM opinion poll (19-21 January 2001). Back
DCMS Review of the Statutory Requirements for the Provision of
Subtitling. Sign Language and Audio Description Services (January
Guardian/ICM opinion poll (19-21 January 2001). Back
RNID survey of over 3,000 deaf and hard of hearing members and
RNID Typetalk Users (January 2001). Back