Joint Committee on The Draft Communications Bill Appendices to the Minutes of Evidence


Memorandum submitted by The Royal National Institute of the Blind


  1.1  The Royal National Institute of the Blind represents the interests of 2 million blind and partially sighted people in the UK. The Draft Communications Bill is of vital importance to this hugely disadvantaged consumer group for upon it depends their future inclusion in the Information Society.

  1.2  Blind and partially sighted people form a highly significant stakeholder group for the new regulator in terms of numbers and needs. The number of people with sight problems is set to increase with the ageing of the general population. By 2031 at least 2.5 million people in the UK will be living with a sight problem. Ensuring the needs of this group are promoted and met by the regulator will benefit the interest of a wider group of consumers—the one in seven of the British public, for instance, who say they cannot easily read television captions.

  1.3  Digital TV, convergence and new communications technologies could bring huge advantages to this growing section of society. For example, the ability to shop, talk to a care worker, vote, check the TV listings, book a taxi, pay bills, or write to a relative through a digital television could revolutionise the lives of hundreds of thousands of citizens who are currently unable to easily undertake these tasks on their own without added cost. Yet, the enormous growth of screen based technologies threatens to deny blind and partially sighted people these benefits. Digital television and radio, EPGs, WAP mobile telephones, the Internet could all easily be made accessible to blind and partially sighted people but overwhelmingly are not. Future converging technologies will have even greater capacity for screens or other visual data output devices and therefore there will be an even greater danger that they will exclude people who have restricted sight.

  1.4  RNIB is extremely concerned that developments in digital broadcasting, radio and telecommunications are already leaving blind and partially sighted people out in the cold. A robust new regulatory and legislative framework is needed to counter this. Yet we can find little in the Draft Communications Bill to reassure us. This is all the more frustrating since there is so much that could be done, even in the face of rapid technological change, to use legislation and regulation to bring about vital social change.

  1.5  Our written evidence focuses on how the Bill might be strengthened to achieve the Government's stated objectives of broadening access to cultural and recreational resources through services such as audio description for blind and partially sighted people and delivering universal access to a choice of high quality services for all disabled people. It is vital the Joint Committee devotes some attention to the issues raised here, otherwise the Bill will simply not be fit for purpose.


The need for a primary objective: universal access

  2.1  We acknowledge that an attempt has been made to give OFCOM something approaching a reasonable general remit—for example, at least there is the suggestion of promoting customers interests as opposed to just protecting them and there is a subsidiary reference to having regard to the needs of disabled people. But the jumbled list of general, competing duties fails to hit the mark. The Government is wrong not to establish a hierarchy of priorities. Competition is never an end in itself it is only one of the means by which consumers gain better services and a flawed one at that.

  2.2  Of the Government's three original objectives outlined in the White Paper by far the most compelling was that of "ensuring universal access to a choice of diverse services of the highest quality". This we would submit should be the primary objective of the new regulator and indeed should be applied equally to the Secretary of State. It puts the consumer and citizen centre stage where they should be. Utilities legislation imposed a primary objective on both regulators and Ministers alike to look after the consumer, yet this Bill gives Government no steer at all on where its priorities should lie.

Serving the customer or the consumer?

  2.3  The use of the term "customer" as opposed to "consumer" in the first Part of the Bill and elsewhere is also worrying. Using the term consumer wherever possible would offer better protection to the rights of disabled end-users of communications services. In a household of more than one, only one person will be the "customer", the person named on the bill or the TV licence. Yet a disabled person in that household is no less entitled to priority fault repair, a bill in braille, text users' rebate, free directory enquiry service, etc for not being the "customer". Using the term consumer wherever possible would offer better protection to the rights of disabled end-users of communications services.

Inclusive Design and Access for Disabled People

  2.4  Furthermore the requirement to merely "have regard to" the needs of disabled people where it appears relevant is no guarantee at all that OFCOM will robustly challenge their growing exclusion. OFCOM should have duties to

    —  secure that inclusive design principles inform the development of all future digital communication technologies, facilities, services and equipment;

    —  promote the need for disability awareness and equality training throughout the communications industries; and

    —  secure that accessible communications services, equipment and facilities, including training and on-going support in their use, are made readily available to consumers who are disabled at no extra cost.

      2.5  Inclusive Design (also referred to as "Design for all" or "Universal design") ought to be a major driver of change in the new communications framework and yet there is no reference to it in the current Draft Bill or in the accompanying policy documents. It means in essence that all services and equipment should be designed taking the needs of disabled and older users right from the design phase. If this has not been done they should be adapted, where possible, to meet the required needs. In the cases where neither of these scenarios can be achieved, appropriate supplementary equipment and services should be proposed. Promoting disability awareness and equality training should happen in tandem with the promotion of inclusive design principles throughout the industries.

      2.6  OFCOM might also usefully be given a specific role in promoting Web Accessibility and the benefits of getting on line. The growth of the World Wide Web means that people with serious sight problems now have the opportunity to enjoy a wealth of information and services that was previously unavailable to them, from up-to-the-minute news and travel timetables to online shopping and banking. With the help of synthesised speech and braille display technology, even completely blind people can use the Web. For these access technologies to work properly, web pages must be appropriately designed and must be written in valid hypertext mark-up language (HTML). Many sites are unusable by visually impaired people simply because they are poorly designed and are written in invalid HTML. People with disabilities have as much of a right to be able to access websites as anyone else, but many designers fail to recognise this. The Web is an information medium, but too many web designers still think of it as a purely visual medium, and are unaware even that visually impaired people can access the web. Access to websites is covered by Part 3 of the Disability Discrimination Act, yet there remains a chronic lack of awareness on the part of service providers. OFCOM should work with the DRC and disability groups like RNIB to proactively raise awareness of and promote compliance with the Web Content Accessibility Guidelines (WCAG) published by the Web Accessibility Initiative (WAI).

      2.7  But promoting inclusive design is not enough on its own. It is one thing to design a universally accessible system or a piece of assistive technology and another thing to bring it to market. The case of the audio-description module developed by the Digital Network is a case in point. It works beautifully when inserted into a common interface slot. It delivers high quality reception of audio description. It is the gold standard. Only 45 households will have access to it because the broadcasters, the multiplex operators, the equipment providers and the government are not prepared to make the additional investment to mass-produce it. Also, it is essential that the audio description software is built into future receiving equipment so that an additional (costly) piece of equipment is not a permanent requirement. Likewise someone may yet develop a fully accessible, interactive mobile phone system, yet there would be nothing in the Bill to ensure it reaches its intended consumer group. Access to the Internet similarly depends on being able to afford the appropriate access technology.

      2.8  Hence the regulator must have a concomitant duty to ensure accessible services, equipment and facilities are made available. A further issue is the need to ensure training and ongoing support to disabled end-users is provided so that they are enabled to make the most of all digital developments.

      2.9  Such duties would we believe be entirely consistent with the "future proofing" requirement. The legislation should also impose similar duties upon the Secretary of State because Government must also offer political leadership here. We would also want conditions relating to access imposed through the new regulatory framework in Part 2 of the Bill. This will happen to an extent in respect of telecommunications but will not happen in respect of access to other communication technologies unless Parliament insists on it.

    Duty to promote equal treatment in employment for disabled people

      2.10  The omission of any duty to promote inclusive design or equal access to communications services for disabled people is all the more bizarre given that the Bill rightly concerns itself with promoting employment opportunities for disabled people in the broadcasting industry. Access to communications services is at least as essential to the employment prospects of disabled people as action to extend opportunities within one industry.

      2.11  That said, RNIB strongly welcomes the duties upon OFCOM to promote equal treatment for disabled people in broadcasting and the corresponding requirements to be placed on broadcasters through their licences. Positive action in relation to employment opportunities for disabled people is desperately needed to make inroads into what remain appalling and unacceptable levels of exclusion from the labour market. Disabled people in general are over twice as likely to be unemployed as those who are not disabled For blind and partially sighted people the situation is particularly acute. Every year 4,000 people leave work when they lose their sight. Of these around 25 per cent are quickly forced out of work even though most could continue to work with the right support, adjustments and commitment. Overall three out of four blind and partially sighted people are unemployed—a figure which has barely changed in ten years. At least 25 per cent of unemployed blind and partially sighted people would like to work if the opportunities and support systems were in place. One of the major barriers they face is employer attitudes with half of all employers say they will not employ someone who has "difficulty seeing".

      2.12  There are, of course, some examples of blind and partially sighted people forging successful careers in the TV and radio industries, albeit far too few. Progress here would not only contribute to wider employment opportunities for those we represent, it might also help ensure that tomorrow's communications policies are not as blinkered when it comes to access and inclusion for disabled people in relation to communications services and equipment as they are today.

    2.13  But the scale of disabled people's labour market exclusion is such that we believe the provisions must be taken further.

    —  First, both OFCOM's duty to promote fair treatment of disabled people and the licensing requirements only apply to the TV and radio industries. We strongly believe they should be applied to the telecommunications and Internet industries and work connected with those services too. There is no logical reason why these industries should be excluded, indeed it will create exactly the sort of regulatory gap the Bill is supposed to close.

    —  Second, the proposed thresholds in Clause 224 are not compatible with current Government policy to end discrimination against disabled people in employment and go against the principle of full and comprehensive civil rights. The Government rightly intends to abolish the small employer threshold in the DDA 1995 in line with the EU Directive on Equal Treatment in employment and occupation by 2004. Future civil rights legislation will allow coverage of both businesses with one employee and businesses seeking to recruit and hold their first employee. For the provisions in the Communications Bill to reinforce the notion that firms can discriminate below a certain threshold is nonsensical and not a message the Government should want to send out.

    —  Third, a job retention strategy for disabled employees should be required of the relevant industries—making available opportunities for retraining is a key part of that but so are a range of other policies such as time off for rehabilitation and to put "reasonable adjustments" in place in the workplace (ie a Disability Leave policy).

    —  Fourth, companies should be given a steer to raise awareness of the Access to Work Scheme for disabled employees while publicising their equal opportunities and training arrangements.

    —  Fifth, the principle of equal treatment of disabled people should be extended to disabled people seeking work experience. Companies should be required to show how they make the process of applying for work experience fully accessible to disabled applicants and demonstrate that they have the necessary policies and practices in place to properly support disabled people on work placements, especially since they may not be eligible for support through Access to Work. The EU Directive on Equal Treatment in Employment and Occupation specifies that vocational training should be covered by anti-discrimination legislation—OFCOM's duty and those of the broadcasters should mirror this.

  2.14  Finally, there is no reference to the need for OFCOM to collaborate with the Disability Rights Commission in relation to its duty in this area. If, as envisaged, OFCOM may disseminate information and advice or even guidance/Codes of Practice in this area such collaboration would seem essential and ideally would be written into the Bill.

The need for an advisory committee on disability access issues

  2.15  If OFCOM is to make a useful contribution to opening up the Information Society to blind, partially sighted and other disabled people by promoting Inclusive Design and effecting solutions to key access problems, expertise and commitment in this area must built into the governance structure of the regulator itself. The Office of Communications Bill 2002 provides that OFCOM may establish advisory committees as it sees fit. Since there is no requirement to ensure there is disability expertise on the Board, the need for a high level advisory committee bringing together representatives of disabled people and experts in the field of inclusive communications design is even greater. The Committee should be charged with helping to steer OFCOM's work on disability access and feed into the work of the different sectoral groups. A member of the Board could take on the role as "Champion" of the work of the Committee so that issues raised by it are fed in and heard at the highest level.


Consumer Panel

  3.1  The Consumer Panel must be an independent advocate of consumer's interests with a clear remit to promote universal access and champion the needs and interests of disabled people in particular. The Bill does not reflect this at present. The legislation should spell out a robust mission for the Panel

  To deliver a one-stop service providing advocacy, dealing with complaints as well as providing clear and accessible information and advice;

  To foster confident and assertive consumers who know their rights and to help them put pressure on the companies to help them get better deals and improved services;

  To campaign for the full inclusion of—and the delivery of real benefits for—disabled, elderly and low-income consumers in the digital communication revolution.

  3.2  This is the kind of mission EnergyWatch, for example, works to. The Consumer Panel will be but a pale shadow of consumer bodies in other areas unless these parts of the Bill are significantly beefed up.

  3.3  Key to the Panel's effectiveness will also be its resourcing, its independence and its ability to represent the full range of consumer interests. Absolutely nothing is said about how large the Panel will be or to what extent the Panel will be resourced, what powers it will have to employ staff, or to generate income. It will undoubtedly need its own Secretariat and sufficient funding from the Treasury to employ administrative and specialist staff and policy researchers if it is to have real clout.

  3.4  Nor will the Panel have sufficient independence of the regulator. All members are appointed by OFCOM and may at any time be removed. In addition OFCOM appears to retain the right to withhold from it any information it chooses (96.6). In Utilities regulation it is the Secretary of State who appoints the consumer council. We call for the Panel to be completely independent of the regulator. A memorandum of understanding could spell out how they can work together with OFCOM to promote the consumer interest. Members should be appointed by the Secretary of State with more limited and explicit criteria for dismissal. Additionally, the Panel should be directly accountable to the Secretary of State and to Parliament for the work it does and the money it spends.

  3.5  We welcome the fact that there will be Panel members representing the nations and that appointments must secure, as far as possible that the Panel are able to give informed advice about the interests of disabled people among other disadvantaged groups. This is rather limited, however. We would argue strongly that there must be room for representatives of visually impaired people and other groups of disabled people on the panel. Disabled people are not a homogenous group; they have different access requirements. A wide range of consumer voices must therefore be supported and heard in the Panel Structure. We would suggest a structure of consumer interest group fora feeding into the main panel to accommodate this. All too often "representatives" of disabled people on quangos are not supported in consulting the constituencies they represent—the onus ends up being with the individual or a sponsoring voluntary organisations. If the consumer structure is to have credibility and deliver the goods it will need to be set up and resourced to facilitate wider engagement with disabled people.


  4.1  Direct service of customer needs will dominate a large part of OFCOM's operations and will require substantial ongoing resource and senior management attention. Yet no attention has yet been given to addressing how disabled people are to be able to interact with the single regulator on a par with non-disabled people for advice, information, to use complaints procedures or participate in consultation processes. Crucial to that is being able to expect to have information and communications needs fully met.

  4.2  Disabled people have a great variety of information needs—from braille, large print and tape for visually impaired people through to textphone access for deaf and deafblind people and plain easy to read English for anyone with learning difficulties. Catering effectively for these needs will only be possible if OFCOM, and indeed the Panel are required to develop and implement an accessible information policy to ensure disabled consumers can interact with both bodies using their preferred format or means of communication. Unless there is a clear policy comprising clear guidelines for staff and an action plan there is a very real risk that OFCOM's systems will not be designed or operate in an inclusive way. Building such provision in from the outset eliminates that risk, will save money in the long run and ensure OFCOM takes a best practice approach.


  5.1  Current areas of exclusion for blind and partially sighted people which we want explicitly addressed by the legislation are set out below followed by our assessment of what action may be possible within the scope of the Bill as currently drafted and what additional provisions might be needed to the draft legislation.

Exclusion from Digital TV

  5.2  The two chief ways that people with sight problems could enjoy television programmes are audio description and text manipulation. Audio description is an additional narration that fits between dialogue and describes action, body language, facial expressions—anything that will help people follow what is happening on screen. Audio describing television programmes, films, plays, sporting events and even an exhibition of paintings is now technically relatively easy especially with digital technology. While it is available at a number of theatres and cinemas in the UK, and RNIB has run a described home video service since 1994, there is still no openly available audio description television service that can be received by everyone.

  5.3  Text manipulation is the key to dealing with written information on the television screen necessary to find your way or "navigate" around digital television. Changing channels, controlling volume, finding out programme information and setting a recording are impossible if they are dependent on being able to read relatively small written information on the television screen. So far nobody is making televisions with a screen reader or a way to manipulate on-screen text. Yet technology has existed for years, which enables text manipulation on screen—it is how partially sighted people use computers at work and in school.

Regulation of Electronic Programme Guides and APIs

  5.4  RNIB welcomes the fact that OFCOM has the power to regulate Electronic Programme Guides and Application programme interfaces. This must be used to require EPG providers and set top box manufacturers, whether through general conditions or universal service conditions, to supply blind and partially sighted end-users with EPGs and APIs with access features to meet their needs:

    —  The majority of visually impaired viewers have some useful sight and could read on screen text provided their EPG and specifications within their set top box enables them to change the size, shape, shade and colour of the text and background to meet their individual needs;

    —  For those without any useful sight, a screen reader providing synthesised speech output would be the only practical way to navigate around digital television;

    —  A significant minority of blind and deafblind people will require EVPGs and APIs which support connection to an electronic braille display.

  5.5  If these options are not feasible in the short-term, providers should be required to make available information via alternative methods such as telephone helpline services or email.

  5.6  There must also be regulation of handsets/remote controls to enable people with sight problems and reduced manual dexterity to operate them easily. The VISTA (Virtual Interface for a Set-Top box Agent) project, led by the ITC, will examine the potential use of technologies that allow a viewer to "speak" commands to the TV as well as have the TV "talk" back, to select programmes from the hundreds of digital channels now available. This project is aimed to improve access for visually impaired people but clearly could have benefits for people with physical disabilities who would simply be unable to manipulate a remote control themselves. OFCOM must champion this project when it takes over from the ITC and ensure the technology is made widely available.

  5.7  If such regulation is not forthcoming soon, the consequences will be extremely damaging, with blind and partially sighted people facing a huge deterrent to "going digital" faced with the impossibility of navigating the different channels.

Regulating the transmission and reception of audio description services

  5.8  It is not immediately apparent that OFCOM necessarily has any power under the proposed regulatory framework to require equipment for receiving audio description to be made available to blind and partially sighted people. It certainly has powers over spectrum and it will be vital to use these to ensure sufficient spectrum is reserved for the transmission of audio description services.

  5.9  Yet it is also vital that OFCOM acts to plug the gap left by the Broadcasting Act 1996 which legislated for audio description targets for DTT broadcasters but failed to address the means of reception. Hence six years on, just 45 households are able to view audio described programmes on digital terrestrial as part of a trial of a new module. Neither the industry, the existing regulators, nor the Government have accepted responsibility for ensuring the module is supplied to blind and partially sighted customers on DTT. Similarly digital cable companies are holding out against supplying their blind and partially sighted customers with a means of receiving audio description. Only Skydigital has made its (very) limited audio description service available to visually impaired customers.

  5.10  The one aspect the Bill does deal with clearly is the retention of the audio description targets for digital broadcasters and their extension to digital cable and satellite, with corresponding amendments proposed to the BBC Agreement. The Policy paper and Regulatory Impact Assessment accompanying the Bill trumpet the fact that audio description, sub-titling and signing requirements are in the first tier of broadcasting regulation. The RIA argues that this is justified because in this case the public interest outweighs any potential impact on the industry. "Whilst there are costs to industry, particularly as regards subtitling, signing and audio description, these have to be set against the resulting considerable social benefits." But owing to the low level at which the audio description targets are set and the fact that the reception issue is not even referred to, let alone addressed blind and partially sighted people are not rejoicing.

  5.11  Instead there is deep disappointment that broadcasters" targets for audio-description have been frozen at 10 per cent over 10 years. RNIB has long called for audio description targets of 50 per cent to reflect the huge importance of this service for blind and partially sighted people's enjoyment of digital TV. People with sight problems compare the importance of audio description to sub-titling for people with hearing problems where the targets are 80 per cent. They simply do not understand why they are getting such a bad deal by comparison. The key excuse the Government used in freezing the targets, following its review last year, was that they were not prepared to "extend and improve" the audio description service until the question of receiving transmission had been resolved. Hence blind and partially sighted people are caught in a "chicken and egg" situation.

  5.12  There is in fact no coherent Government policy or strategy on how they intend to expand access to audio description on digital TV. There is goodwill on the part of the Broadcasting Minister but no firm commitment to do anything in particular other than talk. We think there should be a clear strategy, that now is the time to put it together and that DCMS/DTI should clearly set out what they intend to do via licensing conditions, using provisions in the new regulatory framework set out in Part 2 of the Bill or other legislative or non-legislative means to sort the reception issue out. Options we would want to put forward (which are not necessarily mutually exclusive) include:

    —  Approving the use of general conditions or universal service conditions at an early stage to insist that Digital TV providers supply blind and partially sighted customers with set top boxes which are capable of receiving Audio Description and which support accessible Electronic Programme Guides at no extra cost. Skydigital has already commissioned set top boxes from manufacturers which have the capability to receive audio description making satellite the only option currently (and a pricey one at that) for a blind or partially sighted person wanting to access audio described programmes. There is no practical reason why the cable companies and the new DTT Multiplex Licence holders should not be required to do likewise when they commission set top boxes from manufacturers—they simply need to write these access requirements into the equipment specifications. The technology is not a problem—it exists and it works, what is lacking is any regulatory requirement;

    —  Bring forward the "must offer must carry" obligations and provision for free access to PSBs from other platforms at the earliest possible opportunity. Ensuring this happens to coincide with analogue switch off is far too late. Although it is not clear on the face of the Bill that audio description services are covered by these obligations, the EU directives indicate that this is the case. If that alone was accomplished visually impaired viewers would at least have one viable AD receiving option in the shape of Skydigital, and could opt for a free to air package which offered a far wider range of audio-described programmes than they can access on Sky at the moment;

    —  The Government must invest £3 million in bringing the audio-description module developed for use in the common interface slot of set top boxes for DTT to market. This would extend access to some 20,000 visually impaired viewers. The module is the "gold-standard" in terms of quality for the viewer with sight problems (the weakness of the DTT signal notwithstanding) since it uses the "closed" method of receiving audio description. This is the preferred option for accessing audio description as it allows much more flexibility to the user. An individual can listen to the audio described version with headphones whilst other viewers can watch the programme without audio description. It is also possible to change the volume of both the original programme and the audio described soundtrack, which may be especially beneficial to people with hearing problems. Skydigital operates an "open" method which means everyone in the room has to listen to the audio description whether they want to or not;

    —  Legislate to require all televisions or set-top boxes manufactured in the UK after a certain date to be designed to be compatible with audio-description signals (this can be done without falling within Article 28 of the European Treaty so long as non-compliant imports can come into the UK). Many of the leading television suppliers in the UK manufacture in the UK, so such a measure would have the desired effect;

    —  The Government should robustly pursue a harmonising measure or standard setting at EU level to ensure future generations of set top boxes and digital TVs have a second sound channel built in and support other key access features.

Exclusion from Digital Radio

  5.13  There is no mention in the Bill of radio receiving equipment and indeed this was excluded from the scope of the recent EU Directives and indeed a previous Directive on terminal equipment. Digital audio broadcasting could offer considerable benefits to visually impaired people, in particular better sound quality and stability of signal. However, there are two potential threats to them being able to take advantage of this new service in the foreseeable future—the use of digital displays on sets, and the cost of receivers. Digital radio receivers present huge access problems. On-screen menu systems are used for tuning and programme choice; they also identify upcoming programmes of interest, or alert the listener to new programmes just starting. Apart from these obvious problems, already additional data is being transmitted—what piece of music is playing, weather, traffic, and so on. These systems are also set to become interactive. In all likelihood these developments will simply make the radio—once the mainstay of visually impaired people's access to the Information Society—more inaccessible than ever before.

  5.14  If there is any scope for using the new regulatory framework or other legislation to ensure blind and partially sighted people are provided with accessible digital radio receivers the opportunity must be seized. Otherwise OFCOM and the Government should at least promote the need for action by manufacturers and lobby for standards for accessible radio receiving equipment at EU level.


  6.1  Finally, one specific new provision we want written into the Bill is for the Secretary of State to have a grant making power, similar to that enshrined in Section 93 of the Telecommunications Act 1984 to defray or contribute towards expenses incurred in supporting research into, developing and providing accessible communications apparatus and technologies in the interests of disabled people. Funding to bring the DTT audio description module to market should be a top priority in this respect.


  7.1  RNIB strongly welcomes provisions in the Bill on "access radio" which have the potential to increase access to broadcasting resources for blind and partially sighted people. We are concerned, however, that limitations on sponsorship and advertising might make such stations difficult to sustain.


  8.1  There are many misconceptions and inaccurate characterisations of blindness and partially sighted people, not to mention other disabilities, which have contributed to the stigmatisation of visual disability and to lower expectations of quality of life. These stereotypes have clearly played a part in building up the social exclusion of blind and partially sighted people in employment, education and cultural life. For the one in five of us who will develop an un-correctable sight problem if we live to the age of 75, these myths and misconceptions may lead to emotional isolation and a lack of engagement with the many practicable rehabilitation strategies available.

  8.2  OFCOM must have a duty to ensure licensed public service broadcasting avoids these inaccurate depictions. RNIB calls for a further objective to be added to the objectives for OFCOM's standards code for television and radio services, namely "that material likely to lead to the stigmatisation of disabled people is not included in television and radio services."


  9.1  Blind and partially sighted people are increasingly excluded from many developments in digital technology through exclusive design, the cost or technical difficulty of access, the absence of suitable equipment and the lack of training. We hope the Joint Committee agrees that the legislation must contribute much more to the task of combating this growing exclusion and will reflect the importance of regulating for genuinely universal access in its recommendations on the Bill.

June 2002

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