E-Europe Action Plan
Participation for All
Submission to e-Accessibility Expert Group
27th April 2001
[Document also available in PDF Format.]
- 1 Introduction
e-Europe Objective 2(c): Participation for all in the
- 2.1 Adoption of WAI guidelines for public websites
- 2.2 Review of relevant legislation and standards to ensure conformity with e-accessibility principles
- 2.3 Establishment and networking of national centres of excellence in e-design-for-all
- 2.4 Publication of e-Design for all standards for accessibility of IT products
- 3 e-Europe Objective 1(a): Cheaper and faster Internet access
- 4 Conclusion
- 5 Links
This is a submission to the e-Accessibility subgroup of the High Level Group on the Employment and Social Dimension of the Information Society (ESDIS). It comments on certain specific objectives identified in the e-Europe Action Plan, in response to a request from the Irish Department of Justice, Equality and Law reform, of 5th April 2001.
I would warmly welcome any measures to promote WAI compliance of websites (public or otherwise). Additionally, I have the following more specific comments:
- Achieving effective compliance is not a trivial matter, so this needs to be very carefully planned. I believe that there will be a substantial need for technical training both of those involved in commissioning such work, and of content authors, designers and engineers involved in carrying it out. It may be appropriate to take some proactive initiative to ensure the provision of such training quickly and on an adequate scale.
- In the case of public sector websites, some consideration should be given to providing special funding to support this process, at least in the short term, at national and/or EU levels.
- Conversely, there is a real danger that some agencies may react to requirements for compliance by removing resources or services from sites, rather than by making them accessible. Indeed, there have been some (anecdotal) reports of such effects from other jurisdictions. Any such degrading of web service would, of course, be completely contrary to the spirit of the WAI guidelines, and, indeed, discriminatory, in that disabled users, who rely more heavily on electronic access to information, would be disproportionately affected. It is very important that measures to promote WAI compliance guard against any such effect.
- Any strategy for WAI compliance must clearly address the issues of long term maintenance. That is, while it is important for agencies to take immediate actions to resolve accessibility problems with their websites, this must not be a "once off" exercise. Rather, WAI compliance must be systematically built into the long term management of each agency's web services. Again, continuing training is one clear requirement to support this.
- While certain aspects of WAI compliance can be tested using automated tools, many provisions require expert evaluation and/or testing. Accordingly, a serious commitment to WAI compliance will require provision for independent (and ongoing) auditing of such compliance. To ensure the independence of such auditing, this function must be clearly separated from all those with an interest in the development or management of any site being audited. Again, some proactive initiative to develop or support the provision of independent auditing services would be very helpful.
- The various WAI guidelines themselves are not static, but are rather subject to continuing development and review. Indeed, a major revision of the core, "content" guidelines (WCAG) is currently in progress, with a working draft of the new version (2.0) having been published as recently as 29th March 2001. Accordingly it is important that there be ongoing engagement with the relevant W3C Working Groups by individuals and organisations, both at EU level and within individual member states, to ensure dissemination of best practice and, where appropriate, to contribute to and influence this activity. This is currently being actively addressed through project WAI-DA IST 13470; but it is important that such activity be endorsed and strengthened.
2.2 Review of relevant legislation and standards to ensure conformity with e-accessibility principles
This is an important measure, and again I would welcome any progress on it. However, it is important to note, as emphasised in the e-Europe Action Plan itself, that "... the Internet by its nature is multi-jurisdictional, since its content and services are globally accessible." Thus, in the specific case of e-accessibility standards relating to Internet mediated services, these will only be fully effective if they are agreed and enforced on the widest possible scale.
One particular legislative issue that may merit early review, is the interaction between copyright law and various assistive technologies. The recent EU Copyright Directive allows for "certain exceptions or limitations ... for use by people with disabilities" (paragraph 34), but this general aspiration needs to be translated into more specific, concrete, provision (this is re-iterated in paragraph 43 of the same directive).
For example, where copyright law requires the lodging of copies of published work in designated libraries, should this incorporate a requirement for lodging alternative, accessible formats? In the case of printed materials, guaranteed availability of electronic formats - and, better, guaranteed provision to make such versions freely available to relevantly disabled citizens - could provide significant benefits at negligible cost to publishers.
Another copyright issue relates to the operation of services such as transcoding proxies which, can, among other things, be used to mechanically transform a work from one format to alternative formats, to facilitate the accessibility requirements of particular users. Such technologies are potentially very beneficial in certain situations; but the legal status of such services, under existing copyright legislation, appears to be unclear. Any uncertainty of this sort may serve to inhibit the development or deployment of these services.
I strongly endorse the provision and networking of such centres of excellence--both nationally and internationally. The emphasis in the development of the 6th Framework Programme on such networks would also serve to strongly support and re-inforce any such development at a European level.
From my own specific perspective, I am currently directing a project in the area of web accessibility. While this particular project is benefiting from substantial private sponsorship, it is taking place within the context of the Research Institute for Networks and Communications Engineering (RINCE), a centre founded at DCU with national support from the HEA Programme for Research in Third Level Institutions. It is my intention that the current project should catalyse the establishment, within RINCE, of an e-Accessibility research laboratory, as a facility to support a long term programme of research in this area. I believe that such a laboratory could benefit from, and contribute to, the establishment and networking of centres of excellence, both nationally and internationally.
Again, in the case of Internet related products or services, I would re-iterate my earlier comment on the crucial importance of international co-ordination in this area; and the consequent desirability of encouraging and supporting participation in such processes (particularly through relevant W3C Working Groups). I would also draw particular attention to the W3C standards work on Composite Capability/Preference Profiles (CC/PP). I mention this activity specifically, as it is not explicitly identified among the relevant standardisation efforts in the ICTSB Design for All Report; whereas, in my own view, CC/PP is likely to be of pivotal importance to maximising Internet service accessibility in the future.
The previous sections have commented on the specific issues raised in the original request; however, I would also like to comment briefly on Objective 1(a) of the e-Europe Action plan, which is to achieve cheaper, faster, Internet access.
This issue of Internet access is, of course, very broad, and in that sense it might seem that it is not specifically within the remit of the ESDIS group. However: I would argue that, because Internet technologies offer such great potential for improving the ability of disabled citizens to participate equally in society, then such citizens are especially impacted by the current limitations of Internet infrastructure. Accordingly, while general Internet access facilities continue to be relatively slow and expensive, there is a strong case for special intervention in the short term to provide cheaper (free?) access equipment and facilities to all relevantly disabled people, either on a national or EU level.
In conclusion, I am grateful for the opportunity to comment on the realisation of the e-Europe action plan. I believe the Action Plan does provide an excellent catalyst to exploit information technology to bring genuine and tangible benefits to all citizens. I look forward to the outcomes from the work of the ESDIS and its e-Accessibility Expert Group.
- e-Europe Action Plan
- EU Copyright Directive
- World Wide Web Consortium (W3C)
- W3C Web Accessibility Initiative
- W3C Composite Capability/Preference Profiles (CC/PP)
- Information and Communications Technology Standards Board (ICTSB)
- ICTSB Design for All Report
- Irish Department of Justice, Equality and Law reform
- Dublin City University
- Research Institute in Networks and Communications Engineering (RINCE)
- Project: Web Accessibility in Ireland