E-Europe Action Plan
Participation for All
Submission to e-Accessibility Expert Group

Dr. Barry McMullin
Research Institute for Networks and
Communications Engineering (RINCE)
Dublin City University

27th April 2001
[Document also available in PDF Format.]

1 Introduction

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.

2 e-Europe Objective 2(c): Participation for all in the knowledge-based economy

2.1 Adoption of WAI guidelines for public websites

I would warmly welcome any measures to promote WAI compliance of websites (public or otherwise). Additionally, I have the following more specific comments:

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.

2.3 Establishment and networking of national centres of excellence in e-design-for-all

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.

2.4 Publication of e-Design for all standards for accessibility of IT products

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.

3 e-Europe Objective 1(a): Cheaper and faster Internet access

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.

4 Conclusion

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.

5 Links

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