On behalf of All India Confederation of the Blind
Comments on Draft Consultation Paper on National Policy for Electronic Accessibility I. General: The draft policy currently being circulated in the form of a position paper attempts, in no uncertain terms, to address the complex issue of electronic accessibility with its various shades and nuances. Although the draft encompasses many critical focus areas, it leaves substantial scope for amendments /enrichment. A few of these are suggested below in rather generic terms: 1. The draft policy seems to limit itself to a mere legal mandation at best. It should also focus on implementation, enforcement and vigilant monitoring. 2. The precise technical specifications down to the micro level need to be developed and incorporated into the draft with the help of competent professionals. The W3C accessibility guidelines could be used as a possible model. 3. The focus of electronic accessibility needs to go well beyond the Internet. 4. All the websites currently under the purview of the Government of India, either directly or indirectly, should be statutorily obliged to provide seamless access to all. 5. A public-private partnership mode could be initiated to encourage large corporations to make their online and offline content accessible. II. Section-wise Comments: 1. Preamble: 1.1. The opening sentence of the Preamble has been taken verbatim from the Foreword (sentence 2) to the National Policy For Persons With Disabilities (2006) of the Government of India, contributed by Smt. Meira Kumar, the then Minister for Social Justice and Empowerment. This needs to be recognized, ( just a small point). 1.2. Other important documents the Policy is to expand upon are: The National Policy For Persons With Disabilities of the Government of India (2006), and the New Centrally Sponsored Scheme of Inclusive Education of the Disabled at Secondary Stage (2009) of the Ministry of Human Resource Development, Government of India which, inter-alia, seeks to provide students with disabilities access to computers in Classes 9 to 12. 2. Operational Definitions: ICTE needs to be defined, the basis could be the definition given for the term "Communications" under Article 2 of UNCRPD, with suitable amendments. 3. Objective: The following additional objective is suggested: To help children and adults with disabilities without any gender-bias, to overcome barriers that may hinder their full and effective participation in society and function with maximum ease and independence. 4. Scope: 4.1. The opening sentence may be modified to read as follows: The Policy covers ICTE products and services relating to, though not limited to: print access; mobility; communications; consumer electronics; information technology; home management; recreation including broadcasting systems covering video content, feature films/movies and digital television; interactive transaction machines; telecommunications systems; technologies used in workplaces, any future ICTE product intended for public use. 4.2. Instead of 'Academia', mention "university departments and colleges." 5.1 Awareness: 5.1.3 (to be added) The Union Department of Information Technology will prepare suitable schemes to support such awareness programmes and also motivate other Ministries/Departments to do likewise. 5.2 Education: (Replace existing 5.2.1 with the following): Children with disabilities studying at the Secondary and Senior Secondary stages of education will be provided necessary education in the use of computers on a large scale with appropriate hardware/software adaptations. Resource support available under the new Centrally Sponsored Scheme of Inclusive Education at the Secondary Stage will be used for the purpose. 5.2.2 ( to be modified as follows): Assistive technologies resource centres will be set up across the country, which will have a rich collection of modern assistive devices for persons with disabilities to enable them to identify the right device and facilitate adaptation/technology transfer to the extent possible. 5.2.3 ( to be added): The encoding system for Indian languages will be standardized with the use of the Unicode system for string content in our languages. This will facilitate instant production of reading material into accessible formats. For a textbook to qualify as an officially prescribed textbook for study, educational boards such as the CBSE and the dozens of other state boards should require the PDF version of that book to be deposited with a repository so that visually impaired students can study in a barrier free environment. 5.2.4 (to be added) : All curricular material to be available in alternative, appropriate and accessible format for persons with disabilities. 5.2.5 ( to be added) Educational material and content packages available on CDs be designed in such a way as to make them accessible to existing screen readers. Cyber space and the digital world need to be treated as the physical built environment with access features being integrated into related bye-laws and policies. 5.2.6 ( to be added): The Union Ministries of Communications and Information Technology and Human Resource Development will formulate suitable schemes for initiating and promoting the required action. 5.3 Research and Development: 5.3.1. May read as follows: Para 53, VI of the National Policy For Persons With Disabilities ( 2006) envisages promoting research for developing adaptive technologies " focusing on enhanced personal mobility, verbal/nonverbal communication, design-changes in articles of everyday usages etc., with a view to making available cost-effective, user-friendly and durable aids and appliances with the help of premier technological institutes." The Policy will strive towards this important stipulation through suitable resource-mobilization and information-dissemination, insofar as ICTE is concerned. 5.3.2. ( no change) 5.3.3. DIT along with other Ministries/Departments may take the lead in preparing schemes to support R&D activities and for providing incentives to interested scientists and technology professionals. 5.3.4. ( to read as follows): Disabled persons and their credible national organizations will be closely associated with adaptive technology endeavours. Such partnership and interaction should cover all aspects of actual needs in the ICTE sector relating to determining what is really required on a priority basis by persons with disabilities, conceptualization, prototype-development, beta testing and large-scale production. Our technology professionals and researchers have to work with an open mind and give utmost weightage to the inputs of such reputed organizations at every stage. A user's manual must invariably accompany each new device. Also, representation of persons with disabilities will be ensured in the formulation, implementation and monitoring of schemes. 5.4. Accessibility Standards: (no change) 5.5. Accessible Format for Content: 5.5.1. (add the following): Accessible format refers to material in Braille/large print/audio/e-text. 5.5.2. (to be added): The Union Ministries of SJ&E, HRD and CIT will jointly formulate schemes for production of reading material/content in the aforesaid accessible formats. 5.6. Implementation and Monitoring: 5.6.1 (to be replaced with the following): As required under para 54 of the National Policy For Persons With Disabilities ( 2006), Ministry of Science and Technology will set up a Rehabilitation Technology Centre for necessary coordination, testing and certification purposes and the CIT will provide all necessary support for the purpose. 5.6.2.: ( to be added): An empowered committee will be formed by the DIT to guide and monitor implementation of the National Policy. All stakeholders including experts among persons with disabilities, DPOs, advocacy groups, technology professionals will be represented on this committee. 5.6.3.: (to be added): A legally mandated government agency such as the US Access Board in the United States should be set up to enforce the rules and regulations with respect to accessibility. Although, the US Access Board limits itself mainly to physical accessibility and barrier free environments, the Indian agency or authority could go beyond issues related to physical accessibility and deliberate upon electronic accessibility too. 5.7. Procurement Strategy: (no change). 5.8. Affordable Access: (no change, except the following to be added): 5.8.3. ( to be added): Existing government schemes will be liberalized to enable-- needy persons with disabilities to obtain education/employment-related ICTE devices free of cost or at highly subsidized costs as per their need with a view to enhancing their present capabilities on the recommendation of the concerned educational/appointing authorities. 6. Rights and Priorities (New Section): 6.1. Smooth and need-based development/procurement of ICTE devices for persons with disabilities must be accepted by all concerned as a matter of basic human right for the user group. 6.2. In pursuance of the recognition of this basic human right, we have to undertake work relating to this sector based on carefully assessed priorities. Priorities should be set strictly as per the actual needs and the present level of economic development. 6.3. The devices need to be affordable, easy to operate and the gap between laboratory work/prototype-development and mass production must be eliminated. In consultation with the user group, priority be accorded, inter-alia, to the development and production of devices which facilitate: * Production of accessible reading material * Computer and internet access * Diversification of job-opportunities in urban and rural areas * Independent living and household management * Entertainment including audio-description/sign language interpretation of Bollywood films 7. Review of the Policy: This Policy will be reviewed after every two years. With regards, Swati Sinha when things don't seem to be going your way, always know that God has a plan for you. If you place your trust in Him, He will give you great gifts. We don't always know what God's plans are for us. We just know that His ways are not our ways, but His ways are always best. To unsubscribe send a message to accessindia-requ...@accessindia.org.in with the subject unsubscribe. 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