Meeting with Representative of People with Disabilities
Topic: Review of the Universal Service Obligation (USO)

Date: Tuesday 20 November 2007
Venue: 'As You Like It' Restaurant, Canberra, ACT

Present:
Holly Raiche, Executive Director ISOC-AU
Louise Bannister, TEDICORE
Sue Salthouse, Women with Disabilities, Australia
Sean Fitzgerald, Physical Disabilities Council


Welcome and Introduction:
  
Holly Raiche welcomed participants to this meeting, and said that this
discussion is supported by the Australian Government through the Consumer
Representation Grants program of the Department of Communications, Information
Technology and the Arts. 


1. Background

Holly said that the Department of Communications, Information Technology and
the Arts is conducting a review of the Universal Service Obligation.  The
deadline for submissions to that review has passed, but there will be further
discussions on issues raised by the review and the perspectives of people in
this meeting can form part of the input to those further discussions.

Holly outlined the requirements of the USO including the definition of a
standard telephone service (STS), and the provision of payphones.  She also
outlined issues raised by the review, including the DDSO, in so far as it
requires the provision of transmission capacity above that required by the USO.

The meeting agreed the focus of this discussion would be on provision of the
STS, consumer safeguards associated with the STS and customer equipment used
with the STS.  

The provision of payphones and the provision of the STS to indigenous
communities are important to people with disabilities but will not be the
subject of these discussions.


2. Access to Communications as a Right 

The USO should be linked to the rights of people with disabilities to
communicate.  Specifically, the United Nations Convention on the Rights of
Persons with a Disability (CRPD) (adopted by the UN on December 13, 2006)
recognises the inalienable rights of people with disabilities with respect to
communications. The CPRD contains specific articles on access to communications
and information about it.

Article 4 outlines the General Obligations of signatories to the Convention
with paragraph (g) specifically noting the promotion of the use of new
information and communication technologies (ICTs) 'suitable for persons with
disabilities, giving priority to technologies at an affordable cost'. 

Article 9 of the Convention considers general matters of accessibility, being
concerned with enabling 'persons with disabilities to live independently and
participate fully in all aspects of life'. In the context of communications
this means ensuring that 'persons with disabilities have access, on an equal
basis with others: 

* to information and communications,
* including information and communications technologies and systems,
* and to other facilities and services open or provided to the public, both in
  urban and in rural areas.'

Australia is a signatory to this Convention, and is in the process of assessing
the mechanisms which will need to be put in place for its ratification. 


3. Range of disabilities 

The range of disabilities that people have means there will be a variety of
communications solutions that address particular communications needs.  What
will meet the communications needs for the Deaf community or people with speech
or hearing impairment will differ from how people with other disabilities such
as mobility or dexterity impairments communicate.

Advances in both transmission capacity and customer equipment have opened up
the possibility of far better communications for people with disabilities.
However, unless the regulatory framework for telecommunications, including the
USO, underpins the needs of people with disabilities, they may not benefit from
advances in communications technologies.


4. USO Issues

4.1 Transmission 

* Capacity 

  The USO has been defined by Telstra's Marketing Plan as the delivery of voice
  telephony.  The implication is that the transmission capacity that must be
  accessible to all is only a capacity for voice telephony - approximately 20
  kbits/s.  The DDSO raised the requirement to ISDN capacity - 64kbit/s.
  However, broadband speeds now deliver better means of communications for people
  with disabilities.  

  Examples include:
  + The Internet Relay service recently introduced by the NRS
  + The use of MSN for instant messaging
  + With symmetric speeds of 512 kbits/s, video relay services


* Mobile Communications

  Mobile phones are also playing an increasingly important tool for
  communications for people with disabilities including 
  + The use of SMS for the Deaf community and people with speech or hearing
    impairments 
  + The use of voice activated mobile handsets for people with both dexterity
    and mobility issues

* Coverage

  While voice telephony is largely available in the metropolitan and regional
  areas, there are still areas within cities and regional centres that do not
  provide access to broadband.  If access to broadband capacity is to be an
  upgraded obligation, the 'black spots' in coverage must mapped - not only in
  rural and remote areas, but in the metropolitan and regional centres as well.
  The USO mechanism must then ensure universal access to broadband throughout
  Australia.

  Mobile services are also becoming important means of communications for people
  with disabilities.  This includes not only the increasing use of text for
  communications, but the growing capacity of mobile services to provide access
  to broadband services.  Coverage of mobile services should also, therefore,
  become an element in services that are accessible to all Australians.

* Reliability/Quality of Service

  An important issue for people with disabilities is the quality and
  reliability of their communications service.  This is particularly an issue
  with radiocommunications delivery systems, where coverage (and therefore the
  reliability of the service) can be affected by weather, by whether there is
  'line of sight' delivery, etc. If radiocommunications is to be the delivery
  system for a broadband USO, issues of service quality and reliability must be
  addressed.


4.2 Customer Equipment

Increasingly, there is less need for assistive technology as what is 'standard'
equipment can be modified to meet the communications needs of people with
disabilities.  However, many people with disabilities simply do not know and
cannot easily find out how 'off the shelf' equipment can be used or modified to
meet their particular communications needs.

There is a marketing opportunity for equipment providers, as well as people
with disabilities, for equipment instructions to be written in 'plain English'
as well as education/training programs in how 'standard' equipment can be
programmed/adapted to address special communications needs.  

Clearly, there will be a continuing need for specialised equipment to address
the communications needs for some people with disabilities.


4.3 Affordability - Communications Allowance

The cost of communications can be higher for people with disabilities.  The
affordability of communications has two aspects - the capital cost of
equipment, and the ongoing costs of usage of that equipment.

While standard telecommunications customer equipment increasingly can be
adapted for people with disabilities, this often means having to purchase
equipment at the high end of the price range for the special features necessary
for communications.  Additionally, many people with disabilities will continue
to require specialised equipment to communicate. People with disabilities can
also incur higher usage charges for their communications, such as for Video
over IP or Internet relay services.  

At present, the issue of cost is addressed only through the USO providers
disability equipment program. There could be either a government funded
communications allowance that could address both any higher capital equipment
and usage charges that are incurred because of a person?s disability.  Such
allowance should be based solely on the communications needs of the individual


4.4 Emergency Services and Priority Assistance

Both access to emergency services and priority assistance are particularly
important for people with disabilities.

While the provision of access to emergency services is a requirement on all
service providers of the STS, this does not deal with the Deaf community and
people with speech or hearing impairments that use text to communicate.

The provision of Priority Assistance services is currently only required of
Telstra, and only for  the STS.  For people with disabilities who are reliant
on communications for their health and safety, this means their choice of
service provider is confined to Telstra and those service providers who choose
to provide priority services (currently only two do).  In an environment where
a privatised Telstra is now only one of many service providers (albeit the
largest), people with disabilities should be able to make a choice of service
provider without losing the safety net of a priority assistance service.


5. Conclusions

The technological advances in telecommunications transmission and equipment
technologies provide a real opportunity for people with disabilities to better
access communications.  The USO should be upgraded to ensure that all
Australians, particularly those with disabilities, benefit from those
technological advances.

That upgrade should address both transmission capacity and reliability.  It
should include not only continued access to appropriate equipment, but
information on how that equipment can be adapted to meet particular
communications needs.  It should be upgraded to address issues of
affordability.  And it should be upgraded so that the legitimate concerns of
people with disabilities to who are reliant on communications for their health
and safety concerns.

Participants were thanked for their attendance and input into the consumer
consultation process.