[AI] Comments on Draft Consultation Paper on National Policy

Swati Sinha swatisinha13 at gmail.com
Tue May 18 13:30:31 EDT 2010

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
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
3.	The focus of electronic accessibility needs to go well beyond the
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

            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


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


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.



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