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TELECOMMUNICATIONS FORUM: RECORD OF KEY POINTS OF DISCUSSION

Conference Room 1R1 Parliament House Canberra
November 28 2003

INTRODUCTION

This document contains a record of the key points of discussion at the above forum and is prepared by the Human Rights and Equal Opportunity Commission. It does not constitute minutes of the forum, and the fact that a position is stated does not mean that every party in attendance has committed to that position. However, it does indicate the key points of discussion during the day, and provides a platform for taking work forward on the issues raised.

It has been circulated to participants for their comment prior to publication on the Commission's website, and many, but not all, of those comments have been incorporated in the document.

The references in the document to Recommendations refer to those in the When The Tide Comes In discussion paper. The issues have been divided into the same topic headings used at the forum. Papers from participants are also linked from our telecommunications page.

TEXT TELEPHONY

Recommendations 9, 10, 11, 12, 18

Q1 Is the ACIF-hosted Text Any to Any (TATA) project the best way forward?

Q2 What might be some key principles and features for the ACIF text telephony model?

Q3 How might resources be found to achieve implementation of an agreed text telephony model?

  1. ACIF process is the best way forward - there is consensus on the direction being followed.
  1. The importance of real time communication was stressed.
  1. The importance of interworking between devices was stressed.
  1. The importance of universal design was stressed.
  1. This project must move relatively quickly - 2004.
  1. There are some mobile handsets available which will communicate with TTY's.
  1. There needs to be transition planning, including re-visiting and/or re-negotiating the result of the Scott v Telstra decision to take into account technological developments.
  1. If industry continues to make the running, there may not be a need for legislative change.
  1. There is a clear need for resourcing, in particular for any interworking capability between existing TTY and new text services.. It was suggested that this may occur through DCITA, and/or it may fall under the USO.

PUBLIC PAYPHONE ACCESSIBILITY AND TTY PAYPHONES

Recommendations 22, 23

Q1 Do we need an industry code on public payphones, and what should it contain?

Q2 Do we need an action plan for TTY Pay phones, and what should it contain?

  1. There is a need for an Industry Code for payphones and an Action Plan for TTY payphones.
  1. Payphones have a very important role.
  1. ACA inquiry showed the lack of knowledge of payphone location rules.
  1. 60% of payphone users are carrying mobiles - use of payphones is not diminishing with the increase of mobiles.
  1. There needs to be a phasing in of TTY connection to payphones.
  1. People with disabilities are over-represented in low income groups, which increases the need for access to payphones.
  1. The importance of a volume control on payphones to the broad range of people who are hearing impaired - a much larger sector of the population than people who are deaf - must not be overlooked.
  1. A Code in this area could be site-specific, with percentages of features determined by types of sites.
  1. There appears to be a need to inform the relevant community about the availability of TTY payphones and their locations. It was noted that TTY payphones and their locations are listed on Telstra's website and in the TTY directory.
  1. Industry's capacity to install TTY payphones may be restricted if phone call prices remain fixed.

DISABILITY IMPACT ANALYSIS FOR CHANGES IN TECHNOLOGY

Recommendation 16

Q1 How do we avoid a repeat of the regrettable situation which occurred with digital mobile phones and hearing aids?

Q2 Should we work towards legislative or voluntary industry codes to ensure impact analysis is part of new technology roll-outs?

  1. It was suggested that here should be guidelines or a checklist against which to test new initiatives, and then the registration of a statement with ACA that the technology complies.
  1. There was support for a Community Impact Statement or similar process.
  1. Industry is already doing a lot in this area to raise the awareness of consumer representative organisations, for example, on next generation networks.
  1. There needs to be a debate on an Industry Code in this area in the relevant fora.
  1. Regulators and government can be as guilty as industry in allowing technologies which exclude people with disabilities.
  1. There is a need to monitor international experience.
  1. The Any To Any project is a good model - it has been pre-emptive in addressing issues.
  1. There is a need to influence developments in international Standards bodies and global manufacturers.

SMS PRICING FOR DEAF USERS

Recommendation 17

Q1 Are groups who primarily rely on SMS communications disadvantaged by current pricing?

Q2 If so, what strategies may address this?

  1. UK guidelines for best practice for mobile phone providers should be examined to assess applicability in Australia. AMTA could follow this up..
  1. It is important to recognise the way people who are deaf use SMS - it is virtually their only form of mobile communication. It is not valid to compare the price of one SMS with the price of one voice-call - an interaction which occurs in one short voice-call may take four to six SMS's.
  1. The competitive nature of the market was recognised, but it does not - on its own - address the discrimination between deaf people and hearing people?
  1. Text users take longer to type on TTY's, and need to send more messages to achieve the same result.
  1. A website for SMS pricing comparisons would be very valuable - perhaps AMTA or a consumer organisation could host this.
  1. Industry has not adequately communicated appropriate pricing plans to the relevant community.
  1. SMS pricing is a potential major issue for DDA complaints.

EXPANSION OF SECTION 593 CONSUMER GRANTS PROGRAM & RESEARCH AND DEVELOPMENT

Recommendation 6 & Recommendations 3, 25

Q1 How can consumer participation and accessibility research be resourced effectively in the future?

  1. It was suggested that the following set of principles would underpin an effective model:

a)      Resources to consumer organisations should be allocated following scoping of needs by a representative committee which would make recommendations to Government.

b)      There should be a three-year funding cycle with annual acquittals. This would make funded organisations both efficient and accountable.

c)      Efficiencies are not necessarily gained through competition amongst consumer organisations.

d)      Industry support of consumer organisations can assist industry with equitable development.

  1. It was suggested that research and development could facilitate greater access to telecommunications, and policy-makers, industry and regulators would benefit from a competitive grants program to support innovative research and development as detailed in Recommendation 25. Such a program could:

a)      Be seen as an investment in the future;

b)      Use tax and other incentives as part of its resourcing;

c)      Draw on international experience through networking; Japan, US, the Nordic countries and the EC are good models.

d)      There is a benefit from input of consumers with disabilities involved in research.

e)      Partnering with universities could be valuable.

3. The restrictions on Government in this area caused by budget cycles and current policies were noted, but DCITA's preparedness to discuss these issues with industry and consumers was appreciated.

4. There needs to be discussion amongst consumer groups about generalist v specialist, and project-based v program-based funded activities. DCITA sought the views of consumer groups on funding priorities in these areas.

5. Consumer organisations need to be more strategic, and industry can help.

DISABILITY EQUIPMENT PROGRAM

Recommendations 7, 8

Q1 Should mobile phones be included in disability equipment programs, and if so what is the best way to do this?

Q2 Would people with disabilities be better served by a cross-industry disability equipment program, and if so, how might it operate?

  1. People with disabilities need access to telecommunications.
  1. People with disabilities should not be restricted from carriers by inequitable equipment issues.
  1. An independent cross-industry program was generally supported by consumer representatives.
  1. Such a combined program should be discussed under the auspice of ACIF. Funding and other issues need resolution. Such a program might need to look at micro markets.
  1. There is value in separating the equipment program from the customer - the customer then becomes valuable to industry.
  1. An equipment program does not just involve sourcing- staff training, and consumer support are also necessary components.
  1. The DEP is currently outside the TIO's jurisdiction and this may need to be addressed. This is because the TIO does not deal with complaints about equipment.
  1. Planning for a DEP must look to future technology.

MOBILE PHONES IN DEP

  1. Industry is happy to discuss meeting the needs of micro markets and communicating availability of accessible equipment to relevant communities.
  1. However, devices meeting specialised needs may firstly need to be part of a DEP, although may move to more general availability over time.
  1. Need to consider the definition of the standard telephone service and what it covers. However, although it may not cover mobiles, the convergence with the DDA must also be taken into account.
  1. Need to consider whether the DEP would include handset bundles?
  1. Need to consider whether the DEP would include the handset as a stand-alone item?
  1. Should government or industry lead on this issue?

MOBILE TELEPHONY ACTION PLANS

Recommendation 20

Q1 What are some ways to address the accessibility of mobiles? What are some programs/actions/practices which can be implemented to improve mobile phone accessibility?

Q2 Do we need a mobile telecommunications action plan, what should it contain?

  1. An industry plan could co-operatively provide equity and remove barriers.
  1. Communicating and information sharing are likely to provide a better solution than more prescriptive solutions.
  1. There needs to be consumer involvement.
  1. UK guidelines for best practice for mobile phone providers should be examined to assess applicability in Australia. (as per SMS pricing discussion).
  1. AMTA would be best placed to co-ordinate this work.

EXPANSION OF TELECOMMUNICATIONS DISABILITY STANDARD

Recommendations 13, 14, 15

Q1 Do we need a more comprehensive telecommunications Disability Standard, and if so what areas should it cover?

  1. Universal design and importance of commercially available equipment was noted.
  1. A code on information does not apply to equipment suppliers and importers - it only applies to CSP's.
  1. What has been learned from ACA consultation and other discussions could feed into a draft guideline, although further discussion with consumers is necessary.
  1. There could be a code enforceable by the ACA which is about information provision. Information about features would have to carry all relevant information for CSP's. There could be a second code on information as between CSP's and manufacturers.
  1. A standard set for features that a standard phone has to meet (currently only two) would meet far more needs if it contained more features. By lifting the standards it becomes more mainstream. Many Standard Telephones already on the market exceed the requirements of the current Disability Standard.
  1. The Telecommunications Act may not be the right place for regulation if the aim is to achieve end-to-end connectivity. The DDA may provide an alternate option, although an amendment would be required to the DDA before such Standards could be enacted.
  1. Industry is of the view that Disability Standards cannot limit other customer choices.
  1. It was noted that public procurement in the US requires access. Other countries including the EC are looking to follow this model. However, this will not preclude choices in the market.
  1. Consumers indicated their disappointment about the proposed move from standards to guidelines - they feel they have compromised already in the ACA process which reviewed proposals for adding to the current standard.
  1. Identification of overseas equipment which may be of benefit in Australia would be useful. The CTN work and Tedicor could assist with this.
  1. The ACA and HREOC were requested to look at possible mechanisms going across both regulatory systems.

MOVING FORWARD

  1. Atmosphere to go forward- positive and inclusive.
  1. HREOC does not want to reproduce effective mechanisms which already exist.
  1. HREOC will write up notes to circulate to participants.
  1. Then HREOC will work with other players- particularly industry bodies, regulators and consumer groups - to take issues forward.

HREOC will publish regular status reports on what has been achieved - probably six or twelve monthly.