ACROD Ltd is the national industry association for disability services. It has a membership of some 560 organisations Australia-wide that are responsible for operating several thousand services to people with disabilities and their families. ACROD has a national office in Canberra and divisions in all States and Territories. ACROD is recognised by all Governments as the peak body for the disability industry.

The Australian Blindness Forum (ABF) was formed in 1992. It is an unincorporated body that is funded only through the contributions of its members, currently 19 agencies. Its main purposes are to appoint delegates to the World Blind Union and to nominate a delegate to the National Board of ACROD. As well, the ABF holds conferences to discuss national and international issues affecting the blindness and vision impairment field.

ACROD and the ABF welcome this opportunity to provide general comments on the HREOC Issues Paper, with specific comments in three areas: Copyright law reform; World wide web accessibility audit; and Accessibility of ATMs, information kiosks and other specific purpose devices.

We understand that E-Commerce is defined as "the conduct of commerce in goods and services, with the assistance of telecommunications and telecommunications-based tools" (Roger Clarke, a leading Australian authority on E-Commerce).

We are aware that Blind Citizens Australia (BCA) is conducting a research project, funded by the Commonwealth Government's AccessAbility Grants Program, to investigate the impact of electronic commerce on people in Australia with disabilities, particularly people who are blind or vision impaired. In September 1999, BCA published Accessible E-Commerce in Australia: A Discussion Paper about the Effects of Electronic Commerce Developments on People with Disabilities, one of a series of reports being produced as part of the project. We believe the information provided in the BCA Discussion Paper is vital to the understanding of the needs of people who have disabilities, including vision impairment.

We are also aware that some blindness agencies will make their own submissions to HREOC. In particular, we are aware that the Royal Victorian Institute for the Blind is making a submission and add our support to its content.

In support of the statements made by BCA in October 1999:

• We congratulate the Federal Government on its 1998 amendments to the Copyright Act which streamline the copyright clearance procedures for published works reproduced in accessible formats
• We welcome the introduction into Federal Parliament of the amending legislation which, among other things, extends the Copyright Act to include, under its Statutory Licensing provisions for reproduction of published works in accessible formats for people with print disabilities, electronic formats
• However, we believe a radical simplification is needed of the Copyright Act provision for reproduction of published works in accessible formats in accordance with the Objects and key concepts of the Disability Discrimination Act, particularly Appropriate Adjustments and Unjustifiable Hardship. The Copyright Act should allow the free and unfettered reproduction, exchange and use of published works in accessible hardcopy and electronic formats. This needs to occur unless and until the free distribution is so widespread that it has a significant negative impact on the market demand for the published work and the financial return to the owners of copyright or intellectual property.

People who have disabilities want access to the internet as much as anyone else. Because of improvements made to screen reading programs and cooperation from commercial software developers, access is becoming easier to accomplish. These improvements have made the world wide web a far more rewarding and productive venture than it once was, particularly for people with vision impairment. However, people who are blind can only independently use computers, including internet services, by concurrently running specific screen access software programs. The information that is displayed on the screen by the computer programs is made available non-visually. Screen access programs monitor the computer screen and convert the textual information displayed into synthesized speech or braille on a device known as a refreshable braille display.

While physical access to the web is becoming easier, the majority of web sites are not so easily accessed. Web sites filled with graphics cannot be interpreted by text-to-speech software. Unless web sites become more accessible, people with vision impairment will be left out of the emerging world of online commerce. Web designers unfamiliar with the needs of people with disabilities often assume that taking accessibility into consideration means limiting the aesthetic possibilities of a site. One option, for example, is for the site to provide pop-up text that gives a description of the graphics and can be read aloud by devices for people with vision impairment.

For screen access programs to function effectively in the Windows operating system environment, it is necessary for commercial applications to function in a standard way. Among other things, the commercial application must provide textual labels for all graphics, permit keyboard access to all functions, move the focus whenever the keyboard is used, and rely upon standard Windows controls (for example, dialogue boxes, combination boxes, list boxes, edit boxes and push buttons). Screen access programs cannot read an unlabelled graphic, generally cannot provide an effective way to manipulate a mouse pointer, and generally cannot read or activate non-standard, custom controls that are painted on the screen.

The majority of internet service providers can be used by people who are blind chiefly because they do not force the use of a specific piece of software to obtain that access. Rather, they provide a 'gateway' to the internet, allowing the user to choose the email client, web browser and news reader that functions best with his/her screen access software. However, the largest provider of internet access in the world, America Online (AOL), has refused to adopt this practice. Because of its insistence that users run proprietary AOL software, blind people have been effectively shut out. This has lead to a lawsuit being filed in the USA by nine individual plaintiffs and the National Federation of the Blind. This action is being brought to bring AOL into compliance with the Americans with Disabilities Act (ADA), 42 USC 12101, et seq and Title III of the ADA, 42 USC 12181, et seq.

Problems for people with disabilities arise in regard to both the hardware and the software. The ergonomic requirements of the booths (for example, height, screen angle, circulation space, reach, etc) are crucial for people with a variety of physical disabilities. Work has commenced as part of the revision of AS1428.2, to cover these dimensional aspects of ATMs, information kiosks, and interactive booths for all purposes.

Touchscreens are clearly problematical for people with vision impairments, and we in Australia follow overseas developments such as those of the TRACE Centre in the US with interest, and a view to achieving international standards rather than developing our own.

Through ACROD's representative on the Telstra Disability Forum, we have raised concerns about access to Multimedia Payphones by people with vision impairment. As touchscreens become more common, it is essential that their design, from the outset, enable ease of access by everyone, including those with vision impairment. Measures to do this could include:

• Capacity to increase the size of the characters on screen for individual customers, preferably by storing this information on the customer's card
• Speech output for people who are blind preferably by storing this information on the customer's card – this should give oral assistance and provide sound-based feedback, either in the form of words, or tones and other simple sounds
• Consideration of ways to protect privacy of cardholder's information.

ACROD has also advised Telstra that it has the capacity to contact a variety of disability groups who might wish to be involved in trialling the Multimedia Payphones.

Margaret Verick

Policy Officer (Blindness and Vision Impairment)

ACROD

PO Box 60 CURTIN ACT 2605

Phone: 02 6282 4333 Fax: 02 6281 3488

Email: abfver@ozemail.com.au