11^th November 1999

Mr David Mason
Secretary
E-Commerce Reference
Human Rights & Equal Opportunity Commission
GPO Box 5218
SYDNEY NSW 1042

Dear Mr Mason,

Thank you for the opportunity to comment on the Issues Paper you released on 13^th September 1999. I want to congratulate the HREOC on the quality of the Issues Paper, and on taking on this important work.

Your Issues Paper seems to address all the major areas relating to accessibility of electronic commerce and other new service delivery technologies for older Australians and people with a disability. It would be good to see you add specific reference to the need for improved access to regular telephones, as distinct from mobile phones, which you mention already. A further example of accessibility that could be relatively easily improved in Australia is TV captioning: in the U.S. all new television sets over a certain screen size are required to have captioning capabilities, and this regulation needs to be introduced in Australia also.

I believe it would be helpful in your report to introduce the unifying concept of Universal Design. Universal Design can be defined as "the design of products and environments that can be used and experienced by people of all ages and abilities, to the greatest extent possible, without adaptation". There is little doubt that this will become a central concept as organisations move to meet their responsibilities under the Disability Discrimination Act. However, to date in Australia, there is no education and training in Universal Design, there is little awareness or understanding or application of it, and no enforcement, rewards or awards.

For further information on Universal Design, see Follette, M. "Maximizing Usability: The Principles of Universal Design", Assistive Technology Vol 10.1/1998, pp 4-12, RESNA Press, or the following web sites:

• The Center for Universal Design

North Carolina State University

www.design.ncsu.edu/cud/

• Trace R&D Center
  www.trace.wisc.edu/world/

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I have also attached a draft poster currently in preparation by the National Committee on Rehabilitation Engineering of the Institution of Engineers, Australia, which is seeking to promote awareness of the concepts of Universal Design.

Please don't hesitate to contact me or the National Committee on Rehabilitation Engineering for any further assistance in preparing your report. The National Committee on Rehabilitation Engineering is best contacted via its listserver: ncre@mech.uq.edu.au