The Broadcasting Choices for Slovenia Regarding Accessibility

With permission from Ms Andrea J Saks, we hereby publish her letter of October 17, 2016, addressed to Dr Dušan Caf, Executive Director of the Digitas Institute.


Dear Dušan,

I would like to congratulate you on the establishment of a new institute for digital policies, including accessibility of audiovisual media services. I believe this will be a great step for the discussion on global interoperability and effective accessibility in Europe.

As the chair of Joint Coordination Activity for Accessibility and Human Factors at the International Telecommunication Union (ITU), a UN agency, as well as someone who has been working in the field of accessibility for persons with disabilities for many years and at the ITU since 1991, I would like to point out some aspects of accessibility requirements for broadcasting and television and to recommend a path forward so that the interests of persons with disabilities, older persons with age related disabilities and those with specific needs will not be hindered.

In this respect, I would like to draw your attention to two Recommendations from ITU-T regarding accessibility. The first ITU international standard for accessibility was ITU-T Rec. Y.1901 »Requirements for the support of IPTV services«, which was consented in 2009. It included user requirements and public service requirements. I was a part of that team that included the accessibility features. And the other one is the ITU newest international Recommendation ITU-T Rec. H 702 »Accessibility profiles for IPTV systems«, consented in October 2015. Although these Recommendations bear the term »IPTV« in them, their requirements are rather general and can be referenced by any broadcasting service. It was so agreed that European Broadcasting Union and ITU-T SG9, the cable broadcasting group, are recommended to consider them as their respective standards on accessibility.

Let me elaborate on some of the requirements for accessibility in television broadcasting to provide functional equivalence as required by article 9 in the United Nations Convention on the Rights of Persons with Disabilities (UNCRPD). We must provide sign language for those who are culturally deaf and captioning for those who are losing their hearing later. YOU must have both as some persons are not able to use sign language and never have used sign language and they need captioning. Sign language is vital for those who have it as their only language. The same sort of problem applies to those who are blind from birth or from accidents or health problems and to those losing their sight through ageing. They have different needs and there are different solutions. Some will require audio captioning and others just audio descriptions, and others will need both as in the case of persons who are deaf blind. All these features must be closed and selectable by the users. All these techniques are standardised by the ITU already and are working in the world. It is called IPTV.

I understand that there is a trend in Europe to promote HBBTV as a way to provide interactivity, which has not been available for public broadcasting in Europe except for a few countries like the UK and Italy. But I would like to recommend a cautious approach toward going overboard with HBBTV. As far as accessibility to media and broadcasting is concerned, interactivity does not necessarily mean accessibility, and interactivity itself may bring up even more issues with accessibility for persons with disabilities, with possible consequences of even inequality and discrimination.

HBBTV, as I understand it, resorts to the Internet service to supplement the broadcasting signal for features such as closed captioning and audio description (Note that interactivity is not an issue here). If the HBBTV system is used for free-to-air broadcast services, such as public broadcasting, then it implies that the cost of additional features delivered on the Internet should be covered by someone, but the viewer cannot be required to pay because it would mean the service is not »free«. Especially when the viewer is a person with disability, like a person who is deaf, the cost of the additional feature of closed captioning should not be borne by the viewer because this would discriminate the person who is deaf. It certainly cannot be the persons with disabilities or older persons with age related disabilities and those with specific needs that will be required to pay for the extra cost.

It should also be noted that DVB-T already has a specification for closed-captioning, for example, standardised already in the early 2000’s. If Slovenia has already adopted DVB-T, then it should be able to provide some accessibility features already, without a recourse to the Internet or a hybrid approach. If DVB-T already specifies accessibility features and Slovenia has adopted DVB-T, and if accessibility features are not provided now for persons with disabilities, then how can one expect these features will be provided if HBBTV is adopted and implemented?

Thus it begs the question whether the tandem use of broadcasting signal and the Internet delivery will help anyone, especially in the regions, such as Slovenia, where IPTV is already available, as the latter can provide both the main content as well as the accessibility features on a single delivery medium, the Internet Protocol. IPTV is also interactive. It can include all accessibility features without the need for broadcast spectrum. Currently many people receive video content over IP anyway and IPTV will be a good convergence point for these services.

In my opinion, HBBTV has failed Europe for persons with disabilities especially persons who are deaf and hard of hearing, including those who are deafened later in life. With the life expectancy increasing this population will increase. Persons who are blind or sight impaired are also not included properly. This also will be impacted by the increased life expectancy. HBBTV can’t accommodate all these varieties of needs without resorting to different or specialized channels and unsociable times to have accessible emissions or going to the Internet and IPTV to provide accessibility features. This is discrimination which technically is unnecessary with IPTV.

As Slovenia ratified the UN CRPD on 28th April 2008, the Slovenian Government is responsible for ensuring that the UN CRPD is implemented and equal opportunities of persons with disabilities will be ensured. Choosing HBBTV, which requires the Internet service to receive accessibility features, may result in violation of UN CRPD, as it may be discriminatory. This would be a grave situation for persons with disabilities.

Accessibility features are not some »niceties« or »luxury« for some future time. They are urgent and essential features for persons with disabilities, who need to access to information and media daily. I hope you will take these points into consideration when you decide on the way accessibility policies are implemented and your new organisation is run.

All the best,


Andrea J Saks
International Telecommunications Specialist for the Deaf
Chairman ITU JCA-AHF (Joint Coordinating Activity on Accessibility and Human Factors)
Coordinator IGF DCAD (Dynamic Coalition on Accessibility and Disability)