Submission to ACCAN
Campaigning for Consumers in
Communications
October 2009
Deafness Forum of Australia
218 Northbourne Avenue
Braddon, ACT, 2612
02 6262 7808
Contents
Page
Contents ..................................................................................................................................... 2
1.
Introduction ................................................................................................................. 3
1.1. About the Deafness Forum ......................................................................................... 3
1.2. Our consultation process ............................................................................................. 4
2.
Our comments and answers to questions .................................................................... 4
2.1. General comments ...................................................................................................... 4
2.2. Communications are essential services ....................................................................... 4
2.3. Making the market work for consumers ..................................................................... 5
2.4. Ensuring availability, affordability, and accessibility................................................. 5
3.
Conclusion .................................................................................................................. 7
4.
Contact ........................................................................................................................ 7
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1.
Introduction
Currently, one in six Australians has some form of hearing impairment, and this is
projected to increase to one in four by 20501. Accordingly, it is imperative that the
communications needs of this large and growing sector of society are satisfactorily
met.
1.1.
About the Deafness Forum
Deafness Forum is the peak body for deafness in Australia. Established in early
1993 at the instigation of the Federal government, the Deafness Forum now
represents all interests and viewpoints of the Deaf and hearing impaired
communities of Australia (including those people who have a chronic disorder of the
ear and those who are deafblind).
Deafness Forum members, whose views are incorporated into this submission,
include:

Numerous Better Hearing Australia branches, including Better Hearing
Australia (National)

Most State-based Deaf societies

SHHH Australia (Self Help for Hard of Hearing People)

CICADA groups (Cochlear implants)

Deafness Councils

Deafness Foundation

Many service provider associations such as Deaf Children Australia,
Audiology Australia, Australian Communication Exchange.
Deafness Forum is the peak body for deafness in Australia. Established in early
1993 at the instigation of the Federal government, the Deafness Forum exists to
improve the quality of life for people who are Deaf, deafblind, have a hearing
impairment or a chronic disorder of the ear. We do this across all areas of deafness
and hearing health, through:

Education and information

Systemic advocacy

Consultation

Recommendations to government on policy and legislation.
1
Access Economics: Listen Hear! The economic impact and cost of hearing loss in Australia, February 2006,
pp.41
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1.2.
Our consultation process
Deafness Forum has consulted with members in all states of Australia to gather
feedback on this topic. Some specific comments have been included throughout the
paper to illustrate particular points. Our responses represent a large number of
comments received from individuals and organisations in the deafness sector,
combined with our own deductions (from our Telecommunications Issues Advisory
Panel) and based on our continuing engagement with members.
2.
Our comments and answers to questions
2.1.
General comments
We agree that it is important for ACCAN to aggressively encourage and support
consumers. Our constituents are an often ignored sector because their disability is
invisible, and often misunderstood.
We agree with the five key issue areas:
o
o
o
o
o
Making the market work for consumers
Ensuring availability, accessibility and affordability
Shaping the National Broadband Network
Guarding security, privacy, and fair use
Supporting responsible consumption.
These issues affect all Australians. Some of the issues are of greater concern to
people who are Deaf, deafblind, have a hearing impairment or a chronic disorder of
the ear.
It is important to have clear definitions especially of “consumer” and small business.
See also our later comments about “Deaf”. If the term consumers including people
with disability there is no need for specific or individual references eg to Deaf.
We are hopeful that once ACCAN’s strategic plan is developed, that ACCAN may
convene some roundtables to bring all interested parties to the table on areas of
particular concern. This could include emergency services.
We agree it is important to have consistent standards across all States and
Territories and consumers should not be at the mercy of differing standards because
of their location. We agree ACCAN should lobby for this consistency.
2.2.
Communications are essential services
Communications are central to the lives of consumers and this is especially true of
people who are Deaf, deafblind, have a hearing impairment or a chronic disorder of
the ear. For these consumers, telecommunications are a vital link with others, as well
as a source of frustration.
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We believe that internet-based, mobile and interactive technology are increasingly
becoming essential services, especially for people for whom standard telephone
services do not provide appropriate access.
When internet-based information and services were first available, they were largely
text-based which gave people whoa re Deaf, deafblind, have a hearing impairment
or a chronic disorder of the ear access. However, emerging technologies have
increasingly reinforced accessibility barriers such as online videos without captioning
or Auslan interpreting. From being a boon and favoured son for our constituents,
online technologies have now moved into excluding people.
We believe that internet-based, mobile and interactive technologies, as well as new
and emerging technologies, are a key area for ACCAN to focus on to ensure social
inclusion.
We urge ACCAN to use appropriate terminology. Your consultation paper states
“consumers with disabilities including Deaf”. We urge you to consider all groups, we
do not agree with singling out Deaf.
People who are Deaf, deafblind, hearing impaired, chronic disorders of the ear – all
equally deserve advocacy and representation. As do any other consumers with
disability. Using the term Deaf alone has a certain meaning and we do not agree that
the term Deaf alone should be used.
2.3.
Making the market work for consumers
We agree that service is an important consideration. This can be especially
problematic from people whoa re Deaf, deafblind, have a hearing impairment or a
chronic disorder of the ear, as they can be disadvantaged in the process of seeking
customer service, and in making a complaint about it.
Consumer literacy is also of concern to us.
Deafness Forum has already instigated a training program for new recruits to
telecommunications advocacy, as well as advocacy and lobbying training for
experienced representatives. This has been done through the Telecommunications
Consumer Representation Grant Program from DBCDE. We would be reluctant to
see ACCAN re-invent the wheel when we already have some good groundwork laid
in this area.
2.4.
Ensuring availability, affordability, and accessibility
Access to emergency services and warning systems from popular emerging
technologies like Voice over IP is not guaranteed. This raises a number of
challenges to the effectiveness of the system and consumer awareness of
arrangements.
Consumers with disabilities also require support to access
emergency services through mobile phones and text. This is of major concern to us.
We have some very specific interests for our constituents which we expect would fall
under this area of ACCAN’s work. While we do not expect them to be listed
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specifically in ACCAN’s strategic plan, I outline them here for your information (not
necessarily in order of importance):
1. Captioned Telephone
- Service to be government funded
- Handsets on DEP or government funded
- Emergency services access
- ACCAN policy on Captioned telephone to line up with DF policy on
captioned telephone as the organisation with primary interest in this work.
2. Video Relay Service
3. Text over IP
4. Independent DEP
It is essential that an independent DEP be established, and that consumers must not
be asset-tested, or that access is only for health care/Pension card holders.
The DEP also needs to include the following:
- Neckloops for mobile phones
See the Deafness Forum information sheet for more information
- Tone control
- on fixed phone
- on cordless phone
Tone control can make the difference between understanding and giving up
- Videophones
- landline
- mobile
- additional costs
- Computers and webcams
5. Information and Accessibility Code and guideline
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The failure of the Information and Accessibility Code and guideline to include basic
essential requirements of people with hearing loss means that the current code is a
failure for our constituents, no matter how well it is known and enforced.
It must be expanded to show what our consumers need, rather than what a supplier
can be bothered telling us.
6. Captioning of online audio (whether video is attached or not) or have transcripts
made available. One possible scenario is that this should start with Government
websites immediately, with a 12 month lead time for others, and be enforced with
legislation.
There is proposed legislation on this very issue in America at the moment and
ACCAN should be monitoring and relaying its progress / amendments etc to the
Australian government.
Captioning of television at 100%, with quality targets that must be met. This includes
free to air, and pay TV.
7. Shaping the National Broadband Network
3.
Conclusion
We are in general agreement with ACCAN’s plans. Please refer to specific
comments about terminology and definitions above.
4.
Contact
If you have any questions about the information contained in this submission, please
contact
Nicole Lawder, CEO,
Deafness Forum of Australia
218 Northbourne Avenue
Braddon ACT 2612
Phone 02 6262 7808
www.deafnessforum.org.au
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