A Submission from the Royal New Zealand Foundation of the Blind to the draft Hutt City Long Term Community Plan 

The Royal New Zealand Foundation of the Blind (the Foundation) is a disability support service constituted under the Royal New Zealand Foundation of the Blind Act 2002. It is the primary provider of habilitation and rehabilitation services to over 11,500 blind, vision-impaired and deafblind New Zealanders 

Our vision is that blind and vision-impaired people have the same opportunities and choices as other citizens to participate fully in society. Our mission is to remove the barriers faced by blind or vision-impaired individuals and to promote their participation in all aspects of life. We work in a range of partnerships to ensure that the incidence of preventable blindness is minimised.

Services we provide include specialist assessments, orientation and mobility training for adults and children, communication and adaptive technology instruction, guide dog services, talking book and braille library services, instruction in the techniques of daily living, and vocational services. We operate services specific to the needs of Māori and of Pacific communities. We provide advice and training on access and disability issues.

Accessibility Issues

One of the factors that encourages (or denies) the participation of blind, deafblind and vision-impaired people in community and democratic processes is access. Access may be viewed from a variety of perspectives including access to information and physical access to structures or built environments.  Blind and other print-impaired people use a variety of strategies to access information, but at times this is made more difficult.  One of the ways blind and vision-impaired people access electronic information is through a range of adaptive technologies including programmes which convert text to Braille or text to audio. 

When attempting to access the Hutt City draft Long Term Community Plan it became apparent that the accessibility for blind, deafblind and vision-impaired people to the Hutt City Council website could be improved.  In essence, the full draft Long Term Council Community Plan is only accessible through PDF files, and these do not follow accessibility guidelines.  Furthermore, the summary document does not always give text equivalents for information conveyed as images.  We have provided more detailed information regarding these issues in Appendix 1. 

Design and quality of the built environment is of concern to the blind and vision-impaired community but enhancements that improve the environment for the vision-impaired have the potential to improve the safety of the environment for other users.  This can support increased levels of physical activity such as walking to school/work.  Consideration needs to be given to the sufficiency and adequacy of pedestrian crossings, clear walk-ways and lighting features that enhance safety for all users, including the blind and vision-impaired.  Effective and accessible public transport networks similarly improve the mobility of blind and vision-impaired individuals but also encourage other users to leave their cars and hence attempt at least some of their journey to school or work on foot. 

In terms of the built environment, access may be impeded by poor design or improved through the use of good design and appropriate audit strategies.  Specifically, design can be improved through the application of Universal design principles. 

A fully accessible built environment is one in which any person can freely, and with dignity, express their independence, and one in which any impediment is removed. In relation to the built environment, it is essential that all people can pursue an uninterrupted path of travel, free of any steps, stairs or other impediments, to, in, and through premises; and to be able to utilise services, facilities and programs offered to the general community, in a dignified and equitable manner.[1]

The Foundation recommends that Universal design principles be adopted by Hutt City and that Council undertake an audit of existing buildings. Blind and vision-impaired auditors should be involved. In conjunction with this we recommend that Blindness Awareness and Access training is provide for all Council staff, to increase their level of understanding around disability issues. 

Service Measures

The service measures used by Hutt City in the draft Plan appear to aggregate all responses.  While an ‘overall’ measure may have some use for tracking purposes it will not discriminate between users with different needs, indeed those with specific needs are hidden altogether.  We recommend that the Council review all the outcome measures from the perspective of blind, deafblind and vision-impaired people and measure a variety of indicators of importance to blind, deafblind and vision-impaired people.   In particular, the accessibility of the built environment and information provided by Council should be evaluated in routine outcome measures. 

The Foundation requests that its comments and recommendations are considered and that the Foundation be offered an opportunity to talk to the submission.

Paula Daye

Chief Executive

Appendix 1: Website Accessibility

Downloadable Draft Community Plan

PDF files are not reliably accessible to people using adaptive technology, so if a downloadable version of a document is offered, it is preferable to also offer a format like plain text or Microsoft Word. The NZ e-government guidelines state that "Use of PDF alone for long documents or documents with specific, complex formatting intended for specialist audiences is strongly discouraged. However, if no HTML version is provided, the Acrobat Accessibility Guidelines must be followed" (http://www.e.govt.nz/standards/web-guidelines/web-guidelines-v-2-1/chapter6.html). The PDFs offered on the Hutt City website do not follow accessibility guidelines - for example they are "untagged", which makes it difficult for screen reader software to infer the correct reading order of the document.

Images

In some cases, information is provided in images and is not available in an alternative text form. An example is the pie charts in the "Financial Overview" section of the Summary pages. The alternative text reads "chart", so a user of a screen reader could only learn that a chart was present, and could not read any of the information contained in it. The text labels on the image are very small and have poor contrast, so would be difficult for anyone with less than perfect vision to read, even if using screen magnification software. The information in the charts could be presented in a table below each chart, which would be accessible both to people using screen readers and people using magnification or reading with a larger font size. 

Another example is the Ten year financial summary table on the same page. If this was presented as an HTML table, it would be readily accessible. The current image of a table is completely inaccessible to screen readers and difficult for vision-impaired people to read.

Some images in the Summary document contain too much alternative information - for example the pictures of the woman with orange speech bubbles which run down the left-hand side of the page. The text in the speech bubble is repeated below the image, so there is no need to include it in the alternative text associated with the image. In some cases, the alternative text contains the heading of the related section, which is also unnecessary repetition. The picture of stones that appears on each page is purely visual decoration, and no meaning is conveyed to users of screen readers by using the word "stones" as alternative text. Note that if an image does not add additional meaning to a document, and does not require alternative text, best practice is to include the empty attribute alt="" in the <img> tag, rather than omitting the attribute altogether.

Navigation and Headings

The main navigation around the rest of the Hutt City website is by way of a sidebar. The words which are used to different sections of the website are images of words, which can not be resized and have limited contrast. This could make it difficult for people with low vision to find their way around the site. These images have alternative text associated with them, so should be readily accessible to people using screen reader software. 

Users of screen readers often use HTML headings to navigate around a page. Use of hierarchical heading levels makes it easier for someone using a screen reader to understand the structure of the document, in the same way that a sighted person would infer the relative importance of different headings from their size and colouring. Headings are generally used well throughout the summary document. For example, the main heading on each page is marked as a level 1 heading, which makes it easy for a screen-reader user to skip straight to the main content on a page. However, on some pages, the heading 4 tag is used to make paragraphs look visually the same as a level 4 heading. This could cause confusion for users of screen readers, and would be better achieved by using an HTML paragraph class with the same visual styling. Similarly, column headings within tables are being visually styled using HTML headings, where it would be preferable to use the <th> tag t

[1] Understanding Access Obligations for Development and Building Staff. Published by Access Audits Australia. See http://www.accessauditsaustralia.com.au/access_awareness_handbooks.html.