Submission to the Ministry of Economic Development. March 2005.

Fair and reasonable access to telecommunications

In making this submission, the Foundation is asserting its view that telecommunications is a key area in which "policy and other activities enhance rather than disable the lives of people with impairments" (New Zealand Disability Strategy: "Vision of a non-disabling society").

For all New Zealanders, "fair and reasonable access" to the information and communications technology infrastructure - "connectivity" - is central to the success of the New Zealand Digital Strategy.

Telecommunications and a more equitable society

Telecommunications services have the potential to be a powerful means of helping reduce the disabling effect of a society that does not provide all citizens with the same level of access to written information, services and businesses. Blind, deafblind and vision-impaired people are citizens who participate in the economy and pay taxes but cannot independently access many services others take for granted.

No disabled person should have to rely on charitable donations and voluntary agencies to access the services and businesses made available to the public. Such reliance is inequitable.

Foundation hopes in respect of this review

• Use of the Telecommunications Act 2001 advances the human rights objectives of the New Zealand Disability Strategy, and of whole-government strategies that have a telecommunications component.
• Swifter progress towards broadband infrastructure and more reasonable pricing that will enable a range of commercial providers and social enterprises to develop innovative services.
• A mechanism for the Minister to communicate policy statements directly to the Commerce Commission as required.
• TSO (Telecommunications Service Obligation) levies do not unfairly burden end-users.
• There is a transparent regime for handling TSO non-compliance.
• A facilitation and mediation process to handle complaints is introduced and integrated with a code of practice.
• A group representative of telecommunications end-users is funded by the Government to act as the voice of the public in Commission activities under the Act.
• a code of practice for telecommunications providers is developed in consultation with such a group.
• The code of practice addresses matters of reasonable accommodation and accessibility for people who are blind, vision-impaired and deafblind.
• The telecommunications framework fosters creative and innovative responses to 21st century needs and opportunities.

Accessibility

The Foundation continues to advocate for creative responses to the challenges and opportunities of the digital age.

Requiring all telecommunications providers to consider the accessibility of their products and services would promote equity and support the engagement of blind, deafblind and vision-impaired citizens in education, employment, and the economy. The Foundation endorses the observation that some aspects of an accessible telecommunications service will be a service rather than a technical system. The Foundation also agrees that the Government's wider policy objectives (e.g. the New Zealand Disability Strategy and the New Zealand Digital Strategy, when) should be more fully aligned with the use of the Telecommunications Act 2001.