1.1 The European Blind Union (EBU) welcomes
the initiative on digital libraries launched by the European Commission within
the framework of the i2010 flagship initiative. We appreciate the opportunity
to provide input at this early stage of the digitisation process
1.2 EBU is a non-governmental, non profit-making European organisation founded
in 1984. We are recognised and supported by the European Commission. One of
the six regional bodies of the World Blind Union, it is the only Europe-wide
organisation representing the interests of blind and partially sighted people.
1.3 EBU aims to protect and promote the interests of all blind and partially
sighted people in Europe. EBU currently has 44 member countries; each
represented by a national delegation. Its work is directed by an Executive
Board of 11 elected members, which is accountable to a General Assembly held
every four years. The detailed work of EBU is carried out by Standing
Commissions and Working Groups, whose areas of activity reflect the interests
of EBU members. We are affiliated to the European Disability Forum.
1.4 EBU is happy for the Commission to use and disseminate this response and
is keen to be further consulted as the digital library project proceeds.
2.1 The Commission has a duty to ensure that
the digital library project develops in such a way as to guarantee full
accessibility for disabled citizens in general, and those who are blind or
partially sighted in particular.
2.2 It is essential that the project develops within the overall context of
Europe's e-accessibility programme. It is vital to take these issues into
account from the outset, while technical and procedural standards are still
being developed. Retrospective work on accessibility for people with
disabilities will be much more expensive and much less effective.
2.3 Some thirty million people in the European Union have some form of visual
impairment, while a great many others experience difficulty in accessing
information as a result of dyslexia or other reading related disabilities.
Denying access to the material in question to a significant proportion of the
population would undermine the ultimate aim of this initiative, to enhance
competitiveness across Europe. It would also be contrary to basic concepts of
fairness and social inclusion.
2.4 Digitisation, and the overall spread of information and communications
technology (ICT) is potentially hugely promising. . People with a sensory
disability have for many years had fewer opportunities to read using
traditional and specific reading and writing methods. Documents have been
inaccessible not because of their location but because they existed only on
paper. Broadening the range of what is available could secure the inclusion of
people with a visual impairment in this fundamental process. On the other
hand, if the needs of these users are overlooked, a golden opportunity will
have been lost.
2.5 To advance the needs and interests of people with visual impairment and
safeguard their equal opportunities, we wish to put forward a number of
suggestions that will help to guarantee that this group does not suffer
discrimination or exclusion from this interesting and necessary European
initiative.
3.1 To provide expert opinions and existing
expertise on universal accessibility, it will be vital to have at least one
representative of people with disabilities on the high level group of experts
the Commission intends to set up.
3.2 In addition, it is essential that disabled librarians and other users,
including a cross-section of blind and partially sighted people, are involved
in testing and evaluating the project at all levels as it develops. We
recommend close liaison with bodies such as the Libraries for the Blind
Section of the International Federation of Library Associations (IFLA).
4.1 In its Communication the Commission
employs the term “accessibility” in a general sense, without specifically
mentioning the accessibility of digital libraries to people with disabilities.
The fact that information is "accessible" to the public, by virtue of being on
a publicly accessible web site, does not mean everyone can "access" or read
it.
4.2 Blind, partially sighted and other print disabled people must be able to
access material through audio or tactile output or by enlarging or otherwise
modifying the visual display. Poor design, inappropriate formats or inept
protection measures can render such access impossible.
4.3 Consequently, we believe it is vital to define clearly the concept of
“accessibility” by extending it to “universal accessibility”. This concept
covers a condition that must be met by all environments, processes, goods,
products and services and by all objects and instruments, tools and devices in
order for them to be comprehensible, usable and practicable for all people,
including people with a disability, in line with the e-Accessibility stream of
the i2010 strategy.
4.4 Similarly, we believe future instruments related to this subject, such as
the forthcoming Recommendation on digitisation and digital preservation and
the Communication on the accessibility of scientific information, should
specifically take universal accessibility into account from the outset.
4.5 More broadly, support should be given to initiatives such as horizontal
accessibility programmes that, on the one hand, ensure that projects receiving
funding are accessible and, on the other, provide additional financial support
to those projects that more thoroughly address the issue of accessibility. The
seventh Framework programme, the e-Content plus programme, the Culture 2007
programme and structural funds should all be addressed from this perspective.
5.1 The so-called “on-line accessibility” of
material, an expression used many times during the consultation, must be
fulfilled in its widest sense. It must enable any European citizen, using any
ICT tool, to read any document placed at his or her disposal. If this is not
the case, people with disabilities will never be in a position to benefit from
digitisation and the creation of a European digital library.
5.2 In all digital library projects, the highest standards of web design must
be routinely observed. The guidelines laid down by the Web Access Initiative (www.w3c.org/)
must be fully implemented.
5.3 Accessibility is changing rapidly: from an add-on element that was only
taken into account at the end of the information production chain, it is fast
becoming a driving force for change. New technologies are emerging that enable
information producers to structure documents that meet current accessibility
legislation. This process opens up new markets and new opportunities for this
material. By integrating existing technologies with processing systems it is
possible to incorporate actively the different needs of end users, thus
widening the range of opportunities to use the same information. At the same
time, new and powerful ways to handle information, benefiting all possible
users, emerge as the content is structured more clearly.
5.4 Thus there is great potential for building in true accessibility. However,
even existing access features are not always used by content authors, ignorant
of their existence or their importance.
5.5 At the present time, we can and should benefit from current existing
standards concerning the creation and structuring of digital documents that
can be handled by blind and partially sighted persons. It is not necessary to
use special formats or formats that are difficult to migrate to other
standards, nor add yet another process at the end of the digitisation and
storage chain. From the outset we should select and apply one of the different
document creation standards that fulfil accessibility guidelines. Document
creation standards used by a great number of large European printing houses,
such as XML (in its widest sense, or the different types that have been
developed for specific kinds of documentation) provide important benefits both
to those producing the document and those who will later read it.
5.6 We strongly urge the leaders of the digital library project to work
closely with the partners in the EUAIN Project (www.euain.org),
funded under the Sixth Framework Programme, which is addressing all these
issues.
5.7 We also commend to the project team the work of the Daisy Consortium (www.daisy.org).
5.8 We should bear in mind that digitised documents whose end format will be
an image or a number of images that show the different pages of the original
document are only accessible to fully sighted people. We are, of course, aware
of the need to preserve the look and appearance of certain documents due to
their historic value, for aesthetic reasons and so on but, regardless of how
content is presented, is it equally important to make it known to all European
citizens.
5.9 Little will have been gained if accessible web sites lead only to
documents and records which are themselves inaccessible because of the way in
which they had been digitised.
5.10 There is a particular problem with handwritten documents. We are not
aware of any existing programmes which can scan handwriting in such a way as
to produce records accessible by non-visual means. To transcribe handwritten
material would be very labour-intensive and thus very expensive. We therefore
call for resources to be devoted to research into ways of scanning handwriting
which result in accessible records. Failing this, resources will have to be
devoted to manual transcription if digitised documents are to be truly
accessible.
6.1 The attitude of those who hold copyright
in documents in digital format will have a serious impact on the extent to
which these works are made available to the general public. It is therefore
advisable to separate the two processes of digitisation and access to the
digital document. This will secure the digitisation of as much information as
possible. Access can then be accorded or denied on the basis of exceptions to
copyright for various categories of people.
6.2 The European Copyright Directive (EC/2001/29) allows member states to
enact copyright exceptions for the benefit, inter alia, of people with reading
related disabilities and of libraries. Unfortunately, it does not require such
exceptions, nor does it in any way guarantee consistency amongst the
twenty-five legal regimes in the Community. Pending any improvement to this
shortcoming in copyright legislation, those who do benefit from exceptions
should be able to enjoy them in accessing the riches of digitised library
records.
7.1 There are now technological methods to
protect digital documentation and control access to it. These methods vary in
sophistication and effectiveness. They can inadvertently or deliberately
exclude people using screen reading technology to access content. Thus extreme
care should be exercised in determining what rights management or access
protection technologies are deployed.
7.2 We require the same level of services for the proposed digital library as
exists for conventional libraries. A digital library should be no different
from a “paper” library in terms of the right to read works that are
copyrighted as an alternative to acquiring a personal copy of the work.
Accessing a document in digital format to read it does not necessarily mean it
is downloaded or that a permanent copy is being stored, nor does it imply that
it will be used or distributed indiscriminately (as with printed books, which
are lent out but are not necessarily copied indiscriminately, although this is
possible).
7.3 Technical measures that already exist, or that may be developed, to
protect digital documents (Digital Rights Management) enable us to control the
reading, download, copying and distribution of documents. In the case of
material that may form part of the European digital library archive, it is
vitally important that the rights of blind and partially sighted users to
access works that are protected by some technical measures are respected.
8.1 It would also be advisable to enhance
the standardisation of rules regarding the legal deposit of material in each
Member State.
8.2 One possibility would be to create a European legal deposit for material
in digital format or digitised material that can be accessed from different
countries and to which certain authorised companies, organisations or public
bodies could have access within the limits set down in each case.
8.3 In the same way, it is vital that protected material is handed over to the
respective legal deposit bodies without such protection in order to guarantee
that people with disabilities may exercise their right to access all protected
digital material.