Comments on Department of Empowerment of Persons with Disabilities 'Vision Document 2030'

We appreciate the efforts by the Department of Empowerment of Persons with Disabilities (DEPD) to put together a vision and strategy document to inform and direct the implementation of the new Rights of Persons with Disabilities Act, 2016 (RPWD), and give effect to the rights of persons with disabilities as enshrined in various international treaties.

Overall, we recommend that the vision articulate more clearly in terms of quantifiable targets what it seeks to achieve at different points of time and that these targets, while taking into account the realistic situation in our country, are not so minimally set as to undermine the aims of the Act and the national commitments outlined therein.

We submit that it be kept in mind that this is not the first time that a national conversation has taken place around accessibility and standards, and that many previous attempts such as the Guidelines on Indian Government Websites (GIGW) have been in existence for nearly 8 years.

Therefore, we submit that the steps taken towards implementing this act should be more ambitious, and should seek to resolve the issue within the next 2-3 years. Accordingly please find our brief comments below:

Background

1. Section 2(i) is as follows: Vision: ‘To build an inclusive society in which equal opportunities are provided for the growth and development of Persons with Disabilities so that they can lead productive, safe and dignified lives.’ We propose the addition of the word ‘integration/inclusion/assimilation’ as in the phrase ‘growth, integration and development’, since that implies social acceptance, which is crucial.  We also propose the addition of one more sentence as follows: ‘To enable access to technology and technology enabled resources for every person with a disability to facilitate effective communication and integration in society, as well as to ensure that accessibility considerations and standards are included across the board in all government programmes and initiatives.’
2. We propose in 3(a) - the inclusion of the word technologies in the phrase ‘providing appropriate aids and appliances.’ This is important since aids and appliances are not always technology-based and often times a new technology may be suitable, efficient and contemporary to address a specific need.
3. We propose in 3(b) - the inclusion of the word accessibility in the phrase ‘developing rehabilitation professionals/personnel.’

Long Term Vision by 2030

1. Inclusion of curriculum related to e-accessibility such as knowledge of the Web Content Accessibility Guidelines (WCAG) and universal design principles in all institutes and institutions teaching courses in engineering, computer science, IT etc.
2. Inclusion of disability-related issues in the curriculum of university courses in other fields as well, such as law, sociology, economics, and architecture.
3. Creation of a mechanism to gather more comprehensive and accurate data on persons with disabilities, such as their levels of access to technologies, information and basic resources and amenities.
4. Provision of training to use computers for students and children with disabilities in rural areas and provide training to students receiving aids and appliances as part of schemes. In addition, the Government should also focus on providing appropriate training and access to appropriate content in order to make full use of these technologies.


Seven Years' Strategy

5. The point about making documents, buildings, websites, documents etc. accessible under the Accessible India campaign [1] is appreciated; however, it should be accompanied with a mechanism for transparency and accountability. This should include periodic reports giving updates on the details of websites, documents, etc. taken up for retrofitting. At the moment, this information is not available on any of the public domain web sites such as the Accessible India campaign URLs, and repeated RTIs have failed to make this information available. Hence, there is no clarity on what the exact number of URLs and documents which have been made accessible so far is. Without accountability built into this procedure moving forward, there is very little to ensure that it happens.

Three Years Strategy

1. Review of legislations for persons with disabilities : we propose that a time line be set for this, say within 6 months and a list of existing and new policy/ legislation requiring interventions/ formulation be drawn up for action. Priority tasks could be to take up accessible procurement, accessibility of mobile applications, web sites and electronic documents.
2. One of the foremost tasks should be to identify and notify appropriate standards for different domains of accessibility such as procurement, electronic documents, television and so on, as well as  reaffirm/ update any existing standards already recognized by the Government so that the process of retrofitting existing resources, as well as building new accessible ones commences at the earliest.
3. It is recommended that the Government of India put together an advisory committee of subject matter experts from NGOs and other civil society bodies who can advise on initiatives to be taken for environmental and information accessibility.
4. Regarding the plan for making 50% of all government web sites and documents accessible[2] , this target needs to be revised. The Accessible India campaign, which lists the same target in its strategy document,[3] has already been underway for the past one and a half years, and we hope that this target would have already been achieved under those efforts. Hence, if the Government sets a target of 50% over the next three years, this implies either that work has not been taking place thus far, or that very little will be done over that period of time. Furthermore, the RPWD Act requires all service providers to make their services accessible within 2 years of notification of regulation by the Central Government[4], hence the time stipulated under the Act is much lesser than the vision is providing for and should be amended to making all web sites and documents accessible within 2 years. It may further be noted that the GIGW had been notified since 2009 and despite being in place for eight years, there is currently no official information on how many websites been made fully compliant with these standards. Therefore, we submit that a strict approach with regard to any deadlines and regulatory measures are necessary.
5. It is respectfully submitted that the number of 500 language interpreters[5] is simply not enough. This would work out to approximately 15 interpreters per state in 3 years, a number that we consider far too low for the time allotted. We submit instead that it is urgent that an attempt be made to train at least 30 people per state/UT per year, which would work out to 90 interpreters per state/UT over the 3-year period.
6. It is crucial the DEPD try to work with the Digital India campaign and the Smart Cities Mission to ensure that upcoming smart cities are born accessible. To this end, there needs to be specific measures to ensure that accessibility standards are part of the Terms of Reference and contracts for smart cities and that there is sufficient guidance and accountability for this.

[1]. Section C.6

[2]. Section D.6

[3]. http://www.disabilityaffairs.gov.in/upload/uploadfiles/files/Accessible%20India%20Campaign_Brochure.pdf

[4]. Chapter VIII, Section 46

[5]. Section D.7