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Speaking TV guides: would they help people with visual impairments and are they feasible?

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Speaking TV programme guides

Would they help people with visual impairments, and are they feasible?










Call for inputs

Publication date:

10 July 2014

Closing Date for Responses:

8 September 2014

About this document


This document is a ‘call for inputs’ on speaking TV guides. Ofcom is seeking views on whether these guides could help blind or visually impaired people, and if it would be feasible to introduce them across the UK’s TV services.

Around two million people have visual impairments that make it difficult or impossible for them to use on-screen TV programme guides, though watching TV remains important to them. We are seeking views from interested parties, particularly visually impaired viewers and TV service providers.

In particular, we would like to know whether TVs and set top boxes that allow people to hear information in on-screen TV programme guides could make it easier for blind or visually impaired viewers to choose what they want to watch.

Ofcom would also like to hear whether other forms of assistance – such as mobile apps – currently offered by TV providers could be a suitable alternative to speaking EPGs.

We will consider carefully what respondents say, before deciding whether or not changes to our guidance to EPG providers may be appropriate.


Contents




Section



Page




Annex



Page


  1. Section 1

  2. Summary

      1. Call for inputs

        1. In this call for inputs, Ofcom is seeking the views of interested parties, in particular of visually-impaired viewers and TV service providers, on the benefits of and scope for on-screen programme guides (often known as Electronic Programme Guides or EPGs) that can read out programme information. Please send us your response by 8 September. Annex 1 explains how this can be done.

      2. Many people who are blind or visually impaired can find EPGs on television difficult or impossible to use

        1. Most TV viewers are familiar with the on-screen programme guides or EPGs that come with our digital TV services, whether provided by Freeview, Freesat, Sky, Virgin Media (Virgin), BT or TalkTalk. On average, people watch just over 4 hours of TV a day1, and these guides play an important part in helping viewers choose live programmes, make recordings and select catch-up or other on demand content to view.

        2. Most of us take these EPGs for granted. However, as we explain in section 2, an estimated 1.8 million blind or visually-impaired people in the UK can find it difficult or impossible to use EPGs, even though they watch just as much TV as everyone else. The number of people with sight problems is projected to increase, as the UK population ages.

        3. Those who find it difficult or impossible to use EPGs are unlikely to benefit fully from the wide range of broadcast programming now available, even though much of it is audio described. As EPGs become an important gateway to online content, such as live-streamed TV channels and on-demand films, the gap between the benefits available to those with and without visual impairments is likely to widen significantly.

      3. Ofcom has a duty to require EPG providers to make their EPGs accessible

        1. Recognising the importance of EPGs to consumers, Parliament gave Ofcom a duty (explained in section 2) to provide guidance on the practices to be followed in the provision of EPGs. These practices must include the incorporation of such features as Ofcom considers appropriate for ensuring that people with disabilities affecting their sight or hearing (or both) may use EPGs for the same purposes as other people, so far as practicable.

        2. To this end, Ofcom’s Code of practice on electronic programme guides requires EPG providers, amongst other things, to ‘make such adjustments to their EPGs as are practicable to secure that they can be used by people with disabilities affecting their sight or hearing for all the same purposes as they are used by other people’.

        3. The practices we can require extend only to the use of EPGs in relation to the listing or promotion of programmes included in programmes services (TV channels), not to programmes included in catch-up or other on-demand services. However, given our other duties (also summarised in section 2), we want to encourage relevant parties to ensure that those parts of EPGs that provide a gateway to catch-up and other on demand services are also accessible to people with visual impairments.

      4. We think ‘speaking EPGs’ could be the best way of helping people with visual impairments to make better of use programme guides

        1. EPG providers have already incorporated a variety of accessibility features in their EPGs, including features that allow high contrast displays, a choice of colours for backgrounds and text, the ability to magnify text, and audible cues for programmes with audio description. Some have also developed apps that can be used with mobile devices (such as phones or tablets) to voice information about TV programmes, and control some aspects of the TV. We summarise these in section 3. Ofcom’s understanding is that these features are helpful to some people with visual impairments, but do not meet the needs of all, particularly those with no useful vision, and those with restricted vision who may struggle to afford or use unfamiliar devices.

        2. Ofcom has considered whether there may be scope for EPG providers to do more to improve the usability of their EPGs. In particular, we have sought to assess the potential for speaking EPGs, having regard to commercial and technological developments, and to the discussions we have had with several of the leading EPG providers. We have also considered representations from the Royal National Institute of Blind People (RNIB).

        3. On the basis of information gathered so far, Ofcom considers that:

            1. including features in EPGs that allow text to be voiced (so-called text- to-speech, or TTS) may make it much easier for people with visual impairments to use EPGs for more of the same purposes as sighted people;

            2. it may now be practicable for providers to incorporate such features in future versions of their EPGs; and

            3. ancillary devices and applications that some EPG providers are offering as an alternative are likely to be helpful to some visually-impaired TV viewers, but may be difficult to use and expensive to afford for many visually-impaired viewers, so may not be adequate substitutes.

        4. We now wish to seek evidence and comments in relation to these propositions.

      5. We would welcome your views and any evidence you can provide

        1. Ofcom would welcome responses from any people or organisations with an interest in this issue, in particular from visually-impaired TV viewers and EPG providers. We have asked some specific questions in this document, but would also welcome any other comments in relation to the issues considered in this document. Annex 1 explains how you can respond to this document, including by phone if you would find that more convenient.

        2. This document is available on Ofcom’s website in a PDF version which is compatible with most screen-readers. We have also prepared an audio version of this document, which can be found on Ofcom’s website at http://www.ofcom.org.uk/static/consultations/7940-speaking-tv/speaking-tv.mp3 Please note that the audio version may take some time to load.

        3. If you would like this document in an alternative format or another languages, you can call our Advisory Team from Monday to Friday between 09:00 and 17:00 on 020 7981 3040 or 0300 123 3333. If you are deaf or speech-impaired, you can use our textphone numbers, which are 020 7981 3043 or 0300 123 2024. We will consider all reasonable requests.

        4. We explain in Annex 1 how you can respond to this document, including by phone if you would find that more convenient.

  3. Section 2

  4. Legal framework and background

      1. Introduction

        1. In this section, we set out some context for the call for inputs, including:

            1. the duties placed upon Ofcom and requirements imposed on EPG providers in relation to the accessibility and usability of EPGs;

            2. the estimated number and circumstances of people with visual impairments, and the range of conditions leading to sight loss; and

            3. the particular circumstances of older people, who account for the majority of those with visual impairments.

      2. Duties of Ofcom and requirements imposed on EPG providers

Statutory provisions

        1. Ofcom has specific duties in relation to the accessibility of EPGs, set out in section 310 of the Communications Act 2003 (‘the Act’). In particular, these are to draw up, and from time to time review and revise, a code giving guidance as to the practices to be followed in the provision of electronic programme guides (section 310(1)).

        2. Section 310(3) provides that the practices to be required by the code must include the incorporation of such features in electronic programme guides as Ofcom consider appropriate for securing that persons with disabilities affecting their sight or hearing or both –

            1. are able, so far as practicable, to make use of such guides for all the same purposes as persons without such disabilities; and

            2. are informed about, and are able to make use of, whatever assistance for disabled people is provided in relation to the programmes listed or promoted.

        3. Ofcom’s duties under section 310 do not extend to improving the usability of EPGs in relation to non-broadcast content. However, section 10 of the Act gives Ofcom a duty to take such steps and to enter into such arrangements as appears to it calculated to encourage others to secure -

            1. that domestic electronic communications apparatus is developed which is capable of being used with ease, and without modification, by the widest possible range of individuals (including those with disabilities); and

            2. that domestic electronic communications apparatus which is capable of being so used is as widely available as possible for acquisition by those wishing to use it.

        4. Section 10 also says that Ofcom has a duty from time to time to review whether further steps are needed, or further arrangements should be entered into, for the purpose of performing the duty summarised above.

        5. In carrying out its duties, Ofcom must have regard to a range of factors set out in section 3 of the Act, including the needs of persons with disabilities, of the elderly and of those on low incomes (section 3(4)(i)). Further, under section 3(5), in furthering the interests of consumers, Ofcom must have regard, in particular, to the interests of those consumers in respect of choice, price, quality of service and value for money.

Ofcom’s Code on Electronic Programme Guides

        1. Paragraph 6 of Ofcom’s Code on Electronic Programme Guides (‘the Code’) 2 sets out general principles with which EPG providers must comply. Amongst these is a requirement, in particular, to make such adjustments to their EPGs as are practicable to secure that they can be used by people with disabilities affecting their sight or hearing for all the same purposes as they are used by other people.

        2. Paragraph 7 of the Code says that ‘Ofcom expects EPG providers to consult disability groups about the way they meet their obligations under the code’.

        3. Paragraph 8 of the Code notes that ‘much of the functionality of EPGs is dependent upon set top box hardware and software, as well as the data made available by broadcasters’, but makes clear that ‘Ofcom expects the needs of people with disabilities affecting their sight or hearing to be an integral part of planning for the future development of EPGs’.

        4. In section 4, we discuss the accessibility features that are already incorporated in EPGs, including some with text to speech.

People with visual impairments

The number of people with visual impairments is significant, and expected to grow

        1. Research undertaken by Access Economics estimated the prevalence of visual impairment in the UK population, by age, gender and ethnicity in 2008.3 On this basis, it was estimated that 1.8 million people had partial sight or blindness in 2008, of whom 1.13 million (63%) were female and 664,000 (37%) were male. About 218,000 people were estimated to have no sight, of whom 140,000 (64.3%) were female and 78,000 (35.7%) were male.

        2. The research found that there are people of all ages with visual impairments, but that the group is skewed heavily towards older people. The research suggested that, of the estimated 1.8 million blind and partially-sighted people in the UK in 2008, just under a quarter (418,810) were under 65 years old, and more than three quarters (1,378,178) were 65 or older. These numbers excluded the many more people who can see reasonably well with prescription lenses but who may struggle when reading an EPG.

        3. Applying these prevalence rates to future population projections, the research also estimated how the numbers of people might change over the next few decades. On this basis, the total of those with partial sight and blindness in the UK was projected to grow to 2,262,124 by 2020, and to over 4 million by 20504. Much of this would be driven by the UK’s ageing population, leading to an increase in the number of people with age-related macular degeneration and cataracts.
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