Creative Europe/MEDIA
In the second week of September, as part of the PARVIS project, we had an awareness-raising campaign on Twitter about the right of access to culture, in which we particularly highlighted the need for audio description and audio subtitling for the enjoyment of films by BPS people, and our related demands as regards public funding to the film industry.
Marrakesh Treaty
The European Commission published a Summary Report on its targeted consultation on the availability of accessible-format non-print works within the internal market, which aimed to see whether there was scope for extending the copyright exemption under the Marrakesh Treaty Directive to other types of works and/or disabilities.
Jointly with EDF, we expressed concern about the paragraph reading: “Stakeholders representing cultural heritage or educational institutions and those representing the interests of persons with disabilities mostly expressed their preference for producing ‘accessible format copies’ themselves rather than acquiring already commercially available accessible formats.”
We argued that:
- It sends the wrong signal to producers and undermines the efforts made by the EU in setting a legal framework to ensure that products, services and content are accessible by default, namely through the European Accessibility Act, the Web Accessibility Directive and the Audiovisual Media Services Directive.
- A potential copyright exemption to increase the availability of accessible content would be beneficial, but this should not imply that the responsibilities and the provision of this content should be placed on specialised entities only.
- Because the consultation, in many questions, appeared to target at organisations that produce their own material, has not have given sufficient visibility to the point of view of organisations representing persons with disabilities, let alone of individual persons with disabilities.
- In any case none of the organisations (only 6) that indicated they preferred to produce ‘accessible format copies’ themselves are DPOs, and that the report should indicate that DPOs, for one, clearly mark a preference for the possibility of acquiring already commercially available accessible formats.
Accessible lifts and other standards
The technical revision (EN 81-70:2021/prA1) of the Accessibility to lifts standard EN 81-70:2018 was adopted, which now provides for satisfactory colour contrast requirements. This is the result of ANEC representations within the relevant working group of CEN, in which EDF and EBU were closely consulted.
Reform of EU electoral law
Recommended amendments to improve the European Parliament’s own initiative report to further harmonise the electoral system and procedure applicable to European elections, have now been sent by EDF to the rapporteur of the Constitutional Affairs Committee. We stand ready to act in support, upon EDF request and coordination.
Miscellaneous
European Accessibility Act
We contributed to EDF and ANEC comments to the European Commission on a draft standardisation mandate for the implementation of the EAA. We particularly focused, in direct comments of our own on e-books (jointly agreed with EDF and the Daisy Consortium), to say this in substance:
We do not object to e-books being excluded from the mandate, i.e. going through the route of technical specifications, on condition that it is ensured that current industry standards are effectively fit for purpose. For this, we recommend to the European Commission to ensure, before issuing the final standardisation request, that the technical specifications for e-books refer to the EPUB Accessibility Conformance and Discoverability Requirements 1.1, as argued by the EPUB Accessibility - EU Accessibility Act Mapping.
Connecting Europe Express
In the context of the European Year of Rail 2021, EBU was invited to hop on board of a ‘Connecting Europe Express’ train from Rome to Milan through Genova, on 7 September, to meet with the Executive Director of the Community of European Railway and Infrastructure Companies (CER) and discuss availability for BPS people. Francesca Sbianchi of UICI kindly represented us on that occasion.
Consultations
We responded to the following two European Commission consultations:
- the public consultation on a set of European Digital Principles
- the targeted consultation on improving the SDG monitoring report
We have signalled again to our members the public consultation on the implementation of the Web Accessibility Directive, the which deadline has been extended to 21 October.
And we also signalled the EDF survey on BPS people’s experience with online voting tools, indicating that feedback would also be useful input to our AVA project (Accessible voting Awareness-raising).
Events
We attended the following events:
- EDF e-workshop on the EU Disability Card (16 September)
- EDF-W3C open meeting on the Web Accessibility Directive (28 September)
- EU Roundtable on Equality Data (30 September)