Accessibility with Reasonable Adaptation

First Kuwait International Conference on the Role of People with Special Needs in Building the Information Society "Access to Information",
Kuwait, 1-3 May 2006

Achieving the value proposition of accessibility on the Internet; issues of information policy, structures and technologies

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III. Achieving the Accessibility Value Proposition

A. Defining accessibility operationally

To discuss the value proposition of accessibility it is necessary to define "accessibility" operationally. The 1999 report of the Secretary-General on implementation of the "World Programme of Action concerning Disabled Persons" provides a clear and pithy definition of accessibility in the information and communications field:

"Accessibility is not the concern solely of persons with sensorial or mobility disabilities or older persons. Accessibility refers to provision of "flexibility to accommodate each user's needs and preferences"[88]

B. Value proposition of accessibility for all

The value proposition of accessibility is based on equity and efficiency considerations: removing barriers to participation benefits all; and providing accessible information goods and services contributes to improved quality of service, ease of use and efficiency of mainstream information and communication technologies. Accessibility is the law in many countries, and inclusive design represents a more cost-effective and sustainable approach than one based on negotiated compliance and retrofitting as appropriate.

In a broader sense, accessible information and communication goods and services have the capacity to empower and engage the many since there are no real barriers to seek, use, store or exchange information or to participate in exchanges of knowledge and experience as both agent and beneficiary. Accessible designs, thus, tap the great potential of the many to address development issues both public and private. Accessible work groups – public, private, academic and nongovernmental – contribute to enhanced productivity for all through progressive removal of barriers to participation in decision-making, in business processes and in sharing in productive efforts.

1. Accessible Web design can build market share

By providing flexibility to accommodate a wide range of user needs, preferences and capacities, accessible designs will build market share in the private sector and contribute to improved efficiencies in the organization and delivery of public goods and services. This is particularly the case for Internet-based services: repeated studies have documented how good Web design pays tangible benefits to organizations and enterprises.[89] Good Web design has the capacity to engage, inform and retain the end user through clear and concise presentations of the corporate (or organizational) message and presentation of site resources in usable and accessible formats. Sometimes there will be a need for tradeoffs between those who wish to add multimedia content as an end in itself, while the business case can be communicated equally well with less-dense graphics and accessible content that are easily navigated by all users. In such cases, the principle is equity and choice for the widest possible range of end user interests and capacities. For instance, BBC News <http://news.bbc.co.uk/text_only.stm> allows end-users to access the same content in either a "text" or "graphics" format.

Web site security should provide accessibility options. The tendency of some sites to employ bitmapped security images – CAPTCHA – to deter Internet robots from capriciously exploiting the resources of a Web site can present barriers to users with visual disabilities or who are using older computer systems to register at the site. As discussed in the preceding section, a follow-up email communication provides an equally effective solution to secure access to the resources of a site to humans.

2. Accessible Web design can contribute to search engine optimization

Recent research in search engine optimization also supports the accessibility value proposition: search engine spiders can more efficiently process and rank Web sites that are based on compliant, accessible code.[90] To test the contribution of accessible Web content to search engine optimization, Andy Hagans, a search engine optimization consultant,[91] examined the way in which Priority 1 checkpoints of the W3C Web Content Accessibility Guidelines 1.0[92] can affect search engine optimization:

Checkpoint 1.1 Provide a text equivalent for every non-text element (e.g., via "alt", "longdesc", or in element content). This includes: images, graphical representations of text (including symbols), image map regions, animations (e.g., animated GIFs), applets and programmatic objects, ASCII art, frames, scripts, images used as list bullets, spacers, graphical buttons, sounds (played with or without user interaction), stand-alone audio files, audio tracks of video, and video.

Not only are search engines unable to understand image and movie files, they also cannot interpret any textual content that is based on vision (such as ASCII art). alt and longdesc attributes will, therefore, help them understand the subject of any such content.

Search engines are also "deaf" in reference to audio files. Again, providing textual descriptions to these files allows search engines to better interpret and rank the content that they cannot "hear."

Checkpoint 1.2 Provide redundant text links for each active region of a server-side image map.

Text links are very important to search engines, since anchor text often succinctly labels the content of a link's target page. In fact, many search engine optimizers consider anchor text to be the single most important factor in modern search algorithms. If a Web site uses an image map rather than a text-based menu as the primary navigational method, a redundant text-only menu elsewhere on the page will give search engines additional information about the content of each target page.

Checkpoint 4.1 Clearly identify changes in the natural language of a document's text and any text equivalents (e.g., captions).

Major search engines maintain country and language-specific indexes. Specifying the language of a document (or of text within a document) helps search engines decide in which index(es) to place it.

Checkpoint 6.3 Ensure that pages are usable when scripts, applets, or other programmatic objects are turned off or not supported. If this is not possible, provide equivalent information on an alternative accessible page.

Some users choose to disable JavaScript and applets in their browser's preferences, while other users' browsers do not support these technologies at all. Likewise, search engines' "browsers" do not read scripts; therefore a Web page's usability should not be crippled when scripts are not supported. Otherwise, search engines may not even index the page, let alone rank it well.

Checkpoint 14.1 Use the clearest and simplest language appropriate for a site's content.

If a Web site contains the "clearest and simplest language appropriate for the site's content," it is probably using those keywords with which potential searchers will be most familiar. Searchers tend to use succinct queries containing familiar language. Thus, to receive maximum traffic from search engines, it is best that a Web site contain the same words that the site's audience will use when searching.[93]

C. What is reasonable?

The next consideration is extent to which information goods or services should be accessible. Some argue that "reasonable accommodation" is the basic design consideration, which is the language used in draft article 9 (Accessibility) of the proposed international convention on the rights of persons with disabilities. The logic is that accessible provisions should not involve an "undue hardship" on an organization or enterprise.[94]

Reasonable in this sense refers to a minimum set of provisions to further accessibility provisions of the international convention, once it is adopted by the General Assembly and ratified by (or acceded to) State Parties.

From a policy perspective, the term "reasonable" introduces the question of "reasonable for whom?" Social justice suggests that the level of accommodation provided be fair for all members of society; efficiency concerns introduce the question of resource capacities of society to achieve accessibility for all.

At an Expert Group Meeting on Information and Communications Technologies (ICT) for Persons with Disabilities organized by the United Nations Economic and Social Commission for Western Asia, at Beirut (25-26 May 2004), the concept of "reasonable adaptation" was introduced as an operational concern in the design and development of accessible ICT solutions.[95] Reasonable adaptation is based on the notion that accessibility considerations should be introduced at the outset of the design and planning process and not as ancillary consideration once a design is selected. Reasonable adaptation would ensure that all will benefit from the provision of accessible information goods and services. This is posited to translate into greater equity and efficiency in the implementation of accessibility policies and laws than would designs that accommodate and do not impose "undue hardships".

D. Contribution of the proposed international convention

The value proposition of early adoption of the proposed international convention on the rights of persons with disabilities and its ratification by (or accession to) State Parties is that it will provide normative and substantive guidance for interested Governments in the drafting of national policies, laws and administrative guidance on progressive removal barriers to participation by all.

E. Internet governance and accessibility with reasonable adaptation

The question of Internet governance precedes the Geneva and Tunis phases of the World Summit of the Information Society and was posed at the time in terms of "Who controls the Internet?"[96] The answer at that time – and which remains valid to this date - is that no one body or institution "controls the Internet." Most of the global Internet is managed by the private sector – which includes anyone with Internet access through a DSL gateway or cable modem. Moreover, a great deal of Internet-based content is maintained on Peer-to-Peer networks, such as BitTorrent, and is not immediately accessible as a public Web-enabled resource. This is in addition the number of governmental and corporate Intranets, which connect to the global Internet only at specific points and for specific purposes: a case in point is the Internet presence of the United Nations <http://www.un.org> accounts for only a small portion of the Organization's digital resources; the United Nations Intranet handles a wide range of personnel administration, budgeting and communication activities.

As discussed in the first section, many trans-border Internet management and development issues are handled by nonprofit professional societies and organizations, such as the Internet Engineer Task Force <http://www.ietf.org/> and the World Wide Web Consortium <http://w3c.org>. Allocation of Internet Protocol (IP) address space, protocol identifier assignment, generic (gTLD) and country code (ccTLD) Top-Level Domain name system (DNS) management, and root server system management functions are performed by the nonprofit International Corporation for Assigned Names and Numbers (ICANN) <http://www.icann.org/index.html >.

Follow up to the Tunis phase of the World Summit of the Information Society, includes the recommendation that the Secretary-General of the United Nations convene a forum for "multi-stakeholder policy dialogue", the Internet Governance Forum. Since accessibility did not figure prominently in the consensus text on Internet governance in the Tunis outcome document, it is not likely that it would be prominent on the IGF agenda.

1. Suggested topics for policy dialogue

From the perspective of accessibility on the Internet, an appropriate policy-level issue in dialogue on Internet governance is the extent to which policy options would ensure that the global Internet would not only remain a stable, reliable and open network of computers but one in which the endpoints would progressively promote accessibility with reasonable adaptation for all. If Internet governance does not address barriers to participation, whatever governance regime may emerge would not contribute to improved equity in use of this global resource.

Some have argued that the Internet, a global network based on open standards and nonproprietary protocols, is the "commons" of the twenty-first century. As in the case of the physical commons of the nineteenth and twentieth centuries,[97] the view has been expressed that there is a need for a mechanism to review and resolve conflicts over the best use of the resource for the common good. In a contribution to the Working Group on Internet Governance, Professors Mueller, Mathiason and McKnight[98] observed that the Internet, which is based on open standards and protocols, represents a virtual global commons whose network protocols can be adopted by any user without paying a fee. This is in contrast they note with other standardization models, which are the product of appointed representatives and formal committees, and are commonly are sold. Their second point is that the global Internet is a decentralized network of networks, most of which are under private control. By facilitating interoperability, the Internet allows privatization and decentralization of Internet-based information and communication goods and services. Their third point is that the architecture of the Internet is based on the "end-to-end" principle: the design of the network is not optimized for any particular category of service or application; it only provides a transport mechanism for digital content. They observe that as the number of services and goods that rely on the Internet increase, capacity problems will arise and coordination in the allocation of Internet resources – the unique Internet protocol, IP, and Domain Name Servers (DNS) root servers – will become complex, difficult and a subject for political concern. Professors Mueller, Mathiason and McKnight outline what could constitute a framework of normative concerns for a governance regime for the global Internet:

1. The technical model of the Internet should be preserved: the global Internet is an unparalleled success in facilitating communications and access to information; it is efficient in its use of available infrastructure.

2. Do not allow the "commons" to be privatized: protect and maintain the open, nonproprietary character of core Internet standards and protocols.

3. Do not transform the standards commons into a basis for regulating private markets: maintenance of standards must not result in intrusive regulation of private-sector activities; this represents an important area for development of appropriate definitions and criteria for intervention and nonintervention to ensure that the Internet continues to serve as a network that adds value to all who are connected.

4. Resource allocation and assignment rules and procedures should be consistent with the "end-to-end" principle: allocation of Internet resources should be uniform and objective and facilitate coordination of decentralized, private sub-networks.

5. Management of technical resources should not be overloaded with policy functions: policy considerations should remain separate from technical decisions on the efficient and stable functioning of the global Internet.

6. Regulation of fraudulent and criminal aspects of the Internet must be directed at the responsible endpoints of the network, not at the Internet networking operations itself: controls, if any, on Internet content are appropriately addressed at the endpoints of the channel and not be a task assigned at the level of the global network.

7. Infrastructure development should be decentralized and competitive.

8. Multi-stakeholder governance should be encouraged, maintained, strengthened: since the Internet involves, governments, privates sector, civil society and international organizations, governance institutions should provide structure to ensure involvement of these parties in accordance with their respective role in the aspects on which governance is sought.[99]

Professors Mueller, Mathiason and McKnight observe that any discussion on Internet governance should not be synonymous with increased and intrusive regulation. They identify three "meta-areas" that are appropriate for international concern for promotion and maintenance of a stable and efficient global Internet: (1) determination of appropriate application of national jurisdiction to activities that are global or cross-jurisdictional in scope; (2) facilitation of cooperation and harmonization in transnational law enforcement activities; and (3) management of transnational resources and stable and efficient interoperability of technical network infrastructure.[100]

Within the proposed scheme, accessibility would best be included as a member of the third meta-area and represent a topic for identification and dissemination of appropriate technical standards to the endpoints of the network and not be an issue for juridical action.

2. Efficient and coherent management of Internet resources

Productive dialogue on Internet governance is not a trivial concern. It is essential to the continued stability, reliability and development of the global Internet. One issue of concern is the potential for fragmentation in the assignment of Internet resources. As noted in the first section, ICANN currently manages Internet Protocol (IP) address space allocation, protocol identifier assignment, generic (gTLD) and country code (ccTLD) Top-Level Domain Name System (DNS) management, and root server system, which is based on 264 suffixes, which include .com, .net, .org and two-letter country codes such as .th for Thailand. In February 2002, the Open Root Server Network <http://www.orsn.org/> began providing an additional DNS server-network with a legacy root zone for ISP networks in Europe. ORSN coordinates its registration activities with ICANN and IANA but also operates in an "independent mode" to provide redundancy in the event problems are encountered in the 13 DNS roots servers managed by ICANN, 10 of which are located in the United States.[101] In contrast, the UnifiedRoot Corporation <http://www.unifiedroot.com>, based in Amsterdam (The Netherlands) allows "businesses and individuals to have their own top-level domains (TLDs) at the same hierarchical level" as the current top-level domains of ".com", ".net", or country code top-level domains (ccTLDs) such as ".de", ".uk", and ".jp". UnifiedRoot has established its own global network of root name servers, and states its "system works in the same way the current DNS system for the Internet."[102]UnifiedRoot states that resolution of IP issues is within the purview of concerned Internet Service Providers; there is no mention of a coordination mechanism with ICANN.

3. Multilingualism

Use of non-Latin script to describe an Internet resource was identified as an important issue of Internet governance at the Tunis phase of WSIS. It also is an important technical issue in the further development of assistive and augmentative devices.

The China Internet Network Information Center <http://www.cnnic.net.cn/> now registers domain names in Chinese characters[103] to facilitate Internet usage in the China region. As a member of the set of Regional Network Information Centers, CNNIC coordinates registration data with ICANN.

The nonprofit Multilingual Internet Names Consortium <http://www.minc.org>, an international non-governmental, international organization, is focusing on development and promotion of multilingual Internet domain names and keywords and internationalization of Internet names standards and protocols, MINC undertakes technical coordination and liaison with concerned international bodies and has stated a "commitment to make Internet access feasible for all people, in their own native language."[104]

F. Lessons in promoting and implementing accessible ICT: Republic of the Philippines

Lessons in promoting and implementing the "Manila Accessible ICT Design Guidelines" suggest a two-pronged approach, based on full and effective involvement of all stakeholders: (1) present accessible ICT as a mainstream development issue and not an issue that concerns only certain members of the population in order to realize the value proposition of best possible accessibility solutions for all; and (2) focus on capacity building for accessible design and development among users and producers of information goods and services to promote self-reliance.

The "Manila Design Recommendations" are an outcome of a United Nations supported international seminar and regional workshop on accessible ICT, which was hosted by the Government of the Philippines, represented by its Department of Social Welfare and Development (DSWD), and with the effective cooperation the National Council for the Welfare of Disabled Persons (NCWDP).

1. Strategic framework for promoting awareness and building capacities

The presentation team for the seminar and workshop prepared and submitted as follow up an internal working paper outlining a "strategic framework" for capacity building and promotion of accessible ICT in the Philippines. The framework addresses, first, determination of supply and demand considerations in training for accessible ICT, and then outlines several decision points related to promoting and implementing accessible ICT designs for all.

1. Supply and demand considerations. The framework recommends that two types of capacities should be developed to further an accessible ICT agenda in the Philippines: (a) knowledge and understanding of the normative and rights-based framework in which accessibility for persons with disabilities is set; and (b) knowledge, understanding and abilities to address the technical aspects of accessibility in a mainstream ICT context, which includes knowledge of mechanisms to ensure that Internet-based resources are accessible, and to test whether sites and Web-based applications can be easily accessed and used by all. Knowledge of Universal Design concepts and principles is an important contribution in promoting and implementing an accessible ICT agenda.

2. Key decision points. Six points can be identified:

(a) knowledge and skills to develop and implement an appropriate policy framework for accessible ICT;

(b) knowledge and skills to identify and assess user interests, needs and preferences for mainstream information and communication goods and services;

(c) knowledge and skills to apply technical standards and guidelines on accessible designs appropriate to the national context and capacities;

(d) knowledge and skills to identify and apply relevant procedures and tools to design and develop accessible and usable Internet-based content and services;

(e) knowledge and skills to organize and conduct – or manage, as appropriate – systematic monitoring and evaluation of site content and services in terms of accessibility with reasonable adaptation for all; and

(f) knowledge and skills to plan, organize and conduct promotional efforts, public information and outreach among specialized communities of interest in support of an accessible ICT agenda.

2. WorldEnable online validator

The presentation team also partnered with systems and programming specialists in the Philippines to develop an online validator to test and assess Internet sites with regards to accessibility considerations outlined in the "Manila Design Recommendations <http://validator.worldenable.net/>. The WorldEnable validator aims to promote public awareness of accessibility with reasonable adaptation on the Internet and to assist interested Web site designers and developers to produce designs that are good, usable and accessible to a wide range of users.

3. National capacity building for accessible ICT: 2004-2006

Implementation of a national programme on awareness raising and capacity building has been carried out as a joint venture between the Department of Social Welfare and Development of the Philippines, the National Council for the Welfare of Disabled Persons (NCWDP) in partnership with the National Computer Center (NCC), which is now part of the Philippines National Commission on ICT (CICT) and Vision Office Support Services (North Vancouver BC, Canada), representing the seminar and workshop presentation team.[105] The programme is based on public information and awareness raising activities and regional workshops involving Web masters, concerned governmental officials and members of civil society, nongovernmental organizations and academic institutions. In accordance the memorandum of understanding, workshops aim to promote awareness of accessibility issues, building national capacities for accessible ICT designs and content management, and promote economic opportunities for all in the information and communication technologies field, with emphasis on accessible design solutions. Three workshops have been organized to date, averaging 25 to 30 participants each, and focus on accessibility concepts and principles, design and development standards and techniques, and confidence building through hands-on practical work. One innovation of the programme is the initiation of the "Disability-friendly Web Site" Award, based on tests using the WorldEnable Validator as conducted by the National Computer Center in cooperation with the National Council for the Welfare of Disabled Persons. The first award was presented to the Web master of the House of Representatives of the Republic of the Philippines site <http://www.congress.gov.ph> in the light of its effective, accessible and usable design.[106] The programme envisages compilation of lessons learned and good practices in accessible ICT design, and preparation, in cooperation with CICT, of technical standards and training and resource materials on accessible ICT design, development and management appropriate to the Philippines.

The experience of the Philippines suggests that there is no one policy framework to promote and develop accessible ICT solutions given the rapid pace of technical developments in this field. The "Manila Design Recommendations" have provided effective guidance for the development and testing of locally-appropriate and cost-effective approaches to promoting and developing accessible ICT solutions for all.

G. Return on investments in accessible ICT matters!

The experience in the Philippines suggests that what remains to be done is identification and implementing an appropriate set of key performance indicators (KPIs) on ICT accessibility with reasonable adaptation.

Conventional KPIs do not address accessibility, which if measured is related to compliance reporting for purposes of national law or administrative guidance. These are mainly binary measures – services and applications are / are not accessible. If accessibility is to be a mainstream ICT issue, there is a need to introduce appropriate measures to established monitoring procedures and in calculations of return on investments (ROI) on ICT investments.

ROI matters. It is important to be able to document the ways in which investments in information and communication technologies contribute to the efficiency and effectiveness of an organization or enterprise. ROI should also be able to document the investment in accessible ICT to populations covered by national legislation or administrative guidance concerning persons with disabilities.[107]

Since each ICT investment project has its own goals and objectives, calculating ROI will requires identification of variables and Key Performance Indicators (KPIs) to track and indicate how these relate to business or organizational processes. ROI is preceded by a benchmarking exercise to set the base against which to measure and assess implementation performance and progress in achieving desired goals. Investments in assistive and augmentative technologies would require a working definition of workers with disability if this is not already spelled out in national law. Most definitions of disability are based on an evident condition: (a) sensory impairment, hearing or vision, or both; (b) mobility impairment; (c) cognitive, learning or psychological disability, although some national laws now include non-evident disabilities and serious medical conditions.[108]

The outcome of both the Geneva and Tunis phases of WSIS called for work on ICT indicators, since most available data focus on stock conditions, such as number of telephones, computers or bandwidth. Little work has been done on linking ICT stock with "quality" variables, which should include accessibility.

1. ITU Digital Opportunity Index

As a contribution to the further development of ICT indicators and development of the information society, the International Communications Union published a working paper on "Measuring Digital Opportunity" which is an outcome of a "Thematic Meeting on Multi-Stakeholder Partnerships for Bridging the Digital Divide," organized in cooperation with the Korea Agency for Digital Opportunity and Promotion (KADO) and hosted by the Ministry of Information and Communication (MIC) of the Republic of Korea (Seoul 23-24 June 2005).

The Digital Opportunity Index (DOI) builds upon the ITU Digital Access Index groups,[109] which are stock measures, and identifies three variables for purposes of index construction:

• Opportunity. To participate in the information society, consumers must have accessibility to ICT service and must be able to afford it. The percentage of the population covered by mobile cellular telephony represents coverage (basic accessibility) while the two tariff indicators, Internet access tariffs as a percentage of per capita income and mobile cellular tariffs as a percentage of per capita income reflect affordability.
• Infrastructure, which includes network indicators such as the proportion of households with a fixed line telephone, mobile cellular subscribers per 100 inhabitants, proportion of households with Internet access at home and mobile Internet subscribers per 100 inhabitants. It also includes the devices that provide the interface between the user and the network which is represented by proportion of households with a computer.
• Utilization shows the extent of ICT usage and includes proportion of individuals that used the Internet. Quality reflects a level of access that enables higher degrees of functionality. This provides support for services such as video streaming that can enhance desirable information society applications such as telemedicine, e-government and e-learning. The indicator selected for this category is the ratio of broadband subscribers among Internet subscribers (separated by both fixed and mobile).[110]

Missing from the proposed DOI is a reference to the extent to which ICT provides accessibility with reasonable adaptation for the end user, which represents an important area for further research. Persons with disability as well as older person who may experience some degree of sensory or mobility limitations constitute a not insignificant proportion of the world's population.

2. Other sources of indicators of accessible ICT

Much useful work on identification and testing of ICT accessibility indicators has proceeded apart from the WSIS process. For instance, the State of Maine (United States) has published the following functional performance criteria to judge whether a Web site, Web-based application or intranet accessibility is effectively achieved:

"Maine Web Accessibility Performance Criteria

"All information and functionality presented in a Web site, intranet, or Web-based applications shall be available in a manner that is:

• Compliant with browser and system font size and color settings;
• Completely operable using keyboard only;
• Completely operable using leading screen magnification software;
• Completely operable using leading screen reading software;
• Completely operable using leading speech recognition software;
• Completely understandable without sound;
• Completely understandable without color;
• Clear and consistent;
• Unlikely to trigger photosensitive seizures.[111]

3. Issues in ROL calculation

From the planning perspective information and communication technologies are essential "utilities" that contribute to attainment of organizational or corporate goals, such as improved levels of living, for a public agency, or increased profitability for an enterprise.

Calculation of ROI from the accessibility perspective thus needs to focus on how provision of accessible ICT contributes to outcomes that are verifiable and objective and contribute to desired goals for all. ROI should not dwell on accessibility as a compliance issue but as central to strategies that aim to enhance the efficiency and effectiveness of the workgroup through conscious removal of barriers to participation by all.

Determination of outcomes associated with accessible ICT could include the following considerations:

1) Does the outcome describe an objective end result in terms of an intended population or the community as a whole.

2) How does the outcome relate to the organizational or corporate mission.

3) How does the outcome contribute to specific public policy objectives

4) Does the outcome respond to national legislation or administrative guidance

5) Does the outcome indicate the "why" of the particular good or service rather than "what" is delivered.

6) Is the outcome defined in terms that are realistic of organizational or corporate capacities.

7) Do outcome measures build on KPI (key performance indicator) data.[112]

H. Planning and management considerations

The premise of this paper is that accessible ICT is a mainstream development issue and not a matter of addressing the needs and interests of specific populations as an adjunct to mainstream policy and investment decisions. Designing and implementing accessible ICT solutions from the outset and not as an afterthought or compliance issue contributes to comparative advantage, demonstrates leadership and commitment to the larger community.

As a mainstream issue, analysis, planning and implementation of accessible ICT follows the same set of management practices applied in any infrastructure decision.[113] As a mainstream issue, it is important to recall the twin-fold mission of ICT: management (1) align ICT resources to corporate or organizational strategy, and (2) address technical issues and challenges that are not within the competence of other organizational units. The real task of ICT management is to solve problems and to deliver stable, reliable and accessible information and communication goods and services in support of the corporate or agency mission and to add value to the corporate or agency constituencies.

Promoting and implementing accessible ICT requires vision, leadership, team building and effective communications among the specialized constituencies for information goods and services. It also requires a certain degree of balance in pursuit of an accessible ICT agenda. It is useful to recall five principles attributed to the Google organization in this regard:

1. Work on things that matter;
2. Affect everyone in the world;
3. Solve problems with algorithms if possible;
4. Hire bright people and give them lots of freedom; and
5. Do not be afraid to try new things.[114]

1. Visioning is the appropriate point of departure

Implementing accessible ICT with reasonable adaptation is a future-oriented task: One is not retrofitting but planning and designing for an environment without barriers to participation for all.

The appropriate point of departure is a vision statement on the "why" and "what" of the accessibility with reasonable adaptation initiative. This requires dialogue and discussion with senior policy makers and management and opportunities for input from representatives of the specialized constituencies for accessible ICT, in particular persons with disabilities.

The vision represents a collective effort that describes the "who, what, where and when" of implementing an accessible ICT agenda. It should provide guidance on the norms and standards on which the vision is premised.

2. Institutional arrangements matter: build upon an established base

Strategically, implementing accessible ICT with reasonable adaptation should not involve new institutional arrangements, since it is premised as a mainstream development issue. However, accessible designs may require specialized skills and knowledge, including the knowledge and experience of persons with disabilities, so a special working group or task force may be identified to provide specialized, interdisciplinary guidance, technical resources and support not available to other units in connection with implementing an accessible ICT agenda.

3. Investments add value to core competencies

In-house investment decisions, initially, should result in predictable outcomes in areas that represent a unique corporate or agency competence and would thus serve to distinguish the organization from those which have not yet implemented an accessible ICT agenda. In the case of the cooperative programme with the Republic of the Philippines, an initial focus was an accessible and usable Web site design for the House of Representatives.

4. Monitor performance, and document good practices

Implementation must be accompanied by periodic performance measures and reports to both management and the specialized constituencies on progress as well as obstacles encountered in implementing an accessible ICT agenda. Performance reporting should direct special attention to innovations – good practices - that result in rapid and cost-effective implementation of sustainable and effective accessible ICT solutions.

Investments in assistive and augmentative technologies should be documented in accordance with established ICT ROI metrics for the organization or agency and not be treated as a cost of compliance. The focus is on accessibility as a mainstream issue.

5. Accessibility is "always under construction"

Planning and implementing an accessible ICT agenda is essentially a social process, in which the one truth is that accessibility is "always under construction."

I. Suggested areas for further research on accessible ICT for all

The lessons of implementing the "Manila Declaration" and "Manila Design Recommendations" suggest at least three areas in which there are urgent research needs:

First, there is a need to address in an objective and technical way the question of Internet accessibility and interoperability involving non-Latin alphabets. For instance, the experience of the China Internet Network Information Center in using technical guidance of the Internet Engineering Task Force in the registration of Chinese domain names could prove useful to other interested parties, including those concerned with the "multilingualism" recommendations of the outcome documents of the Tunis phase of WSIS.

Second, there is a need for continued development of lightweight tools to test and evaluate accessibility of Web sites, Web-enabled applications as well as Intranets. For instance, the WorldEnable Validator, which is freely available on the global Internet, provides guidance with reference to the accessibility performance requirements identified in the "Manila Design Recommendations." Experience suggests that it is generally compatible with a range of Latin alphabets for languages that use special characters, such as French and Spanish. It has had limited applications in assessing accessibility of Web sites that use non-Latin text.

Third, documenting the business case of accessible ICT for all requires identification and development of an objective and verifiable set of mainstream performance indicators, which can provide a basis for assessing investment alternatives and calculating returns on investments in implementing an accessible ICT agenda.

J. Final observation

The case for accessible ICT in mainstream development is based on equity and efficiency considerations. Progressive removal of barriers to participation is not only the right thing to do, but a good strategy.

Complexity presents barriers to all, as can intrusive regulation.

As a character in William Gibson's All Tomorrow's Parties observes, "the flashier a Web site is, the greater the chance that there's a dinky, nothing company behind it."[115]

Notes to the text

[88] "Implementation of the World Programme of Action concerning Disabled Persons; Addendum, Report of the Secretary-General" (A/54/388/Add.1), paragraph 15, available at http://www.un.org/esa/socdev/enable/disa54e6.htm.

[89] Jim Rapoza, "Good Web design pays dividends," eWeek (February 28, 2005), available at http://www.eweek.com/article2/0,1759,1769591,00.asp; see also Jim Rapoza, First impressions count even more on the Web," eWeek (January 30, 2006), available at http://www.eweek.com/article2/0,1759,1915986,00.asp.

[90] Brandon Olejniczak, "Optimizing Your Chances with Accessibility; Effectively increasing search engine ranking with W3C Accessibility guidelines and Section 508 [of the Rehabilitation Act of the United States]," Digital Web Magazine (March 10, 2004), available at http://www.digital-web.com/articles/optimizing_your_chances_with_accessibility/.

[91] Andy Hagans Link Building, LLC, http://www.andyhagans.com/.

[92] The checkpoints are part of the WCAG, version 1.0, available at http://www.w3.org/TR/WAI-WEBCONTENT/. Version 2.0 is the current draft and is now under review for adaptation by W3C, http://www.w3.org/WAI/intro/wcag20.php.

[93] Andy Hagans, "High Accessibility Is Effective Search Engine Optimization," A List Apart Magazine (November 08, 2005), available at http://www.alistapart.com/articles/accessibilityseo.

[94] Title I of the Americans with Disabilities Act of 1990 (ADA) requires an employer as well asemployment agencies, labor organizations, and joint labor-management committees , to provide reasonable accommodation to qualified individuals with disabilities who are employees or applicants for employment, unless to do so would cause undue hardship. "In general, an accommodation is any change in the work environment or in the way things are customarily done that enables an individual with a disability to enjoy equal employment opportunities." ADA identifies three categories of "reasonable accommodations":

"(i) modifications or adjustments to a job application process that enable a qualified applicant with a disability to be considered for the position such qualified applicant desires; or

(ii) modifications or adjustments to the work environment, or to the manner or circumstances under which the position held or desired is customarily performed, that enable a qualified individual with a disability to perform the essential functions of that position; or

(iii) modifications or adjustments that enable a covered entity's employee with a disability to enjoy equal benefits and privileges of employment as are enjoyed by its other similarly situated employees without disabilities."

The duty to provide reasonable accommodation is a fundamental statutory requirement because of the nature of discrimination faced by individuals with disabilities.

Available at http://www.eeoc.gov/policy/docs/accommodation.html.

[95] Clinton E. Rapley, "Promoting Accessible Information and Communications Technologies with Reasonable Adaptation:

Learning from the Manila "Declaration" and "Design Recommendations" on Accessible ICT," (May 2004), available at http://www.worldenable.net/reasonablea/promoting.htm.

[96] See for instance, John R. Mathiason and Charles C. Kuhlman, "The Internet, international regulation & new policy structures." Paper presented to the International Telecommunications Society Conference (Stockholm, 21-24 June 1998), available at http://www.un.org/esa/socdev/enable/access2000/ITSpaper.html.

[97] Garrett Hardin, The Tragedy of the Commons," Science. New Series, vol. 162, no. 3859 (December 13, 1968) pp. 1243-1248, available at http://www.sciencemag.org/cgi/content/full/162/3859/1243. In this seminal article Hardin argues that the "tragedy" is associated with unrestricted access and use of a resource by individuals – a "commons" – since it inevitably dooms the future potential of that resource due to overexploitation by individuals, who benefit from its unfettered exploitation, while society bears the cost of this individual exploitation. Hardin developed his thesis in connection with population and environmental issues, so his focus is on solutions for environmental quality that yield the "maximum good per person" – a concept that is admittedly difficult to define in operational terms. He notes that such solutions are not based entirely on technology but require changes in human values and behaviour. He observes, "social arrangements that produce responsibility are arrangements that create coercion, of some sort." Hardin adds, "The only kind of coercion I recommend is mutual coercion, mutually agreed upon by the majority of the people affected." Hardin is not without his critics, particularly those who are of the view that technological advances and market mechanisms – the "invisible hand" - will produce efficient solutions to resource management issues.

[98] "Making Sense of Internet Governance," op. cit., pp. 108-109.

[99] Ibid, pp. 111-113.

[100] Ibid, p. 114.

[101] "About ORSN" http://european.de.orsn.net/about.php.

[102] UnifiedRoot "Products" http://www.unifiedroot.com/products.

[103]Chinese Domain Name complies with RFC3454. RFC3490. RFC3491. RFC3492 published in March 2003 by IETF (Internet Engineering Task Force), available at http://www.cnnic.net.cn/html/Dir/2005/10/11/3218.htm.

[104] MINC Board of Directors, http://www.minc.org/nomcom/newboard.shtml.

[105] Empowering Persons with Disabilities through Accessible Information and Communications Technologies (ICT); A Capacity-Building Project with the Government of the Philippines, 2004-2006, available at http://www.visionoffice.com/ictpwd/default.htm.

[106] Alexander Villafania, "Congress website cited as 'disabled-friendly'," INQ.7.NET (June, 3, 2005), available at http://news.inq7.net/infotech/index.php?index=1&story_id=39092. See also, Congress of the Philippines, House of Representatives, "HOR website awarded as "disabled-friendly," (02 June 2005), available at http://www.congress.gov.ph/press/details.php?pressid=747.

[107] For instance, the Australian Disability Discrimination Act 1992 requires all government bodies to provide equitable access to people with disabilities. In the state of New South Wales government websites (and others, including commercial sites) risk exposure under the Act to complaints from anyone claiming disadvantage by lack of access. ADDA requires equal access for disabled people, where it can reasonably be provided <http://www.austlii.edu.au/au/legis/cth/consol_act/dda1992264/>. In the United States, Section 508 of the Rehabilitation Act requires that when Federal agencies develop, procure, maintain, or use electronic and information technology (EIT), Federal employees with disabilities have comparable access to and use of information and data as Federal employees who have no disabilities, unless an undue burden would be imposed on the agency. Section 508 also requires that individuals with disabilities, who are members of the public seeking information or services from a Federal agency, have comparable access to and use of information and data as the public without disabilities, unless an undue burden would be imposed on the agency: Synopsis of Section 508 Accessibility Requirements is available at http://www.hhs.gov/siteinfo/508synopsis.html.

[108] Ambassador Don MacKay, chairman of the Ad Hoc Committee of the General Assembly considering the proposed international convention on the rights of persons with disabilities has prepared the following "definition" of disability:

"Disability" results from the interaction between persons with impairments, conditions or illnesses and the environmental and attitudinal barriers they face. Such impairments, conditions or illnesses may be permanent, temporary, intermittent or imputed, and include those that are physical, sensory, psychosocial, neurological, medical or intellectual."

Available at http://www.un.org/esa/socdev/enable/rights/ahc7pddisability.htm.

[109] DAI is built around four vectors that impact a country's ability to access ICTs: infrastructure, affordability, knowledge and quality, and actual usage of ICTs. See also ICT Statistics, http://www.itu.int/ITU-D/ict/statistics/.

[110] ITU, "Measuring Digital Opportunity" (July 2005), p. 4, available at http://www.itu.int/osg/spu/ni/wsisbridges/linked_docs/
Background_papers/Measuring_Digital_Opp_Revised_31_Oct_2005.pdf.

[111] http://www.maine.gov/oit/accessibility/performance_criteria.htm.

[112] See Government of Western Australia, Department of Treasury and Finance, Outcome Based Management (Perth, WA, November 2004), available, Adobe® Portable Document Format (PDF), at http://www.dtf.wa.gov.au/cms/uploadedFiles/obmnov04.pdf.

[113] The World Wide Web Consortium would appear to view accessibility as a special class of business – or public-sector - decision making, "Developing a Web Accessibility Business Case for Your Organization: Overview," available at http://www.w3.org/WAI/bcase/Overview.

[114] Chad Dickerson, "The Google Way," Infoworld (February 20, 2004), available at http://www.infoworld.com/article/04/02/20/08OPconnection_1.html.

[115] New York, Penguin Putnam, 1999, available at http://www.voidspace.org.uk/cyberpunk/all_tom.shtml.

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