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Equitable Library Service for Canadians with Print Disabilities In Canada

Date: 
Friday, April 1, 2005

A Brief Submitted In Response to:

Opening the Book:
A Business Plan for the National Network for Equitable Library Service for Canadians with Print Disabilities

Submitted By:

Alliance for Equality of Blind Canadians / L'Alliance pour l'ÉgalitÉ des Personnes Aveugles du Canada #6 - 1638 Pandosy Street
Kelowna, BC V1Y 1P8
info@blindcanadians.ca

Background:

Sighted Canadians have the opportunity to visit their local library, which is publicly funded, publicly run and operated in a library milieu. There, they can read a wide range of books, government documents, periodicals in their preferred format -- print -- and borrow books, videos and CDs, and gain access to the internet. Canadians who are blind, deaf-blind and partially sighted must be provided with the same range of information access! This is particularly important to members of our community, because most people who are blind acquire blindness later in life, they should be able to continue to get the same services at their community library once they can no longer read print.

Who Are We?

The Alliance for Equality of Blind Canadians / L'Alliance pour l'ÉgalitÉ des Personnes Aveugles du Canada, (formerly National Federation of the Blind: Advocates for Equality), is a national consumer organization of persons who are blind, deaf-blind and partially sighted. Founded in 1992, our work has focused on public education and advocacy on blindness issues, including access to the printed word. For further information on our organization and work, please visit http://www.blindcanadians.ca.

THE CONSULTATION PROCESS TO DATE

"Consultation Guidelines for Managers in the Federal Public Service," December 21, 1992, http://www.pco-bcp.gc.ca/default.asp?Language=E&Page=publications&Sub=com-con&Doc=consult_e.htm, states in part:

"Canadians desire and demand more direct involvement in government decision-making... Consultation enhances service to Canada and to Canadians by involving members of the public in program and policy matters that affect them directly or indirectly."

The Guideline goes on to state:

" ... Consultation is not synonymous with consensus. It is, however, a process that permits and promotes the two-way flow of ideas and information among all sectors of society and between them and the government. The process ensures that Canadians are aware of and consulted about options that ultimately will become decisions affecting their lives. Effective consultation is based on principles of openness, transparency, integrity, and mutual respect."

The consultation process used to date in this instance does not conform to this Government of Canada Guideline.

The proposal, "Opening the Book: A Business Plan for the National Network for Equitable Library Service for Canadians with Print Disabilities," by the Canadian Library Association, Working Group to Define the National Network for Equitable Library Service, dated February 10, 2005, is DRAFT 2, which indicates previous consultations were conducted among a select range of individuals and organizations. A very brief window for comment was provided with March 25, 2005 as the stated deadline.

As an organization of consumers who are blind, deaf-blind and partially sighted - whose members will be directly affected by whatever direction is developed - our organization should reasonably have been directly included from the start in the full consultative process, and was not, and we must ask why?

The previous consultations have developed the current proposal to a considerable extent, and consumers and other stakeholders were asked to provide input at the eleventh hour, a process which does not conform to the Government of Canada's Guideline on open consultations. This short time line and lack of resources prevents us from undertaking any n-depth consultation with our membership, though we will discuss This issue at our upcoming 2005 Ottawa Conference (April 29-May 1, 2005), and will forward any resolutions that are adopted during that national Conference. In the meantime, we are including the text of Resolution 2001-03, which presents our current position on the recommendations contained in the report, "Fulfilling the Promise."

SCOPE

According to the 1991 Statistics Canada Health and Activity Limitations Survey, 3 million people, or 10% of the population, have print disabilities. A sizable portion of this group is seniors, and this portion of Canada's population is growing. By the year 2026, one in five Canadians will be a senior citizen. Twenty-six percent of them will be blind or have low vision. This will drastically increase the number of Canadians who rely on access to information in various alternative formats.

THE LEGAL FRAMEWORK

Canada's Charter of Rights and Freedoms, the Canadian Human Rights Act, and provincial and territorial human rights codes, require employers and service providers to accommodate persons with disabilities short of undue hardship. This legal requirement has been reaffirmed by a number of court decisions.

FREE LIBRARY SERVICE

For years, the Canadian National Institute for the Blind (CNIB) operated Canada’s largest bilingual free library service for persons who are blind or have a vision disability in Canada. The CNIB Library has produced only between 2,000 and 2,500 audio and Braille titles a year.

However, recently, CNIB has begun switching its recorded materials to digital formats, and playing materials in that format requires the purchase of a special player. This has eliminated Canada's largest free library service for persons who have a vision disability.

Most post-secondary institutions across Canada provide some local services to their students. The level of production services varies considerably, and too often still results in students receiving their materials late in a semester or after a course is completed. This inequitable access causes widespread difficulties for students with a vision disability who are attempting to compete on equal terms with their non-disabled counterparts.

Over the past 25 years, the Federal Government has consistently acknowledged the rights of Canadians with disabilities to equitable access to information, but except for the Canadian Government’s free circulation of Literature for the Blind" through Canada Post, which is valued at 12 million dollars per year, there is no comprehensive initiative to close the serious gap between what Canadians with print disabilities can access and what Canadians without print disabilities can access. Sustained government funding must be made available to address the gap on a broad and long term basis, and the Government of Canada must assume its rightful role in bridging the information gap that continues to confront Canadians who have a print disability.

CONCLUSION

Based on the need for meaningful consultations with all stakeholders, especially consumers who will be affected by any new model of service delivery, we recommend that consumer organizations such as ours be provided with time and resources so that we might consult widely with our membership, examine alternatives and develop a comprehensive response to this Draft paper.

Resolution 2001-03

Be it resolved that on the NFB:AE Board's position on the Task Force's recommendations from "Fulfilling the Promise Report" was ratified.

REC. 1. self-identification be sufficient to give a person with learning disabilities the right of access to multiple alternate format materials.

The NFB:AE Board is in favour of recommendation "1". However, it does have implications in terms of availability of resources.

REC. 2. the Canadian National Institute for the Blind energetically pursue the extension of its library services to all print-disabled Canadians.

The NFB:AE Board was against recommendation "2" as the Board felt these services should be provided by the N L C in conjunction with community libraries - not left up to not for profit charities.

REC. 3. the Federal Government act on the recommendations from "Toward Implementing In Unison."

REC. 4. Human Resources Development Canada establish a universal support programme for funding print-disabled Canadians to acquire and be trained in the use of assistive technologies.

The NFB:AE Board is in favour of recommendations 3 and 4 which go hand in hand. It is essential for people with disabilities to be able to use the new technologies. Implementation could be a shorter term goal as well. It is slated as medium term.

REC. 5. Canadian Heritage seek an amendment to Section 32 of the Copyright Act to include exemption for large print publications.

The NFB:AE Board is in favour of this recommendation. However, concern was expressed that this type of exemption takes the burden off the publishers to produce alternate formats themselves.

REC. 6. Canadian Heritage seek an amendment to the Copyright Act to include exemption for the non-commercial narrative description of cinematographic works.

The NFB:AE Board deferred any decision on recommendation "6" until additional information is obtained.

REC. 7. the Government of Canada establish and fund a clearinghouse for e-text to which Canadian publishers must make their works available.

The NFB:AE Board is against recommendation 7 as it establishes the library system as the only means to obtain e-text. Further more, it is only available to not for profit alternate format producers. It is also a means for the publishers to avoid producing alternate formats themselves. However, it was pointed out that this clearing house could or might be a step toward something better.

REC. 8. federal, provincial and territorial subsidies be available only to publishers which provide e-texts to the clearinghouse simultaneous with print publication.

The NFB:AE Board is against recommendation "8" because it does not put pressure on publishers to provide the e-text to individuals who want to purchase a copy, and it goes against the Board's position in recommendation "7". However, there was concern that an opportunity to at least make a step toward something better could be missed by not establishing a clearing house.

REC. 9. The National Library of Canada keep its CANUC-H/CANWIP databases up-to-date, comprehensive (inclusive of new media, e.g. tactile), representative and available to all alternate format producers. Access to the databases must be free.

The NFB:AE Board is in favour of recommendation "9", and notes the phrase "all alternate format producers" (private and not for profit).

REC. 10. the Government of Canada, through Canadian Heritage, annually appropriate at least $7.5 M, beginning FY 2001/2002, to support the production in Canada of multiple formats (audio/braille/large print) of materials which have authorship outside governments.

The NFB:AE Board is in favour of recommendation "10" only if it includes the following: The money must be open for tender to all alternate format producers, and publishers should receive money to produce their own alternate formats, including Braille, audio formats and large print to name three.

REC. 11. braille be recognized as a standard alternate format.

The NFB:AE Board is in favour of recommendation "11" - goes without saying.

REC. 12. the National Librarian expand the availability of braille materials by negotiating access for Canadians with national and international providers of braille materials.

The NFB:AE Board is in favour of recommendation "12".

REC. 13. the National Librarian negotiate a Canadian site licence with Recordings for the Blind and Dyslexic.

The NFB:AE Board is in favour of recommendation "13). One question related to this recommendation was discussed: why does this agreement need to be made when Canadians can already access material from RFB&D?

REC. 14. the Government of Canada, through Industry Canada, take a lead in participating in and funding the development, adoption and promotion of information and access standards such as NISO/DAISY/WAI and alternate format production standards.

The NFB:AE Board is in favour of recommendation "14".

REC. 15. governments at all levels use the force of procurement to promote and encourage the adoption of universal design standards for accessibility; only materials complying with such standards should be purchased.

The NFB:AE Board is in favour of recommendation "15".

REC. 16. the Treasury Board Secretariat require that all federal print material be available concurrently in multiple formats on demand.

The NFB:AE Board is in favour of recommendation "16".

REC. 17. departments and agencies of government at all levels train their personnel to be aware of the needs of print-disabled Canadians, of the availability of multiple format materials and in the use of the related assistive technology.

The NFB:AE Board is in favour of recommendation "17".

REC. 18. all levels of government make their publications available in multiple formats through the Canadian library system at no additional cost to the library.

The NFB:AE Board is in favour of recommendation "18".

REC. 19. the Government of Canada, through Canadian Heritage, recognize the primary role of the public library system by funding services for the use of print-disabled members of their communities.

The NFB:AE Board is in favour of recommendation "19".

REC. 20. the National Library of Canada provide leadership and support to Canadian libraries to facilitate interlibrary loan and encourage the sharing of materials in alternate formats.

The NFB:AE Board is in favour of recommendation "20".

REC. 21. the National Library of Canada's Adaptive Technology in Libraries Program, which operated from 1991 to 1995, be re-established.

The NFB:AE Board is in favour of recommendation "21". But, the Board is only in support of this recommendation if the following criteria are part of eligibility for funds: Consult with consumers when making this money available to ensure that the equipment is appropriate to meet local consumers needs, and local libraries make it publically known that the equipment and technology is available.

REC. 22. the Government of Canada, through Human Resource Development Canada and Industry Canada, fund training programmes for staff of Canadian libraries and for users of adaptive technology.

The NFB:AE Board is in favour of recommendation "22". It is essential to ensure the equipment and technology purchased under recommendation "21" can work for local library users.

REC. 23. Canadian Heritage, working in collaboration with the National Library of Canada, the CLA and ASTED, negotiate the delivery of alternate format materials as an integral component of the Library Book Rate.

The NFB:AE Board is in favour of recommendation "23".

REC. 24. Canadian Heritage seek method to expand Free Matter for the Blind to include all print-disabled persons and to include new formats.

The NFB:AE Board is in favour of recommendation "24".

REC. 25. the National Librarian of Canada immediately establish a Council on Access to Print Information to provide advice, recommend funding, monitor progress and make recommendations regarding the implementation of this report. Its membership should be drawn from consumers, advocacy groups, librarians, public servants, publishers and alternate format producers.

The NFB:AE Board is in favour of recommendation "25", and it strongly promotes the inclusion of "of advocacy organizations" being on the Council.

REC. 26. in conjunction with every programme designed to increase accessibility for print-disabled Canadians there must be an aggressive programme of public awareness.

The NFB:AE Board is in favour of recommendation "26". However, one note was made that the promotion should not be oriented to any one organization other than the Government itself.