Draft Not Ready for Dissemination

European Disability Forum

EDF Response to the Public Consultation with a View to a European Accessibility Act

March 2012

“In the development and implementation of legislation and policies to implement the present Convention, and in other decision-making processes concerning issues relating to persons with disabilities, States Parties shall closely consult with and actively involve persons with disabilities, including children with disabilities, through their representative organizations.” Article 4 § 3 of the United Nations Convention on the Rights of Persons with Disabilities

EUROPEAN DISABILITY FORUM > > FORUM EUROPÉEN DES PERSONNES HANDICAPÉES SQUARE DE MEEÛS 35 | 1000 BRUSSELS | T +32 2 282 46 00 | F +32 2 282 46 09 [email protected] | WWW.EDF-FEPH.ORG European Disability Forum

List of contents List of contents...... 1 1. Introduction...... 2 2. EDF Response...... 3  Introductory remarks...... 3  Too many accessibility barriers continue to prevent the freedom of movement of persons with disabilities...... 4  A patchwork of accessibility legislations across Europe...... 6 Accessibility legislation varies largely between Member States and EDF cannot comment on each Member States’ legislation; however a few examples are worth giving: 6  As customers, persons with disabilities are constrained by the different accessibility rules across the EU...... 9  Possible effect of adopting EU wide common accessibility standards...... 10  Coherence between EU and international accessibility standards...... 11  Costs and benefits of making accessible goods or services...... 11  Impact of persons with disabilities and older persons on market share...... 13  Impact of an increased availability of accessible goods and services on the purchasing behaviour of potential customers...... 13  General approach to evaluate the accessibility of goods and services...... 15  General approach to evaluate the conditions of access to services (and to the goods linked to the provision of these services)...... 17  Most important policy and legal measures to improve accessibility...... 20  Essential provisions for the effectiveness and success of a European legislation on accessibility...... 22  Role of public authorities and market operators...... 23  Role of SME's...... 24 3. Acknowledgments...... 25 4. APPENDIX...... 25 A. EDF Freedom Guide is available in English online (check website)...... 25 B. Contact Person at the EDF Secretariat:...... 25

EDF Response to the Public Consultation with a View to a European Accessibility Act, March 2012 The document is available in English, and on alternative format upon demand. ©European Disability Forum 2012. This document may be quoted and reproduced, provided the source is given.

2 EDF RESPONSE TO THE PUBLIC CONSULTATION WITH A VIEW TO A EUROPEAN ACCESSIBILITY ACT - MARCH 2012 European Disability Forum

1. Introduction

The European Disability Forum (EDF) is the European umbrella organization composed and led by disabled people, representing the interests of 80 million persons with disabilities in Europe. The mission of EDF is to ensure persons with disabilities full access to fundamental and human rights through their active involvement in policy development and implementation in Europe. EDF works closely with the institutions of the European Union (EU), the Council of Europe and the United Nations.

EDF welcomes the launch of the public consultation on the European Accessibility Act by the European Commission (EC). This shows a commitment to develop concrete measures to remove barriers faced by persons with disabilities in the single market.

EDF regrets that the consultation was only available in English preventing many organizations of persons with disabilities at national or local level from providing valuable contributions to this important exercise.

We believe that each goods and services should be accessible to everybody, regardless of their disability. EDF therefore calls on the European Commission to come forward with a strong proposal for legislation before the end of 2012. This should be based on internal market rules, and include effective requirements for public and private service providers and industry to provide accessible mainstream goods and services allowing consumers with disabilities to benefit from the internal market.

No other instrument beside legislation would achieve an adequate and effective response to the difficulties faced by consumers with disabilities in accessing ordinary products and services under the same conditions as other EU consumers. Instead people with disabilities frequently have to rely on adapted products and services where choice is limited and prices are higher.

The Act should have a scope as broad as possible, with a clear and extensive definition of accessibility, and include the requirement to provide accessibility in specific sectors.

In elaborating its response, EDF has made explicit references to the relevant questions of the consultation. This has been done so that our comments can, if necessary, be analysed by the European Commission section by section in accordance with the original structure of the questionnaire.

3 EDF RESPONSE TO THE PUBLIC CONSULTATION WITH A VIEW TO A EUROPEAN ACCESSIBILITY ACT - MARCH 2012 European Disability Forum 2. EDF Response

 Introductory remarks

Following the conclusion by the EU of the UN Convention on the Rights of Persons with Disabilities (UNRPD), EDF believes that no goods and services should be allowed on the internal market unless they are accessible for persons with disabilities. EDF therefore believes that the material scope of the European Accessibility Act should be as broad as possible and cover all services and as many goods and as possible, whilst respecting the competence of the EU to act.

The objective of the Act must be to ensure the good functioning of the internal market by developing accessible goods and services. At present, there are many commercial and technical barriers that hamper persons with disabilities and service providers/producers to benefit from freedom of movement of goods and services. In this respect, accessibility of goods and services must be considered both in virtual environment and in built environments. Corresponding legal provisions should therefore be adhered to in both spheres (physical and virtual).

Persons with disabilities include persons with a wide range of impairments and they can require specific communication and assistive technologies in specific situations. The Act should therefore also cover the compatibility and interoperability between mainstream accessible goods and services and assistive technologies designed for disabled people. The Act should also encourage the provision of information on goods and services in accessible formats. Accessible formats means that information should be provided using text, audio, video (equipped with subtitles and/or sign language interpretation) and/or electronic means so as to be accessible to all. Accessible formats include, but are not limited to, large print, Braille version, easy-to-read version, audio format such as tapes or CDs, video format like DVDs, and electronic format.

Today, there is a severe lack of accessible goods and services, despite the potential benefits of providing accessibility in terms of an increased number of customers and the creation of a wider market for goods manufacturers and service providers. In spite of these potential benefits, the internal market is failing to provide accessibility on a wide scale, and EU regulatory intervention is needed.

From the perspective of the EU, the priority is to ensure that goods and services which fall under its legislative competences are subject to accessibility requirements (see discussion above). This means all the services and all goods covered broadly through the provisions of the internal market and derived from the freedoms of goods, persons, and capitals, as well as those governed by provisions on transport in the Treaty on the Functioning of the European Union should be fully accessible.

4 EDF RESPONSE TO THE PUBLIC CONSULTATION WITH A VIEW TO A EUROPEAN ACCESSIBILITY ACT - MARCH 2012 European Disability Forum In this sense, we believe that a pronged approach should be developed in the future legislation: - Accessibility of goods and services - Access to services (and the goods linked to the provision of these services) - Procurement This approach is further explained later on in the paper, under the sections “General approach to evaluate the accessibility of goods and services” and “Conditions of access to services (and the goods linked to the provision of these services)”.

The Act should also include a broad, but sufficiently clear, definition of accessibility. This definition should cover all domains and levels including urban/rural applications and conventional/electronic applications. It should also combine the concept of accessibility to the concepts of autonomy, safety and sustainable development. In elaborating such a definition it is also important to refer to the concept of universal design. According to article 2 of the United Nations Convention on the rights of persons with disabilities, Universal Design is “the design of products, environments, programmes, and services to be usable by all people, to the greatest extent possible, without the need for adaptation or specialized design. Universal design shall not exclude assistive devices for particular groups of persons with disabilities where this is needed”.

EDF has developed a definition of accessibility which we would like to see included in a future legislation:

‘ Accessible’ means a good, service, site, technology (including information and communication technologies and systems) or built environment which is easy to approach, enter, exit, operate, participate in and use safely, independently, and with dignity by a person with a disability or reduced mobility under all circumstances (including emergency cases). This does not exclude the use of assistive devices or augmentative and alternative communication to achieve accessibility for particular groups of persons with disabilities where this is needed.

Finally, the Act should be linked to technical accessibility European standards, which will be established by the European standardization organizations following the issuing of standardization mandates by the European Commission. Where no relevant standards have (yet) been set, the generic essential requirement to provide accessibility should apply.

 Too many accessibility barriers continue to prevent the freedom of movement of persons with disabilities

Specific question for individuals, and in particular persons with disabilities

5 EDF RESPONSE TO THE PUBLIC CONSULTATION WITH A VIEW TO A EUROPEAN ACCESSIBILITY ACT - MARCH 2012 European Disability Forum Question 10: Please describe the main accessibility barriers you are facing when you want to exercise your right of freedom of movement. What would be the possible effect of adopting EU wide common accessibility standards?

Following the consultation that the EDF has carried out with its membership, a whole range of accessibility barriers were identified. The EDF Freedom Guide1 gives a full and detailed insight into the barriers persons with disabilities encountered. A few extracts from this EDF publication are listed here, but only as illustrating experiences. More detailed examples can be provided upon request.

The main accessibility barriers identified for persons with disabilities to access services include: - Barriers to the physical environment in which the service is provided, - Barriers to adequate transport to and from the place of the service provision, - Barriers to accessing information and communication (including ICT) , as well as to material provided, - The lack of possibility to be accompanied by a non-paying assistant and a guide dog, - Barriers to purchasing a service without extra costs

The main accessibility barriers for persons with disabilities to access goods include: - Packaging of the goods, - Safety (this includes inaccessible product or service information, warranty conditions, user manuals, including inaccessible electronic information and communication material), - Barriers to the physical environment where goods are available, - Where mainstream goods are not accessible, persons with disabilities must use adapted goods which are only available at an excessive price and/or with a very limited choice, - Subsidies to the individual disabled purchaser provided by a Member State to enable the purchase of accessible products do not apply to foreign products (which mean that choice is restricted for the person).

A recent survey conducted by Ipsos MORI on behalf of Leonard Cheshire Disability2 looked at disabled people’s experience of accessing goods and services in the UK, and their awareness of Part 3 of the Disability Discrimination Act (which specifies disabled people’s rights regarding access to goods and services). The survey highlights that: - Two in five (40%) of disabled people have experienced difficulties accessing goods and services in the last twelve months, with around a quarter of all disabled people (23%) directly identifying their experiences as discriminatory.

1 http://www.edf-feph.org/Page_Generale.asp?DocID=13855&thebloc=29268 2 http://www.lcdisability.org/?lid=12274

6 EDF RESPONSE TO THE PUBLIC CONSULTATION WITH A VIEW TO A EUROPEAN ACCESSIBILITY ACT - MARCH 2012 European Disability Forum - The difficulties they experienced included: lack of appropriate facilities (15% of respondents) difficulty using public transport (16% of respondents) difficulty in entering or getting around premises such as shops, banks and hotels (13% of respondents). - Three-quarters (76%) of disabled people who responded to the survey agreed that shops and providers would make their services more accessible if they felt they might face legal action if they failed to do so.

Below are some testimonies of persons with disabilities that reveal the accessibility barriers they encounter on an everyday basis (these testimonies, as well as many others, are taken from the EDF Freedom Guide): - “The list of physical barriers that still exist today is endless: steps everywhere, lack of lifts or lifts requiring keys to function, inaccessible public transport, not enough time for people with reduced mobility at pedestrian crossings, impossible access to goods on the top or bottom shelves in supermarkets.” Aneliya, 59, Bulgaria - “The buttons in the elevators are often placed in different orders. Before you find the button for the floor to which you want to go, you might have pressed the emergency signal and or the stop button. This could be solved either by standardisation or by labelling the buttons in Braille.” Blenda, 38, Sweden - “We, persons with disabilities, do not have the same access to information as other EU citizens, not even to information coming from public services.” Eliisabet, 39, Estonia - “ Persons with disabilities do not have the same opportunities as any other persons when planning their travels or holidays, regardless of the destination. The choice is dramatically restricted. Everything must be planned far in advance and cheap tours such as last-minute are precluded. Too often, one has to depend on occasional - though welcome - help.” Jessica, 76, UK - “I often wonder why it is possible to fly to the moon but so difficult to access public buildings and public transportation.” Klara, 29, Sweden

 A patchwork of accessibility legislations across Europe

Questions common to all respondents: Questions 11 or 13: Please provide your general assessment of the accessibility in your country in the areas of built environment, transport and ICT? Question and 12 or 14: Please provide your opinion on the accessibility legislation in your country in terms of its scope and efficiency?

Accessibility legislation varies largely between Member States and EDF cannot comment on each Member States’ legislation; however a few examples are worth giving:

7 EDF RESPONSE TO THE PUBLIC CONSULTATION WITH A VIEW TO A EUROPEAN ACCESSIBILITY ACT - MARCH 2012 European Disability Forum - France: the law of February 11, 2005 "for equal rights and opportunities, for the participation and the citizenship of people with disabilities"3 contains a chapter about accessibility of built environment, transport, and new technologies. However, this law has been poorly implemented because of a lack of adequate budget allocated and the overuse of derogations, especially in the area of built environment.

- Italy: the legislation4 focuses on physical and ICT barriers while barriers to communication are completely ignored5. It is therefore important that EU institutions do not make the same mistake and include all those barriers in the European Accessibility Act.

- Spain: the key legal instrument in term of accessibility is Act 51/2003 6, regarding equal opportunities, non-discrimination and universal accessibility for persons with disabilities, known in Spanish as LIONDAU. Its implementation is taking place more quickly than pre-2003 legislation but relies on the quality of the technical regulations and the monitoring systems accompanying the legislation. EU institutions should not forget that aspect when designing the future European Accessibility Act.

- Austria: the future European Accessibility Act should also take inspiration from the situation in Austria, where the Austrian Federal Disability Equality Act 7 (entered into force in 2006) provides for a “graduated realization plan” that foresees the gradual improvement of accessibility of all infrastructures (the EAA should however go beyond and include goods and services). The law provides that all adaptations that do not involve any cost must be made immediately; whenever significant renovations to the built environment are made, they must take into account the latest accessibility requirements. Adapting publicly accessible facilities (such as doctor´s surgery) can be made with up to 50% state funding.

- UK: In the UK, both the Equality Act 20108 and the European Convention on Human rights9 are highly recognized as the legislation promoting accessibility for all especially disabled people. The Equality Act 2010 aims to protect disabled people and prevent disability discrimination. It provides legal rights for disabled people in the areas of: Employment, education, access to goods 3 http://www.legifrance.gouv.fr/affichTexte.do?cidTexte=JORFTEXT000000809647&dateTexte= 4 http://www.pubbliaccesso.it/normative/law_20040109_n4.htm 5 Report by the Italian Institute of Juridical studies, national council for research on the complia nce of the Italian legislation to the UNCRPD Art 9 6 http://www.boe.es/aeboe/consultas/bases_datos/act.php?id=BOE-A-2003-22066 7 http://www.parlament.gv.at/PAKT/VHG/XXII/I/I_00836/fname_036804.pdf 8 http://www.legislation.gov.uk/ukpga/2010/15/contents 9 http://conventions.coe.int/treaty/en/Treaties/Html/005.htm

8 EDF RESPONSE TO THE PUBLIC CONSULTATION WITH A VIEW TO A EUROPEAN ACCESSIBILITY ACT - MARCH 2012 European Disability Forum and services including larger private clubs, land based transport services and functions of public bodies. Unfortunately, due to the cost of legal action when people are discriminated, it seems the Act is ineffective especially with regards access to goods and services. However, the Equality and Human Rights Commission (EHRC) does give support and help in some legal cases which would set precedence for other cases.

- Greece: the legislation that is already in force in Greece does not cover all areas (only for built environment and transport). Unfortunately existing accessibility legislation does not include penalties for non-compliance nor deadlines for the application of the provisions, which makes it inefficient.

- Sweden: Despite decades of governmental investigations and a proposal presented in June 201010, the Swedish Discrimination Act does not cover lack of accessibility. In addition, specific legal instruments covering persons with reduced mobility and orientation exist for public transport and built environment, but the existing legislation is not enforced. Finally, apart from the introduction in 2011 of accessibility requirements for a commercial broadcaster, ICT is not at all covered in Swedish legislation.

- Norway: The Discrimination and Accessibility Act (2009)11 is mainly focused on transport, ICT and the built environment and has legally established the principle that inaccessibility is a matter of discrimination. The Act refers to the sector legislation in each field as well as specific regulations elaborating on the regulations in the Act itself. The paragraph referring to universal design of built environment and outdoors areas refers to The Public Procurement Act (2007)12 and the Planning and Building Act (2010)13. The Antidiscrimination Ombudsman in Norway is responsible for following up and monitoring this Act14.

The current situation in the different Member States on access to websites varies greatly and this leads to fragmented rules across the EU. This hampers the functioning of the internal market with regard to web and e-accessibility and means that service providers find it more difficult to freely trade in a cross-border context. Under the Digital Agenda for Europe, the European Commission is now envisaging binding measures to make sure that public sector websites are fully accessible by 2015 (action 64). Such requirement would be complementary to a European Accessibility Act: legislation on accessibility of websites would target accessibility of

10 http://www.regeringen.se/sb/d/12476/a/148924 11 http://www.ub.uio.no/ujur/ulovdata/lov-20080620-042-eng.pdf 12 http://www.iclg.co.uk/khadmin/Publications/pdf/3348.pdf 13 http://www.regjeringen.no/en/dep/md/Selected-topics/planning/planning-for-all.html? id=449510 14 http://www.ldo.no/en/Topics/Disability/Laws-and-regulations/

9 EDF RESPONSE TO THE PUBLIC CONSULTATION WITH A VIEW TO A EUROPEAN ACCESSIBILITY ACT - MARCH 2012 European Disability Forum the content (i.e. the web) while a European Accessibility Act would focus on accessibility of the ICT goods and services (e.g. computer or tablets).

At this point in stage, EDF would like to draw the reader’s attention to the following studies produced by the European Commission on e-accessibility in Europe and which can be useful for the creation of a European Accessibility Act: - Study Measuring progress of E-Accessibility in Europe, 2008: (http://ec.europa.eu/information_society/activities/einclusion/library/studies /meac_study/index_en.htm) - Study Monitoring eAccessibility in Europe: o (http://www.eaccessibility-monitoring.eu/)

EDF members also published reports focusing on specific aspects of e-accessibility in Europe: - The European Federation of Hard of Hearing issued the State of subtitling access in EU, 2011 Report: o (http://www.efhoh.org/mp/db/file_library/x/IMG/30890/file/Stateofs ubtitlinginEU23March2011.pdf)

 As customers, persons with disabilities are constrained by the different accessibility rules across the EU

Specific questions for the industry and business Question 10: To which extent are you confronted as customers with different accessibility rules in different Member States?

EDF has collected examples from its members which illustrate a number of barriers for customers due to different accessibility rules in different Member States. A few examples include: - Legislation on transport accessibility varies a lot. This does not only mean that passengers in different Member States have different levels of access but also makes travelling difficult for passengers who cross state borders. There are also safety implications when, for example, tactile markings are used differently in different Member States etc. - Accessibility for persons with disabilities varies considerably, not only between Member States, but also between different service providers at national level. - Different requirements relating to accessibility of the built environment at the national level leads to many potential customers being prevented from entering and/or using service facilities in many Member States. - The availability of accessible self-service terminals varies a lot not only between different Member States, but also between different service providers.

10 EDF RESPONSE TO THE PUBLIC CONSULTATION WITH A VIEW TO A EUROPEAN ACCESSIBILITY ACT - MARCH 2012 European Disability Forum - The use of braille on mainstream products is almost absent in many Member States, but used more frequently in others. - Telephone service companies provide different level of accessibility in different Member States. - Signage is not used in a standardized way, which complicates matters for many persons, in particular those with intellectual disability or visual impairments. - The lack of or different accessibility requirements of ICT services make it prohibitive to use online or e-services especially for people with

 Possible effect of adopting EU wide common accessibility standards

Specific questions for individuals, and in particular persons with disabilities Question 10: Please describe the main accessibility barriers you are facing when you want to exercise your right of freedom of movement. What would be the possible effect of adopting EU wide common accessibility standards?

Adopting EU wide common accessibility standards would significantly contribute to reduce the accessibility barriers described above and will have a positive impact for the internal market. If harmonised legal requirements linked to European standards were established, goods manufacturers and service providers would know that, if they respect those standards, they could sell their products or services throughout the EU. Moreover, looking beyond the potential costs involved in adapting goods and services to make them accessible, EU wide common accessibility standards would greatly improve the quality of goods and services offered (accessibility is also a benchmark for quality) and meet the needs of many more EU citizens, thus enhancing competition and increasing the market share of goods manufacturers and service providers.

In short, a common EU-wide legal framework underpinned by accessibility standards can help both persons with disabilities, who would gain greater access to accessible goods and services, and the industry, which would benefit from a market expansion. Economies of scale will also be ensured thanks to a higher production.

 Complementary role of EU, national, regional and local authorities in improving accessibility

Questions common to all respondents Question 18 or 20: Please provide your comments about the complementary role that the EU, national, regional and local authorities could play in improving accessibility.

EDF believes that numerous differing accessibility requirements at different levels (European, national, regional and local) would not be helpful for industry. Having binding legislation at EU level would instead give business operators clear and consistent rules to adhere to and allow them to operate across borders. Therefore, framework rules should be established at the European level, and underpinned by European standards. Only in the absence of European requirements should national/regional/local legislation and standards apply. Public authorities should also have a role in implementation and control.

 Coherence between EU and international accessibility standards

Specific questions for the industry and businesses Question 11: Will the adoption of EU accessibility standards coherent with international ones facilitate the implementation of accessibility in goods and services?

In today´s globalized world, industry will benefit from producing goods based on EU accessibility standards because production prices will go down thanks to economy of scale, whilst market shares will increase. Moreover, if the requirements set in EU legislation match the ones in other parts of the world, for instance the US or Japan, a potential global market will open up for EU manufacturers. Competition will also increase, which will stimulate innovation and better performance, as well as lead to more adapted products and services on the market.

In addition, a holistic and coherent legal framework underpinned by European standards will boost the ability of European industry to produce accessible goods and services and to efficiently react to this emerging market share. It will also enable industry to meet accessibility requirements, already set or to be set, outside the EU, and to allow industry to be at the forefront of this emerging global market.

 Costs and benefits of making accessible goods or services

Specific questions for the industry and business Question 9: Please explain the costs and benefits, current or potential, of making the goods or services produced accessible?

First of all, we would like to start by stressing the need for the industry and public authorities to understand and accept the general rule that dependence and exclusion is more costly than inclusion and participation. The European Accessibility Act could build on the experience gained with the implementation of the American with

12 EDF RESPONSE TO THE PUBLIC CONSULTATION WITH A VIEW TO A EUROPEAN ACCESSIBILITY ACT - MARCH 2012 European Disability Forum Disabilities Act (ADA)15 (in particular the US Access Board16), whose “Father”, Justin Dart, stated: “the economic costs of excluding two thirds of the Americans with disabilities from the mainstream is about $200 billion annually, in public and private payments, $300 billion when you include lost taxes and lost productivity”.

It is a common misconception that accessibility is expensive. In fact, building accessible infrastructure, goods and services costs no more money than building inaccessible ones, and actually creates added value for the industry since a good, service or building that meets accessibility requirements will be able to adapt more easily to changing needs, including the ageing or emerging disabilities of its occupants. Moreover, the costs associated with making goods and services produced and provided by companies accessible are not high if accessibility is factored in as one of the criteria from the outset and considered in the design, manufacturing and distribution processes in the case of goods and the conception development and delivery processes in the case of services. The benefits of doing so, on the other hand, are considerable because it considerably expands the potential market for the goods and services. Moreover, increasing accessibility of products and services gives persons with disabilities access to do things by themselves, which decreases the need for individualized services and sets resources free for public authorities.

The UN Convention on the Rights of Persons with Disabilities, which has been ratified by the majority of EU Member States17, requires States Parties to take action in the area of accessibility. If no coherent set of rules relating to accessibility is established at EU level, various and differing requirements will be established at national or even at regional level18. For businesses, adapting their products to different sets of requirements, depending on the Member States in which the products or services are sold, is both challenging and expensive. The greater the number of national accessibility rules in the various Member States, the more complicated and pricy marketing is. A harmonized set of European requirements would therefore lower prices and increase the willingness and ability of a company to sell products or services in all Member States. This would enlarge the market for enterprises, and also lead to increased competition, which should lead to better products at a lower price for the customer.

Finally, adopting a more holistic perspective to evaluate the costs and benefits of making products and services accessible to persons with disabilities, one can note that having access to accessible mainstream products and services facilitates their participation in all aspects of society and contributes to catalyse economic growth. For instance, as ICT, transport and service facilities become usable, persons with

15 http://www.ada.gov/ 16 http://www.access-board.gov/ 17 Estonia, Finland, Greece, Ireland, Malta, the Netherlands and Poland have not yet ratified, but, in most cases, are close to doing so. 18 Lisa Waddington, “A Disabled Market: Free Movement of Goods and Services in the EU and Disability Accessibility”, European Law Journal, 2009, 15(5), 575-598.

13 EDF RESPONSE TO THE PUBLIC CONSULTATION WITH A VIEW TO A EUROPEAN ACCESSIBILITY ACT - MARCH 2012 European Disability Forum disabilities will also gain greater access to education and to the employment market. This will foster their participation to the labour force and therefore contribute to economic prosperity.

 Impact of persons with disabilities and older persons on market share

Specific questions for the industry and business Question 8: Please explain the role that persons with disabilities and older persons play in terms of customers and market share? Could you please provide concrete examples?

There are approximately 80 million persons with disabilities in the EU, and they are all potential customers, providing products and services are accessible to them. This is a huge number of customers – more than 15 % of the whole European population. Furthermore, with the on-going demographic changes, the number of older persons will substantially increase.

In addition, statistics on persons with disabilities do not take into account the vast number of Europeans of all ages that have either milder disabilities (such as persons with sight, hearing, mobility, dietary issues) or that have a temporary disability. Accessibility measures would benefit this very important part of the EU population. Taking the needs of persons with disabilities into account and producing goods and services that meet their needs would therefore open up key market opportunities and generate higher profits for companies. Furthermore, older consumers and younger consumers do not usually have the same needs in terms of design/functions of a product or service.

The CEO of Vodafone, Mr Vittorio Colao has stated in article published in the Freedom Guide that: at Vodafone ‘we believe that the real power of the smartphone lies in its ability to transform lives, not in the processor and we are committed to tackling barriers of cost, geography and access to take the benefits of the mobile internet to all”. This is confirmed by the widespread acceptance among older people of “easy-to-use” mobile phones, thus overcoming their reluctance to make use of mobile telephony and converting older people into a niche market for operators.

 Impact of an increased availability of accessible goods and services on the purchasing behaviour of potential customers

Specific questions for individuals, and in particular persons with disabilities Question 9: What would be the impact of an increased availability of accessible goods and services in the market on the purchasing behaviour of potential customers? Could you give concrete examples?

Increased availability of accessible goods and services would enable consumers with disabilities to buy products at a reasonable cost and have a wider range of products and services to choose from. Moreover, there is evidence that in Member States where measures have been taken to increase access to services, persons with disabilities (both temporary and permanent) and elderly people are using those services more and more19. This would boost the competitiveness and thus the economy, as an increased number of customers will have access to the mainstream market.

Moreover, accessibility features have proven to be used also by non-disabled people (see for instance easier use of transport modes where there are available services such as subtitling for foreign language learners, escalators and lifts). Accessibility could therefore facilitate use of goods and services by many non-disabled consumers, which means that accessible goods and services could potentially benefit a majority of customers.

The positive impact of an increased availability of accessible goods and services can be demonstrated in the market of technical devices used by persons with disabilities. When people with disabilities are reimbursed through the social security system, they are often not allowed to buy devices in another Member States, even if the devices are of a higher quality and or less expensive. Expanding the market of technical devices would have a significant effect on the purchasing behaviour of customers with disabilities. They will be able to buy goods and services that they would not have bought before, because they were not accessible to them.

Access for persons with disabilities to goods and services is increasingly taken into account in the development of national legislation or standards following the ratification by the different EU Member States of the UN Convention on the Rights of Persons with Disabilities. However, EDF warns that the development of potentially diverse rules and standards for product accessibility at the national level would create barriers to trade and market fragmentation, as well as a lack of certainty in the assessment of product accessibility and a significant loss of market share.

Finally, EDF wants to highlight that accessibility of goods and services is also a gateway. Thanks to accessible goods and services, persons with disabilities can access higher education, have a job or create jobs for others, as well as enjoy leisure and cultural activities. All of these aspects would also directly impact on economic growth.

 General approach to evaluate the accessibility of goods and services

19 http://www.bbc.co.uk/go/em/fr/-/news/uk-16785138

15 EDF RESPONSE TO THE PUBLIC CONSULTATION WITH A VIEW TO A EUROPEAN ACCESSIBILITY ACT - MARCH 2012 European Disability Forum Specific questions for individuals, and in particular persons with disabilities Question 8: What are the most important goods and services that in your opinion should be covered by accessibility legislation in order to ensure their accessibility? Questions common to all respondents Question 13 or 15: The accessibility for persons with disabilities of which goods and services should be given priority?

When thinking about accessibility, one must understand that it functions as a chain that requires the proper functioning of each of the links, as well as all the links together, in order to be effective. This means that a global, horizontal and holistic approach to accessibility of goods and services is absolutely essential. For instance, in order to be able to benefit from telecommunications, a person with a disability requires (a) accessibility of the landline, mobile or smart phone, (b) availability of accessibility services (e.g. text and video relay services to write or sign when calling someone) and (c) the possibility for the IT network to transmit these services.

Taking that holistic approach into account, EDF proposes the European Union to create a level of accessibility of goods and services whose methodology would be somehow similar to the one identifying levels of energy performance for household items (e.g.: dishwashers): - Maximum level of accessibility - Medium level of accessibility - Minimum level of accessibility Another example to accessibility levels of products and services is the A, AA and AAA approach taken by the World Wide Consortium for the web content accessibility guidelines.

The classification used to evaluate the level of accessibility of the goods or service could be based on the following criteria: - Safety - Affordability (what is meant here is that the cost of a product put on the market should not be higher than the cost of an ordinary product. At present, if a person needs accessible goods that meets his/her specific needs, he/she must pay for the product many times more than the ordinary product. For instance, you can have a perfectly accessible mobile phone, but if it costs 1000 euros then it does not change your situation because you cannot buy it.) - Interoperability: (i.e. compatibility with assistive devices or accompanying services) - Autonomy: (this criteria would determine to what extent a person with disabilities needs to be accompanied to be able to manipulate or use the service20) - User-friendliness

20 On the case of guide dogs, they form an indivisible unit with their users and should be considered accordingly when evaluating the level of autonomy of the person with disability

16 EDF RESPONSE TO THE PUBLIC CONSULTATION WITH A VIEW TO A EUROPEAN ACCESSIBILITY ACT - MARCH 2012 European Disability Forum - Choice: (Here we want to underline the importance of having a choice of products and services available in order to have a healthy competition within the internal market. Persons with disabilities must also be able to choose from a range of products and services and determine the best option for their use is.)

The accessibility requirements suggested above would have to include the conditions under which goods are supplied (e.g. retail premises, online retail) and information relating to goods (e.g. packaging, labelling, contracts and instruction manuals). In addition, the accessibility requirements would have to address the electronic operation of goods, navigating tools, as well as packaging and labelling.

The level of accessibility of a product or service should be communicated through the use of a European label. In this way, consumers would be able to understand to which extent goods and services are accessible (that is particularly useful for persons travelling across Member States). This classification of goods and services would need to be regularly reviewed, with the objective to have more and more goods and services meeting the higher level of accessibility in the future.

We also want to underline that there is a lack of understanding about inclusive design amongst developers and designers of goods; which is the reason why we believe that the Act should create provisions that encourage manufacturers to create products with a “design for all” approach, where representative organisations of persons with disabilities have the capacity to interfere on the designing and on the expertise of accessibility of a product. It is also necessary to ensure that the gender perspective is mainstreamed during this exercise. The Act should finally contain a provision suggesting the creation of a mechanism that would allow persons with disabilities (and the organisations representing them) to provide feedbacks if goods or services are not accessible enough.

At this stage, we finally want to stress that crucial goods and services (related for instance, to health, transport, education, communication…) must absolutely be fully accessible and systematically meet the maximum level of accessibility criteria suggested previously because they are essential for the participation of persons with disabilities in society.

Last but certainly not least, it is crucial that the accessibility criteria are included in the procurement procedures for goods and services purchased by public authorities and public entities, including in the technical specifications of tenders.

 General approach to evaluate the conditions of access to services (and to the goods linked to the provision of these services)

Specific questions for individuals, and in particular persons with disabilities

17 EDF RESPONSE TO THE PUBLIC CONSULTATION WITH A VIEW TO A EUROPEAN ACCESSIBILITY ACT - MARCH 2012 European Disability Forum Question 8: What are the most important goods and services that in your opinion should be covered by accessibility legislation in order to ensure their accessibility? Questions common to all respondents Question 13 or 15: The accessibility for persons with disabilities of which goods and services should be given priority?

The Act should contain provisions that ensure the following conditions of access to services (and the goods linked to the provision of these services):

- Access to the facility: It remains very difficult for persons with disabilities to access products and services because of the difficulties they encounter to access the premises used to provide such services. Accessibility of the facilities where a service is provided should however be required, which is the reason why it is essential that the surrounding infrastructure and the built environment that provide access to the service are made accessible. The Act should therefore cover access not only built environment but also the physical environment in which the service is provided, which also implies access to adequate transport to and from the place where the service is provided.

- Adequate equipment: Access to services for persons with disabilities is impossible without accessible goods (e.g.: increased accessibility of packaging and leaflets) which correspond to their needs and are based on a gender equality perspective. The Act should therefore ensure that accessibility requirements are applied to the physical infrastructure, equipment and materials related to a service. The Act should also ensure that automatized equipment like self-service machines, but also telematics or electronic devices including websites etc. that are placed at the disposal of the customer for consulting, and handling services are fully accessible.

- Access to information: The Act should tackle the information and communication (including Information and Communication technologies (ICT)) barriers to services. This issue relates to the way in which information is presented and is the most challenging accessibility issue for many persons with disabilities. The insufficient availability of clear displays and adapted orientation signs, for instance in public transport, remains an important communication barrier for persons with disabilities. The Act should also foresee that information provided to service users, as well as contracts and general rules, complaints forms, and customer satisfaction forms, are made available in accessible formats on request.

- Wide range of services offered: Too few service offers provide basic access for persons with disabilities. For instance tickets for trains and flights often cannot be bought on line due to the inaccessibility of the travelling ticketing machines for persons with disabilities. In many cases, they have to pay an extra-fee when buying over the phone or at a physical counter. This

18 EDF RESPONSE TO THE PUBLIC CONSULTATION WITH A VIEW TO A EUROPEAN ACCESSIBILITY ACT - MARCH 2012 European Disability Forum lack of accessible offers should be stressed in the Act as it contributes to the distortion of the service market.

- Trained staff: Training of staff is an essential condition to guarantee access to services and should therefore be covered in the Act. One of the key persistent problems regarding accessibility is the lack of capacity from staff to provide accessible services that meet the need of persons with disabilities. The problems experienced by persons with disabilities in accessing services often relates to prejudices, lack of awareness and stigma. Most such problems are invisible and therefore it is essential that service providers understand that different clients/patients/passengers have different needs and further develop disability awareness and disability equality training for their staff. The presence of trained staff can for instance contribute to build confidence for persons with disabilities to use services which are becoming increasingly automatized.

- Accessible sub-contracting services: In the light of the increasing tendency to sub-contract the provision of certain services via public and private procurement procedures, it is essential that these procedures are also accessible and that the selection criteria include compulsory accessibility standards.

The following list contains a few examples of services for which the conditions mentioned above must be fully applied (as a reminder, EDF believes that all services must be accessible, and the conditions for accessing a service must also be covered by the Act, including the accessibility of goods linked to the provision of that service):

- Transport services: The Act must guarantee full accessibility to all modes of transport, which is far from being the case today and amounts to a barrier to the freedom of movement and access to goods and services. The Act should also cover accessible services providing taxis and rental vehicles for persons with disabilities - Health services: Accessibility of health services is a crucial issue that must be covered by the Act. Access barriers to health have been well-documented in the 2011 WHO World Report on Disability21. In the past, EDF has also raised concerns about the grave impact that inaccessible health services have on women with disabilities, who are unable to access breast and cervical cancer screening. - Education and training services: Education services must be accessible for students and job seekers with disabilities. In this way Member States can comply with their obligations under the UN CRPD to ensure mainstream education services. - Social Services, including social housing: The Act should cover accessibility of social services, including essential services provided directly to the person.

21 http://whqlibdoc.who.int/publications/2011/9789240685215_eng.pdf

19 EDF RESPONSE TO THE PUBLIC CONSULTATION WITH A VIEW TO A EUROPEAN ACCESSIBILITY ACT - MARCH 2012 European Disability Forum These services comprise rehabilitation, social security, employment and training services, social housing, child care, long-term care, and social assistance services. - Emergency services: Persons with disabilities (including elderly) are usually those who are using emergency services the most, which is the reason why the sector should be modernized in order to meet the need of this category of population. Therefore, emergency services (including the contacting of emergency services using 112 and emergency numbers, the rescuing of persons with disabilities, prevention, assistance, and reconstruction) must be tackled by the Act. - Services in relation to cultural life, recreation, leisure and sport: Persons with disabilities should be able to access sites and cultural services delivered in public and privates places (e.g. museums, theatres, cinemas, libraries), including indoor and outdoor exhibitions and shows, and musical and cultural festivals. In this respect, accessibility must include the provision of accessible formats. - Tourism services: Persons with disabilities and their families are increasingly using mainstream tourism services but they are still confronted with many barriers that prevent access to those services. - Banking services: Access to banking services (physical and online) remains an issue for many persons with disabilities, who often must use more expensive services or resort to the help of a personal assistant to be able to manage their bank account or financial portfolio. - Insurance services: Persons with disabilities are generally excluded from health and life insurances preventing them in several EU Member States to access derived services such as mortgage loans which constitute a breach of the principle of freedom of movement and establishment. - Housing services: Persons with disabilities must have access to housing services such as property rental and acquisition services, since these are prerequisites to a life on an equal basis with non-disabled people. Housing services should include social housing, as mentioned in the social services section above. Housing construction services are another aspect to be taken into account. The existing funds for supporting refurbishment provided by the public authorities are insufficient and do not cover the 100% of the reasonable accommodation costs of private houses. In addition, it is practically impossible for many persons with disabilities to live in their own homes because the support needed to do that after the death of parents is not provided. - Retail services: In order to be able to purchase accessible goods and services, persons with disabilities must have the shops (facilities, staff…) made accessible to them. This also implies that the accessible items provided in the shops are displayed alongside for persons with disabilities to be able to purchase the products.

As we already said earlier, goods and services that are placed on the market should be made accessible on the basis of the definition of accessibility proposed by EDF and therefore covered by the European Accessibility Act. However, depending of the type

20 EDF RESPONSE TO THE PUBLIC CONSULTATION WITH A VIEW TO A EUROPEAN ACCESSIBILITY ACT - MARCH 2012 European Disability Forum of goods or service, industry does not need the same amount of time to develop an accessible product. Mechanisms should therefore be set up to encourage companies/industry to provide goods and services that are accessible for persons with disabilities. For instance, incentives like funds allocated for research programmes could be put in place for industry to develop more accessible goods and services, where there is still a technological gap in relation to accessibility.

 Most important policy and legal measures to improve accessibility

Questions common to all respondents Question 14 or 16: Which are the most important policy and legal measures to improve accessibility in your opinion?

First of all, EDF would like to point out the importance of horizontal measures tackling accessibility at every level of EU action, including legislation, in order to ensure equal competition within the internal market, and thus providing the means in favour of equal opportunities between EU citizens. EU funded programmes should also include accessibility for persons with disabilities as a horizontal requirement.

As regards the most important policy and legal measures to improve accessibility, EDF suggests: - A legislation, such as a European Accessibility Act, that is based on the internal market legal basis and includes a generic definition of accessibility; - This Act should be underpinned by formal European standards - Legislation addressing accessibility of websites, especially public ones, as foreseen under the Digital Agenda for Europe Action 64 should complement the European Accessibility Act (addressing ICT goods and services). - Legislation should include a link to EU public procurement rules (which should normally be adopted before the Act). Draft revised legislation on public procurement already includes a reference to future EU legislation on accessibility22. EDF however would like to remind that the threshold to be subject to public procurement rules is very high; so many products and services bought or provided through public procurement would not be required to be accessible to persons with disabilities. We also believe that private procurement should include accessibility rules. - To facilitate the access to products and services for persons with disabilities, education and training of service providers should be required, and structural funds could be used in that sense. - EU funding that encourage the development of accessible goods and services:

22 Proposal for a DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on public procurement: http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=COM:2011:0896:FIN:EN:PDF

21 EDF RESPONSE TO THE PUBLIC CONSULTATION WITH A VIEW TO A EUROPEAN ACCESSIBILITY ACT - MARCH 2012 European Disability Forum o The recent Commission´s proposals to create a Connecting Europe Facility23, as a financial instrument to fund the future trans-European transport Network (TEN-T) projects24, would also be very important if the European Parliament and the Council agree to include accessibility as an eligibility criteria to fund TEN-T projects. o Disability has been recognized as a general ex-ante conditionality requiring every EU co-funded project to take it into account as a mainstreaming principle in the proposal for the new General Regulations governing the structural funds25. It means that funding could be suspended if these conditions would not apply. In addition, article 87 of the proposal states that operational programmes shall include accessibility requirements in the description of the actions funded. It is however important that the article 7 of the proposal, which sets common provisions that apply to all the funds, includes accessibility as it the case in the current regulations, so as to ensure effective implementation. o The new EU research framework programme should also require accessibility as a precondition for awarding funding to a project. It should also specify that funding should be dedicated to further develop accessibility of some products and services (e.g. provision of accessibility features on TV). EU funding must however exclude the costs for disability-related assistance. For instance, sign language interpreter costs must be separate to the budget allocated, in order to ensure competitiveness of projects including or being led by persons with disabilities. - EDF believes that legislation which lacks a proper enforcement mechanism and monitoring system (involving the disability movement) is not capable of delivering accessibility. In addition, legislations setting out monitoring, control and sanctioning mechanisms must be put in place to make it possible to report and provide retribution for the harm caused to people as a result of failure to comply with accessibility legislation. Finally, it is important the EU provides a legislation that obliges Member States to comply with accessibility, placing deadlines on Member States and/or market operators for compliance.

23 Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL establishing the Connecting Europe Facility : http://ec.europa.eu/commission_2010- 2014/president/news/speeches-statements/pdf/20111019_2_en.pdf 24 Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on Union guidelines for the development of the trans-European transport network : http://ec.europa.eu/transport/infrastructure/connecting/doc/revision/legislative-act-ten-t- revision.pdf 25 Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL laying down common provisions on the European Regional Development Fund, the European Social Fund, the Cohesion Fund, the European Agricultural Fund for Rural Development and the European Maritime and Fisheries Fund covered by the Common Strategic Framework and laying down general provisions on the European Regional Development Fund, the European Social Fund and the Cohesion Fund and repealing Regulation (EC) No 1083/2006: http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=COM:2011:0615:FIN:EN:PDF

22 EDF RESPONSE TO THE PUBLIC CONSULTATION WITH A VIEW TO A EUROPEAN ACCESSIBILITY ACT - MARCH 2012 European Disability Forum - Finally, European Institutions and Member States should develop campaigns to raise public and stakeholder’s awareness about accessibility for persons with disabilities. Awareness-raising campaigns directed to market operators are also useful so that companies appreciate the advantages of producing accessible goods and services designed to be used by all.

 Essential provisions for the effectiveness and success of a European legislation on accessibility

Questions common to all respondents Question 17 or 19: Based on your experience with existing national or foreign accessibility legislation, which provisions do you consider as essential for the effectiveness and success of such legislation? In that context could you please explain how prescriptive and detailed do you think accessibility legislation should be and how it should be enforced?

We believe that the EU should draw inspiration from the US experience of legislating on accessibility for goods and services. In the US, there is evidence that the cost of providing accessibility is very limited compared to the benefits for society, such as increased employment, consumer spending and decreased welfare dependency. It is for example imperative to define clearly in legislation which websites have to be accessible.

EDF also believes that a European Accessibility Act should be linked to European standards, which will be established by the European standardization organizations following the issuing of standardization mandates by the European Commission. Where no relevant standards have (yet) been set, a generic essential requirement to provide accessibility will apply. However where higher standards are already in place, these new technical European standards (if lower) are not to replace them.

Public awareness is particularly important for an efficient implementation of the legislation. In order to ensure the success of accessibility legislation, it is therefore necessary to convince the stakeholders and the public that the issue of accessibility is a major challenge for the whole society. A key factor for the success of accessibility legislation in Europe consists in an effective and full evaluation of the potential niche market for the suppliers of accessible products and services. Companies must be made aware of the fact that an increasing part of the population in Europe faces some type of accessibility difficulty (mostly due to the ageing of European societies). They must understand that adapted and accessible products would not be targeted for a small target group of potential customers.

A European legislation on accessibility should ensure effective enforcement and monitoring:

23 EDF RESPONSE TO THE PUBLIC CONSULTATION WITH A VIEW TO A EUROPEAN ACCESSIBILITY ACT - MARCH 2012 European Disability Forum - The legislation must impose clear deadlines for Member States and/or market operators to comply. - The European Commission would need to report regularly to the European Parliament and the Council on the implementation of the legislation. - The legislation shall also set up a clear timeframe for the application and monitoring of accessibility requirements of goods and services (that we mentioned under the section on a general approach to evaluate the accessibility of goods and services).

Both individuals and civil society organizations should also be allowed to take legal action at national level where accessibility criteria are not complied with. However, taking legal action on an individual basis is very costly and is simply not an option for many disabled people, which is the reason why alternative legal actions (e.g. collective redress) must be part of the equation to effectively secure robust enforcement.

 Role of public authorities and market operators

Questions common to all respondents Question 15 or 17: What should public authorities and market operators do to improve accessibility of goods and services?

The European Accessibility Act must establish some basic accessibility requirements for goods and services. European standards, which would be linked to the Act and adopted by CEN, CENELEC and ETSI, would need to be progressively elaborated and extended to cover as high a number of goods and services as possible. Public authorities have a strong role to play in creating and fostering an accessible environment and should use their purchasing power (public procurement) to buy accessible goods and services for their employees and citizens / residents. European standards that are currently being developed (i.e. Standardization mandates 376 and 420) will assist public authorities to do that. Public authorities have also an important role to play to monitor and provide independent certification of accessible goods and services put on the market.

Accessible goods and services will give persons with disabilities the possibility to do things by themselves, so the need for public authorities to provide individualised services to persons with disabilities will decrease, which will release resources from national, regional and/or local budgets. Public authorities could dedicate these resources for boosting the actions to improve accessibility of goods and services. Tax incentive measures could be put in place so as to encourage the renovation of existing facilities where services are provided or for goods that go beyond requirements established in legislation.

24 EDF RESPONSE TO THE PUBLIC CONSULTATION WITH A VIEW TO A EUROPEAN ACCESSIBILITY ACT - MARCH 2012 European Disability Forum Market operators, such as manufacturers or service providers, should be encouraged to include accessibility requirements within the design process, right from the very beginning. Market operators could also foster research in the areas where technical means for achieving accessibility are still absent, supported by European research and innovation programmes and /or the Cohesion Policy funds. Economic incentives, such as tax reductions could be envisaged for market retailers that develop innovative accessible products and services.

Education and training on accessibility for staff of public authorities and market operators is also crucial. Training programmes must highlight the principles of design for all persons and accessibility requirements. Public authorities and market operators should also give information to their clients on the levels of accessibility provided.

Finally, the cooperation of public authorities with market operators with national and European disability movement is the basic prerequisite for the improvement of accessibility in all domains. Disabled people organizations have to be involved in the design, monitoring, evaluation of the whole process for the improvement of accessibility.

 Role of SME's

Questions common to all respondents Question 16 or 18: Could you please provide your opinion on the role that SME's could play in the provision of accessible goods and service? Should there be any specific measures to that extent?

SMEs should be covered by the European Accessibility Act because their role is crucial in ensuring access to goods and services for persons with disabilities. Furthermore many SMEs already employ persons with disabilities.

Currently, providers of accessible goods and services are mostly SMEs. They could therefore benefit from important competitive advantage if EU requirements for accessibility are set up. For instance supplying accessible goods and services and delivering accessibility-related services to other companies can be an interesting market for many SMEs. They can also contribute to the development of Assistive Technologies, and therefore play a strong role in innovation in the area of accessibility.

In light of this, we believe that no derogations for SMEs should be included in the legislation. However we believe that SMEs could benefit from further incentives to provide accessible goods and services. For instance, innovative driven solutions in accessibility and design for all could be boosted through credit facilities. Public authorities could offer programmes aimed at promoting the implementation and

25 EDF RESPONSE TO THE PUBLIC CONSULTATION WITH A VIEW TO A EUROPEAN ACCESSIBILITY ACT - MARCH 2012 European Disability Forum development of good practices in accessibility in SMEs. SMEs could also receive support to organize training that would strengthen the capacity of their staff to provide accessible services for persons with disabilities.

3. Acknowledgments

This document has been prepared in consultation with all EDF membership. EDF would like to thank all those that have actively contributed to the drafting of this document, and in particular Autism Europe, French Council of Disabled People for European Affairs (CFHE), Disabled Peoples Organisations Denmark (DH), European Blind Union (EBU), European Guide Dog Federation (EGDF), National Confederation of Disabled People of Greece (ESAEA), European Union of the Deaf (EUD), European Women’s Lobby (EWL), National Council of Federations of People with Disabilities in Hungary (FESZT), Italian Disability Forum (FID), the Finnish Federation of Hard of Hearing (FFHOH), the Swedish Disability Federation (HSO), Mental Health Europe, and Lithuanian National Forum of the Disabled (LNF). A special thanks to Professor Lisa Waddington (University of Maastricht).

4. APPENDIX

A. EDF Freedom Guide is available in English online (check website).

B. Contact Person at the EDF Secretariat:

Carlotta Besozzi, EDF Director Tel: +32/0 2 282 46 06, Email: [email protected] More information about EDF is available on www.edf-feph.org. Should you have any problems in accessing the document, please contact the EDF Secretariat (T: +32/0 2 282 46 00; E: [email protected]).

26 EDF RESPONSE TO THE PUBLIC CONSULTATION WITH A VIEW TO A EUROPEAN ACCESSIBILITY ACT - MARCH 2012