Relay Service (hereinafter referred to as the VRS), the scope is limited. So far,
there is no consensus among authorities as regards how to introduce a service
platform with the cooperation of telecommunication companies to achieve fully
accessible phone communication. 46 The NHRC will continue to monitor the
results of the follow-up improvements.
53.
The NHRC is concerned that the NCC has listed the television broadcasters’
promotion of media accessibility for persons with hearing or visual impairments
as an assessment item for the renewal of licenses and review of terrestrial
television broadcasters but as a bonus item applying to establish a satellite
channel.47 However, the actual results of the promotion of media accessibility to
46
47
According to Article 2, Subsection 14 of the PDRPA: “The competent authorities in charge of
communication and propagation are responsible for the planning, implementation and supervision of
the affairs/issues concerning the access-free information, technology and appliance scheme/system of
communication & propagation, Internet platforms, appliances and processing without discrimination
in favor of people with disabilities, etc.” However, the NCC appears to believe that the scope of
responsibilities of the competent authority mentioned in Article 2, Subsection 14 of the PDRPA does
not include VRS. The commission states that the law's scope mainly involves accessible webpages
and Public Warning System (hardware for the hearing impaired, screen reader software for the visually
impaired), which the commission has adequately handled. However, the focus of VRS is on humanto-human, or “the hearing impaired” to “the hearing people”, which may differ from the scope of
Subsection 14. The VRS platform used by persons with hearing impairments is not a general
communication service. Still, a complete information service system established on the Internet
combines images, text, and sign language interpretation to provide information application services,
which is not included in the scope of the telecommunication services provided by telecom companies.
Additionally, it would require sign language interpreters who work long shifts and must complete
video relays and access the control system, which is an enormous investment and difficult for the
commission to require telecom companies to cooperate to build arbitrarily. There are already
businesses that provide VRS, and some local governments (such as the Penghu County government)
have collaborated with them to adopt these services. If the telecom industry is asked to establish
similar services, there are concerns about redundancy. The NCC suggests following the guidelines
specified in the PDRPA, in which the allocation and subsidization of the welfare budget for persons
with disabilities should be managed by the MOHW or local governments, which can consider
providing subsidies or rewards to information service providers that provide relevant services.
However, on November 23, 2020, when the MOHW’s Committee for the Promotion and Protection
of the Rights of People with Disabilities held the first meeting of the 7 th convention, the representatives
of persons with disabilities had already raised this need with the NCC. The MOHW held the second
meeting on March 12, 2021, and a resolution was passed to “ask the NCC to hold a meeting inviting
telecom companies to discuss the possibility of introducing VRS technology, and inviting MOHW
members to participate when necessary. A recommendation was also made to incorporate the corporate
social responsibility of telecom companies into future laws.” The NCC then asked the telecom
companies to conduct a preliminary assessment based on the resolution.
In the NCC’s Regulations for Terrestrial Television Business License Renewal Applications, under
“other matters designated by the competent authority”, companies are required to fill in “the handling
of matters related to gender equality, child protection, cultural diversity, or the promotion of media
accessibility to persons with visual or hearing impairments”. Additionally, under “other matters
designated by the competent authority” in the Guidelines for the Planning and Operations of the TV
Broadcast Industry, companies are required to describe “the handling of matters related to gender
equality, child protection, cultural diversity, or promotion of media accessibility to the visually and
40