I've written twice about the way the BIS handles it's consultations. In November 2009, I remarked on their massive inflation of the file size, while removing functionality, and readability. Then, last month (September 2010) I noted they did the same things again, but did such a poor job that some of the footnotes and references were not only illegible, they were missed off. So, I sent the following complaint to the BIS.
From: Andrew Norton [mailto:[email protected]]
Sent: 14 September 2010 21:25
To: [email protected]
Subject: consultation documents and responses
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I am writing to complain about the state of the documents published as responses to consultations. I have participated in several over the past few years, and each time, when the responses are published, the documents are published in a vastly degraded quality in comparison to how they were submitted.
Additionally, the way these documents have been processed (printed out, doodled on, scanned back in) means that they are treated as images, and thus incapable of being adequately viewed by those who are disabled. As an example, I'm using this response document, published today by the BIS.
As they are full page image files, screen-readers are incapable of being used, which is discriminatory against blind and partially sighted people. The degradation of clarity that arises from printing and rescanning compounds this further. Pages 10 and 11 in the reference document are a prime example.
Additionally, as I understand things, the publication of these responses is to allow the data that the government has recieved and based its decision on to be publicly reviewed so that any outragously false evidence that has been submitted can be identified and brought to public attention. Unfortunately, the process for handling documents by the BIS has meant that certain references in some of the responses are missing, while others are mangled by incompetent image handling.
Again, page 10 is a clear example, as reference 6 is missing entirely, cut off at the bottom of the page. Additionally, the image-based format makes it impossible to copy hyperlink references to check. Instead they must be laboriously copied out, a process made near-impossible at times by the poor quality of the text.
Finally, I know that many of the submissions were made digitally, and required no redaction of any sort, yet instead of using the digital data, it was converted to an analogue medium, at a vastly increased size. This additionally increases overheads for the publication of documents due to increased disc space, and bandwidth usage. For an example, last year I submitted a consultation response (http://ktetch.files.wordpress.com/2009/09/uk-p2p-consultation-response-290909.pdf) on the Digital Economy Bill. It was 272kb, and disabled accessible. The version the BIS released (in this zip - http://www.berr.gov.uk/files/file53678.ZIP) was 3.88Mb, and unable to be read by many. increasing the file size 14x but making it worse, that's not smart.
I would appreciate a response on these important questions
Norton P2P Research
Tel: +1 (352)6-KTETCH
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(yes, I automatically sign all my emails - I always stand behind my statements, and it helps make sure they're quoted accurately)
This morning, I got a result.
Subject: RE: consultation documents and responses...partially sighted people not able to view BIS consultation responses
Date: Mon, 4 Oct 2010 12:00:18 +0100
From: "Turnbull John \(Communications\)" <[email protected]>
To: <[email protected]>
Cc: "Idowu Babatunde \(CLG\)" <[email protected]>,
"Rosenberg Jeanette \(EDD\)" <[email protected]>
Dear Mr Norton
Thank you for your email of 14 Sept. You pointed out that partially sighted people are not able to view some of the BIS consultation responses that we publish on the BIS website.
We are well aware of web accessibility issues and are committed to making the information on our website accessible to the widest possible audience. We should and can do better when it comes to consultation
Consultations often receive many dozens of responses. Those received as hard copy are scanned and then published on the website. As you point out, this process often degrades clarity and renders documents inaccessible to assistive technology. We will in future aim to scan documents in such a way as to make the text accessible.
Those received as electronic documents should not need to be scanned. We will no longer publish scanned documents when an electronic version is available.
In addition, my team is working with policy colleagues to raise awareness of web accessibility issues and to ensure that accessibility is integrated into the process for dealing with consultation responses.
I will update you on progress at a later date.
John Turnbull | Web Publishing Manager | Department for Business,
Innovation & Skills | [email protected] | Abbey 1, 7th Floor,
1 Victoria Street, London, SW1H 0ET | Tel: 020 7215 6196 | Web:
www.bis.gov.uk | Twitter: http://twitter.com/bisgovuk | YouTube: