[pic] | COMMISSION OF THE EUROPEAN COMMUNITIES |

Brussels, 8.11.2007

SEC(2007) 1469

COMMISSION STAFF WORKING DOCUMENT Accompanying document to the

COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS

European i2010 initiative on e-Inclusion

"To be part of the information society"

Impact Assessment [COM(2007) 694 final][SEC(2007) 1470]

Impact Assessment of the

COMMUNICATION FROM THE COMMISSION TO THE COUNCIL, THE EUROPEAN PARLIAMENT AND THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMITTEE OF THE REGIONS

European i2010 initiative on e-inclusion "No one left behind in the information society"

Table of Contents

Scope of the IA 6

Contents, and Guidelines analytical steps 6

1. What problem is the Communication expected to address? 7

1.1. What are the issues that may require action? 8

1.2. Who are the actors? 16

1.3. Key e-inclusion enablers for a barrier-free information society 21

1.4. How would the problem evolve, all things being equal? 22

1.5. Should the EU act? 23

1.6. European Union grounds for action: subsidiarity and proportionality tests 28

1.7. Lessons learnt and the European added value 29

2. Objectives 32

2.1. General objective, specific objectives and actions 32

2.2. Consistency with the horizontal policy objectives of the European Union 35

3. Defining the options 38

3.1. The options 42

3.2. Option A 42

3.3. Option B 42

3.4. Option C 42

4. Options impacts and comparison 45

4.1. Options' implications and potential impacts 46

4.2. Comparing the options 54

4.3. e-Inclusion policy impacts on quality of life and the environment 59

4.4. Tangible impacts if disparities are halved: a scenario 60

5. Monitoring and evaluation 65

5.1. Measuring achievement of outputs 65

5.2. Continuing Riga Dashboard 65

5.3. Current knowledge gaps 66

5.4. Proposed new monitoring instruments 67

6. Conclusions – the preferred option 68

7. Annex 1: Procedural issues and background 70

7.1. Procedural issues 70

7.2. Compliance to the opinion of the Impact Assessment Board 71

7.3. Ad Hoc Consultation 72

7.4. Methodology and studies supporting the proposed policy measures 73

7.5. Other consultation and contacts 75

7.6. What did we learn? 76

7.7. Proportionality of the impact assessment. 77

8. Annex 2: Riga dashboard and beyond 78

8.1. Reducing regular internet usage disparities in at risks groups 78

8.2. e-Accessibility 86

8.3. Broadband coverage 86

8.4. Digital literacy 90

8.5. Beyond Riga Dashboard: Inclusive e-Government 92

8.6. Beyond Riga Dashboard: ICT and active ageing 95

8.7. Beyond Riga Dashboard: ICT and cultural diversity 96

9. Annex 3: Literature review and modelling e-Inclusion 98

9.1. Beyond the digital divide and S-Shaped thinking? 99

9.2. Insights from social theories and research 104

9.3. Insights from emerging theories of digital inequalities 112

9.4. Modelling e-Inclusion 115

9.5. A Heuristic Model of Digital Inequalities and inclusion/exclusion outcomes 118

10. Annex 4: e-Inclusion potential impacts 124

10.1. Avoiding risks 124

10.2. e-Inclusion Positive Impact Framework 124

10.3. Illustrative quantitative evidence of potential impacts 128

10.4. e-Accessibility impacts 138

11. Annex 5: State of play in e-Accessibility 141

11.1. What is e-Accessibility and which problems can it solve? 141

11.2. Why is public intervention on e-Accessibility needed? 142

11.3. What is the current legislation on e-Accessibility 143

11.4. Market barriers for e-Accessibility and digital inequalities 144

11.5. Assessing e-Accessibility: trends and recent developments 148

11.6. TV broadcast 152

11.7. Computer hard- and software 154

11.8. Web content and services 156

11.9. Self-service terminals 157

11.10. Overview of Member States e-Accessibility legislation and policy 159

11.11. Technology challenges in e-Accessibility 164

12. Annex 6: Preliminary Assessment of policy options for e-Accessibility 170

12.1. What are the main options to achieve policy objectives for e-Accessibility? 170

12.2. Policy implication/impacts of different options 173

Introductory remarks and definition of key concepts

This is the Impact Assessment (henceforth IA) for the forthcoming proposal for a Communication on the EU e-Inclusion Initiative (henceforth simply the Communication).

All the procedural requirements prescribed by Commission Impact Assessment Guidelines (henceforth simply Guidelines) have been met and are listed in Annex 1.

Background to the Communication and procedural issues

The Communication is the result of a long process involving several intermediate policy steps and documents, activities of ad hoc work groups and broad stakeholder consultation.

This IA takes into considerations the opinions and recommendations of the impact assessment board IAB (see also annex 1).

The Communication will provide a comprehensive approach to e-Inclusion as was requested in the i2010 Communication[1]. Following the roadmap for the activities of DG Information Society and Media, the Communication aims to launch a more coherent set of actions in 2008.

The actions foreseen in the Communication build on the consensus and commitments of the Riga Ministerial Declaration on an Inclusive Information Society of 11 June 2006. In many instances the Riga Declaration explicitly invited the Commission to act on these areas.

The preliminary results of the ad-hoc consultation launched for this e-Inclusion Communication provide a very strong consensus and support for the EU to undertake these actions (see Annex 1). Additionally, the ad hoc work of groups and consultation with stakeholders conducted between 2002 and 2007 confirm such support and consensus.

It is worth recalling that the need for review of the e-Accessibility situation was already foreseen in the 2005 e-Accessibility Communication[2] and the Riga Declaration explicitly invited the European Commission to re-assess the status of e-Accessibility in the EU in 2007[3]. The IA considers e-Accessibility along other measures in its core part. In addition, it provides an indepth analysis of this specific topic in Annexes 5 and 6.

Therefore the justification for this Communication is already strongly inscribed in policy antecedents, as well as in consensus and commitments from Member States. Such support entails lower coordination costs and makes the proposed measures highly feasible, in line with the proportionality principle.

Scope of the IA

The actions proposed in the Communication are essentially non-regulatory and impose little burden if any on all affected players.

Accordingly, the IA defines the problems, explores possible options for solutions, and provides a qualitative assessment of the impacts of the various options. In doing so, it fully meets the principle of proportionate analysis set out in the Guidelines[4].

In addition to this the IA provides preliminary quantitative estimates of tangible economic impacts that could be achieved if the targets set in the mentioned Riga declaration were met in the next five years. This is done to illustrate that e-Inclusion is not to be seen as a problem only but is equally an opportunity. These estimates do not imply that such economic gains can be achieved simply as a direct result of the Option proposed for the e-Inclusion Communication. Rather, while the proposed Option will provide an important contribution, for this scenario to materialise additional efforts, outside the scope of where the EU can act, will be required from all other involved players (Member States, industry, civil society, etc).

Any legislative measures that may be proposed in the future and follow from the proposal contained in the Communication would be subject to a further impact assessment of the options to be considered.

Contents, and Guidelines analytical steps

- Chapter 1 defines the problem, actors how the problem may evolve, the need for action at EU level.

- Chapter 2 presents the objectives and their consistency with broader EU objectives.

- Chapter 3 defines and briefly discusses the options.

- Chapter 4 combines a qualitative assessment of the impacts and a comparison of the options.

- Chapter 5 discusses monitoring and evaluation mechanisms.

- Chapter 6 summarises the findings in a conclusion.

The annexes present measurements of the state of play of e-Inclusion, reflections based on literature analysis on the nature of e-Inclusion, a general and selective quantification of the potential impacts that could be achieved by the e-Inclusion policy, the state of play in e-Accessibility, and the more detailed of the consideration options for e-Accessibility.

1. WHAT PROBLEM IS THE COMMUNICATION EXPECTED TO ADDRESS?

E-inclusion means both inclusive information and communication technologies (ICT) and the use of ICT to achieve wider inclusion objectives[5]. In other words, e-inclusion refers to the extent to which information and communication technologies help to equalise and promote participation in society at all levels by enhancing social relationships, facilitating economic opportunities for work and entrepreneurship, developing cultural aspects of society, encouraging civic participation.

The e-inclusion problem is therefore both the lack of inclusive ICT, i.e. an information society that has barriers due to the technology itself, as well as the lack of contributing with ICT to advancing economic and social inclusion in general. It is conservatively estimated that currently some 30% to 40% of the population does not fully benefit from the information society[6] (see annex 2 and 4).

However, it is worth stressing that “the e-Inclusion problem”, in fact, is an opportunity . To state it better, the problem would become a missed opportunity if not addressed properly by policy makers at EU, national, regional and local level.

We are today at a turning point both in policy making and in academic research on the approach to inclusion in general. Inclusion is increasingly seen as one of the corner stones of economic growth itself, or in other words social inclusion and economic growth are the two sides of the same coin, namely growing and sustainable well being for all society. This is not simply a normative principle or a hope, as an increasing number of economic arguments put forward show that robust growth and inclusion can be complementary objectives[7]. Enlarging the pool of included people is thus no longer considered a way to counter balance the negative consequences of market economy growth and to pay lip service to social cohesion showing the ‘charitable face’ of policy making[8]..

As our everyday and work lives are increasingly entangled in activities and relations enabled by ICT, growth depends from ICT use to a large extent, and will increasingly continue to do so in the future. Therefore, the goal of broad-based growth is dependent also on the number of digitally included and digitally empowered individuals.

The wellbeing of a vibrant European society depends also on human capital, social capital, health, and reduction of the costs of social exclusion and in general on the quality of life. All of these variables add up to determine the level of social cohesion of our societies and ICT can help in most of these areas. As a simple indication of the more socially oriented gain, today the costs of social exclusion in the EU27 can be estimated between an upper bound of € 764 billion and a lower bound of € 440 billion p.a. Even under the conservative assumption that e-inclusion policy will help reduce this cost by only a few percent this would already amount to tens of billions of euros. This would be the cost of the non-participation of 30% to 40% of the population in the information society.

If all Riga targets were met (see Box 1 below), reaching the goals of a digitally included society could boost economic growth in Europe by an estimated €85 billion in the next five years. The proposed e-Inclusion Initiative is intended to contribute to the fulfilment of these targets by stepping up efforts at EU and Member States level. This will result into a social and an economic opportunity for people currently at risk of exclusion.The initiative will mainly rely on enhanced synergy of policy instruments and activities already in place. When new actions are proposed for further assessment, such as in the case of exploring potentials of horizontal legislation on e-Accessibility in order to address areas were particular market or coordination failures exist, this impact assessment only anticipates potential benefits and costs in a preliminary manner while due assessment will be performed in the eventuality of regulatory measures being proposed.

There are thus significant potential benefits for economic and society at large. The potential benefits for individuals by becoming digitally engaged include:

- Better skills increasing employability or entrepreneurial opportunities;

- Increased productivity and income;

- Better health awareness and access to health services through e-Health, better health;

- Better quality of life;

- Stronger and strengthened social relations through ICT enabled networking;

- Strengthened community cohesion and trust;

- Improved access to entitlements through simplified online forms;

- Ease and convenience to comply with government obligations through online services (taxes, permits, information), saving time, increasing trust in government;

- Better access to information and engagement in public issues (e-Participation).

1.1. What are the issues that may require action?

The Riga Ministerial Declaration, using the 2005 data available at the time, agreed that ”many Europeans still reap few or no benefits from ICT and there are resilient gaps in ICT use”. For instance, it stated that 57% of individuals living in the EU did not regularly use the Internet in 2005; only 10% of persons over 65 used Internet, against 68% of those aged 16-24; only 24% of persons with low education used the Internet, against 73% of those with high education; only 32% of unemployed persons used the Internet against 54% of employed persons. Only about 5% % of public web sites surveyed comply with the minimum web accessibility standards and guidelines, hindering access to web content and services for people with disabilities who comprise some 15% of the EU population"[9].

The Riga declaration also identified key issues and targets in 6 areas, namely ICT and ageing, geographical digital divides, e-accessibility (i.e. the usability of ICT for people with disabilities), digital literacy and competences, ICT for cultural diversity and inclusive e-government. Relevant extracts are reported in the box below.

Box 1: Riga targets: extracts from the Riga Declaration

___________________________________ Overall Considerations and inspirations Information and communication technologies (ICT) are a powerful driver of growth and employment. A quarter of EU GDP growth and around 50% of productivity growth are due to ICT. ICT services, skills, media and content, and their use in other industry sectors, are a growing part of the economy and society. ICT is thus strongly instrumental to achieving the Lisbon strategy goals. ICT contributes to improving the quality of everyday life and social participation of Europeans, facilitating access to information, media, content and services, to enhanced and more flexible job opportunities, and to fight against discrimination. Improving ICT access for people with disabilities and elderly is particularly important. “e-Inclusion” means both inclusive ICT and the use of ICT to achieve wider inclusion objectives. It focuses on participation of all individuals and communities in all aspects of the information society. eInclusion policy, therefore, aims at reducing gaps in ICT usage and promoting the use of ICT to overcome exclusion, and improve economic performance, employment opportunities, quality of life, social participation and cohesion. ___________________________________ General quantitative target To convincingly address e-Inclusion, the differences in Internet usage between current average use by the EU population and use by older people, people with disabilities, women, lower education groups, unemployed and “less-developed” regions should be reduced to a half, from 2005 to 2010 ___________________________________ Area specific quantitative and qualitative policy targets and actions ICT and Ageing. Reduce to a half the gap in current average internet use between the EU population and older people; remove barriers to internal market of ICT services and products for the elderly; support active ageing at work, especially through greater training for ICT skills; support active participation of elderly in society; support independent living and quality of life Geographical Divides. Significantly reduce regional disparities in internet access across the EU, increase the availability of broadband (coverage) in under served locations, and aim for broadband coverage to reach at least 90% of the EU population by 2010 e-Accessibility. Fully implement the e-Accessibility provisions in EU legislation, use all instruments available, from voluntary industry commitments to new legal provisions at EU and national level where appropriate, regularly assess the effectiveness of these various instruments Inclusive e-Government. Promote and ensure accessibility of all public web sites by 2010. Designing and delivering key services and public service policies in a user centric and inclusive way, using channels, incentives and intermediaries that maximise benefits and convenience for all so that no one is left behind Digital Literacy. Reduce by half by 2010 the digital literacy gap between the EU population and the unemployed, immigrants, people with low education levels, people with disabilities, and elderly, as well as marginalised young people Cultural Diversity. Promote cultural diversity in relation to inclusion by: fostering pluralism, cultural diversity and linguistic diversity in the digital space (multilingual, local, cultural heritage, European values content); improving economic and social participation and integration, creativity and entrepreneurship of immigrants and ethnic minorities through their greater participation in information society |

- Progress on the Riga targets

The data available show that in most areas only limited progress has been made toward achieving the Riga targets (see more in Annex 2)[10]. Below, responses from the public consultation are given. These are quoted here to illustrate tendencies.

1. General usage disparities

While gender disparities in regular use are decreasing (the percentage of women using regularly the Internet in the EU27 at the end of 2006 was only 7% lower than the aggregate average for the entire population) in other areas disparities are still considerable.

For instance the percentage of regular Internet usage in 2006 (against data for 2005) for the EU27 was:

- 71% (68%) for 16-24 versus only 10% (10%) among those aged 65-74;

- 76% (73%) among Europeans with high formal education versus only 25% (24%) among Europeans with no or low level of formal education

- 58% (54%) among those in employment versus 36% (32%) among the unemployed in EU27 at the end of 2006).

- 51% among individuals living in densely populated areas versus 35% for those living in sparsely populated areas.

Moreover, about 15 million students in EU27 do not use Internet, which is a big disadvantage to leverage the potential of education, and among the 16-24 groups still 18 million do not use Internet. While statistics do not allow a precise quantification, figures on younger Europeans not using the Internet will to a large extent overlap with the pool of marginal youth, from which a large part of the cost to government and society of dealing with social exclusion originates. It is also worth stressing that in the group 24-55 still about 50% do not use the Internet.

2. e-Accessibility and ICT usability[11]

- on average in the EU27 only 5% of public websites comply with the minimum web accessibility standards and guidelines[12]

- the percentage of subtitled audio-visual programming varies widely (from 2.5% to 95%)[13]

- the percentage of sign-language programming is a lot less than for subtitling and varies considerably (from less than 0.5% to 5%)

- Broadcasting with audio description ranges from less than 1% to more than 10%

- Considerable fragmentation across product ranges refers to built-in accessibility in PCs and software.

From the public consultation[14] There has not been sufficient progress since 2005 in overcoming legal fragmentation (69% of individual respondents), nor market fragmentation (72% of individual respondents). Respondents from the ICT industry also shared some concerns on possible market fragmentation due to emerging regulatory approaches at member state level. e-accessibility provisions in EU must be reinforced (83% of individual respondents), notably through standards (80% of individual respondents), by revising current EU legislation and funding programmes (90% of individual respondents), and introducing new EU legislation addressing e-accessibility (74% of individual respondents). Industry players, while recognising risks of market fragmentation under current regulatory approaches by member states, voiced a more cautious approach to introducing new legislation, suggested improving standardisation and invited to pursue solutions based on codes of conduct and voluntary requirements. Further European efforts are specifically necessary on web accessibility (87% of individual respondents). Stronger requirements on e-accessibility will be beneficial to individuals, European industry and overall society (respectively, 85%, 75% and 86% of individual respondents). |

- 3. Broadband

Here progress has been more visible and most recent data show that the broadband coverage target set in Riga has been met: 89% of the EU27 population is covered by broadband at the end of 2006 (92% in EU 15). But when looking at the territorial dimension it appears that geo-divides persist as in rural areas the average coverage stands at only 71%, with lower download speeds available than in urban areas and less competition between alternative providers. Moreover, there are wide differences at country and regional level: Greece is still lagging behind with only 18% while Benelux countries as well as DK or the UK are close to 100% (see more in Annex 2).

4. Digital literacy and competences

The situation with the diffusion of digital skills is summarised in the table below.

Table 1: Digital literacy in the EU27

Internet User Skills |

Internet user skill level | EU total | Low educated | Aged 55-64 | Aged 65-74 | Retired/ inactive | unemployed | women |

Never used | 43 | 67 | 65 | 85 | 76 | 48 | 47 |

Have some degree of internet skills | 57 | 33 | 35 | 15 | 24 | 52 | 53 |

Computer User Skills |

Computer user skill level | EU total | Low educated | Aged 55-64 | Aged 65-74 | Retired/ inactive | unemployed | women |

Never used | 41 | 65 | 61 | 83 | 73 | 44 | 44 |

Have some degree of computer skills | 59 | 35 | 39 | 17 | 27 | 56 | 56 |

Notes 1. Figures are the percentage of the population in the particular group 2. Low educational level applies to those with no formal education, primary or lower secondary education (corresponding to UNESCO's ISCED classification levels 0, 1 or 2) |

Source: Eurostat, Community Survey on ICT use in Households and by Individuals, 2006 |

Only 57% of Europeans have some degree of Internet and computer skills, and the way this is measured refers to really basic and operational competence, that would still be insufficient to gain full benefits from ICT (See Annex 3).

Groups with the lowest computer and Internet skill levels when compared to the EU average are again the less educated, older people and the economically inactive. The unemployed, however, though still slightly below the EU average have better computer and Internet skills levels than the other three groups. However, if unemployment situations are combined with other forms of social exclusion (such as low education levels, specific disadvantage in terms of geographical locations or old age) digital skills become particularly important to ensure a potential for reintegration in labour markets.

From the public consultation ICT-related competences should be promoted through formal and in formal education schemes (92% of individual respondents). In this area there should be more active partnerships (85% of respondents) and European co-ordination efforts to promote standard qualifications and support initiatives (78% of individual respondents). Business players and industry representatives strongly supported the establishment of partnerships to increase digital competences. |

- 5. Use of e-Government services.

Among the population in the age group 15-74 in 2006 in EU27:

- 21% used the service to get information;

- 13.3% downloaded forms;

- 8.8% completed transactions

For the EU25, where data are available also for 2004 and 2005, the growth in this figure is very flat. The low take up of transactional services clearly limits the efficiency savings than can accrue to government.

While non disaggregated data are available by socio-economic parameter, given the usage disparities described earlier, it is fair to assume that the less socially included, being those who most need government services, use e-Government services to a very limited extent.

From the public consultation Further guidance and support is needed on increasing ICT competences and resources for public services providers in relation to services for social inclusion (e.g. education, employment, social support) (85% of individual respondents). Business players and industry representative also supported this statement. |

- 6. ICT for cultural diversity

ICT for cultural diversity is still an exploratory field. There is still uneven and limited availability of public websites providing multi-language access. Concerning multi-language information on public sector web sites, evidence shows that, when available, usually on central government portals or those of regional authorities and the largest municipalities, it is almost always still limited to English and is targeted to tourists, foreign investors or researchers. Of course, e-Government portals are also available in other official national languages where they exist[15]. The Czech Republic has a national web site devoted to foreigners living in the country and translated in several languages[16]. In the UK the Cabinet Office has issued guidelines with regard to designing information resources in different languages for government websites. In the Netherlands many local governments use specially designed 'virtual integration counters' to facilitate access to services by immigrants and ethnic minorities[17], also much appreciated by native users.

From the public consultation There is a need for a coordinated approach at European level to increase with the help of ICT the participation opportunities in economy and society of cultural and ethnic minorities and of young people (74% of individual and business respondents). |

- 7. ICT for ageing

The fact that today only 27% of people over 54 and 10% of those over 65 years old use the internet regularly, compared to 45% for the EU27 on average, means that barriers, technical and economic, but especially those linked to awareness and skills, still prevent the goal of using ICT to support healthy and active ageing processes.

Projections elaborated by the European Commission show that at the current pace the Riga target of halving such disparities by 2010 will not be met .

This mismatch between policy objectives and actual results is the main problem addressed by the Communication. Without the increased efforts the Communication calls for and aims to facilitate, progress is expected to continue but at very moderate pace.

This would entail a risk of new forms of exclusion and, missed economic and social opportunities resulting from digital inclusion for millions of Europeans.

The challenge for Europe is thus to address the information society access and usage divides (e.g. access to ICT, e-accessibility) that continue to exist, the limited capacity to derive benefits from ICT, as well as to address new inequalities in use of ICT that arising as technologies continue to develop.

From the public consultation Different national and regional regulations for reimbursement and certification of ICT solutions (assistive technologies as well as solutions for independent living) are a barrier to an EU-wide market for ICT in support of ageing well (56% of individual respondents). There is lack of awareness (by older workers and employers) slowing the pace of uptake of age-friendly ICT for the workplace (75% of individual respondents). Training courses on digital literacy and competences for older people are not sufficient for them to embrace information society services (72% of individual respondents). Incentive schemes are needed for promoting broadband access by elderly people (69% of individual respondents). Participants to the consultation from the ICT industry also recognised in majority the fragmentation of markets for ICT targeting older users and the need to promote standardisation, interoperability and more coordination in this nascent market. |

- 1.2. Who are the actors?

The situation of e-Inclusion results from the interactions between:

- the demand side;

- the supply side and

- the institutional side.

There are numerous interactions in the way the demand side, the supply side and the institutional actors shape access to and use of ICT. The demand side includes both the users and non-users of ICT, who are at risk of exclusion. Business actors in the supply side are important players interacting with the demand side and potentially contributing to either e-Inclusion or e-Exclusion. They are also influenced by the business environment which is affected by regulatory interventions and other policies measures.

1.2.1. The demand side

The demand side refers in general to individuals and groups being at risk of digital exclusion due to their status characteristics such as available income and behaviours in terms of motivations, attitudes and personal objectives, their education level, age group, socio-professional and employment status, abilities and disabilities, place of residence, citizenship (citizens, permanent foreign residents, foreign with temporary residence rights, etc) and/or ethnicity. These social conditions influence each other. Together, they shape individuals and groups' access to, use of, and capacity to gain benefits from the information society.

Even when users may have the most sophisticated connection and equipment they might still become “Internet drops out” as a result of frustration with services usability due to the lack of attention to the human/computer interaction and ergonomics dimension of the side of the designers. This is, evidently, even more salient for people suffering from various forms of functional impairments (more or less severe disabilities or simply decreased functional performance due to ageing) and who do not find accessible services and devices.

Potential users may not become actual users because services are not targeted to their needs and interests, a fact that is highly relevant for online public service provision. Others may not find culturally and linguistically suitable content, both because of the way information is searchable online and because of lack of adequate resources to supply such content. Niche cultural content for ethnic minorities is not always adequately catalogued in the portals and popular search engines. In addition, those potentially capable of providing such content do not have the resources do so, while the limited pool of potential users do not represent a sufficient market incentive for mainstream suppliers to cater such users.

In particular, based on the availability of data on Internet use by Socio-Economic Status, the groups mostly affected and the potential target of policies are (data on EU27 in 2006[18]):

- Older workers and the elderly: about 43 million aged 55-64 and 37 million aged 65-74 not using Internet;

- Individuals with no or low levels of education who do not use the Internet: about 74 million;

- Unemployed who do not use the Internet: about 20 million

- Employed people who do not use the Internet: about 89.5 million;

- Young people (15-24) who do not use the Internet: about 18 million.

- In addition there are other groups, for which no statistics are available on Internet usage, but that are clear targets of policies:

- Disabled people in general: an estimated 74 million Europeans (including both severe and less severe disabilities)[19];

- Europeans at risk of poverty: 98 million (of which about 9% of working poor);

- Foreign born residents: about 15 million.

Women, have almost filled the gap with men in Internet usage, but will still have to be considered when defining e-Inclusion policies.

The European population affected by the e-Inclusion challenge (with Internet use as a proxy) is thus estimated at around 200 million. In this figure the overlaps between the groups mentioned before as been eliminated as far as possible.. However, it has to be stressed that also others can find themselves on an occasional or temporary basis at risk of exclusion, e.g. when falling ill, being in an emergency situation, when exposed to extreme information overload, or even when being confronted with new technology. Consequently solutions that help the target groups above more than once turn out to benefit a much wider population.

NGOs and other voluntary sector organisations represent the (potential) users’ interests. These players can be enabled to become intermediaries helping individuals gaining benefits from ICT and thus can also be the target of policies. In some instances they also play a role as suppliers of support and solutions. A sample is:

- organisations of people with disabilities – which includes both umbrella organisations such as EDF[20] as a great number of interest groups around a specific disability, from large ones such as ONCE[21] or RNID[22] to very small ones. Some large groups of users (e.g. cognitively impaired) are represented by relatively small organisations. The demand side organisation can be characterised as fragmented.

- organisations of the homeless or others in social need such as Feantsa[23] and the Social Platform[24],

- organisations of elderly people, at the national level or European level such as AGE[25].

From the public consultation ICT users (current or potential) and representative associations should be more involved in designing and implementing e-Inclusion policy measures (76% of individual respondents) and more involved in designing and deploying ICT products and services on the market (69% of individual respondents). The ICT industry also stated that user-centre design is one of the key elements for the delivery of inclusive and accessible ICT tools and services. |

- 1.2.2. The supply side

The players of the supply side can be seen as both affecting the problem and being affected by the solution. In as much as their strategies and behaviours decrease or increase access and use barriers, they either create opportunities for further inclusion or increase the risks of exclusion. They are affected by the solution positively if increased e-Inclusion leads to increased demand for ICT product, services and ICT enabled services. The supply side players are also affected when the solution is the result of government regulation and policies either imposing certain requirements on them, or steering them in the right direction.

Market actions continuously transform and re-shape the field and contribute to make e-Inclusion a moving target (either closer or further away). For instance, basic access in terms of the technical equipment available to users (type of connection, hardware and software) becomes insufficient in as much as suppliers of online services design them in such a way that effective use requires faster connections and more up-to-date hardware and software.

Supply side actors are confronted with many different approaches to e-inclusion across Europe. In particular the ICT suppliers are often faced with a lack of common approaches in the internal market as regards e-accessibility, posing serious barriers for a thriving business in inclusive ICT to develop.

The supply side includes:

- the private sector;

- other civil society players providing ICT enabled services and contents;

- public administrations, at all level of government and in all sectors, in their role of provider of ICT enabled public services.

The key players within the supply side include (list only exemplificative):

- Governments at all level in their role of providers of ICT enabled public services

- Telecommunication operators

- Producers of hardware and software

- Producers of other broadly defined ICT related technological devices

- Producers of assistive technology

- Private sector and other civil society providers of ICT enabled services

From the public consultation According to individuals (72% of respondents) there has not been sufficient progress since 2005 in overcoming market fragmentation in e-accessibility. Industry players state different messages quoting increasing attention to user-centric design of products and referring to increased standardisation efforts as a means to achieve progress. The ICT business players also invited to strengthen international dialogue on standardisation and reduce possible divergences in requirements at the international level. e-inclusion should be further promoted through Corporate Social Responsibility (CSR) and public authorities' commitment in relation to customers and own employees (76% of individual respondents). Business actors also strongly supported the use of CSR in establishing sustainable partnerships for delivering e-Inclusion. |

- 1.2.3. The institutional side

The institutional side refers to public authorities firstly in their legislative and regulatory functions, and secondly in their non-regulatory functions at EU and national levels. Within the institutional side, the list of relevant players includes:

- National governments and regulatory and policy making bodies;

- EU institutions;

- Regional and local level governments.

The institutional side has a potential role of shaping both demand and supply, various institutional levels can be affected by e-Inclusion policies coming from the international level ( e.g. national governments by a EU directive). Also the institutional actors as a whole can be affected by meta-policies aiming at improving policy making and delivery through more integration and coordination.

From the public consultation e-Inclusion considerations be further incorporated into design and implementation of other policies (90% of individual respondents together with a strong business support). National and local efforts on e-Inclusion should be further coordinated at European level (82% of individual respondents), international co-operation on e-Inclusion should be reinforced (78% of individual respondents), and EC research and innovation efforts relating to e-Inclusion should be increased (84% of respondents). The European Commission should further support dialogue of e-Inclusion between relevant stakeholders (88% of individual respondents, strong support also from business players). |

- 1.3. Key e-inclusion enablers for a barrier-free information society

The persisting access divide and the new emerging use and benefits divide result from the complex interaction between demand side and supply side factors. Demand side factors include both individual status characteristics (Socio-Economic Status, SES, that is resources) and behavioural, situational and social relational patterns. SES and other demand side factors shape whether individuals have (material access), or decide to (mental access) access ICT.

SES shapes four important influencing enablers of e-Inclusion which, if not realised, constitute barriers to the information society and thus lead to e-Exclusion[26]:

1. Affordable technical means of access (quality of hardware, software, connection, accessibility). Persistence and breadth of use are a direct function of the quality of the technical means of access available to individuals. Slow connections and limited software capabilities constrain the breadth of use, cause frustration and can weaken motivation thus possibly causing stopping ICT use;

2. Place of access (home, work place, public points). This dimension matters as it defines the degree of autonomy of use. Greater autonomy of use impacts positively on persistence and breadth of use and also on quality and effectiveness of use;

3. Digital Competences including basic competences and advanced competences. Basic competences influence the chances of using ICT at least for simple purposes. They can be expected to grow with use. Advanced competences, which are more strongly correlated with individuals cultural and cognitive assets and are harder to achieve without proper education and training, impact individuals’ capacity to use ICT for obtaining quality jobs and more effectively participate in the information society;

4. Social support . The degree to which individuals can rely on formal support (training facilities, schools, and social carers) and informal support (from relatives, friends, and colleagues) can help late adopters persist and improve in their use, thus counterbalancing potential skills gaps.

These four enablers determine the likelihood of persistence and increased breadth of use. Persistence and breadth of use in turn influence effectiveness of use.

Several of the key enablers for a barrier-free information society are strongly linked to individual resources, behaviours and attitudes. The most socially disadvantaged groups are thus most at risk of falling further behind. In many cases for such groups to become full users of ICT will be difficult.

Thus, the implication is that e-Inclusion policies should both focus on helping the most excluded individuals to use ICT and on the use of ICT to help them.

1.4. How would the problem evolve, all things being equal?

Regarding the expectations on the future evolution of e-Inclusion, two opposing views can be identified characterising both the academic and policy debate. They are worth being briefly discussed for they have inevitably contrasting implications in terms of policy. These two views are termed hereafter as the “S-shaped optimistic view” and the “Differentiation Realistic View” (more in depth analysis of these two views is presented in Annex 3 ).

S-shaped optimistic view . The paradigm here is the one assuming that a better functioning of market mechanisms and increased competition would make it possible to reduce the costs and to make ICT products and services accessible by the greatest number of users, as has happened with fixed telephony. The argument is that differences in use of ICT among groups simply reflect their position on a S-shaped curve differentiating from early to late adopters. As users catch up and move on the S-shaped curve, most differences will disappear.

Exhibit 1: Typically S-Shaped diffusion curve

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The Differentiation Realistic View . Finding inspiration from the consolidated theories and research on access to, use of and benefits deriving from education, cultural and information goods and media, this view maintains that as access to ICT increases, new forms of social differentiation and inequalities emerge. This is so because more advantaged groups are in a better position to use ICT effectively and thus derive benefits leading to desirable social outcomes such as increase in human capital, social capital, participation.

Accordingly less advantaged groups, even when they use ICT, may further fall behind in relative terms. This view is based also on a detailed and in depth explanation of why ICT must be considered in analogy to cultural and informational goods and services, rather than assimilated to mere technology devices (TV, VCRs, etc). In this respect ICT cannot be assimilated in drawing projections scenarios to Telephone, Radio and TV.

Which of the two views finds stronger support is not indifferent for policy. Assuming and showing that disadvantaged groups are simply a few paces behind in the same S-shaped curve as other groups, the gaps will be filled over time and only minimalist policies will be needed (general argument for ‘no action’ option).

On the contrary, by assuming and showing that disadvantaged groups are on a qualitatively and radically different trajectory and are left behind as the rest of the world moves ahead, it follows that more active policy intervention is needed to fill the gaps.

The two views have been given an in depth and fair assessment in Annex 3 by using a mixture of:

a) data on access and usage over time;

b) theory based arguments;

c) historical comparisons.

Such analysis clearly support the more realistic view, as could also be already derived from the quantitative data presented in paragraph 1.1 (see further analysis in Annex II). Beyond the relative lack of progress to realise the Riga targets, the evidence gathered for this IA shows that, as access to ICT increases, new processes of differentiation in use of ICT can lead to new inequalities and contribute to further exclusionary processes if not tackled by e-Inclusion policies.

Moreover, often the supply side does not address spontaneously the problems of the socially excluded and can at times create further barriers and exacerbate the problem.

It is for these reasons that e-Inclusion policies are needed .

1.5. Should the EU act?

In order to answer the question whether the EU should act, a conceptual map on e-Inclusion policies is provided, which helps assessing their current status. Such assessment is also instrumental to outline the lessons learnt and the related European added value (par. 1.7).

1.5.1. A conceptual map of e-Inclusion policies

The conceptual map visually represented below identifies three macro-areas of policies termed for the sake of simplicity: a) Enable; b) Accelerate and c) Integrate.

Exhibit 2 Mapping e-Inclusion Policies

[pic]

[pic]

The fairly exhaustive repertoire of specific measures included above in each area already shows what they are about:

- The targets of the measures: Demand, Supply, Mixed Demand/Supply;

- The typology of instruments: regulatory, non regulatory, strategies and actions for online public service transformation and innovation;

- The most likely and appropriate level of intervention/competence: local, national, EU and cross-levels.

A very brief illustration is provided of the various areas identified in the exhibit above. Horizontally the map uses a progression logic resembling that of the model of digital inequalities and inclusion processes presented in Annex 3 and moves from access, through use, to benefits.

Vertically it distinguishes between the upper part that is about helping individuals/communities access and use ICT to improve their lives and life chances, whereas the bottom part is about using ICT to help individuals/communities improve their lives and life chances even if they will not become in the short term regular and effective users of ICT.

The left end side of the Enable areas includes measures strictly addressing mental and material access. They aim at removing barriers and providing opportunities to access ICT. Five classical measures in this areas are coverage (broadband and geographical divide), universal service provisions, basic affordability (with competition and regulations addressing the supply side and tax relief schemes to purchase PCs and get connections addressing demand), availability by way of spreading Public Internet Access Points (PIAPs) and motivation through awareness campaigns.

Enable and Accelerate overlap at a point where the issues of access, use, persistence of use or dis-adoption are very entangled, uncertain and can turn in any of the possible directions (from access and infrequent use to more regular use and possibly to dis-adoption or conversely to persistence and breadth of use). Accessibility, advanced affordability (referring to technical means of access and to autonomy of use or place of access) and usability are probably closer to access and eEnable. On the other hand, the provision of transformed, citizen-centred and inclusive existing public services, together with the provision of new targeted contents and services for special groups (addressing the Riga areas of cultural diversity, ageing and marginal youth), increase the chance of meeting needs and interests thus contributing to stimulate use and thus moving toward empowerment as a result of persistent and more effective use.

The more clearly Accelerate policies consist in supporting the acquisition of more advanced skills to make use more effective alongside the stimulus and support to the realisation of more advanced and targeted applications and services.

Finally, the bottom part is about using ICT to help individuals/communities improve their lives and life chances even if they will not become in the short term regular and effective users of ICT.

- First, most straightforward policies in this field are the preservation and reinforcement of alternative mode of access through ICT enabled multi-channel delivery together with the use of mobile and wireless to ICT enable intermediaries who can brings access and effective use of ICT based services into the home of the less advantaged individuals;

- Second, there are more wide-ranging approaches in which ICT are mainstreamed into broader social inclusion policies to help groups at risks and deprived communities address their most pressing priorities and needs;

- Third, there are those that can be termed ‘meta-measure’ in that they aim at the policies themselves and precisely at rationalising and improving in terms of their degree of integration across policy silos, of their evidence base and of their supporting monitoring and evaluations mechanisms.

1.5.2. The policy challenge: current status of e-Inclusion policies

In Annex 1 (table 12) a number of policy studies financed by the EU are listed, which provide the most up-to-date, extensive, comprehensive and in depth review and assessment of the current status of e-Inclusion policies at national and EU level. They have been realised by different organisations and for different Commission departments, yet to a large extent they converge in their appraisal of e-Inclusion policies. Below such appraisal extracted from the mentioned studies is presented in a very synthetic fashion. As will be further illustrated in the following paragraphs, these studies corroborate and confirm the views gathered in the past few years from stakeholders in the various stage of consultations illustrated in Annex I and within the work of the i2010 e-Inclusion subgroup of Member States representatives.

Overall access policies can be considered so far only very moderately successful. Efforts at spreading coverage have been relatively successful but differences in the geographic coverage of broadband clearly point to persisting market failures not yet successfully addressed by policies. Tax relief and other fiscal measures to overcome financial barriers have achieved some success but present some limits. In many cases they have been limited to people already in employment thus missing the unemployed. Public Internet Access Points (PIAPs) and awareness campaign have had little impact because only in a few cases have they been embedded in deeper and broader local level policies and contexts. In general the cases of successful access policies show that they focus on the measures targeting the most deprived communities and complementing other local actions. It can be concluded that access policies have not yet addressed effectively market failures, they are fragmented, not sufficiently targeted to groups at risks and deprived communities, and not mainstreamed into wider social inclusion policies;

The situation of e-Accessibility is clearly unsatisfactory despite good efforts of part of the industry[27]:

- market failure is evident from lack of provision of accessible ICT, lack of choice and high prices of accessible ICT;

- at national level accessibility policies are either insufficient or developing in different ways from one Member State to another thus endangering the principle of the Internal Market;

- e-Accessibility provision in EU relevant directives lacking a mandatory basis are partially implemented, and general fragmentation further increases risks for the Internal Market;

- Additionally in the related area of usability, especially in the sector of online public services, the situation is unsatisfactory even for individuals with no major disadvantages. There is often an overload of information and services but not enough tools helping users find the right information or providing sufficient interactions, no concentration of services, a lot of fragmentation. Successful national portals such as the UK DirectGov are good examples.

In terms of the dimensions of digital inequalities discussed in the conceptual framework it is evident that possessing more advanced technical means of access and using broadband at home (place of access and autonomy of use) are still materially outside the reach of less advantaged groups, thus strongly limiting their chances of increasing breadth and quality of ICT use and, consequently achieving benefits from it. Policies in this area have so far failed to address market failure and steer supply in the desired directions;

The situation is mixed when considering the inclusiveness and citizen-centricity of online public services. Aggregate take up figures are still low and growing slowly, although areas of success can be identified i.e. tax online and in general e-Government take up by business. With few exceptions, little targeted efforts have been made so far to increase usage of e-Government services by those who in many cases need them most (especially for access to welfare benefits and to job opportunities, namely disadvantaged groups). If such efforts are not made and if multi-channel supporting strategies are not implemented this could compound the difficulties of such groups in accessing basic services enabling them to participate in society and exert their rights;

In the field of digital literacy policies are not sufficiently targeted, are fragmented and mostly concentrated on providing only the most basic and operational skills through standardised courses following the guidelines of the European Computer Driving License[28]. While commendable, these efforts fail to tackle to more subtle and sophisticated cognitive skills required to increase quality of use and, consequently, the benefits derived. Little use is found of policies supporting local e-Champions approaches and peer learning to diffuse more advanced skills but they exist and they should be encouraged;

Policies using ICT to improve employability are very scattered and fragmented. New initiatives however are heading in the right directions such as the recently adopted e-Skills policy relying on key partnerships between public authorities and private champions in e-Skills. Also fragmented isthe provision of other advanced empowering mechanisms provided by actions in the field of such as e-Democracy , e-Learning and ICT for social capital;

Policies for specially devised and targeted content and services for seniors citizens, marginal youth and cultural diversity are scattered and limited (see Annex 2, par. 8.7 and 8.8);

In terms of policies aimed at encouraging the use of ICT to deliver services to disadvantaged groups more effectively and efficiently, the situation is at a very embryonic stage due to still limited use of ICT enabled front desks and the lack of using multi-channel strategies to provide services and reach users. Besides, delivery approaches inspired by the integration of measures for e-Inclusion as part of broader social inclusion policies are still an exception in policy-making.

Finally at a general level, EU policies directly or indirectly related to e-Inclusion are also fragmented and forego the benefits that would derive from integration, mainstreaming and from a more holistic strategic approach.

In view of the data presented earlier and the appraisal of e-Inclusion policies (see also Annex 2), there emerges ample scope for improvement on the way to achieve a fully inclusive information society at both EU and Member States' level.

Autonomous socio-economic processes already tend to produce inclusive outcomes and have had positive results in many European countries in terms of internet access and use, broadband penetration, affordability of electronic communications. However, when disparities within categories of users in terms of geographical, social, economic, physical and educational conditions are taken into account, a proactive policy engagement and a greater coherent approach are needed to extend the benefits of the information society to all.

1.6. European Union grounds for action: subsidiarity and proportionality tests

Following the analysis of the societal and policy challenges that the current evolution of societal uptake of ICT is posing, there is an evident need to act at EU level in public policy terms.

Persistent and dynamic divides together with more explicit (internal) market failures (such as for e-Accessibility) will not be solved without public policy intervention either in the form of better coordinating existing efforts of public and private entities or by proposing regulatory interventions when needed.

A clear challenge that has also emerged from the analysis is the lack of coherence between initiatives both at Member States and EU level with insufficient focus and targeted policies for groups at risks. There is still a need to establish the enabling conditions for a truly inclusive information society.

1.6.1. In the area of e-Inclusion policies

Achieving many of the Riga targets would require direct policy interventions falling outside the EU direct competence. However, in line with the subsidiarity and proportionality principles , the EU can complement Member States and support actions to address e-Inclusion at EU level with increased added value. The EU Treaty contains principles with regard to social cohesion and equitable development on which subsequent European policy frameworks (e.g. the EU Sustainable Development Strategy) are based.

The root causes and key drivers for the highlighted societal and policy challenges affect the European level in two dimensions:

- From a root perspective , the information and knowledge society presents spill-over effects which are cross-boundary by definition. Most of the challenges (e.g. using ICT for delivering added value services to the ageing society or providing e-Government services to citizens) have a truly European dimension. Lack of digital skills for groups of persons at risk of exclusion can be a hindrance to mobility and an obstacle to enjoy the benefits of the single market in terms of employment and social integration. Similarly, the lack of many advanced services that the information society can offer for the benefit of European users are frustrated by a number of legal and technological barriers, for instance in the case of ICT for ageing well and e-Accessibility, that fragment the internal market for ICT tools and services;

- From a solution perspective, the European dimension relies on the fact that by improving policy coherence at EU level and fostering activities, such as in research and innovation, the EU can create the necessary scale for significant impacts and sufficient replicability of successful experiences. EU activities can act in this case as a key multiplier of impacts.

The proposed activities in the e-Inclusion Communication fully respect the proportionality principle as they mainly concern measures on awareness, coordination and support actions that impose almost no burden on stakeholders and require only little efforts for the EU itself or for Member States.

1.6.2. In the area of e-Accessibility

In the area of e-Accessibility, the IA provides evidence of a persistent market failure in addressing the e-Accessibility challenge. It suggests that neither coordination of Member States activities in the domain, nor timid efforts pursued by stakeholders have produced sufficient mechanisms to tackle the challenge in organic and systematic ways and have scored poorly in terms of effectiveness. The IA also highlights potential challenges to the internal market for accessible ICT technologies, if the current situation remains unchecked with negative consequences for users. It therefore recommends considering possible legislative action in the course of 2008 at the EU level. This will allow for positive impacts not only for users by strengthening their rights but also for the ICT industry and service providers by incorporating the internal market dimension. In this respect, it also suggests that further legislation would be assessed in terms of the proportionality of measures to be adopted and regarding their scope for application.

1.7. Lessons learnt and the European added value

The studies mentioned earlier and listed in

Table 8 in Annex converge in concluding that, while EU and Member States policies for e-Inclusion are commendable, they suffer from shortcomings . Namely they:

- Are fragmented and lack coordination;

- Lack mainstreaming of e-Inclusion across policies;

- Are poorly targeted to the needs and interests of disadvantaged groups.

These studies and consultations with business entities and user organisations in several workshops and also within the work of the i2010 e-Inclusion subgroup of Member States representatives also provide as common recommendations that:

- The several dimensions of digital exclusion ranging from a number of e-Exclusion factors such as e-Accessibility, digital literacy, exclusion from publicly provided services, etc. closely interact and mutually reinforce if policies remain fragmented and not effectively coordinated and mainstreamed;

- e-Inclusion is to be tackled in systemic ways relying on the interaction of all possible instruments and all stakeholders stressed the importance of EU level multi-dimensional action thorough: mechanisms supporting research and innovation, regulatory measures, policy coordination;

- e-Inclusion does not only mean the provision of policies, technologies and services countering risks of exclusion and fostering social inclusion. It also has the potential to translate into economic engagement hence business opportunities for the individuals and the economy overall. More e-Inclusion can lead to more economic growth;

- Inclusion in the information society and especially of marginalised groups does not only depend on active coordination of policy goals and implementation strategies at EU, national, regional and local level;

- Work on the enabling factors of e-Inclusion needs to be pursued. Workshops with key stakeholder and studies identified access, accessibility, digital literacy and inclusive services as key enablers for inclusion and engagement in the information society

It results that, given the currently fragmented e-Inclusion policy landscape, impact is limited:

for users – to fully realise their benefits,

for industry – to realise a thriving inclusive ICT business in the internal market,

for institutions – to achieve efficient and coherent policies.

There emerges a clear need and scope for EU action both in the direction of more coordination and integration of existing policies and initiatives and in the direction of stimulating and supporting further efforts to enable and accelerate e-Inclusion.

The added value of the European e-Inclusion Initiative rests on its contribution to the realisation of a common and systemic approach to e-Inclusion to implement these recommendations, address thereby the shortcomings and achieve the impacts mentioned above. It relies on strategies aiming at improved synergies across policy initiatives at EU and national levels. It also relies on efforts to cluster business led initiatives, increase their visibility and ensure replication of successful ones. By doing so, the initiative is aimed at delivering so called "multiplier effects" necessary to increase positive impacts of ongoing actions at all level.

The enhanced impact derives from the fact that, as the causes of digital exclusion are mutually reinforcing, so are the benefits of inclusion in the information society once the necessary drivers are activated and act synergistically. This will finally deliver greater impact in terms of social cohesion and economic growth for society (see more on this in Annex 4 ).

The e-Inclusion Initiative aims precisely at unlocking this potential combination of positive effects by proposing a common integrated approach. Coordinated actions will deliver more than separate vertical ones, in other word the end results will be greater than the simple sum of the separate components.

Most of the value added will be derived from clustering and mediating activities on e-Inclusion. Experience shows that with the help of the Commission involvement, dialogue between stakeholders and users on defining inclusive services and technologies is encouraged and can reach successful outcomes. Without a central role played by the Commission in replicating positive experiences, these latter ones will remain largely isolated and will not produce widespread impact. EU research and innovation programmes are needed to share risks and achieve economies of scale in Europe, especially in these areas where market failures clearly hamper progress. Finally, given the fragmented regulatory landscape and solutions for e-Accessibility and the continuing market failure in coping with this domain, exploring a more central role for establishing legislative measures in this area is justified by necessity, subsidiarity and proportionality tests (see annexes 5 and 6).

At this stage, progress is to be measured on a number of supply and demand side indicators (the Riga Dashboard, see annex 2), though this IA contains initial estimates on economic benefits. Future studies and modelling should be undertaken to further strengthen the evidence and understanding of the relationship between these indicators and wider economic and social progress.

2. OBJECTIVES

2.1. General objective, specific objectives and actions

Following the analysis of the societal and policy challenges that the current evolution of societal uptake of ICT is posing, the General Objective of the proposed communication for a European e-Inclusion Initiative is: to promote both inclusive ICT and the use of ICT to achieve wider inclusion objectives while providing grounds for economic growth and new business opportunities. This objective –and some of the operational targets- are clearly stated in the 2006 Riga Ministerial Declaration [29] .

However, the Riga Declaration did not clearly spell out the way to achieve those targets, nor natural dynamics have come forward in this direction. In other words, Riga did not provide a framework for action . As anticipated in Table 3 in chapter 3, a number of policies are already undertaken and intend to support the achievement of the Riga targets. However, as shown by available data in most areas only limited progress has been made (see more in Annex 2). A strong reminder of the appeal of Riga for an inclusive information society appears to be needed, i.e. raising awareness and reinforcing commitment.

In addition, and as highlighted in section 1.7 a number of lessons have been learnt which confirm that the use of policy instruments should be improved for the delivery of e-Inclusion objectives.

On the one hand, the need to mainstream e-Inclusion into other policies should be recognised by increasing coordination at all levels. On the other hand, existing instruments and policies in the field of research, innovation, and legislation need to be mobilised to create the enabling conditions for e-Inclusion, accelerate uptake of inclusive services multiply positive impacts through stakeholder engagement. The lessons learnt also point to the fact that –as e-Exclusion factors mutually reinforce- so e-Inclusion policies produce greater impact if implemented in synergistic ways.

Following the analysis of the main problem in chapter 1 (lack of progress on Riga targets), and the identification of key challenges in the demand, supply and institutional sides, the IA suggests that the Communication on the European e-Inclusion initiative should propose an integrated strategy increasing the coordination and coherence of policies between Member State initiatives and also at EU level to maximise their impact.

Therefore, the e-Inclusion initiative, which is defined in the e-Inclusion Communication, should propose two main elements:

- Raise awareness on the potentials of inclusive ICT (through an e-Inclusion campaign in 2008) and foster awareness among policy-makers of the fact that e-Inclusion policies need to be tackled organically in order to have significant impacts, since its many dimensions interact and mutually reinforce. These measures will also attempt reinforcing best practice sharing (i.e. in replicating positive experiences for broadband penetration, digital competences) and lay down the conditions for innovative and inclusive services.

- Provide a framework for action along with three operational objectives to address e-Inclusion challenges for:

- Users: bridging the digital availability, accessibility, affordability and ability gaps,

- ICT industry and service providers: stimulating and enabling inclusive ICT as a viable and thriving business,

- Public authorities: putting in place actions and initiatives aimed at coherent and efficient e-inclusion policies.

- Within this framework highlights of actions are proposed to be:

- Exploring opportunities for proposing legislation in the area of e-Accessibility as a key enabler for a fully inclusive information society. Following the demand of the 2005 Communication on e-Accessibility to thoroughly assess this domain, the impact assessment proceeds to a specific (and more detailed analysis) in annexes 5 and 6;

- Fostering projects targeted at specific groups at risk of exclusion in ICT research and innovation within the FP7 and CIP (ICT-PSP) programmes for new inclusive and barrier-free ICT and for encouraging their innovative deployment;

- Improving coordination of policies and activities for e-Inclusion at all levels (national, regional and stakeholder-led) and monitoring.

The full achievement of these objectives will require efforts on the side of all players and particularly by Member States, regional and local governments, the private sector and Non Governmental organisations (NGOs). Many intervening factors like the effects of other general social or economic policy measures, mediate for the achievement of targets and the success of the proposed initiative. Yet, the proposed Communication provides support and stimuli for players at all levels to step up efforts.

On the realisation that many activities and policy measures are occurring at the EU as well as Member States and stakeholders' level, the IA suggests focusing on actions for which the EU can have greater added value resulting from the coordination and enhanced coherence of individual ongoing initiatives at all levels.

The objectives and actions of the Communication are identified below. They match the SMART (Specific, Measurable, Accepted, Realistic, Time depended) requirements of the Impact Assessment Guidelines.

- Specific . The general overarching objective can be declined into a specific awareness effort and three very specific axes each corresponding to a specific objective. Each specific objective is in turn broken down into operational objective or outputs/actions;

- Measurable . Their measurability (see Section 6 on monitoring and evaluation) should be ensured by their formulation and by the monitoring and evaluation mechanisms already in place (i.e. Riga Dashboard) and by the new ones (i.e. e-Inclusion Impact Measurement Framework);

- Accepted . As stated at the very beginning, the actions proposed by the Communication rest on a strong consensus of all involved stakeholders and represent an answer to the invitations that Member States have made to the EU to act in these areas. So they can count on a high level of acceptance ensuring their feasibility and safeguarding the principle of proportionality;

- Realistic . the objectives are realistic in that their added value is to provide coherence and increase efficiency and effectiveness of the many efforts and action that are already ongoing at both EU and Member States level;

- Time-dependent . They fully respect the timing set in the i2010 framework in that many high impact activities will be initiated and some also realised in 2008 with steady follow-up in the following 5 years.

The general objective is broken down in the following specific objectives with a number of proposed outputs/actions:

Box 2: Specific objectives and outputs/actions

"e-inclusion, be part of it": Raising awareness, promoting good examples, and connecting efforts |

Campaign, “e-inclusion, be part of it” A High-Level Conference on e-inclusion and European e-Inclusion Award |

1. Enabling the conditions to take part in the information society |

1.1 Bridging the broadband gap |

e-Inclusion in the "Regions for Economic Change" Connecting regional initiatives Survey on the funding of information society projects by EU Rural Development and Regional Policy programmes, as input for new orientations in 2007-2013 |

1.2 Bridging the e-accessibility gap |

explore horizontal legislative approach for an accessible information society Work on standardisation and requirements for accessibility that can also be used in public procurement of ICT. Interoperable solutions for total conversation and access to emergency services. Solutions for accessible digital TV. European training programme on Inclusive ICT Design (Design for All). Strengthen follow-up of e-accessibility requirements in current EU legislation and accessibility of public websites, support by common benchmarking. |

1.3 Closing the digital competences gap |

Basic digital literacy training those most at risk of exclusion. Recommendations on digital competences' status. |

2. Accelerating effective participation of target user groups at risk of exclusion |

2.1 Targeting the socially disadvantaged through modern public e-services |

Reinforce inclusive e-government services and e-participation. e-participation programmes for reinforced exchange and practice |

2.2 Ageing well in the information society and ICT support for those at risk of exclusion due to health condition |

implementation of the EU Action Plan on “ageing well in the information society” Support for research and deployment for ICT-enabled innovative solutions relating to ageing Recommendation on e-Health interoperability and European initiative on telemedicine |

2.3 Exploring ICT-enabled solutions for increased economic and social opportunities and choice for young people and migrants |

Explore potential of ICT for services empowering people (in particular young at risk of exclusion, migrants and cultural minorities) Research and analysis into these new areas of e-inclusion |

3. Co-ordinating and mainstream e-inclusion actions to maximise lasting impact |

3.1 Enhancing and sustaining impact through mainstreaming e-inclusion and co-ordinating actions by joining forces |

Address potential of ICT in social and economic policies and in related impact assessments. Promoting social inclusion in the application of universal service principles in electronic communications. Co-ordinate efforts on e-inclusion and join forces in an open e-inclusion partnership Closer co-operation between stakeholders and support organisations representing users |

3.2 Comparing progress and improving understanding of e-inclusion |

Monitoring and analysis of e-inclusion evolution, “Riga Dashboard” Surveys and studies for the e-inclusion agenda |

All actions taken together cover the e-Inclusion policy targets set in the Riga Ministerial Declaration. All these actions are non regulatory.

2.2. Consistency with the horizontal policy objectives of the European Union

The general and specific objectives of the e-Inclusion Communication are fully consistent with broader EU principles.

Social cohesion is one of the objectives of the European construction process, as mentioned in the Single European Act, the Amsterdam Treaty and the Lisbon and Sustainable Development[30] Strategies. The Lisbon Summit highlighted social policy as a core element in Europe’s strategy for becoming “the most competitive and dynamic knowledge-based economy in the world, capable of sustained economic growth with better jobs and greater social cohesion” by 2010. The European Council of Lisbon in March 2000 recognised that the extent of poverty and social exclusion was unacceptable and that a more inclusive European Union was considered an essential element in achieving this goal. The Lisbon Council agreed to adopt an overview of policies that combat social exclusion and promote inclusion through an Open Method of Coordination. The strategy made a substantial plea on the objective to ensure that all citizens are capable to live and work in an Information Society. E-Inclusion in this regard was considered as one of the constituents and social dimensions of the development of the knowledge based economy, overall inclusion and cohesion policies.

As a part of the Lisbon strategy the eEurope action plan (2002 until 2005) contained dedicated e-Inclusion action lines, which aimed at enhancing a “design for all”, “public Internet access points” and the adoption of web accessibility guidelines in public websites. Within eEurope 2005 the fields e-government, e-health and e-learning as well as e-skills and digital literacy required to use ICT were accentuated. The European Council of March 2005 re-launched the Lisbon strategy by refocusing on growth and employment in Europe, and the i2010 strategy[31] is the information society contribution to this revised strategy. The third pillar of the program i2010 introduces the field of “inclusion, better public services and quality of life”. An Information Society that is inclusive provides high quality public services and promotes quality of life. i2010 is the digital economy component of the revised Lisbon strategy for growth and jobs. Emphasis is placed on digital literacy as a priority objective as well as on public services.

The 2006 Spring European Council [32] stated that “focused, effective and integrated ICT policies at both European and national levels are essential to achieving the Lisbon goals of economic growth and productivity. As such, the European Council calls on the Commission and the Member States to implement the new i2010 Strategy vigorously”.

In March 2006, the European Council also adopted a new framework for the social protection and social inclusion process with a new set of common objectives, among others: access for all to the resources, rights and services needed for participation in society, preventing and addressing exclusion, and fighting all forms of discrimination leading to exclusion[33].

The 2007 Spring European Council stated the need to strengthen economic and social cohesion throughout the Union. The European Council highlighted the importance of the social dimension of the EU. The European Council also stressed the need to fight social exclusion. It invited to give more attention to active inclusion, i.e. ensuring adequate levels of minimum resources for all, balanced with making work pay.

The EU and its Member States endorsed the UN Convention on the Rights of Persons with Disabilities as a fundamental step for the promotion, protection and full realisation of all human rights and fundamental freedoms for all persons with disabilities.. In this respect efforts undertaken for a rapid signature of the Convention were recognised and participants encouraged further initiatives for quick ratifications. Some of the EU legislative provisions relate to the Convention (in particular Directive 2000/78/EC establishing a general framework for equal treatment in employment and occupation).

Consensus has been reached to work on a coherent and coordinated approach for European implementation of the UN Convention on the basis of close cooperation between the Member States, the Community and civil society. Such a coordinated approach will be facilitated by the fact that the UN Convention encompasses the essential elements of the EU Disability Strategy, combining anti discrimination, equal opportunities and active inclusion.

Non-discrimination is at the core of the UN Convention and it is also among the fundamental values of the European Union enshrined in Article 13 of the Treaty establishing the European Community. EU legislation against discrimination in employment and vocational training is already in place in the Member States. Nevertheless a vast majority of the EU citizens consider it is still a disadvantage to be disabled. To tackle discrimination in other areas of life the initiative announced by the European Commission as a follow up of the European Year of Equal Opportunities for All could provide the basis for completing the EU framework of protection against discrimination, inter alia on ground of disability, within the limits of EU competencies. This in turn could help to underpin the effective implementation of the UN Convention.

Four principles inform the EU’s approach to the UN Convention: non-discrimination; equality of opportunity; autonomy and participation and inclusion. The EU has also underlined that existing human rights instruments apply in their entirety to persons with disabilities and that the main focus of the new convention must be to secure full enjoyment of human rights by people with disabilities. The Commission seeks to work closely with a wide range of disability NGOs on the question of the human rights of people with disabilities, including with respect to the UN Convention.[34]

The Commission also established the European Disability Action Plan (DAP) to ensure a coherent policy follow-up to the European Year of Disabled people in the enlarged Europe. The Plan provides a dynamic framework to develop the EU disability strategy[35].

e-Inclusion, and specifically digital literacy, will also be considered within the actions implemented within the "European Year for combating poverty and social exclusion" in 2010.

3. DEFINING THE OPTIONS

e-Inclusion has been already addressed in a number of policies for information society starting with the first e-Europe programmes[36] and continuing within the i2010 initiative (see section 2.2). In many priority areas identified in the Riga Ministerial Declaration, objectives and actions up to 2010 and sometimes beyond have been envisaged already at EU level. Many more initiatives have been identified in the same areas at national, regional and local levels in all Member States (see Table 2 ).

However, a common reference framework and the supporting mechanisms to exploit all possible synergies across the different areas, is still missing and policies are fragmented, defined and implemented often along strictly vertical lines without much coordination and integration.

The proposed options base themselves on ongoing policies and activities in the area of e-Inclusion and seek to assess ways of improving the current situation within the proposed European e-Inclusion Initiative, namely:

5. Ensure that all initiatives -which very often address cross-cutting issues affecting several sectors of society (e.g. multi-channel delivery strategies in e-Government, digital literacy measures) - pay more attention to the specific needs of groups at risk of exclusion.

6. Ensure that initiatives for groups at risk of exclusion, beyond promoting greater and more effective own use (direct use) of technology by removing key barriers and stepping up digital competences, also address all opportunities for transforming through ICT existing government services for the vulnerable, including by involving and supporting frontline staff and intermediaries in bringing the benefits of digital services to non ICT users into their homes or at community centres.

7. Maximize the impact of the initiatives by monitoring progress, exchanging good practices, mobilizing stakeholders fully and by guaranteeing that initiatives with similar objectives and targets developed in different areas (e.g. ICT skills and competence for elderly people) are coherent and synergetic.

8. Table 2: Policies already defined in Riga areas at EU level

Other Riga areas | Objectives | Actions |

Halving usage disparities by 2010 | Horizontal objective: no specific initiative can be mentioned, all of those below are expected to contribute to the achievement of this objective |

Older workers and elderly people COM(2007)332 "Ageing well in IS", June 07 | Raising awareness and building consensus | Make ICT and ageing prominent in EU policy Develop common visions, strategies etc. -> Innovation platform for ageing well Contribute to e-Inclusion 2008 Initiative + internet portal |

Enabling conditions in place | EC to further assess market barriers, research and large scale pilots (on RFID) + Recommendation on privacy issues EC to provide guidance for removing legal and technical barriers + map national regulatory and organisational approaches + exchange practices EC to issue Recommendation on e-Health interoperability Member States, LGA etc. to enforce e-Accessibility Member States, etc. to promote access (broadband and digital competences). Exchange practices + monitor progress Study and possibly provide Guidance on ethical aspects |

Promoting uptake | In CIP, pilot projects on independent living and chronic disease monitoring + explore active ageing at work Link to Structural Funds and innovative use of standards in public procurement European award scheme for smart homes and independent living applications -> exchange of good practices Develop training on ICT and ageing (design for all, e-Accessibility etc.) |

Preparing for the future | Achieve leadership in innovation in ICT for ageing: step up research on e-Health and e-Inclusion in FP7 new research initiative under Article 169 on "Ageing well in the IS" |

Geographic digital divides COM(2006)129 "Bridging the broadband gap", March 06 and May 2007 Conference conclusions | Close supply/demand gaps for broadband access services in under-served areas | On the supply side: review regulatory framework on electronic communications (radio spectrum management, etc.) assess 2000-2006 IST policies under EU Rural Development and Regional expenditure; orientations for new actions in 2007-2013 develop national broadband strategies with clear regional targets for under-served areas and strategic usage of EU, national and local funding complementary to private investment On the demand side: promote and develop local digital content production, e-Government services and broadband public services such as e-Health and eLearning to foster uptake of value added services make ICT skills and digital literacy development an integral part of broadband strategies exchange best practices on broadband initiatives for less-developed, remote and rural areas |

e-Accessibility | Accessible ICT for people with disabilities and the growing group of elderly people | 2005 e-Accessibility Communication launched actions to develop standards for reference to e-accessibility to be possibly used in public procurement, an analysis of certification and compliance schemes, and assessment of the legislative situation (as well as international cooperation), Analysis of progress of e-accessibility in the eCommunications Framework (INCOM subgroup of the COCOM regulatory committee of the Framework) Analysis of progress of e-accessibility in the R&TTE Directive (TCM group) Stakeholder cooperation (e-Inclusion partnership) e.g. on accessible digital TV Member states cooperation in e-Inclusion subgroup Research projects in 6th Framework Programme |

Digital literacy and competences Annex to COM "e-Skills in 21st century", (in preparation) | Promoting long-term cooperation and monitoring progress | Regular dialogue with stakeholders and online community Monitoring supply and demand of e-Skills (including global sourcing) + annual report, conferences etc. |

Supporting actions and tools | EU eCompetence framework in line with EQF Feasibility of European e-Skills and career portal Actions within the European Year for combating poverty and social exclusion Handbook on e-Skills multi-stakeholder partnerships Develop Europass and online self-assessment tool Quality criteria for industry-based training and certifications Promote e-skills education in e-Accessibility and R&D Develop eCompetence curricula guidelines Incentives + study human capital investment tax credit for individuals |

Empowering future generation | Exchange good practices for promotion of science, maths and ICT Support innovative teaching and learning approaches, sense of initiative and entrepreneurship Awareness of parents, teachers and pupils Reinforce links between ICT, learning and innovation Experiment web 2.0 to promote ICT training and careers to young people |

Fostering employability and social inclusion | Launch e-Inclusion 2008 Initiative in line with Riga Encourage CSR and partnerships between (ICT and business) trainers and job placement services Support multi-stakeholders initiatives |

Better and greater use of eLearning | Recommendations on eLearning initiatives for enterprises Develop eLearning courses and brokerage mechanisms Network eLearning and training centres in liaison with European Network of Living Labs |

Cultural diversity Riga declaration | Identify priorities and needs for action | Study on the potential of ICT for the promotion of cultural diversity Thematic network on social integration and cultural diversity under CIP-ICT PSP programme |

Inclusive e-Government Riga + "inclusive e-Government roadmap" January 07 | e-Accessibility Guide by end 2007 + accessibility of all public web sites by 2010 Disseminate user-centric security concepts Common European approach for inclusive eGov 2007-2010 (priorities, core disadvantaged groups etc.) Develop key services (CIP pilots and Member States projects) and policies in user-centric and inclusive way for target groups, using multi-channels, incentives and intermediaries so that no one is left behind Specifications for Multi-Platform service delivery by end 2008 Electronic documents in EU-wide recognised formats available also by people with disabilities Measure and benchmark progress in inclusive e-Government -> revise approach and roadmap |

3.1. The options

The option analysis assumes as a starting point the e-Inclusion targets provided for in the Riga Ministerial Declaration. Therefore, the options represent different strategies for reaching those targets. Three options have been analysed against the identified objectives to be reached:

9. Continuing the status quo, carry on separated activities at EU level and rely on internal social and market dynamics to close distances in the information society;

10. Pursue some specific actions with limited targeting of groups at risk with no additional coordination or integration of efforts and with only;

11. Enhance synergies and impact through a common integrated strategy which is:

12. better targeted to the needs of groups at risk;

13. more coordinated and integrated across policies fields;

14. focused both on encouraging groups at risk to benefit from ICT and on using ICT-enabled solutions to provide groups at risk with inclusive services more effectively;

15. monitoring and evaluation mechanisms based on stronger and more robust knowledge and quantitative evidence.

3.2. Option A

Option A considers the continuation of the status quo with a number of specific policies for e-Inclusion at EU and Member States level. It assumes that no further action is taken based on the belief that access and use gaps will automatically close over time. This option also assumes that the current experimental measures at EU level such as the ones aimed at fostering engagement of stakeholders in a number of areas will be one-off or pursued in a discontinued manner. This option constitutes the benchmark against which option B and C will be assessed.

3.3. Option B

Option B assumes that a number of specific but separate initiatives as recently defined by the European Commission are sufficient and will be continued, that only limited targeting action at groups at risk needs to be added without the need to comprehensively address the many interrelated aspects of digital exclusion. This option also maintains that cooperation with Member States, local administrations and stakeholders will not need to be stepped up.

3.4. Option C

This option assesses a coherent approach based on enhanced policy synergies and impact through a common integrated strategy aimed at: a) considering comprehensive and integrated policy responses to the many interrelated aspects of exclusion in the information society; b) establishing the enabling conditions for an inclusive information society; c) accelerating the diffusion of inclusive information society services; and d) increasing impact by better leveraging from efforts by Member States, local authorities, business stakeholders and civil society organisations.

Enable line

Accessibility . the Commission should explore to propose in the second half of 2008 a horizontal legislative approach to promote accessible ICT with positive outcomes in terms of equal rights to ICT access and use and proper functioning of the internal market for accessible ICT products and services. This should establish a comprehensive EU legal framework for a barrier-free information society: building on a public consultation and an impact assessment in the first half of 2008. This is complemented by targeted EU deployment and research support.

Digital competences . Insufficient digital competences are the most critical issue as they shape the likelihood that late comers will continue using ICT and will not stop using them; improve the effectiveness of use; and as a result; achieve individual benefits.

This adds up to desirable social outcomes such as increased human capital leading to improved employability and to more productivity for those already in employment (see more in annex 3 on the quantification of impacts.

Evidence discussed earlier and documented in more depth in annex 2 clearly indicates that many people in Europe have low or no digital competence and that divides along socio-demographic variables persist and in some cases even tend to increase. Riga targets on halving skills divides require much stronger action.

Here, the main call for action is to national and local authorities as well as private players. The EU, given limits imposed by subsidiarity, will support these efforts reviewing their actions and providing guidance.

Broadband . In the spirit of coordination and of realising synergies within the framework of the ICT-PSP programme (part of CIP)[37] it is anticipated to launch regional thematic networks on broadband and e-Government as part of the new initiative "Regions for Economic Change"[38].

Accelerate line :

General . Call for and put in place targeted efforts in selected topics and specific target groups at risk of exclusion.

Inclusive e-government actions, as part of the i2010 e-Government Action Plan : in particular with support of the ICT-PSP programme for pilot projects, good practice exchange and investigating issues relating to the delivery of inclusive e-public services to the socially disadvantaged.

The action plan on “ageing well in the information society”. Its implementation will be supported in various ways through FP7 and the CIP.

Other financial support in the area of ICT for ageing, health and disability : the EU R&D and the ICT-PSP programmes will continue supporting research and deployment efforts in these areas. The Commission will also launch in 2008 a "lead market initiative" on e-Health and will follow up on the implementation of the e-health interoperability recommendation.

Integrate line:

Mainstreaming EU level policies . To improve coordination at EU level it is suggested to call upon policy makers to address the potential of ICT in social and economic policies, and conversely, to consider in the use of impact assessments and policy evaluations social inclusion aspects when designing new initiatives related to ICT.

Calling for mainstreaming of Member States policies . Stimulate more policy coordination at national level:

- Through information sharing and stakeholder cooperation (extending the current e-inclusion partnership and using the i2010 framework for cooperation);

- By stimulating better forms of monitoring and reporting schemes relying on a wider range of indicators. In this respect it is worth noticing that this IA also takes stock of the Member States Social Inclusion National Action Plan (NAPs) 2006-2008 and concludes that e-Inclusion is taken into account in a very modest way.

7 countries, including key ones ( CZ AT FR LU NL SE IT), do not mention e-Inclusion at all in their NAPs. approaches are fragmented and little systematic analysis of all groups at risk is provided. Comparing these new NAPs with the previous versions 2003-2005 it emerges that the focus on e-Inclusion has decreased considerably. Through increased EU support in the exchange of best practices. In this respect it must be anticipated that e-Inclusion will increasingly be included and addressed both in the new e-Practice portal for good practice exchange and in the new bench-learning activities that are set to start in September 2007 and last for two years aiming at building impact measurement capacities bottom up.

- Improve quantitative evidence and knowledge by launching studies on the socio-economic impacts of e-Inclusion

- Improve monitoring and evaluation. The Riga dashboard benchmarking will continue and will be integrated in the proposed launch of an e-Inclusion Impact Measurement Framework;

- Sustainability. New mechanisms to support sustained and steady stakeholders cooperation will be introduced.

4. OPTIONS IMPACTS AND COMPARISON

Before proceeding to the analysis of the policies implications and qualitatively assessing the impact of the three options, a paint brush assessment of where we are today is provided with respect to the three options and to the achievement of the sought objectives.

Table 3: Where we are and where we can go

Halving usage disparities by 2010 | Policies status : in option B stage Objective: not reachable in the short term all things being equal Option feasibility: C feasible in sh