Last minute inclusion? Re: Due date for 2021 Harmonised Guidelines draft inputs is over.

[Vaishnavi Jayakumar]

⏰ *Draft 2021 Harmonised Guidelines Feedback* 

Tracked down and spoke to Abhishek Bose, CPWD. 

Re the new harmonised guidelines, the minister is clear it has to be released  October 1st week. Process has been going on for a year and 2-3 stakeholder consults have been conducted.

It's our fault that our grapevine hasn't worked properly - going forward we really need to fix both govt channeling info for public consultations via MyGov only and our own sectoral representatives' duties and responsibilities to inform.

Anyway, told him about non slip floor needing a cut off value and gave example of hospital emergency in Bangalore receiving many senior citizens who fell in nearby metro.

Maybe that resonated so he said to send inputs today tomorrow types, he will try and get it included.

I'm not hopeful given October 1st week minister keenness, but no harm trying. He brought up the fact that statute requires frequent updating and it's 5 years. No arguments there.

The compressed draft HG = http://bit.ly/2021-hg-draft

Am sending him inputs (to bose.a...@gov.in ) which he will in turn pass on to others heading this : NIUA spearheading agency and Gaurav Raheja of IIT Roorkee, for last minute inclusion.

DRA had DMed Hitesh Vaidya of NIUA on Twitter but received no response. 

---

On Thu, 9 Sep, 2021, 8:23 pm Vaishnavi Jayakumar, <jayakumar...@gmail.com> wrote:

Draft : https://cpwd.gov.in/WriteReadData/other_cir/50837.pdf#page=19  - A compressed ~9MB version is hosted online at http://bit.ly/2021-hg-draft ( The original is 83 MB file - The first 18 pages have not rendered properly, maybe because not in English or unicode. Either way it's all messages and acknowledgements. Exception is the first page, inaccessible. Pasting OCRed version here as well as inaccessible NIUA document content.https://niua.org/intranet/sites/default/files/1464.pdf )

~ OCR of Page 1 https://cpwd.gov.in/WriteReadData/other_cir/50837.pdf#page=19 ~

Government of India
Central Public Works Department
Office of ADG (Works)
Room No. 306, A Wing Nirman Bhawan, New Delhi- 110011
Phone: 23062138 ; 23061401, Fax : 23061396D
email: adg-ar...@nic.in

F.No. :6/25/2019/ADG (Works)
Date: 12.08.2021
Office Memorandum
Subject: Seeking comments on draft of ‘Harmonized Guidelines & Standards for Universal Accessibility in India- 2021’

The draft of ‘Harmonized Guidelines & Standards for Universal Accessibility in India-
2021’ has been prepared after stakeholder consultations. Now the draft is being put up
in public domain for seeking comments.

The comments may be submitted up to 27-08-2021 at the email id:
bose.a...@gov.in.

Encl: As above

ADG (Works)

CPWD Nirman Bhawan
(Through CPWD Website)

To all concerned.
ADG (Works)


-----
~ OCR of https://niua.org/intranet/sites/default/files/1464.pdf ~


NATIONAL INSTITUTE OF URBAN AFFAIRS

Hitesh Vaidya
Director

Date: 12/08/2021
Ref. No: NIUA/BASIIC/D-17

Subject: Seeking comments on the draft “Harmonised Guidelines & Standards for Universal Accessibility in India”

The draft of the “Harmonized Guidelines & Standards for Universal Accessibility in India"
has been prepared under the Building Accessible, Safe and Inclusive Indian Cities (BASIIC)
programme at the National Institute of Urban Affairs. The programme is supported by the Foreign
Commonwealth and Development Office of the UK Government. The revision process of the
guidelines was undertaken in partnership with the Department of Architecture, Indian Institute
of Technology, Roorkee and Central Public Works Department (CPWD).

An inclusive approach was taken in the revision of the document, which included conducting
perception surveys, public consultations, and focused group discussions with persons with
(different) disabilities, elderly, women, caregivers, and children through different stages.
The draft document is now available on the public domain for further comments and suggestions.
The comments may be submitted by 27.08.2021 at the following email id - uchou...@niua.org,
kba...@niua.org

The report can be downloaded from https://cpwd.gov.in/WriteReadData/other_cir/50837.pdf

Hitesh Vaidya
Director, NIUA
1st Floor, Core 4B, India Habitat Centre, Lodhi Road, New Delhi-110003
(T) 24643576 (Direct), 24617517, 24617543, 24617595 » (F) 24617513
(E) dire...@niua.org » (W) www.niua.org

[Vaishnavi Jayakumar]

 🏁 Also, what do you think of MSJE idea of departmentwise guidelines

❗during the eci meet, Tarika Roy from Ministry said something alarming. That each dept was going to bring out its own accessibility guidelines before December 2021

 This is alarming, I'd heard recently of this, but never thought our own ministry would be behind this.

 As it is Road Transport Ministry has come out with a draft.

Having so many competing manuals will be a mess.

We need just 1 overarching accessibility code that is available on an official website as HTML that departments can easily link to.

Furthermore the Harmonised Guidelines, GIGW and ARAI AIS bus body code are what makes the guideline statutory as they alone are mentioned in Law+Rules

 Thoughts 🤔💭 ❓

[K Raghuraman]

its real rubbish to have diverse manuals on accessibility guidelines.
it is only an attempt to accumulate more official documents and
provide the authorities to claim public image as Xavier of
disabilities and inaction in field.
instead, we should incorporate varied accessibility requirements
pertaining to diverse departments if necessary on a single structured
head binding the whole administration across nation

wonder how could these gimic thoughts creep into the minds, as there
are enormous pending immediate requirements on hand
regards
raghu

On 22/09/2021, Vaishnavi Jayakumar <jayakumar...@gmail.com> wrote:
> 🏁 *Also, what do you think of MSJE idea of departmentwise guidelines*

>
> ❗during the eci meet, Tarika Roy from Ministry said something alarming.
> That each dept was going to bring out its own accessibility guidelines
> before December 2021
>
> This is alarming, I'd heard recently of this, but never thought our own
> ministry would be behind this.
>
> As it is Road Transport Ministry has come out with a draft.
>
> Having so many competing manuals will be a mess.
>
> We need just 1 overarching accessibility code that is available on an
> official website as HTML that departments can easily link to.
>
> Furthermore the Harmonised Guidelines, GIGW and ARAI AIS bus body code are
> what makes the guideline statutory as they alone are mentioned in Law+Rules
>
> Thoughts 🤔💭 ❓
>
> On Tue, 21 Sep, 2021, 12:40 pm Vaishnavi Jayakumar, <
> jayakumar...@gmail.com> wrote:
>

>> ⏰ **Draft 2021 Harmonised Guidelines Feedback**

>>> *Date: 12.08.2021*Office Memorandum
>>>
>>> *Subject: Seeking comments on draft of ‘Harmonized Guidelines &
>>> Standards
>>> for Universal Accessibility in India- 2021’*

>>> The draft of ‘Harmonized Guidelines & Standards for Universal
>>> Accessibility in India-
>>> 2021’ has been prepared after stakeholder consultations. Now the draft
>>> is
>>> being put up
>>> in public domain for seeking comments.
>>>
>>> The comments may be submitted up to 27-08-2021 at the email id:
>>> bose.a...@gov.in.
>>>
>>> Encl: As above
>>>
>>> ADG (Works)
>>>
>>> CPWD Nirman Bhawan
>>> (Through CPWD Website)
>>>
>>> To all concerned.
>>> ADG (Works)
>>>
>>>
>>> -----
>>> ~ OCR of https://niua.org/intranet/sites/default/files/1464.pdf ~
>>>
>>>
>>> NATIONAL INSTITUTE OF URBAN AFFAIRS
>>>
>>> Hitesh Vaidya
>>> Director
>>>
>>>

>>> *Date: 12/08/2021*Ref. No: NIUA/BASIIC/D-17
>>>
>>> *Subject: Seeking comments on the draft “Harmonised Guidelines &
>>> Standards for Universal Accessibility in India”*

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>


--
best regards
raghu

[Vaishnavi Jayakumar]

Hi,

Multiple sources have indicated that the current draft has erroneous diagrams, missing text etc and is nowhere near ready for release.

Will be writing officially to the concerned ministries today for an extension and requesting CCPD office to intervene - apparently they had also worked along in this exercise though MSJE has not received this draft either, looks like. I discovered this report of stakeholder consultations on NIUA website - it has links to entire discussion on YouTube

In the meantime just wanted to flag the following recent developments in MSJE's multiple manuals (AIC?) idea : Links are to PDFs

• Roads 18-3-2021Draft Comprehensive Accessibility Guidelines for Road Transport Infrastructure including Bus terminals/Bus stops
• Railways 30-12-2019 HARMONISED GUIDELINES FOR PASSENGER WITH DISABILITIES, OVER INDIAN RAILWAYS
• TV programmes 11-9-2019 Accessibility Standards for Persons with Disabilities in Television Programmes (Deaf / HI only)

Rama & whoever else is commenting on the draft here https://bit.ly/2021-hg-draft - thanks. It's way more transparent and open when we share our observations.

This '2021 Draft Harmonised Guidelines Deadline Discussion' thread can be accessed at https://bit.ly/2021-hg-draft-topic

Regards,

Vaishnavi

[Vaishnavi Jayakumar]

Vaishnavi Jayakumar (Inclusive India)	24 September 2021 at 11:40
To: ccpd <cc...@nic.in> Cc: secy...@nic.in, secretar...@nic.in
24 September 2021 The Chief Commissioner for Persons with Disabilities Sarojini House Bhagwan Das Road New Delhi   Sir,   Sub: Urgent Intervention sought to ensure extension of draft 2021 Harmonised Guidelines public feedback deadline for wider participation by disabled citizens in the spirit of Nothing About Us Without US     This is to bring to your attention that an overwhelming majority of stakeholders in India's disability sector have only this week realised that the Harmonised guidelines were under review with online public consultations held on 22nd and 24th April 2021.  Even the handful of representatives from the disability movement who were consulted on 20 May 2022 for a focus group discussion were unaware that the draft had been readied and that the date for submitting comments was over! (The 2021 draft Harmonised Guidelines was submitted to the MoHUA by IIT Roorkee for launch approval by 10 August 2021, released on the NIUA website on 12 August 2021 with CPWD cutoff date for comments being 27 August 2021)    We have been given to understand that there are pressures of time as the MOHUA's planned release  of the revised Harmonised Guidelines is by October 2021.  This timeline is unviable as multiple corrections and changes seem to be required with experts opining that "this version is certainly not ready for release."  While the policy process undergone has been inclusive in ideation technically speaking, the lack of awareness and effective publicity among target stakeholders is regrettable. Not even our own MSJE ministry has publicised this matter or shared this draft formally! In view of this sub-optimal awareness and participation in public policy making, you are requested to intervene and ensure that the latest draft is provided in a variety of accessible formats, with adequate awareness by way of press release and publicity by relevant ministries, for review by public via citizen engagement portal MyGov.in for a minimum of a month as prescribed by 2014 Pre Consultative Legislative Policy (PCLP) para 2. (The draft was up for comments with only 15 days before deadline) It would be appropriate here to recollect the observations of the Supreme Court in the recent Vikash Kumar judgement paras 77 & 78  77 We find it apposite to mention here that consultation with persons with disabilities and their involvement in decision making about matters affecting their lives is necessary to bring about any meaningful change in the realization of their rights. Taking note of the emergence of movements of persons with disabilities and the philosophy of “nothing about us without us”, the CRPD Committee in its General Comment No. 7  has also underscored the importance of such participative decision making by involving persons with disabilities and organizations of the persons with disabilities.   78 In India, as reflected by the policy disconnect in this case, there is often a lack of involvement of the disabled in such decision making processes, leading to their voice not being heard and their grievances remaining unaddressed. This has also been listed as an area of concern by the CRPD Committee in its concluding observations on India. Taking into account our constitutional and international obligations, we direct the MSJE to frame the abovementioned guidelines in consultation with the public, specifically with persons with disabilities and organisations representing them .     Given that only 18 out of 63 participants in the online April discussions were disabled citizens and fewer than that paltry number participated in the May FGD, we request that other requirements of the PCLP are also met. That would include a plain language summary and a table of changes between the 2016 and 2021 Harmonised Guidelines. Additionally the recordings of the public consultation lack the promised captions and the live sign language interpreter screen has not been pinned for the recording rendering the record inaccessible to deaf, deafblind (and at least machine translation as there is complete exclusion on anyone who is not urban and English speaking with access to Internet.) Sign language interpretation of the same with closed captioning in addition to text description transcript for deaf and deafblind would be necessary. Records of the focus group discussion with key findings are not available online and would also be required as per PCLP. Blind and other TTS screenreader users are also facing challenges with the draft PDF which is not PDF/UA compliant - the number of fixes required as  per the test report are mindboggling. A properly structured HTML version hosted on an official website may be most usable currently, and a similar standalone website in future a better idea for easy sharing and referencing (without a massive sized, formidable document) and crossposting by authorities (who can thus link extracts for thematic guidelines without reinventing the wheel.) I'm sure you will appreciate that any haste to release an error-ridden draft standard (that as a statutory requirement can potentially have cascading, harmful repercussions on the lived experience of disabled Indians in every sphere) will be unseemly and undesirable. Please take cognisance of this matter and the requests listed above and issue  appropriate directions at the earliest.    Sincerely, VAISHNAVI JAYAKUMAR Member, Disability Rights Alliance

On Tue, 21 Sept 2021 at 12:40, Vaishnavi Jayakumar <jayakumar...@gmail.com> wrote: