Abstract

We evaluate access for people with disabilities in two Canadian federal government eConsultations — the development of its Innovation Strategy and as part of the Parliamentary sub-Committee on People with Disabilities consultations around the Canada Pension Plan — Disability hearings. From qualitative interviews with government and the disability community as well analysis of key documents, we illustrate what worked in ensuring access for Canadians with disabilities and what served to create additional barriers to access. We suggest, first, that accessibility is not the same thing as usability and requires meeting, at minimum, commonly held standards of access. Secondly, we argue that access is not enough to bring people with disabilities into eConsultations. Proactive measures to reach people experiencing a wide spectrum of disabilities are essential to "enfranchising" people with disabilities in eDemocracy. Addressing both access and inclusion are simply good public policy, not extraordinary measures to address a minority population.

Keywords

Information and Communications Technologies (ICTs), citizen engagement, eDemocracy, disability, eGovernment, Canada Pension Plan-Disability, Government of Canada, innovation strategy, teledemocracy, digital democracy, web site accessibility, technology, usability, community access programs, social and political access, consultation tools

Introduction

Information and Communications Technologies (ICTs) are having social, political and economic impacts on the lives of most people around the world. Their reach has extended from simply technical tools that ease our word processing or communication tasks to shape how we buy consumer goods, organize in collective action, and engage in policy development and evaluation with our governments. Some have suggested that ICTs are creating both more and better opportunities for engaging citizens at all levels of government through e-government and e-democracy initiatives (Parent et al, 2004; Gronlund, 2001; Phil Noble & Associates, 2001). In particular, e-democracy and e-government are seen as ways to bring previously marginalized groups, such as people with disabilities, into the policy process.

In this article we consider how the Canadian federal government has used eConsultation as a tool in two instances — the development of its Innovation Strategy and as part of the Parliamentary sub-Committee on People with Disabilities consultations around the Canada Pension Plan — Disability hearings. From qualitative interviews with government officials as well as representatives of disability organizations, we illustrate what worked in ensuring access for Canadians with disabilities and what served to create additional barriers to access.

We outline the challenges involved in consulting with Canadians with disabilities using eConsultations. We explore why this group is so difficult to engage and how ICTs can be used to address this issue. We suggest, first, that accessibility is not the same thing as usability and requires meeting, at minimum, commonly held standards of access. Secondly, we argue that access is not enough to bring Canadians with disabilities into eConsultations. Rather, attention to inclusion, including proactive measures to reach people experiencing a wide spectrum of disabilities, is essential to "enfranchising" Canadians with disabilities in eDemocracy. Finally, we suggest that addressing both access and inclusion are simply good public policy, not extraordinary measures to address a minority population.

Defining eDemocracy and eConsultations

The Organization for Economic Development and Cooperation (OECD) suggested in 2001 that government-citizen interaction can be seen on a continuum of information, consultation, and active participation. Many governments, including Canada's, have chosen to use ICTs to facilitate these interactions. eGovernment is most often defined as "the use of ICTs, and particularly the Internet, as a tool to achieve better government" (OECD, 2003, p.1). This can include government Web sites and service provision online, such as online application forms for various government programs. eDemocracy, sometimes called teledemocracy or digital democracy, refers to "the use of ICTs to connect politicians and citizens by means of information, voting, polling, [consultation] and discussion" (Gronlund, 2001, p. 22), of which eConsultations are a valuable tool. eConsultations are understood as "the use of ICTs for enhancing citizen engagement in public policy-making" (OECD, 2003, p. 1). Most commonly, eConsultations are conducted by creating an information-based Web site that informs the public about a particular area of policy and any changes to that policy being considered and allows a mechanism for the citizen to give their input on the information received.

Citizen participation in the political process has been declining over the past 20 years. This could be closely related to a growing distrust in government and lack of faith in the political process (Parent et al, 2004). When citizens do engage with government, they are most often interested in government services. As a way to address the growing "democratic divide" eConsultations are regarded as a valuable tool for obtaining the opinions of ordinary citizens not necessarily considered experts in a particular field, but whose opinions are valued by governments nonetheless.

In the process of our interviews, various government officials involved with the two eConsultations told us that they are guardedly optimistic about the potential of eConsultations as a tool to address a perceived lack of citizen engagement in the policy process. People with disabilities, for a number of reasons, are one of the hardest groups to consult. While there are several key organizations in Canada represent the interests of people with disabilities and may end up on stakeholder lists and thus are often consulted by government, the average Canadian with disabilities is harder to reach.

Approaches to People with Disabilities and Technology

Technology, including ICTs, has been seen as a "solution" for fixing the problems faced by people with disabilities. In what some have called the deficit, rehabilitation or medical model of disability, people with disabilities are compared unfavorably with the norm and technology is seen as a solution to address the gaps.

The basic premise of the rehabilitation model of new technology is that it succeeds in either attenuating the physical or sensory problems the disabled person has (note that the word "disabled" is used to mean actual impairment within the rehabilitation approach), or that it augments the person, who because of a disability has not attained the normal and accepted range of disabilities ... Technology, then, has a corrective function, one that corrects an individual's personal shortcomings (Roulstone, 1998, p. 11).

This deficit model is widely used, by medical and technical "experts," to create new and specialized technologies to address the gaps between the person and their limited abilities as a result of their impairments. The technological solutions are viewed as requiring a case-by-case approach rather than as something to be developed in the mainstream. The deficit model identifies the relationships between disabled people and technology primarily as those taking place at the individual level — between a single person or a cluster of individuals with similar impairments, whose life or lives can be made better by the development and application of technology.

A Social Barriers Approach

In contrast to the deficit model, people with disabilities themselves have developed what is called the "social barriers" approach to explore the relationships between disabled people and technologies. Drawing on the social model of disability (Oliver, 1996), the social barriers approach suggests that our understandings of both people with disabilities and technology are socially constructed. We assume that simply because some people's bodies or minds are different than what is portrayed as "normal" they are significantly different and unable to act in ways that "normal" people might act. The social model suggests that disability is created and sustained by barriers within society. Roulstone (1998) takes this approach and applies it to new technologies in the context of employment. He suggests when we consider the benefits of and barriers resulting from new technologies from the vantage point of people with disabilities themselves, we see that new technologies are both potentially liberating and fraught with new obstacles for inclusion. He identifies three sets of barriers resulting from new technologies in the workplace: attitudes, environments (both communication and specialized technology) and technical barriers. When we consider other sectors of society, we may find other barriers and enablers.

The social barriers approach allows us to consider the relationships between people with disabilities and technology not only at the individual level, but also in its implications for communities or social networks, and at a more systemic or structural level. For example, we may be able to identify the ways in which ICTs create or enhance the social networks of people with disabilities (Seymour & Lupton, 2004; Renblad, 2000). We may examine how interpretations of human rights legislation, including the duty to accommodate, are ignored when we consider ICTs and thus reinforce the deficit model (Light, 2001). We may also consider the ways in which using inclusive design principles in developing ICTs are useful both for disabled people and broad segments of the Canadian population (National Council on Disability, 2002-03).

People with Disabilities, ICTs and eConsultations

During the 1990s, several equality-seeking groups in Canada and around the world used ICTs to increase their potential for citizen engagement. For example, the Canadian Advisory Council on the Status of Women, an advisory body within Status of Women Canada, set up a moderated e-mail discussion list for exchanging information about policy, action, and research on issues of concern to women in Canada. Called "PAR-L", this bilingual (English/French) list is intended as a support for the community of feminist researchers and activists in Canada (Senjen & Guthrey, 1996). Feminists across the country have used this discussion list to consult amongst themselves about particular issues of policy that affect them. They use this tool to help them formulate strategies and positions to present to government during consultations. Similarly, international human rights organizations, such as Amnesty International, also use such tools as e-mail and the Internet to connect their large internal network. Daily staff communications, liaisons with outposts and the rapid distribution of urgent actions and news releases facilitates the coordination of a coherent lobby and activist strategy.

While organizations such have these have found the use of ICTs to be an effective tool in broader goals of civic engagement, when we apply the social barriers approach to ICTs and eGovernment, we see that people with disabilities can face a number of unique barriers. Technical barriers such as inaccessible software and hardware, as well as political and social barriers, such as the mechanisms used to include people with disabilities or the representation of issues from the vantage point of disability, present obstacles to the effective use of ICTs for engaging citizens with disabilities.

Technical Access

Technical barriers to access can include both ensuring Web site accessibility as well as access to computers in general and specialized technologies required for accommodation.

Web site access

Governments in Canada and other industrialized countries increasingly rely on eGovernment. They are shifting the site of public goods and services to the Internet, including access to political information, communication about political issues, communication with government officials and elected representatives and the delivery of government services (Nugent, 2001).

The World Markets Research Centre (WMRC) and Brown University in the U.S. teamed up to conduct the first survey on Global e-Government issues in 2001 (WMRC, 2001). Canada ranked fourth in the e-Government ranking, coming in at 49.6% behind the U.S., Taiwan, and Australia (WMRC, 2001).

Yet, individuals with certain types of impairments, including visual, hearing, learning, and mobility, continue to experience many of the same access barriers as they did with government services before they went online (Jaeger, 2004). The WRMC survey also evaluated access for people with disabilities. Only 7 percent of Canada's Web sites were accessible at the time of this survey. Canada ranked behind the U.S. (37%), Ireland (24%), Australia (23%), Italy (20%), Madagascar (17%), Jamaica (8%) and South Korea (8%) (WMRC, 2001).

Several sets of guidelines and assessment tools are available to ensure technical Web site accessibility, including the Bobby and W3C guidelines. Bobby is a comprehensive Web accessibility desktop testing tool that helps to expose barriers to accessibility and encourages compliance with existing Web accessibility guidelines, such as section 508 of the U.S. Rehabilitation Act and the W3C's Web Accessibility Guidelines (W3CAG). The most current version of the W3C guidelines were developed June 2003, although a draft of the 2004 guidelines is available on the Web (http://www.w3.org/WAI/Resources/#gl).

To broaden access for people with disabilities, Web sites can also display features that would be helpful for the people with hearing or visually impairments. For example, TTY (Text Telephone) numbers can be provided in case people have additional questions that would require a human response (World Markets Research Centre, 2001). Using "plain" language or simple, uncomplicated language, Web site access is widened for those with learning or developmental disabilities, in addition to the many people whose first language is not English.

While we argue in this paper that accessibility and usability are not the same thing, they are two sides of the same coin. As Stephen Beesley, from the U.S. Disability Rights Commission (DRC) points out, "People tend to concentrate on the technical guidelines for accessibility, but real life is much messier than that. You have to take the human element into account" (quoted in Johnson, 2004). In particular, elements of Web design, such as navigation and content, while not adhering to accessibility guidelines, can improve the usability of a Web site for people with disabilities. One way to make a Web site more usable for a person with a vision impairment might be including alternative text, or "alt-tags" on images to tell a person with a vision impairment the nature of the image contained. Apart from making sure images have usable alt-tags, other common mistakes include a lack of scalable fonts (which let the user increase the size of text), and choosing colors that do not contrast properly, or look the same to people who are colorblind (Johnson, 2004). However, these are things that most Web developers don't think about. Educating them is something that Beesley recommends. In particular, while most design testing is done on technologists themselves, testing on ordinary users would ensure that the needs of people with disabilities were incorporated into Web site accessibility and design.

Improper planning of an eConsultation's Web site can create huge technical barriers to the inclusion of people with disabilities in the process. A few of the government officials we interviewed for this project expressed frustration over the dislocation between the content and technical aspects of the eConsultation. While the people planning the process may have recognized the importance of keeping the eConsultation content-driven, technical aspects often overshadowed the process. For example, while regular updating of the Web site was an important part of keeping the public informed about the issues, the people in charge of content were at the mercy of the people in charge of the technical aspects of the Web site when it came to uploading content to the site. In the end, it was their schedule that dictated the updates, not the appropriateness to the process. Also, in the CPP-Disability eConsultation, which was particularly focused on consulting Canadians with disabilities, accessibility of the Web site was something of importance right from the beginning. However, no matter how much they stressed this importance to the people involved with designing the Web site, the ultimate design and layout of the site fell upon their shoulders.

Access to Computers

As mentioned previously, accessibility of Web site is only one part of the usability issue. Other human elements, such as access to hardware, or computers themselves, can limit access for many people with disabilities. Many people with disabilities cannot obtain access to a computer or the adaptations to make it accessible to them. People with low incomes have more difficulties getting on the Internet (Department of Commerce, 2002; Leslie Harris & Associates, 2002; Kozar, 2001). People with disabilities in Canada are disproportionately represented in those who are low income (Office for Disability Issues, 2004).

Recently released statistics from the Household Internet Use Survey (HIUS), conducted as a subsample of the Labour Force Survey, indicated that in 2003, about 3.6 million Canadians had never used the Internet (The Daily, July 8, 2004). Of this group of non-users, 49% were from the lowest household income group (The Daily, July 8, 2004). According to data gathered by the Canadian Council for Social Development (CCSD), people with disabilities are less-likely than their non-disabled counterparts, in every age group, to have access to the Internet (CCSD, 2002). Among persons aged 15 to 34, 75.9% of those without disabilities had used the Internet in the previous 12 months, compared with 69% of those with disabilities. For people aged 35 to 54, the figures were 58.6% and 44.6%, respectively, and among those aged 55 to 64, the rates were 35.6% for those without disabilities and 23.6% for those with disabilities. Even among seniors, persons without disabilities were almost twice as likely as those with disabilities to have used the Internet in the previous year, 11.3% and 6.6%, respectively (CCSD, 2002).

Many countries are trying to address the issue of access to the technology by providing community spaces to access technology. In Canada, Community Access Points (or CAP sites) are funded by the federal government and provided in variety of locations, such as schools, libraries, and non-profit organizations. While CAP sites were created to provide greater public access and more opportunities for consultation with the public (and there is debate about whether they have been successful in accomplishing this [Rideout, 2000]), the public that can use these sites is circumscribed. Part of this comes because of the advocacy and political negotiations that take place in establishing CAP sites.

Many of these sites are inaccessible for people with disabilities because they don't provide the proper technology, software, or physical spaces for people with disabilities to use them. Industry Canada's Web Accessibility Office (WAO) has tried to address these issues. They have developed and piloted Web-4-All technology to people with disabilities using CAP sites in order to adapt specific CAP site computers to their accommodation requirements and carry those accommodations with them on a smart card. To date Web-4-All and related specialized technology (including larger screens etc) are available in 1000 CAP sites across Canada.

Other Access Issues

However, Seana Kozar (2001) found that accessibility issues affecting the use of CAP sites by women with disabilities were much broader than issues of technical and physical accessibility. For example, she urges that when we think about accessibility of these sites, we need to consider transportation issues, hours of availability, privacy, and on-site support, as well as issues of technical accessibility (Kozar, 2001).

While many academics laud the effectiveness and efficiency of the use of ICTs for eGovernment, one must wonder how efficient the technology is for people with disabilities themselves. For example, sending out mass e-mails alerting people to the existence of an eConsultation may be an effective and efficient way for governments to get the word out about an eConsultation, but if a person with a disability is required to find accessible transportation so that they can get across town, to go to the public library or other CAP site, during operating hours, to check their e-mail, is the use of this technology really more efficient for them?

Privacy is another important component in the use of CAP sites. While the CAP sites can play a vital role in their communities, having to access often sensitive personal materials in a public space can provide a deterrent to using CAP sites to some (EDC Center for Media & Community, 2004). Participants interviewed for this project reinforced this concern. They argued that people with disabilities are often afraid that speaking up about a particular policy could limit or restrict their access to programs and resources, or if they already receive funding through these programs, trigger an internal review or audit of their case. Some expressed fear about the security of their personal information.

If people don't feel that their information is secure ... or that there could be tracing ... The paranoia around CPP-D ... You never used to phone, even to ask a question, because you didn't want to trigger a review. People were very protective. People were not prepared to volunteer, even, in some instances (Representative of disability organization).

Others suggested that people with less visible impairments may not want to look at self-help or other related materials in a public place. One participant described using or getting the technology itself as the biggest barrier for people with mental health concerns:

Well, I think that [the biggest access issue] would be access to having the technology. Not everybody wants to go into a library, for example, and ... if it has anything to do with mental health then they're stigmatized just by putting it into the computer, so that's an issue ... It's a definite barrier (Representative of disability organization).

Social and Political Access

To evaluate social access of e-Democracy initiatives, we could look at the social practices and capabilities of those being involved in, or who we are trying to bring into, the policy process (Whyte & Macintosh, 2003). We need to consider more than issues of technical accessibility (Web sites that are accessible and the physical access to the technology) and the political issues involved (whether e-Democracy initiatives are meeting their mandate of engaging all citizens) (Whyte & Macintosh, 2003). We may consider the extent to which target audiences of the consultation are involved in establishing the parameters of the consultation and assessing its results. Some specific questions related to people with disabilities include: Are people with disabilities adequately trained and skilled in the use of the technology? Are in-person supports in place for those who may require it? Do they have access to the information needed in the format (e.g. plain language, Braille, etc.) to engage in the process? Are there multiple entry points for participation that allow for different capabilities and interests?

When we examine political access to eConsultations, Whyte and Macintosh (2003) suggest that we evaluate whether e-Democracy initiatives are meeting their mandate of engaging all citizens. Thus a critical question from the vantage point of people with disabilities is: Are issues related to disability, especially those identified by people with disabilities and their self-representational organizations, included in the eConsultation agenda? Are they given the same weight as other issues? In addition, we can consider the strategies used to engage citizens. Who is the audience of the eConsultation? Does the communications strategy adopted to implement the eConsultation proactively reach out to groups which are regularly marginalized, including people with disabilities? How are the results of the eConsultation analyzed? Are the voices of marginalized groups represented in the results?

Very little literature exists on how best to consult with Canadians with disabilities. While the OECD (2003) acknowledges that those who are disadvantaged in the digital divide can also be disenfranchised from e-Democracy, little has been done, in terms of research, to define the most appropriate approach to bridge the divide. For people with disabilities, the approach must be multidisciplinary and address many of the social, technical, and political access issues discussed.

At least one country, Australia, has begun to address this gap. Its Office of Disability Policy published "Inclusive Consultation: A Practical Guide to Involving People with Disabilities" (Department of Family and Community Services, 2003) as part of their Commonwealth Disability Strategy. While this guide lacks an analysis of the benefits and constraints of the use of ICTs, it does present a number of issues that should be considered when planning any government consultation in order to better engage citizens with disabilities. For example, the report outlines several accessible methods for consultation, but points out that there is no set way to consult with people with disabilities. Active participation of people with disabilities often requires a variety of tools and approaches.

Access and Inclusion in two Federal eConsultations

As one theme in a major research project entitled Disability and Information Technologies (Dis-IT) Research Alliance (www.dis-it.ca), we looked in detail at access and inclusion issues for people with disabilities in two federal government eConsultations: the Parliamentary Subcommittee on Disabled People's e-Consultation on Canada Pension Plan Disability Program in 2002-2003 and Industry Canada and Human Resources Development Canada (HRDC)'s e-Consultation on Canada's innovation strategy in 2002. These were chosen out of a very limited number of eConsultations because they illustrated a range of addressing eConsultation, the materials of and results from the eConsultations were readily available and they aimed to reach a broad audience.

For each eConsultation we reviewed the public documents available, including the methods of consultation (e.g. questionnaires etc). We undertook key informant interviews with government officials responsible for developing and/or implementing the eConsultation. Finally, we interviewed representatives of national self-representational disability organizations about their experiences with eConsultations in general and these two eConsultations, in particular, if they were involved in them.

Two Case Studies

CPP—Disability eConsultation

In 1998, the Government of Canada undertook a review of the Canada Pension Plan (CCP) that significantly restricted the eligibility criteria of the Canada Pension Plan Disability Program (CPP-D). Citizens who were unhappy with the changes to their programs took their issues to their MPs, who in turn expressed their frustrations in the House of Commons. In 2002 the Parliamentary Sub-Committee decided to undertake a consultation on this program. Its chair, Carolyn Bennett, suggested undertaking an eConsultation as a pilot project. The Sub-Committee agreed that an e-consultation could be a valuable tool when used in conjunction with more traditional methods of consultation.

To decide on how to implement this, staff received a briefing on CPP-D from the Income Security Programs Branch of Human Resources Development Canada. A roundtable with organizations, including disability organizations and various other stakeholder groups, experts, and federal departments, was held in May 2002. The roundtable was a scoping exercise to set out the priority areas that would serve as the basis for the study and the e-consultation.

In June, the Subcommittee launched an information-based Web site to keep the public up-to-date with their activities and to give the public the opportunity to have input into their work at this early stage of the e-consultation process. This site was in place for 6 months before the official e-consultation was launched on December 2, 2002, the International Day of Persons with Disabilities. It ran for 13 weeks and ended March 3, 2003. People could become involved in the eConsultation in three different ways: completing an issue poll; sharing stories; and/or offering solutions to a range of issues facing the CPP-D program.

The e-consultation reached a large number of people: 1,500 people participated in the issue poll, 135 people shared their stories, and 28 individuals or advocacy groups shared their solutions (Report, p. 4). After the eConsultation process ended, roughly 10 or 12 of the respondents were asked to come to Ottawa and share their stories with the SubCommittee, and officials from Human Resources Development and Finance.

Innovation Strategy eConsultation

In May 2002, the Minister of Industry and the Minister of Human Resources launched an engagement process on behalf of the Canadian Government to arouse discussion about the challenges facing Canadian innovation. Two policy documents were drafted by HRDC and Industry Canada that outlined the current situation of Canadian innovation and offered solutions to the challenges facing the industry. These documents were circulated to target groups for their feedback and input into what they believed they could contribute to Canadian innovation.

An Innovation Secretariat was launched to decide how the six-month engagement process would proceed. They decided to hold a series of 34 regional meetings and events. Participants were invited to attend a series of full-day events. The engagement process proceeded in two streams: one sponsored through Industry Canada, called Achieving Excellence: Investing in People, Knowledge and Opportunity and another held by Human Resources Development Canada, called Knowledge Matters: Skills and Learning for Canadians. Each of the 34 regional events held throughout Canada produced a report on the recommendations made and the outputs identified.

The methods used to engage citizens varied. E-mails went out to about 30,000 small and medium sized enterprises to solicit their opinions and about 600 responded. A small workbook, or toolkit, was created for individual citizens to give their input into the process online. About 130 individuals responded to the online portion of the process, but the toolkits were also used by organizations to organize their roundtable events. Submissions were then made on an organizational basis.

Once all the written submissions were received from the events and roundtables, as well as the ones received online, then the data was synthesized and categorized. Two documents were produced as a result: one by Industry Canada and one from HRDC, outlining the broad thematic recommendations and reactions for the national summit of key regional national leaders held in November 2002. A workbook and discussion guide were produced and all of the submission documents were posted online.

Once the engagement process was completed, two major reports described the outcome: Canadians Speak on Innovation and Learning and The Practice of Innovation. No formal evaluation of the process has been completed, but the work at the national level is ongoing.

The following sections include only an initial analysis of the data gathered. We are continuing to interview and undertake a content analysis of the related documents.

Analysis of Case Studies

Technical Access

Issues related to technical access for people with disabilities in each of the case studies can be assessed in part by looking at the extent to which Web accessibility guidelines were implemented as well as whether some of the broader issues of technical access (including availability of human supports, training, information in a variety of formats etc) were addressed.

In 1998, the Government of Canada's Treasury Board Ministers made several policy decisions aimed at strengthening the identity, presence, and visibility of the Government of Canada. One of their decisions focused specifically on the opportunities inherent in electronic media, and set out a clear mandate for optimizing its potential. In May 2000, Treasury Board Ministers approved the Common Look and Feel (CLF) standards and guidelines and required all institutions to comply with them by December 31, 2002. Any Web site related to the government of Canada must meet these common look and feel guidelines, which include meeting a minimal level of accessibility. Under the CLF standards, all Government of Canada's Web sites must comply with W3C Priority 1 and Priority 2 checkpoints to ensure that sites can be easily accessed by the widest possible audience (Treasury Board, 2001).

In interviews with government officials from both eConsultations, technical accessibility was described as a priority in both cases. However, it is interesting to note that when we spoke to the official responsible for content in the Innovation Strategy's eConsultation, they claimed that no requests for alternate formats or other accommodations were made, but that their office was prepared to deal with them if there was. However, when we spoke with someone involved with the technical aspects of the eConsultation, it appears as though accessibility was considered a much higher priority and was dealt with much more proactively than we were at first lead to believe. For example, the government official we spoke with who was involved with the technical aspects of the Innovation Strategy's eConsultation stressed that meeting accessibility guidelines was of great concern to them from early on in the process.

The officials in charge of the CPP-D consultation suggested that because people with disabilities were their target group of stakeholders, accessibility had to be considered when designing their information-based Web site.

In doing all this work we were pretty aware all the time that this had to be accessible, so that was built in from the very beginning ... we made efforts to make sure that stuff was in plain language, we made efforts to ensure that the site was clear, that the design of the site accommodated people as much as possible (Government official).

In some cases, accessibility was as simple as ensuring that there was always an actual person on hand to help people with their accessibility issues.

We had one, an e-mail system built into the Web site that people could send their comments into and it went to four or five different people here and whoever was best equipped amongst that group would handle the question and we all look at it and say yeah, that's what we need to do, or we need to send this to the programmers to fix (Government official).

At first, it appeared as though the eConsultation on the Innovation Strategy was not so proactive in addressing accessibility. The official we spoke with in charge of content described accessibility as being addressed in reaction to accommodation requests. However, when we spoke with an official involved with the more technical aspects of the eConsultation it became clear that since the government put into place their Look and Feel guidelines, accessibility was something that was very naturally considered from the beginning. This illustrates again the dislocation that can occur between those driving the content and those applying the technical aspects. What is odd is that in the Parliamentary Sub-Committee's eConsultations it appears as though the content people were the ones encouraging considerations of accessibility, while in the Innovation Strategy's eConsulation, it was the technical people who brought these concerns into the process.

For the CPP-D consultation, technical accessibility became more of a challenge because they had to fight to ensure that the technology did not drive the process, but rather that the content shaped the process. Information was uploaded to the Web site by the people in charge of technology for the department. Information was often posted on the site by the people in charge of technology that was not accessible in one form or another, and not written in plain language. People also noted significant time constraints arising from a lack of control over technology. The requirement that the technology people post the content to the Web site meant that there were often lags of a week or so from when the content was produced until it could be put on the site.

There were huge amounts of delays and time lost because of the way they conceived of what their job was. They set things up in such a way that they had to make every change. When you're doing stuff it goes through many drafts right, so that meant that they had to actually physically make the changes, there wasn't a way that we could sit down here, do it up, plug it in and get it inputted. So there was all that kind of stuff, and then the other thing was I guess probably doing the programming in house. That was against our advice (Government official).

If they had had customizable software that would have been flexible enough to allow them to upload the content themselves, the situation might have been remedied.

Without access to information generally, people will find it difficult to engage in consultations. The OECD (2001) suggests that the first step to a successful consultation is to ensure the information is "complete, objective, reliable, relevant, easy to find and understand." For people with disabilities to be included in the process, the information must also be accessible. If the information is not readily available to them, and extra time and energy needs to be invested into obtaining even the major policy documents, people with disabilities will be less likely to engage in the process.

Assessing social and political access and inclusion

The OECD suggests that the second step to holding a successful government consultation with its citizens is to ensure it has "clear goals and rules defining the limits of the exercise and the government's obligation to account for its use of citizen's input" (OECD, 2001, p. i). This complements our assessment based on social and political access and inclusion.

Both case studies revealed that eConsultations added something to traditional methods of consultations, but were not sufficient by themselves. Consistently throughout the interviews, we found that an approach that married the two approaches and sets of tools was the most effective for reaching the broadest population of Canadians. As one of our participants explained it:

[The tools you use in consultation] depends on your audience. What tools will get your audience. From all the consultations we looked at, you know you can't just use one tool; you've got to use a whole range of tools to get the different groups (Government official).

Each of the case studies identified a target audience and used its communications strategy to ensure the audience was aware of the consultation and could participate.

The CPP-D e-consultation brought stakeholders into the process at an early stage. The formal roundtable meeting with members of the disability community enabled the advocacy groups to have a significant impact upon shaping the process and what the outcome of the consultation would be. Because this e-consultation was seen as mostly a scoping exercise, from the outset people were aware that the outcome would be a report to which the government of Canada would respond. Whether or not the report has any significant bearing on policy or not, it acts as a tool for the disability community in their lobbying efforts.

It was also useful that the conclusion of the e-consultation involved a final roundtable discussion where some individuals who had responded by posting a message on the Web site were invited to sit around the table and share their stories with organizations, experts and government policy makers. According to one participant, this had a significant impact particularly on the policy makers. For example, a client who had worked for 25 years and paid into CPP, had become ill and had to leave his original line of work, sought retraining in another field but then developed cancer--by this time he had not paid sufficient contributions to CPP to be eligible for disability benefits though he was now severely disabled. It was very important for policy makers to hear clients' stories first-hand since they do not usually have access to this.

The e-consultation for the Innovation Strategy did not target people with disabilities in their engagement process. While participation in their events was not limited to any particular group, you did have to be on the invitation list to attend. The engagement process broadly claimed to solicit the viewpoints of large and small businesses, industry sectors, national business associations, youth, Aboriginal peoples, academic and research institutions, municipalities, economic development organizations, sector councils and labor groups. The general engagement process was supposed to consult the general public and communities, but the focus was upon engaging those groups and individuals who were generating economic activity. One official involved in the process told us:

We were looking for influencers and opinion leaders, so ... people who represent organizations or broader groups of people, but we also wanted to have ... small business owners and corporations, large employers and people who were generating economic activity (Government official).

People with disabilities are often viewed as not contributing to the economic health of the nation, so these groups were not actively recruited for their participation. There were no disability organizations involved in any aspect of the e-consultation, and few organizations that included disability within their mandate were involved. In fact, the Caledon Institute of Social Policy was the only organization mentioned on the consultation list that does any direct research on disability and social policy issues.

A final way to assess eConsultations is to consider how the results have shaped the policy process. The OECD suggests that to ensure active participation of citizens in a consultation, sufficient time and flexibility are needed "to allow for the emergence of new ideas and proposals by citizens, as well as mechanisms for their integration into government policy-making processes" (OECD, 2001, p. i). In both eConsultations, those interviewed identified consistency within government, especially in terms of vision and policy direction, as a critical requirement for a successful eConsultation. One government official from the innovation strategy e-consultation commented that:

Changing ministers doesn't help and changing Deputy Ministers doesn't help either. The Deputy who led the innovation strategy process, our Deputy, moved, got moved over to the Department of Foreign Affairs and International Trade, that was April of 2003, like at the point where you're trying to figure out how you're going to do the strategy, he gets shifted, the Deputy shuffle, so he goes over to Foreign Affairs and actually he brought the agenda over there, innovation in the international trade department had led to this initiative ... which is the technology partnerships initiatives. And our Deputy who came into replace him, it took a while to, and he's been shuffled again, so May 10th we have another new Deputy ... So these things don't help with continuity (Government official).

The disability community has also found this problematic:

[The] change in Prime Minister, change in different cabinet ministers has really put a stop on a lot of activities because we do advocate and that has really curtailed our advocacy efforts. There's an election now, there's difficulty in people wanting to make commitments. There's difficulty in people wanting to meet with you and being able to commit to something. That has really made a huge impact in a lot of non-profit organizations and NGOs. A stable government that will be stable for a while so that we can get things put into place again [is what we really need] (Disability organization representative).

This suggests that while changes in government may lead to greater vibrancy within a democracy, it may act as a barrier to ensuring the implementation of recommendations or directions from an eConsultation.

Conclusion

eConsultations are increasingly used by governments to engage citizens in the policy processes. To ensure that all citizens can be included, eConsultations need to ensure technical, social and political access and inclusion for all people. This means not simply making sure consultation Web sites are useable, but that they meet commonly-held accessibility standards. But access and inclusion require more than meeting technical guidelines. To ensure that all Canadians can engage, eConsultations need to be inclusive; that is, work proactively to include often marginalized populations. This may entail using plain, or clear and simple language to facilitate the participation of those with developmental disabilities as well as those whose first language may not be English or French. It may involve identifying as a target audience those who have often been left out of the policy process, regardless of whether or not they have been seen to have an interest in the issues. To ensure their inclusion means including them in the development of the eConsultation process, both in identifying areas of content, but also ensuring they can use the tools of technology to participate. eConsultations by themselves will not reach all people, but together with more traditional forms of consultation, they may be able to increase the possibilities for participations of all Canadians, including those with disabilities.

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