I am strongly in favor of the proposed rule making on video description. Approval and implementation of the rule will provide substantial benefit to visually impaired viewers. My opinion is mostly based on a 1997 report published by American Federation for the Blind entitled "Who's Watching? A Profile of the Blind and Visually Impaired Audience for Television and Video" prepared by Jaclyn Packer and Corinne Kirchner. In addition I served for 4 years as a member of the DVS National Advisory Board (established under the WGBH Foundation). The AFB report states approximately 3% of the US population are visually impaired people who can benefit from video description. Of this 3% about 20% are most likely to benefit. They are likely to be older, unemployed, better educated, women, have other disabilities and have no useful or very limited vision. Described video programming should be directed to serve this audience segment on a priority basis since they are likely to be early adopters and lead others to adopt the new technology. A May 1993 report by Dr. Arnold Katz, a DVS Advisory Board member, based on his research using students, showed that their level of comprehension of video material was dramatically increased by video description. For students whose vision was artificially impaired, comprehension with video description was increased to levels near the levels of non-visually impaired students without description. For non-visually impaired students, video description increased their comprehension of the material by approximately 20%. Described programming should also be directed to serve the student and children audience. Note that since video description helps the comprehension of both visually impaired and non-visually impaired students, in some situations video descriptions can be run on an open basis (non-SAP). Eighty-seven percent (87%) of the individuals in the AFB report defined as most likely to benefit from video description had not heard of it. Even if the proposed rule is put into effect, there will still be a large need to make the potential beneficiaries aware of its availability. Promotional messages with open description is most likely the most effective approach. The final barrier to the full adoption of video description by the visually impaired is the lack of availability of SAP decoders. This can be overcome by the FCC requiring SAP decoders in all new TVs.