Before the
FEDERAL COMMUNICATIONS COMMISSION
Washington, D.C. 20554
In the Matter of )
)
Implementation of ) MM Docket No. 99-339
Video Description of )
Video Programming )
)
To: The Commission
COMMENT OF THE NARRATIVE TELEVISION NETWORK
Date: February 22, 2000
Jim Stovall, President
Narrative Television Network
5840 South Memorial Drive
Suite 312
Tulsa, Oklahoma 74145-9082
Phone Number: (918) 627-1000
Fax Number: (918) 627-4101
E-mail: Narrative@aol.com2
Introduction
The Emmy Award-winning Narrative Television Network (NTN) was founded in
1988 by blind and visually impaired people who understood the many frustrations
experienced by those who cannot readily access the education, socialization, and
information that television provides for sighted people in our society. As NTN is owned
and operated by blind and visually impaired people, and as we have over twelve years of
experience in making all types of movie and television programming accessible for the
visually impaired, NTN is in a unique position to respond to several points in the FCC’s
Notice of Proposed Rule Making.
NTN has more experience, over a longer period of time, producing more hours of
a broader spectrum of accessible programming, distributed to more people via a wider
variety of methods and systems, than virtually anyone in the field of video description.
NTN applauds the FCC and the overall intent of its Notice of Proposed Rule
Making, which, when adopted, will improve the lives of millions of blind and visually
impaired people across the country. NTN also wishes to applaud the efforts of the many
broadcast and cable networks, program producers, and syndicators that have worked with
the Narrative Television Network over the last twelve years to make their programming
accessible on a voluntary basis. NTN agrees with the response of the National Television
Video Access Coalition, and wishes to address comments to specific areas of expertise
that NTN has, based on its years of experience.
Cost
In the NPRM, the FCC requested information on pricing issues as it relates to
making television accessible for the visually impaired community. In over twelve years
of the highest quality service to the visually impaired community, NTN has been able to
provide narrated programming at a lower price than anyone in the industry. Increased3
volume over the years has brought NTN’s current price to below $2,000 per completed
hour of accessible programming. NTN anticipates that as the demand for more
programming increases as a result of the FCC mandate, pricing will come down even
further to a point approaching the cost of closed captioning for the deaf and hard of
hearing. With the current industry cost of producing television or movie programming, it
is difficult to imagine that the very modest expense of making programming accessible to
visually impaired people will be a significant factor.
SAP Delivery
In the NPRM document, the FCC cited the Narrative Television Network in a
footnote on page two as an organization that has done openly narrated programming.
While NTN began in 1988 with only openly narrated programming, as of this writing,
Second Audio Program (SAP) delivery constitutes the majority of NTN’s work for
broadcast and cable delivery.
While the SAP channel is being used for Spanish language translations, the
majority of those translations are done for news, sports, or talk format programming.
These are not the types of programming that generally need to be narrated for the visually
impaired, and would not be considered priorities as more programming is to be made
accessible. Therefore, NTN does not see the conflict with Spanish translations for the
SAP channel to be a significant issue. We do feel that as a number of broadcast and
cable outlets across the country already carry narrated programming on the SAP channel,
that when the FCC mandate is in place requiring major markets to pick up the signal, any
affiliate which is SAP equipped and has been delivering programming via the SAP
channel should be required to continue carrying the signal, even if they are not in a major
market.4
Timetable
The FCC, in its NPRM, requested comments on the 18-month timetable for
beginning to require accessible programming. The Narrative Television Network, along
with the other entities currently engaged in the field of accessible programming, presently
have the capacity to produce and deliver the amount of programming outlined in the
NPRM. Systems have already been put in place by NTN to provide rapid turnaround to
meet network schedules. Therefore, NTN believes that a one-year period before the
requirement would be mandatory should be adequate for all concerned.
NTN would further recommend that the requirements for year two and beyond be
addressed immediately, so that networks, program producers, and those in the field of
providing accessible programming can have the systems and the capacity in place to meet
the expansion demands into the future. As outlined in the National Television Video
Access Coalition?s response, a mandate should be put in place so that all prime time
network programming would be accessible by the seventh year after this requirement is
in force. The top 35 markets, along with any others currently delivering SAP, should be
required to pass the signal on in the first year, and this should be increased annually so
that by year four, all broadcast or cable affiliates which cannot demonstrate an undue
hardship would be required to carry accessible programming.
Once a program is narrated, the narration sound track should be required to be
delivered in all subsequent presentations of that programming, although repeat showings
of an accessible program should not satisfy the FCC’s quarterly requirement for narrated
programming. The hourly requirement should only relate to newly narrated shows.
Digital Set-Aside
Visually impaired people, including those who own and operate NTN, have been
waiting for many years to be able to enjoy the many benefits of accessible television and5
movie programming. While everyone in the industry agrees that the digital world is
coming, the most informed estimates still project it to be many years away. Therefore, it
is critical that the FCC take this important action while we are still in an analog format,
but set aside the digital bandwidth for narration once digital delivery becomes pervasive.
Copyright
In the NPRM, the FCC requested comments on the copyright issues surrounding
narrating television and movie programming. For over twelve years, NTN has worked
with broadcast and cable networks, as well as program producers and syndicators, on a
voluntary basis. Copyright issues have never been a factor, and we do not feel they will
be an encumbrance to the FCC’s action at this time.
Conclusion
The FCC is poised to take a vital step in the lives of millions of blind and visually
impaired Americans and their families. While the Narrative Television Network and
other organizations have made great progress in the field of accessibility over the past
twelve years, implementation has not worked on a voluntary basis throughout the
industry. As NTN has been honored for its work in accessible programming by the
American Council of the Blind, the American Foundation for the Blind, the Foundation
Fighting Blindness, and the President’s Committee on Employment of People with
Disabilities, among others, it is obvious that there is widespread demand among the
visually impaired community for accessibility.
As NTN has received an Emmy Award, a Media Access Award from the
television industry, the top script-writing award from the Writers Foundation of America,
as well as an International Film and Video Award, it is obvious that responsible and
broad-minded industry leaders are willing to embrace the millions of visually impaired
Americans as a significant and important audience.6
The FCC exists to regulate the communications industry to ensure that it provides
the greatest possible good for all Americans. As we move further into the complex
information age, it is critical that millions of visually impaired Americans not be left out
of this vital aspect of our society.
Respectfully submitted,
NARRATIVE TELEVISION NETWORK
5840 South Memorial Drive
Suite 312
Tulsa, Oklahoma 74145-9082
Jim Stovall
President