Before the
Federal Communications Commission
Washington, DC 20554
In the matter of )
Implementation of )
Video Description of ) Docket No. 99-339
Video Programming )
February 23, 2000
Comments by the Massachusetts Assistive Technology Partnership
The Massachusetts Assistive Technology Partnership (MATP) is a federally
funded project under the U.S. Department of Education, National Institute on
Disability and Rehabilitation Research. The administering agency for the
grant is the Massachusetts Commission for the Deaf and Hard of Hearing. The
MATP is a consumer-responsive project that promotes capacity-building and
systems change activities. Our mission is to increase awareness of - and
access to - assistive technology for individuals of all ages who have
disabilities so that they can participate more fully in education,
employment, and community activities, and thus, live more independently.
We applaud the Commission's ongoing commitment to developing and
implementing regulations that promote access to telecommunications for
individuals with all disabilities.
Introduction:
As the Commission notes in the introduction to this Notice of Proposed
Rulemaking (NPRM), "Television plays a significant role in our society.
Television programming shapes public opinion and culture in myriad ways. It
is the principal source of news and information and provides hours of
entertainment every week to American homes." Television is a medium for
viewers to participate in the public discourse on local, national, and
international levels. The widespread availability of closed-captioning has
already served to narrow the gap in access to television programming for
deaf and hard of hearing citizens. Under the Commission's rules and careful
monitoring, closed-captioning is thriving in the United States! With our
response to this NPRM, along with those of other consumer and provider
organizations, we hope to assist the Commission to set an equally ambitious
agenda and to accelerate the schedule for implementing Video Description in
television distribution markets throughout the United States from network
broadcasts to cable .
After reviewing the NPRM and the Commission's proposed rules, we offer the
following comments and recommendations (based on the paragraph numbering
system for section III. Proposal and Request for Comment).
#19: Although we agree with the concept of a "phase-in" of "closed" Video
Description into the marketplace, we urge a more ambitious "phase-in" with a
wider scope and more accelerated schedule than is proposed in this NPRM.
The technology for Video Description has been available for ten years. It
should be noted that after ten years of closed-captioning, almost all prime
time, day time, and news programs were captioned by the networks. We urge
the Commission to establish rules that will allow the availability of Video
Description to catch up with that of closed-captioning.#20: We urge that the Commission apply its rules to more than just the four
broadcasters listed in this NPRM and, include cable television programming,
PBS, Warner Brothers (WB) and United Paramount Network (UPN) as well.
Limiting the rules to only four broadcasters will unnecessarily slow the
process of establishing industry-wide standards and closing the
communication access gap in television programming for blind and visually
impaired viewers.
We also urge the Commission to raise this NPRM's proposed minimum
requirements for DVS hours per week, and to include cable within those
hours. We recommend ten hours of Broadcast programming and ten hours of
Cable programming per week, no later than twelve months after the effective
date of these rules. We further recommend a phase-in period of three to
five years. We also recommend ten hours of children's broadcasting per week
after the first year, with a similar phase-in period of three to five years.
#21: We recognize that the technology for Video Description is still new
and being developed. However, its current widespread availability to
television producers and distributors should allow for timely implementation
of the technology to network broadcasters, cable television programming,
PBS, WB, and. We urge that the Commission establish an ambitious blue
print with a more accelerated schedule than is proposed for the
implementation of Video Description. We realize that later NPRMs will be
necessary as television technology and Video Description technology expands.
We do hope that this particular NPRM will result in a set of rules that will
guide the industry as it continues to grow to ensure that Video Description
is not omitted from new technological advances. This is a Universal Design
perspective that will benefit both the industry and consumers.
#22: We recommend that the Commission closely monitor the "analog to
digital" transition, and present further rules, as needed, to ensure that
digital television will be developed in such a way as to allow for smooth
implementation of Video Description. However, as we state in our response
to number 21 above, we hope that this NPRM results in rules that will serve
as preliminary guidance to the industry as it transitions from analog to
digital television.
#27: As we stated in our comments on number 19, we recommend ten hours of
Broadcast programming and ten hours of Cable programming per week no later
than twelve months after the effective date of these rules. We further
recommend a phase-in period of three years to five years. We also recommend
an initial ten hours of children's broadcasting per week after the first
year, with a similar phase-in period of three to five years.
#28: (please see our response to #27). We believe that due to the current
availability of Video Description technology, the initial one-year
implementation requirement, with a three to five year phase-in period would
not pose an undue or excessive burden on network broadcasters, cable
television programming, PBS, WB and UPN distributors.
#29: Re: the "Programming to be described." As we stated in our comments in
number 19 above, we recommend ten hours of Broadcast programming, ten hours
of cable programming per week, and ten hours of children's programming per
month, no later than twelve months after the effective date of these rules.
We agree that the Commission should "establish certain parameters to ensure
that distributors select programming that has a significant audience thatwould benefit from video description programming."
The Commission seeks comment on ways to "ensure that the public, and in
particular, people with disabilities know when described video programming
is available."
We recommend expanding the use of the Descriptive Video Service "DVS" symbol
in TV guides and on-screen TV preview guides. This symbol is already in use
by the WGBH monthly program guide. Other promotional avenues include, but
are certainly not limited to: (a.) On-screen cable preview information
(including information on Video Description programming) read aloud on the
Secondary Audio Programming (SAP) channel; (b.) Broadcasters can announce
Video Description programming (as some similar verbal announcements for
closed-captioned and Spanish language programs); (c.) Information and
updates on Video Description programming may be distributed with bills for
cable television (and made available in alternate formats upon request; (d.)
Information and updates on Video Description programming may also be listed
on websites already dedicated to television programming information; (e.)
And, finally, a public service advertisement or announcement about Video
Description done in Video Description and aired by all broadcasters who
offer DVS, would be an excellent way to demonstrate the technology and
promote its availability.
#32: We recommend that the Commission establish rules to require that
public safety messages be provided in both "open" description and "open"
captions. This is a critical access issue.
#33: " Waivers and Enforcement Procedures." We agree that the guidelines
the Commission established in developing its closed-captioning rules can
serve as guidance in developing similar rules for Video Description.
Conclusion:
We thank the Commission for this opportunity to comment on this critical
issue, and we look forward to a proactive spirit of implementation by the
producers and distributors of television programming.
Respectfully submitted,
Carol Menton
Coordinator of Policy and Evaluation
MATP Center
Children's Hospital
1295 Boylston Street, Suite 310
Boston, MA 02215
617-355-7061 TTY
617-355-7820 V
617-355-6345 FAX