Alan Clive
11540 Stewart Lane, Apt. C-1
Silver Spring MD 20904
January 10, 2000
Honorable William E. Kennard
Chairman
Federal Communications Commission
445 12 th St. N.W.
Washington DC 20554
RE: FCC Docket 99-339
Dear Chairman Kennard:
These comments support the FCC’s NPRM for audio description of television programs
for blind or visually impaired persons. I have been totally blind since 1967, when I lost
my vision due to retinal detachments. Since going blind at age twenty-three, I received a
Ph.D. in American history from the University of Michigan, published an award-winning
book on the World War II home front, and received a National Endowment for the
Humanities fellowship. I have taught at the University of Michigan, University of
Massachusetts, and Northeastern University. When academic jobs grew scarce, I obtain
employment as first director of the Office of Handicapped Affairs for the city of
Worcester, Mass.
In 1982 I received and accepted an offer to work for the Federal Emergency Management
Agency (FEMA) in Washington. My employment at FEMA began in early 1983 and I
will mark 17 years service there in mid-January. My current work for the Agency’s
Office of Equal Rights includes management of a cadre of temporary employees who
handle EEO and Civil Rights matters at disaster sites. From my earliest days at FEMA I
have had special concern for the disaster-related needs of people with disabilities, writing
and speaking on this subject throughout the nation. I believe this latter qualification
allows me to speak with some expertise on certain elements of the audio description
debate.
I also serve on the Board of Directors of the Metropolitan Washington Ear Services for
the Blind, the key organization in the struggle for audio description.Alan Clive Comments Docket 99-339 p. 2
Benefits of Audio Description
Because the amount of audio-described material is still so limited, my intake of TV and
movies is far more limited than it might otherwise be. While this might be a good thing
in the case of TV, given the amount of junk on the air, the fact is that there are many fine
shows that I did not watch in the past and do not watch today because I know I could not
understand them fully without sighted help. That help has not always been available.
You’ll recall the famous episode of Homicide: Life on the Streets, entitled “Subway,”
about a man who has fallen to the tracks in the Baltimore Metro. I watched that episode
without sighted help, and although I did guess most of what was happening, I missed
critical elements, including the last scene. This is fairly typical of the blind person’s
experience with movies or TV: some of it makes sense without description, but vital
scenes and meanings are lost. This is especially true as both media move increasingly to
high-energy, low-dialogue presentation. At the FCC hearing that approved the NPRM,
you showed a clip from “Casablanca.” That film is typical of the “talky” movies of the
1940s, and actually could be followed fairly well without sighted aid. But even
“Casablanca” benefited greatly from audio description, especially during the flashback to
Paris, when music provided the only clue as to the action on-screen.
The limited audio description now available through PBS and its Descriptive Video
Service has made it possible for me to follow complicated dramas independently, as
when I watched various “Masterpiece Theater” programs. Television and cinema are
becoming ever more visual, and only audio description will allow blind persons to remain
in the cultural mainstream with their sighted friends and colleagues.
Miscellaneous Notes on the NPRM
I now wish to discuss certain specific elements of the NPRM. It calls for description to
commence in the top 25 markets after an eighteen-month grace period. The American
television and movie industry is large, lucrative, and filled with talented people. There is
no reason why more markets, as many as 35,could not be included in the startup phase.
Moreover, the years of experience gained by PBS in audio description is there for the rest
of the industry to use. Why it should take more than a year to gear up for the service is
something I cannot understand. A year’s preparation certainly is sufficient.
There is, too, no reason why it should take seven years for all prime time programming to
be described. In the mid 1980’s the video cassette recorder barely existed as a consumer
item: five years later, it had penetrated to most households. I use this analogy because I
believe that, once underway, the art and science of description would accelerate, thus
making it possible to describe all prime-time programs within four or five years.Alan Clive Comments Docket 93-339
I want to point out something else that is critical to the discussion but mostly overlooked.
The great majority of blind people are over the age of 65. I think it is almost cruel to
make them wait extra years for description. Many will die before it happens. My wife
and I are friendly visitors to an 86-year old blind woman who uses TV as her daily
companion. She watches CNN, the History Channel, and the biography shows on A&E.
These are the shows she can follow by listening. But there is a lot of good TV she could
be watching if only it was described. Under the current NPRM, she would have to live to
93 to have all of prime time available to her through audio description.
The NPRM gives networks the option of describing either prime time or children’s
programming. This loophole should be closed. I point to the demographic reality cited
above: most blind persons are elderly adults. While blind children should not be
overlooked, there are not that many of them compared to adults, and therefore the
entertainment industry should describe for both, rather than be given a choice.
We all know by now that many stations and cable networks gain their audiences and
profits from reruns. If a program is audio described, the description track should follow
the program into syndication. After all, a blind person will want to see old episodes of
the hits of 2003 just as much as sighted people will.
The broadcasters have urged that audio description be put off until digital TV arrives. I
cannot agree. Digital TV will not burst on the scene all at once, anymore than color
television did back in the ‘50s. It may take additional years for the technology to become
perfected and to spread. Since audio description works well with both analogue and
digital TV, why not start now?
Welfare for the Blind?
I now wish to take up two other arguments used against description. The first raised is
that, by forcing television and motion pictures into audio description, a kind of welfare is
being created for the blind. It is said that captioning for the deaf is required, because the
deaf would be completely cut off from TV without it. Since the blind can hear, they can
discern much from many programs by themselves, and with the aid of sighted relatives or
friends, can take care of the rest.
But why push this dependency model of blindness? Why should I have to rely on my
wife or child to describe something that could be described to me? Why lessen their
enjoyment by making a demand on them for help? More to the point, the original
Communications Act of1934 declared that the airwaves were to be used for the “interest,
convenience, and necessity” of the public. The Act did not add the phrase “tax-paying”
public, but almost all blind persons do or have paid taxes and thus deserve to be treated
like other citizens in terms of access to the media. It is in our interest, it is necessary, and
it is convenient to use audio description.Alan Clive Comments Docket 99-339
Recently the NAACP threatened a boycott of the networks unless they added more
African-American roles to upcoming programs. Nobody has asserted that this action is a
hidden welfare scheme to provide work for under-employed black actors. No, the
NAACP is making a point about inclusiveness. That is what audio description does: does
not provide welfare for unproductive blind people; rather, it provides inclusiveness to a
portion of the population that either still is productive or is receivint its just rewards in
retirement for years of productive work.
Description of Emergency Broadcasts
You also will hear a demand from some advocates for the blind that all television
ultimately be described, including all information broadcast during emergencies. In my
work at FEMA on the issue of disaster-related needs of disabled people, I have always
sought the most common-sense solution to a problem. Deaf people cannot hear the radio,
so must depend on TV for emergency information. The FCC wisely many years ruled
that TV stations should provide visual as well as audible emergency information. That
rule still too often is honored in the breach, but the deaf community has made great
strides in getting local TV stations to understand the need to provide crawls with vital
data, such as school closings.
Well, the blind can hear the radio. Most also have good enough hearing to know that a
storm is kicking up, even if they can’t see the threatening clouds. I am sure that every
one of the top 25 markets the FCC intends for audio description of TV has at least one
all-news station. In Washington, that station is WTOP, and it touts its abilit y to provide
everything a person needs to deal with bad weather, including those long lists of school
closings and event cancellations. Many other radio stations go into weather-disaster
mode, giving a blind person several choices from which to obtain critical news. The
push for audio description has the objective of bringing access to that which is largely
inaccessible: increasingly visually oriented television programs and motion pictures. We
fully concede that TV news must be left out of this mix, because it is usually live and
often fastbreaking. This does not mean that all live events, such as award shows (the
Oscars come to mind), should be excluded, since they are carefully scripted. But that is
for the future. Right now our concern is with pre-taped prime time or entertainment for
children. It is not necessary to delay the worthy objective of audio description for this
type of entertainment by raising the false issue of emergency information access, since
that information is readily available on radio.Alan Clive Comments Docket 99-339
I appreciate the opportunity to comment on this most important issue for my blind
brothers and sisters. If you wish to contact me, you may reach me at the address above,
or during the day at (202) 646-3957 (E-mail at ACLIVE@CLARK.NET).
Sincerely,
Alan Clive