Before the
FEDERAL COMMUNICATIONS COMMISSION
Washington, DC 20554
In the Matter of ) MM Docket No. 99-339
)
Implementation of )
Video Description of )
Video Programming )
COMMENTS OF THE COUNCIL OF
ORGANIZATIONAL REPRESENTATIVES
REGARDING NOTICE OF PROPOSED RULEMAKING
ON VIDEO DESCRIPTION
(COR)
Carol Fraser Fisk Donna L. Sorkin
American Academy of Audiology Alexander Graham Bell Association
8300 Greensboro Drive, Suite-750 for the Deaf and Hard of Hearing
McLean, VA 22102 3417 Volta Place, N.W.
(703)-790-8466 Washington, DC 20007-2778
Co-Chair COR (202) 337-5220
Co-Chair COR
February 23, 20002
Before the
FEDERAL COMMUNICATIONS COMMISSION
Washington, DC 20554
In the Matter of ) MM Docket No. 99-339
)
Implementation of )
Video Description of )
Video Programming )
Introduction.
COR is a coalition of national organizations that are committed to improving the lives of
individuals who are deaf or hard of hearing. Constituencies of COR organizations provide a
variety of services, including technological and telecommunications services, educational
programs, support groups and self-help programs, medical, audiological, and speech-language
pathology assessment and rehabilitation services, information on assistive devices and
technology, and general information on other services for deaf and hard of hearing consumers.
Among other things, COR serves as a bridge among interested organizations, the general public,
and the community of people with disabilities on matters concerning deaf and hard of hearing
individuals. COR has been an active participant in virtually all of the FCC’s earlier proceedings
on issues concerning people who are deaf and hard of hearing.
1
1 The following members of COR support these comments: Alexander Graham Bell Association
for the Deaf and Hard of Hearing; American Academy of Audiology; American Speech-Language-Hearing
Association; American Society for the Deaf; Auditory Verbal International; Conference of
Educational Administrators of Schools and Programs for the Deaf; Convention of American Instructors
for the Deaf; League for the Hard of Hearing; National Association of the Deaf; Self Help for Hard of
Hearing People; and TDI.34
General Comments
In its Notice of Proposed Rulemaking (NPRM) on video description of video programming, the
Federal Communications Commission (the "Commission") stated that, "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." As an organization representing the interests of
people who are deaf or hard-of-hearing, we know this to be an essential truth and we have
labored long and hard to assure that television, a vital source of news, information and
entertainment, is as accessible as possible to our membership via closed captions.
Through the TV Decoder Circuitry Act, the Americans with Disabilities Act and the
Telecommunications Act of 1996, Congress and the Commission have agreed on the necessity
for regulations to assure that significant amounts of captioned programming is available and that
the video transmission and reception infrastructure and consumer equipment is ready to display
it.
Now, under provisions of the Telecommunications Act, the Commission is considering a
mandate to assure equal access to video programming for people who are blind or visually
impaired as well. We wholeheartedly support the Commission's efforts in this area and
recommend an accelerated and comprehensive requirement schedule for "leveling the playing
field" for our colleagues and friends in the blindness community. We know only too well how5
marginalized and excluded one can be when denied communications access. We also remember
all too well the days when only one or two hours per week of TV programming was closed
captioned, when decoders were expensive and difficult to install, and when captions would often
be garbled or disappear or be left out of repeat showings of captioned programs. We hope the
Commission will take action to avoid these costly and debilitating delays and mistakes when
considering a video description mandate.
We urge the Commission to extend as rapidly and as broadly as possible the amount of
programming made accessible to people who are blind or visually impaired through the
addition of video description. While we recognize that video description is not as mature a
technology and service as closed captioning is, we remind the Commission that more
than ten years have passed since video description first became a regularly available service (on
certain PBS programs). Now, ten years later, only the Turner Classic Movie channel, of all
commercial video programming providers, has agreed to make the effort to extend its
programming to people who are blind or visually impaired. This is clearly an inadequate amount
of access. In comparison, ten years after closed captioning began, virtually all of prime-time,
news and children's programming was accessible on the major broadcast networks. Surely the
networks, both cable and broadcast, can do better than they are doing today.
We also urge the Commission to NOT wait for the roll-out of digital television before requiring
video description, as some would argue. It will likely be another decade before the majority of
video description users will be purchasing digital television equipment (whose standards to this
day are still being discussed and perfected) and will be able to receive signals as readily as they6
do today's analog signals with the tried and true SAP channel employed to carry video
description.
Most of the major organizations representing the interests of deaf and hard-of-hearing people
also count people with visual impairments among their membership. For this reason
as well we feel that the Commission should continue their dedication to accessible technology
and support both captioning and description as a means to help close the "digital divide" and
make sure as many Americans as possible are afforded the opportunities of the Information Age.
We thank you for your consideration of these comments.
Sincerely,
______________________________ ____________________________________
Carol Fraser Fisk Donna L. Sorkin
American Academy of Audiology Alexander Graham Bell Association
8300 Greensboro Drive, Suite-750 for the Deaf and Hard of Hearing
McLean, VA 22102 3417 Volta Place, N.W.
(703)-790-8466 Washington, DC 20007-2778
Co-Chair COR (202) 337-5220
Co-Chair COR
February 23, 2000