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 *Pages 1--4 from  Microsoft Word - 6011056168.doc*
 March  23,  2000 
 Magalie  Roman  Salas 
 Office  of  the  Secretary 
 Federal  Communications  Commission 
 445  Twelfth  Street,  S.  W.,  TW-  A325 
 Washington,  D.  C.  20554 

 Dear  Ms.  Salas: 
 RE:  COMMENTS  ON  NOTICE  OF  PROPOSED  RULEMAKING 
 IN  THE  MATTER  OF  VIDEO  DESCRIPTION  OF  VIDEO  PROGRAMMING 

 MM  Docket  No.  99-  339 
 The  responses  received  to  FCCs  proposal  to  mandate  description  of  a  few 
 television  programs  is  no  doubt  puzzling  to  the  commissioners.  FCC  probably 
 expected  to  hear  universal  acclaim  from  the  blind  community  and  whining  from  the 
 television  industry.  After  duly  and  politely  characterizing  the  responses, 
 FCC  could  then  finalize  its  rule  and  feel  very  positive  about  helping  the 
 blind.  Unfortunately,  its  not  that  simple. 

 For  two  principal  reasons  and  a  host  of  contextual  ones,  I  urge  FCC  to 
 abandon  its  proposed  rule  mandating  description  of  a  few  TV  programs.  I  should 
 mention  that  I  am  a  blind  person  and  have  been  so  for  over  thirty  years. 

 The  two  reasons,  in  a  nutshell,  are:  (1)  there  is  something  more 
 important;  and  (2)  adoption  of  this  rule  will  probably  be  the  extent  of  FCC 
 action,  thus  ignoring  the  more  important  issue. 

 Something  More  Important: 
 Nobody  disagrees  that  blind  people  need  enhanced  access  to  information 
 provided  through  the  medium  of  television.  The  disagreement  concerns  what 
 information  is  most  important  and  should  be  mandated  first. 

 FCCs  proposal  is  to  require  description  of  entertainment  portions  of 
 television.  While  many  blind  persons  consider  this  nice,  its  not  the  most 
 important  piece  of  information  blind  people  need  from  television.  Rather, 
 safety  and  news  information  are. 

 Our  TV  screens  contain  all  kinds  of  information  not  accessible  to  a  blind 
 Person--  printed  on  the  screen  but  not  voiced.  That  is  far  more  important  than 
 the  description  of  events  within  a  television  program. 

 Some  examples  are:  emergency  weather  information  crawled  across  the  bottom 
 of  the  screen  while  the  program  remains  in  progress;  identities  of  interviewees 
 on  national  nightly  news  programs;  800  numbers  for  more  information  in 
 ommercials;  program  guides  available  on  cable  TV 
 systems;  sports  scores  from  local  games  during  local  news  programs.  Each  of 
 these  instances  in  which  the  information  is  not  available  to  a  blind  viewer  is 
 safety-  or  information-  related  and  vastly  more  vital  to  ones  life  and 
 participation  in  ones  nation  than  is  the  plot  of  a  weekly  TV  show. 

 The  reason  FCC  has  even  considered  mandating  descriptions  of  programming 
 is  because  a  TV  station  in  Boston  has  a  significant  voluntary  commitment  to 
 description  through  which  both  television  programs  and  movies  are  produced  with 
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 descriptions  included.  In  other  words,  somebody  thought  of  a  way  to  do  it  and 
 the  concept  is  widely  known  among  the  blind  community. 

 But  knowing  a  concept  neither  makes  it  the  most  important  goal  nor  desirable  as 
 a  mandate.  On  the  other  hand,  no  one  is  working  on  providing  the  blind  with  the 
 core,  unvoiced  information  about  safety  and  news  mentioned  earlier.  Until  an 
 idea  is  taken  seriously,  it  cannot  be  operationalized.  Blind  persons  watching 
 television  are  constantly  frustrated  by  lack  of  access  to  safety  and  news 
 information  printed  but  not  voiced.  But  no  one  has  produced  what  looks  like  a 
 solution. 

 And  no  one  will  unless  the  FCC  steps  in. 
 A  very  simple,  low-  tech  solution  for  broadcasting  this  printed,  unvoiced 
 information  exists.  Station  employees,  news  producers,  and  advertisers  could 
 include  soft,  voiced  versions  of  the  information  during  the  actual  program  or 
 could  include  human-  voice  simultaneous  reading  of  the  unvoiced  information 
 through  the  secondary  audio  channel.  Without  a  mandate  from  FCC,  this  will 
 never,  ever  be  done. 

 And,  with  a  mandate,  technology  will  certainly  be  developed  along  with  standards 
 for  production  that  would  produce  the  voiced  information  (again,  either  softly 
 in  the  actual  program  or  through  the  SAP)  by  synthesized  digital  voice  rather 
 than  by  human  voice.  The  technology  and  standards  would  evolve  pretty  quickly 
 and  be  very  cost-  effective  as  compared  to  hiring  employees  and  in  view  of  the 
 large  potential  market  in  all  television  stations,  ad  production  facilities,  and 
 TV  production  facilities  in  the  country. 

 No  such  fundamental  change  in  our  access  to  core,  unvoiced  information, 
 taken  for  granted  by  sighted  viewers,  will  occur  without  an  FCC  mandate. 

 A  Little  Will  Seem  Enough 
 If  FCC  finalizes  the  rule  on  description  of  entertainment  TV,  that  will 
 likely  be  considered  enough.  Efforts  to  change  and  improve  access  to  any 
 information  broadcast  on  television  will  likely  stop  there.  Oh,  well,  its 
 possible  that  the  number  of  hours  per  quarter  required  to  be  described  might  be 
 tweaked  a  bit  now  and  then,  but  no  whole  new  topic  is  ever  likely  to  be  raised. 

 Im  speaking  here  of  time  management,  of  the  fact  that  handling  the  concerns  of 
 the  blind  is  not  and  will  never  be  a  big  priority  for  FCC.  If  there  is  ever 
 time  for  handling  of  two  issues  concerning  the  blind  ,  then  all  the  better.  But 
 Im  skeptical. 

 And,  if  we  get  one  chance,  we  should  insist  that  it  be  to  achieve  access 
 to  core,  unvoiced  information  such  as  safety,  news,  and  programming  information 
 being  broadcast.  This  information  protects  citizens  and  enables  use  of  the 
 medium.  Detailed  use  of  a  given  program  (largely  achieved  in  most  cases 
 through  dialog  and  sound)  can  be  handled  in  a  second,  later  rulemaking  if 
 FCC  wants  to  devote  more  time  to  access  for  the  blind. 

 But  the  facts  of  workload  and  other  pressing  issues  make  one  shot  much  more 
 likely  than  two.  I  urge  FCC  to  take  that  first  shot  with  care  and  thought  and 
 to  take  it  on  behalf  of  protective  and  enabling  information  rather  than 
 entertainment. 

 Other  Notes 
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 1.  Regardless  of  what  FCC  may  have  been  told,  description  of 
 entertainment  programs  is  not  standardized  and  routinized  as  is  closed 
 captioning  or  printing  of  words  on  the  screen  for  the  deaf.  Rather, 
 describing  entertainment  is  actually  an  added  form  of  art,  going  beyond 
 what  the  original  producers  have  provided  by  adding  a  level  of  audible 
 description  chosen  by  the  describer.  No  two  persons  would  choose 
 the  same  words,  items,  and  matters  to  ignore.  Given  these  facts,  requiring 
 description  of  entertainment  television  is  requiring  something  that  cannot  be 
 standardized  and,  in  effect,  cannot  be  checked.  In  other  words,  a  very  few 
 lines  of  description  will  actually  suffice  for  a  bare  minimum  when  another 
 describer  might  choose  to  talk  constantly  during  the  entire  silent  space  of  the 
 original  production.  Potential  for  lots  of  fights  over  what  description  means 
 if  adoption  of  the  proposed  mandate  occurs. 

 2.  Access  to  printed,  unvoiced  information  is  going  to  have  to  occur 
 sometime.  What  about  competition  between  description  of  entertainment  and 
 voicing  of  printed  information?  Which  is  more  important?  If  safety  and  news 
 information  is  more  important,  its  provision  should  be  settled  first  so  that  its 
 priority,  should  it  use  the  SAP,  can  be  established  in  standards  used  to  produce 
 core  information  and  entertainment  information.  In  other  words,  if  an 
 entertainment  program  in  progress  with  SAP  description  is  underway  when  a 
 weather  bulletin  starts  its  crawl,  the  weather  bulletin  must  trump  the 
 entertainment.  So  we  should  establish  the  system  for  weather  bulletins  first  to 
 know  what  it  is  so  we  can  know  how  to  give  it  priority  in  case  of  potential 
 conflicts.  If  the  entertainment  description  is  established  first,  we  may  never 
 get  to  the  core  information  and,  if  we  do,  we  may  not  be  able  to  get  it  the 
 proper  priority  in  the  stream  of  voiced  information. 

 3.  This  problem  is  all  the  more  acute  given  the  practice  of  voicing 
 Spanish  language  translations  for  English  programs  on  the  SAP.  It  is  unclear 
 which  will  have  priority  if  both  are  being  fed  to  the  SAP  channel;  it  is  equally 
 clear  that  weather  bulletins  should  have  priority  over  both  and  so  need  to  be 
 factored  in  before  translations  and  entertainment. 

 4.  The  need  for  establishing  priorities  and  standards  for  production  is  all  the 
 more  acute,  given  the  impending  shift  to  digital.  Digital  will  give  producers, 
 networks,  and  stations  more  flexibility.  There  should  be  no  flexibility  in 
 whether  core,  unvoiced  information  is  voiced.  But  there  should  be  clear 
 standards  and  mandates  in  place  before  digital  gets  going  very  far  so  that 
 all  players  will  know  they  have  to  build  in  broadcast  of  core  information  and 
 just  how  to  do  it. 

 5.  FCC  will  unquestionably  get  numerous  comments  urging  it  to  finalize  its 
 proposed  rule.  However,  Ill  bet  large  sums  that  no  such  commenter  will  disagree 
 with  the  need  to  have  core  information  voiced.  In  conversations  Ive  had  with 
 proponents  of  the  proposed  rule,  these  commenters  at  first  think  FCC  is 
 requiring  both  core  information  and  entertainment  information.  When  the 
 distinction  is  drawn  and  the  fact  that  FCC  is  only  requiring  entertainment 
 information  is  explained  to  such  commenters,  they  invariably  reply  in 
 frustration:  Well,  then,  why  cant  we  have  both?  In  effect,  these  persons, 
 when  questioned,  say  that  they  want  the  entertainment  information  and  that  they 
 need  the  core  information. 

 5.  My  final  point  is  to  urge  FCC  to  take  heed  of  the  distinction  between 
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 needing  information  and  wanting  it.  If  FCC  is  to  bring  the  power  of  the  federal 
 government  into  play  to  require  a  change  in  broadcasting,  it  should  do  so  for 
 needed  information  rather  than  wanted  information.  Protect  lives  before 
 describing  chase  scenes;  identify  news  figures  prior  to  telling  me  which  actor 
 does  what  gesture;  give  me  program  guides  so  that  I  can  find  the  programs  at  the 
 right  times. 

 Please  consider  with  care  the  distinction  between  what  is  needed  and  what 
 is  wanted.  Please  consider  with  care  the  emotional  basis  for  much  of  what  you 
 will  be  hearing  from  commenters  who  are  not  familiar  with  the  details  of  the 
 proposal  or  with  the  possibility  of  access  to  core,  unvoiced  information. 
 And,  upon  consideration,  please  abandon  the  current  proposal  and  start 
 again  with  the  information  that  must  come  first. 

 Sincerely  yours, 

 Peggy  Pinder  Elliott 
 805  5  th  Avenue 
 Grinnell,  IA  50112-  1653 
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