NFB is less concerned about video description of entertainment programming than it is of more important information that appears textually on the screen, such as critical weather updates. Significantly, NFB questioned the Commission s comparison of video description to closed captioning requirements, stating that such an inappropriate analogy will only lead the FCC down the wrong road to the imposition of inappropriate rules. NFB observed that the proposed separate audio obligation is not comparable to closed captioning because video description is less central to enjoyment of television and because it would entail serious practical difficulties arising from the need to create new product involving countless value judgments about what to describe, whether and how to interrupt the existing audio track, etc. There are compelling reasons to accord great weight to NFB s views in this proceeding. More importantly, NFB has devoted significant attention to the issue of video description.
Audio description is clearly in the former category.
The comments reflect that the FCC has paid insufficient attention to the costs that would be imposed by mandatory video description will impose. The comments are supported by the FCC s video description report, which noted that the costs of providing video 61 Id. at 2- 3. NFB is active throughout the 50 states and Puerto Rico, with over 700 local chapters. 81 NFB at 3. 101 See infra note 13 and accompanying text.