gee, I found a lot of truth in this message and now, you have to delete it
again.
On Sat, 22 Apr 2000, Christopher J Chaltain wrote:
_This is a multipart message in MIME format.
_--=_alternative 007B221A862568C9_=
_Content-Type: text/plain; charset="us-ascii"
_
_To the moderators of this list,
_
_Isn't this a moderated mailing list? If so, I would think the following
_note wouldn't have been distributed to the list. It doesn't add anything
_to the merits or short comings of descriptive video. On the contrary, it
_serves no purpose but to stifle debate on this issue and promote
_hostility. I'd like the moderator(s) of this list to keep this Spam from
_my incoming mail. I enjoy the information and announcements I receive
_from this list, but I don't have the time or energy to deal with this kind
_of politics and hypocrisy.
_
_Christopher
_
_Christopher J Chaltain
[log in to unmask]
_----- Forwarded by Christopher Chaltain/Austin/IBM on 04/22/00 04:00 PM
_-----
_
_Bill Gallik <[log in to unmask]>
_Sent by: "VICUG-L: Visually Impaired Computer Users' Group List"
_<[log in to unmask]>
_04/21/00 11:52 AM
_Please respond to Bill Gallik
_
_ To: [log in to unmask]
_ cc:
_ Subject: Re: edu: NFB Comments to FCC on Video Description
_
_
_If any of you in this list server group are members of NFB would please
_tell your brass hats to stop pretending that they represent the
_majority
_of blind people. I myself experimented with NFB and I found the
_organization obnoxious and
_very intolerant of opposing opinions. If they (the NFB) are so
_presumptuous to
_speak for myself or my friends they will find themselves in
_court with a lawsuit.
_
_They are quite welcome to their own opinion, but they should proclaim it
_as their own opinion and not
_be so presumptuous as to speak for the majority of blind persons.
_
_
_
_William Gallik
[log in to unmask]
_
_And let me warn NFB members right now that if I start getting "hate
_mail" from any
_of them I do have the means to retaliate.
_
_Bill Gallik
[log in to unmask]
_
_----- Original Message -----
_From: "Kelly Pierce" <[log in to unmask]>
_To: <[log in to unmask]>
_Sent: Monday, April 17, 2000 7:37 PM
_Subject: edu: NFB Comments to FCC on Video Description
_
_
_: Below are comments filed with the Federal communications commission by
_the
_: National Federation of the Blind opposing a proposed rule that would
_: require the major broadcast networks such as ABC, FOX, CBS, NBC, PBS,
_UPN,
_: and the WB Network to air about four hours a week of programming that
_is
_: audio described.
_:
_: kelly
_:
_:
_:
_: February 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 National Federation of the Blind
_: welcomes the opportunity to comment on the above- titled Notice
_: of Proposed Rulemaking (NPRM) which proposes to mandate use of
_: audio description of visual images by television networks and
_: stations using the Secondary Audio Programming (SAP) channel. The
_: National Federation of the Blind supports continued development
_: of audio description on a voluntary basis. We oppose the
_: imposition of audio description as a federal mandate.
_:
_: We recognize that the NPRM proposes only a limited mandate at the
_: outset, but the FCC's intent to "expand these requirements" is
_: very clear.
_:
_: When blind people gather and talk, the hottest topic has always
_: been access to information. These days, our talk is dominated by
_: terms such as technology, computers, names of software
_: applications, and Braille printers. Sooner or later, however,
_: someone will bring up television-- but not for the purported
_: problem the FCC proposes to fix. Rather, we decry the lack of
_: access to emergency weather and news information scrolled across
_: the bottom of the screen; the lack of access to the identities of
_: talking heads in national and local news broadcasts; the lack of
_: access to sports scores for our local team; or the lack of access
_: to printed information during commercials some of which are
_: healthrelated and display vital phone numbers. In other words, a
_: fundamental part of television is inaccessible to us, but that
_: part is not the plot of a situation comedy nor the costumes in a
_: televised drama.
_:
_: When these same blind people turn to more social topics, favorite
_: movies and beloved television series form part of our
_: conversation just as they do for sighted Americans. Some like the
_: service of "descriptive video"; some dislike it; many are frankly
_: indifferent.
_:
_: Part of the reason for this wide disparity in the reaction of
_: blind people to "descriptive video" is the makeup of the blind
_: population itself. While figures vary, most agree that there are
_: somewhere near one million legally blind persons in the United
_: States. But only about one in ten persons in this population
_: cannot see anything. The
_:
_: term "legally blind" means having 10% or less of normal vision.
_: Many in the blind population, in other words, can see some, and
_: television is one of the things persons with poor vision can see.
_: However, persons with poor vision cannot read crawlers or names
_: of talking heads or phone numbers printed or flashed on the
_: screen.
_:
_: Another reason why so many in the blind population are ambivalent
_: to "descriptive video" is more fully detailed in our specific
_: comments: the lack of standards. Many blind people don't use the
_: current service because they find it irritating, overdone, and
_: full of irrelevant information. Many of us have experimented with
_: secondary audio only to turn it off in relief and watch the
_: program with our other senses in peace. While the use of SAP is
_: obviously voluntary, this reaction raises questions, more fully
_: detailed below, as to whether that voluntary use by blind people
_: should be linked to mandatory production by networks.
_:
_: But the most important reason why mandatory "descriptive video"
_: is not supported by many blind people is the frustration of
_: having genuinely important information right there on the screen
_: to which we do not have access. We fail to comprehend why anyone
_: would either want to receive or want to require describing
_: costumes, lighting, and gestures when the real information
_: remains unavailable.
_:
_: We urge FCC to place "descriptive video" in abeyance until the
_: real access issue is solved: access to information printed or
_: flashed on our screens. The purveyors of this information come
_: from the entire universe of television: networks in news shows
_: and emergency crawler information; local stations with emergency
_: weather information, local news and sports; producers of shows at
_: all levels; and advertisers. That's a very large bite for FCC to
_: contemplate, but it's the real first bite in achieving access for
_: the blind to television's inaccessible areas. Once we have access
_: to information equal to those viewing the screen with vision and
_: once the needs of this vital access for use of SAP are
_: determined, then and only then will it be time to consider
_: whether an actor's silent progress across the screen (usually
_: obvious in the plot anyway) or the vase of flowers (which may be
_: pretty and unnecessary to the plot) need to be described and what
_: relation this entertainment material should bear to any printed
_: information such as weather announcements that may appear.
_:
_: In other words, many of us would turn on our SAP if we could get
_: the printed information; many of us would not if we can only
_: learn about costumes and facial expressions. We urge FCC to give
_: us information and to worry about entertainment at some later
_: date.
_:
_: What we truly seek is technically feasible. What we truly seek
_: will never be provided unless FCC mandates it. We therefore have
_: the following more specific comments on the NPRM:
_:
_: 1. Federal mandate lacks sufficient support among blind people.
_: The National Federation of the Blind is a membership
_: organization, and our membership is overwhelmingly composed of
_: blind and visually impaired individuals. With
_:
_: more than 50, 000 members, we are America's largest and most
_: active organization of the blind with hundreds of chapters
_: located throughout the fifty states, the District of Columbia,
_: and Puerto Rico. Our members are well aware of the fact that--
_: when done right-- audio description can add to the entertainment
_: value of certain movies and television programs. However, that
_: does not justify a federal mandate for its use.
_:
_: In July of 1996, thousands of our delegates and members gathered
_: at our annual National Convention and discussed the issue of
_: mandated audio description. As a result, our convention
_: democratically (and overwhelmingly) adopted the attached
_: resolution (9604), which expresses our Federation's opposition to
_: federally mandated audio description. We trust that the FCC will
_: give this resolution great weight in considering whether to go
_: forward with rulemaking in this area.
_:
_: As blind citizens, we in the NFB have long been concerned that
_: undue emphasis on entertainment as an issue for the blind draws
_: attention away from the real and cruel forms of economic
_: discrimination and exclusion of blind people from normal
_: integration into society. Our members understand the difference
_: between what we as blind people might enjoy versus what we really
_: need. Audio description is clearly in the former category. As for
_: our real needs, we would much prefer that the FCC work with us to
_: use the SAP channel or other means to provide us voice output of
_: print- displayed safety messages, news captions, and other
_: important information. We are concerned that mandated SAP channel
_: use for audio description could potentially interfere with these
_: far more compelling uses.
_:
_: 2. Audio description not an analogue to closed captioning. Closed
_: captioning of television dialogue is undoubtedly very important
_: for deaf people. It is, no doubt, more important for deaf
_: television viewers than audio description is for the blind. The
_: fact that countless thousands of "TV sound" receivers are sold to
_: the general population shows that television programming can
_: usually be enjoyed by the average member of the public without a
_: picture. There is, of course, no such market for video- only
_: television receivers. Yet, we note that the FCC has chosen to
_: model its proposed audio description mandates on its closed-
_: captioning rules. In our view, such an inappropriate analogy will
_: only lead the FCC down the wrong road to the imposition of
_: inappropriate rules.
_:
_: 3. No standards exist. The closed captioning model also fails
_: here because closed captioning does not present the serious
_: practical difficulties that would be presented by mandated audio
_: description. Basically, closed captioning just conveys scripted
_: dialogue. It does not require creation of a new product, as audio
_: description does. In contrast, audio description is very
_: subjective. Its creators must make countless value judgments
_: about what to describe, when to interrupt spoken dialogue or
_: musical score, etc. Yet the NPRM proposes to impose an audio
_: description mandate when no recognized standards exist for making
_: such determinations.
_:
_: Today many blind people may find some audio- described movies and
_: programs enjoyable, but some are useless or even annoying. It is,
_: of course, not satisfactory for the FCC to say that blind people
_: (the alleged intended beneficiaries of the proposed regulations)
_: are free to turn off the SAP channel if they find a poorly
_: described program annoying, when the FCC has forced programmers
_: to incur significant costs for its production. Again, we are
_: dealing here with more difficult issues than those that have
_: arisen with closed captioning. Audio description and closed
_: captioning services are not analogues and the FCC should not
_: treat them as if they were.
_:
_: 4. Safety first. To the extent that any federally mandated use of
_: the SAP channel for the blind is justified, the SAP channel
_: should be used to transmit audio warnings about hazardous weather
_: and other emergency conditions. Often such warnings are scrolled
_: across the screen for sighted folks. The SAP channel should be
_: used to transmit the same information to blind people. It would
_: indeed be ironic if the SAP channel were unavailable to warn
_: blind people about an impending emergency because it was already
_: tied up describing the set of some sitcom so that a network could
_: comply with its governmentimposed audio description mandate.
_:
_: Although paragraph 30 of the NPRM says that adoption of digital
_: technologies may eventually eliminate the problem of competing
_: SAP channel uses, that capability does not exist today, and the
_: FCC should not ignore this issue in today's television
_: environment.
_:
_: 5. The news exclusion. News coverage is television's most
_: important public service. However, the FCC's proposed audio
_: description mandate would apparently exclude "live newscasts"
_: (NPRM paragraph 18). Here we must point out that many newscasts--
_: both network and local- now print the names of speakers without
_: oral identification. Thus, a sighted person could read that the
_: speaker is "Senator Smith," but the blind person would not know
_: who is speaking. The FCC should work with us to encourage
_: networks and other news programmers to identify orally speakers
_: used on news clips. That might not even need to tie up the SAP
_: channel. But, in any case, it involves a much higher priority for
_: us than mandated audio description. Providing oral output of
_: printed material would also not raise the subjectivity and
_: standards problems inherent in producing audio description
_: programming. We urge the FCC to put its focus on our need for
_: news ahead of entertainment.
_:
_: 6. Other printed information. Many advertisements contain print-
_: displayed information such as phone numbers and addresses. Some
_: of these advertisements are carried on networks, but others are
_: local. Just behind print- displayed emergency and news
_: information, our experience is that blind people complain most
_: about not being able to get the information printed on the
_:
_: screen during advertisements. This information is sometimes
_: health- related. Sometimes it steers people to other sources of
_: information, such as government agencies. Many blind people have
_: reported calling stations only to find out that such information
_: is not retained by the stations. Without the information being
_: voiced as it is displayed in print visually, there is simply no
_: way blind people can get the data.
_:
_: 7. Focus on needed information instead of networks. As noted
_: above, the need for audio presentation of emergency, news, and
_: other print- displayed information, is as likely to involve local
_: stations as networks. Networks are the wrong target. Any proposed
_: regulation addressed to meet our needs must focus on what
_: information needs to be provided rather than on who is being
_: regulated. Such an approach would cause all programmers,
_: advertisers, and stations to think twice before presenting
_: printed information without some other method of presenting it to
_: their blind audiences.
_:
_: 8. Needs of Spanish- speaking blind people. Paragraph 30 of the
_: NPRM notes that mandated SAP channel use for audio description
_: would put blind users in competition with Spanish- speaking
_: users. We would note that blind people constitute a cross-
_: section of the society. Some Spanish- speaking Americans are also
_: blind. We have no doubt that the vast majority of Spanish-
_: speaking blind people would much prefer to have the SAP channel
_: used to translate Englishlanguage dialogue into Spanish rather
_: than to have it used for English- language description of sets,
_: costumes, and the like.
_:
_: 9. Conclusion. We strongly recommend that the FCC refocus any
_: proposed regulation to address first how the SAP channel and
_: other means should be used to meet the need to provide voice
_: output of emergency, news, and other print- displayed
_: information. Only when these fundamental issues are resolved
_: should the FCC turn to the secondary entertainment issues
_: involving audio description. First things first. In addition, any
_: such regulation should cover all programmers, not just a few
_: network producers.
_:
_: Respectfully submitted, James Gashel
_:
_: Director of Governmental Affairs NATIONAL FEDERATION OF THE BLIND
_:
_:
_: NATIONAL FEDERATION OF THE BLIND
_:
_: RESOLUTION 96- 04 WHEREAS, presentation of information by audio-
_: visual means is now a vital part of modern life; and
_:
_: WHEREAS, audio description of visual images is a service that
_: adds oral description of visual images to television and movie
_: programs; and
_:
_: WHEREAS, audio description of visual images can be quite useful
_: by adding to the entertainment value of the presentation for
_: blind viewers; and
_:
_: WHEREAS, the Federal Communications Commission is considering the
_: extent to which audio description should be required in
_: television programming; and
_:
_: WHEREAS, although audio description may at times make the
_: presentation more enjoyable, this fact alone does not necessarily
_: justify a requirement by the federal government that virtually
_: all audio/ visual programming must contain audio descriptions of
_: visual images; and
_:
_: WHEREAS, a requirement by the federal government for audio
_: description in virtually all television programming would place
_: an undue emphasis on entertainment as an issue for the blind and
_: tend to draw public attention away from the real and cruel forms
_: of economic discrimination and exclusion of blind people from
_: normal integration into society which exist: Now, therefore,
_:
_: BE IT RESOLVED by the National Federation of the Blind in
_: convention assembled this fifth day of July, 1996, in the City of
_: Anaheim, California, that this organization support voluntary use
_: of audio description in television programming but oppose the
_: imposition of audio description as a federal mandate; and
_:
_: BE IT FURTHER RESOLVED that, to the extent that a mandate is
_: justified, we urge the Federal Communications Commission to
_: require both audio and visual presentation of essential
_: information for the public such as warnings of hazardous weather
_: or other emergency conditions.
_:
_:
_: VICUG-L is the Visually Impaired Computer User Group List.
_: To join or leave the list, send a message to
_: [log in to unmask] In the body of the message, simply
_type
_: "subscribe vicug-l" or "unsubscribe vicug-l" without the quotations.
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_:
_
_
_VICUG-L is the Visually Impaired Computer User Group List.
_To join or leave the list, send a message to
[log in to unmask] In the body of the message, simply type
_"subscribe vicug-l" or "unsubscribe vicug-l" without the quotations.
_VICUG-L is archived on the World Wide Web at
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_
_
_
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_
_
_<br><font size=2 face="sans-serif">To the moderators of this list,</font><font size=3 face="Times New Roman"> <br>
_</font><font size=2 face="sans-serif"><br>
_Isn't this a moderated mailing list? If so, I would think the following note wouldn't have been distributed to the list. It doesn't add anything to the merits or short comings of descriptive video. On the contrary, it serves no purpose but to stifle debate on this issue and promote hostility. I'd like the moderator(s) of this list to keep this Spam from my incoming mail. I enjoy the information and announcements I receive from this list, but I don't have the time or energy to deal with this kind of politics and hypocrisy.<br>
_<br>
_Christopher<br>
_<br>
_Christopher J Chaltain<br>
[log in to unmask]</font><font size=3 face="Times New Roman"> </font><font size=1 color=#800080 face="sans-serif"><br>
_----- Forwarded by Christopher Chaltain/Austin/IBM on 04/22/00 04:00 PM -----</font><font size=3 face="Times New Roman"> </font>
_<table width=100%>
_<tr valign=top>
_<td width=0%>
_<td width=60%><font size=1 face="sans-serif"><b>Bill Gallik <[log in to unmask]></b></font><font size=3 face="Times New Roman"> </font><font size=1 face="sans-serif"><br>
_Sent by: "VICUG-L: Visually Impaired Computer Users' Group List" <[log in to unmask]></font><font size=3 face="Times New Roman"> </font>
_<p><font size=1 face="sans-serif">04/21/00 11:52 AM</font><font size=3 face="Times New Roman"> </font><font size=1 face="sans-serif"><br>
_Please respond to Bill Gallik</font><font size=3 face="Times New Roman"> </font>
_<td width=39%><font size=1 face="Arial"> </font><font size=1 face="sans-serif"><br>
_ To: [log in to unmask]</font><font size=3 face="Times New Roman"> </font><font size=1 face="sans-serif"><br>
_ cc: </font><font size=3 face="Times New Roman"> </font><font size=1 face="sans-serif"><br>
_ Subject: Re: edu: NFB Comments to FCC on Video Description</font></table>
_<br><font size=3 face="Times New Roman"><br>
_</font><font size=2 face="Courier New"><br>
_If any of you in this list server group are members of NFB would please<br>
_tell your brass hats to stop pretending that they represent the<br>
_majority<br>
_of blind people. I myself experimented with NFB and I found the<br>
_organization obnoxious and<br>
_very intolerant of opposing opinions. If they (the NFB) are so<br>
_presumptuous to<br>
_speak for myself or my friends they will find themselves in<br>
_court with a lawsuit.<br>
_<br>
_They are quite welcome to their own opinion, but they should proclaim it<br>
_as their own opinion and not<br>
_be so presumptuous as to speak for the majority of blind persons.<br>
_<br>
_<br>
_<br>
_William Gallik<br>
[log in to unmask]<br>
_<br>
_And let me warn NFB members right now that if I start getting "hate<br>
_mail" from any<br>
_of them I do have the means to retaliate.<br>
_<br>
_Bill Gallik<br>
[log in to unmask]<br>
_<br>
_----- Original Message -----<br>
_From: "Kelly Pierce" <[log in to unmask]><br>
_To: <[log in to unmask]><br>
_Sent: Monday, April 17, 2000 7:37 PM<br>
_Subject: edu: NFB Comments to FCC on Video Description<br>
_<br>
_<br>
_: Below are comments filed with the Federal communications commission by<br>
_the<br>
_: National Federation of the Blind opposing a proposed rule that would<br>
_: require the major broadcast networks such as ABC, FOX, CBS, NBC, PBS,<br>
_UPN,<br>
_: and the WB Network to air about four hours a week of programming that<br>
_is<br>
_: audio described.<br>
_:<br>
_: kelly<br>
_:<br>
_:<br>
_:<br>
_: February 23, 2000 Magalie Roman Salas Office of the Secretary<br>
_: Federal Communications Commission 445 Twelfth Street, S. W., TW-<br>
_: A325 Washington, D. C. 20554<br>
_:<br>
_: Dear Ms. Salas: RE: COMMENTS ON NOTICE OF PROPOSED RULEMAKING IN<br>
_: THE MATTER OF VIDEO DESCRIPTION OF VIDEO PROGRAMMING<br>
_:<br>
_: MM Docket No. 99- 339 The National Federation of the Blind<br>
_: welcomes the opportunity to comment on the above- titled Notice<br>
_: of Proposed Rulemaking (NPRM) which proposes to mandate use of<br>
_: audio description of visual images by television networks and<br>
_: stations using the Secondary Audio Programming (SAP) channel. The<br>
_: National Federation of the Blind supports continued development<br>
_: of audio description on a voluntary basis. We oppose the<br>
_: imposition of audio description as a federal mandate.<br>
_:<br>
_: We recognize that the NPRM proposes only a limited mandate at the<br>
_: outset, but the FCC's intent to "expand these requirements" is<br>
_: very clear.<br>
_:<br>
_: When blind people gather and talk, the hottest topic has always<br>
_: been access to information. These days, our talk is dominated by<br>
_: terms such as technology, computers, names of software<br>
_: applications, and Braille printers. Sooner or later, however,<br>
_: someone will bring up television-- but not for the purported<br>
_: problem the FCC proposes to fix. Rather, we decry the lack of<br>
_: access to emergency weather and news information scrolled across<br>
_: the bottom of the screen; the lack of access to the identities of<br>
_: talking heads in national and local news broadcasts; the lack of<br>
_: access to sports scores for our local team; or the lack of access<br>
_: to printed information during commercials some of which are<br>
_: healthrelated and display vital phone numbers. In other words, a<br>
_: fundamental part of television is inaccessible to us, but that<br>
_: part is not the plot of a situation comedy nor the costumes in a<br>
_: televised drama.<br>
_:<br>
_: When these same blind people turn to more social topics, favorite<br>
_: movies and beloved television series form part of our<br>
_: conversation just as they do for sighted Americans. Some like the<br>
_: service of "descriptive video"; some dislike it; many are frankly<br>
_: indifferent.<br>
_:<br>
_: Part of the reason for this wide disparity in the reaction of<br>
_: blind people to "descriptive video" is the makeup of the blind<br>
_: population itself. While figures vary, most agree that there are<br>
_: somewhere near one million legally blind persons in the United<br>
_: States. But only about one in ten persons in this population<br>
_: cannot see anything. The<br>
_:<br>
_: term "legally blind" means having 10% or less of normal vision.<br>
_: Many in the blind population, in other words, can see some, and<br>
_: television is one of the things persons with poor vision can see.<br>
_: However, persons with poor vision cannot read crawlers or names</font>
_<br><font size=2 face="Courier New">: of talking heads or phone numbers printed or flashed on the<br>
_: screen.<br>
_:<br>
_: Another reason why so many in the blind population are ambivalent<br>
_: to "descriptive video" is more fully detailed in our specific<br>
_: comments: the lack of standards. Many blind people don't use the<br>
_: current service because they find it irritating, overdone, and<br>
_: full of irrelevant information. Many of us have experimented with<br>
_: secondary audio only to turn it off in relief and watch the<br>
_: program with our other senses in peace. While the use of SAP is<br>
_: obviously voluntary, this reaction raises questions, more fully<br>
_: detailed below, as to whether that voluntary use by blind people<br>
_: should be linked to mandatory production by networks.<br>
_:<br>
_: But the most important reason why mandatory "descriptive video"<br>
_: is not supported by many blind people is the frustration of<br>
_: having genuinely important information right there on the screen<br>
_: to which we do not have access. We fail to comprehend why anyone<br>
_: would either want to receive or want to require describing<br>
_: costumes, lighting, and gestures when the real information<br>
_: remains unavailable.<br>
_:<br>
_: We urge FCC to place "descriptive video" in abeyance until the<br>
_: real access issue is solved: access to information printed or<br>
_: flashed on our screens. The purveyors of this information come<br>
_: from the entire universe of television: networks in news shows<br>
_: and emergency crawler information; local stations with emergency<br>
_: weather information, local news and sports; producers of shows at<br>
_: all levels; and advertisers. That's a very large bite for FCC to<br>
_: contemplate, but it's the real first bite in achieving access for<br>
_: the blind to television's inaccessible areas. Once we have access<br>
_: to information equal to those viewing the screen with vision and<br>
_: once the needs of this vital access for use of SAP are<br>
_: determined, then and only then will it be time to consider<br>
_: whether an actor's silent progress across the screen (usually<br>
_: obvious in the plot anyway) or the vase of flowers (which may be<br>
_: pretty and unnecessary to the plot) need to be described and what<br>
_: relation this entertainment material should bear to any printed<br>
_: information such as weather announcements that may appear.<br>
_:<br>
_: In other words, many of us would turn on our SAP if we could get<br>
_: the printed information; many of us would not if we can only<br>
_: learn about costumes and facial expressions. We urge FCC to give<br>
_: us information and to worry about entertainment at some later<br>
_: date.<br>
_:<br>
_: What we truly seek is technically feasible. What we truly seek<br>
_: will never be provided unless FCC mandates it. We therefore have<br>
_: the following more specific comments on the NPRM:<br>
_:<br>
_: 1. Federal mandate lacks sufficient support among blind people.<br>
_: The National Federation of the Blind is a membership<br>
_: organization, and our membership is overwhelmingly composed of<br>
_: blind and visually impaired individuals. With<br>
_:<br>
_: more than 50, 000 members, we are America's largest and most<br>
_: active organization of the blind with hundreds of chapters<br>
_: located throughout the fifty states, the District of Columbia,<br>
_: and Puerto Rico. Our members are well aware of the fact that--<br>
_: when done right-- audio description can add to the entertainment<br>
_: value of certain movies and television programs. However, that<br>
_: does not justify a federal mandate for its use.<br>
_:<br>
_: In July of 1996, thousands of our delegates and members gathered<br>
_: at our annual National Convention and discussed the issue of<br>
_: mandated audio description. As a result, our convention<br>
_: democratically (and overwhelmingly) adopted the attached<br>
_: resolution (9604), which expresses our Federation's opposition to<br>
_: federally mandated audio description. We trust that the FCC will<br>
_: give this resolution great weight in considering whether to go<br>
_: forward with rulemaking in this area.<br>
_:<br>
_: As blind citizens, we in the NFB have long been concerned that<br>
_: undue emphasis on entertainment as an issue for the blind draws<br>
_: attention away from the real and cruel forms of economic<br>
_: discrimination and exclusion of blind people from normal<br>
_: integration into society. Our members understand the difference<br>
_: between what we as blind people might enjoy versus what we really<br>
_: need. Audio description is clearly in the former category. As for<br>
_: our real needs, we would much prefer that the FCC work with us to<br>
_: use the SAP channel or other means to provide us voice output of<br>
_: print- displayed safety messages, news captions, and other<br>
_: important information. We are concerned that mandated SAP channel<br>
_: use for audio description could potentially interfere with these<br>
_: far more compelling uses.<br>
_:<br>
_: 2. Audio description not an analogue to closed captioning. Closed<br>
_: captioning of television dialogue is undoubtedly very important<br>
_: for deaf people. It is, no doubt, more important for deaf<br>
_: television viewers than audio description is for the blind. The<br>
_: fact that countless thousands of "TV sound" receivers are sold to<br>
_: the general population shows that television programming can<br>
_: usually be enjoyed by the average member of the public without a<br>
_: picture. There is, of course, no such market for video- only<br>
_: television receivers. Yet, we note that the FCC has chosen to<br>
_: model its proposed audio description mandates on its closed-<br>
_: captioning rules. In our view, such an inappropriate analogy will<br>
_: only lead the FCC down the wrong road to the imposition of<br>
_: inappropriate rules.<br>
_:<br>
_: 3. No standards exist. The closed captioning model also fails<br>
_: here because closed captioning does not present the serious<br>
_: practical difficulties that would be presented by mandated audio<br>
_: description. Basically, closed captioning just conveys scripted<br>
_: dialogue. It does not require creation of a new product, as audio<br>
_: description does. In contrast, audio description is very<br>
_: subjective. Its creators must make countless value judgments</font><font size=3 face="Times New Roman"> </font><font size=2 face="Courier New"><br>
_: about what to describe, when to interrupt spoken dialogue or<br>
_: musical score, etc. Yet the NPRM proposes to impose an audio<br>
_: description mandate when no recognized standards exist for making<br>
_: such determinations.<br>
_:<br>
_: Today many blind people may find some audio- described movies and<br>
_: programs enjoyable, but some are useless or even annoying. It is,<br>
_: of course, not satisfactory for the FCC to say that blind people<br>
_: (the alleged intended beneficiaries of the proposed regulations)<br>
_: are free to turn off the SAP channel if they find a poorly<br>
_: described program annoying, when the FCC has forced programmers<br>
_: to incur significant costs for its production. Again, we are<br>
_: dealing here with more difficult issues than those that have<br>
_: arisen with closed captioning. Audio description and closed<br>
_: captioning services are not analogues and the FCC should not<br>
_: treat them as if they were.<br>
_:</font>
_<br><font size=2 face="Courier New">: 4. Safety first. To the extent that any federally mandated use of<br>
_: the SAP channel for the blind is justified, the SAP channel<br>
_: should be used to transmit audio warnings about hazardous weather<br>
_: and other emergency conditions. Often such warnings are scrolled<br>
_: across the screen for sighted folks. The SAP channel should be<br>
_: used to transmit the same information to blind people. It would<br>
_: indeed be ironic if the SAP channel were unavailable to warn<br>
_: blind people about an impending emergency because it was already<br>
_: tied up describing the set of some sitcom so that a network could<br>
_: comply with its governmentimposed audio description mandate.<br>
_:<br>
_: Although paragraph 30 of the NPRM says that adoption of digital<br>
_: technologies may eventually eliminate the problem of competing<br>
_: SAP channel uses, that capability does not exist today, and the<br>
_: FCC should not ignore this issue in today's television<br>
_: environment.<br>
_:<br>
_: 5. The news exclusion. News coverage is television's most<br>
_: important public service. However, the FCC's proposed audio<br>
_: description mandate would apparently exclude "live newscasts"<br>
_: (NPRM paragraph 18). Here we must point out that many newscasts--<br>
_: both network and local- now print the names of speakers without<br>
_: oral identification. Thus, a sighted person could read that the<br>
_: speaker is "Senator Smith," but the blind person would not know<br>
_: who is speaking. The FCC should work with us to encourage<br>
_: networks and other news programmers to identify orally speakers<br>
_: used on news clips. That might not even need to tie up the SAP<br>
_: channel. But, in any case, it involves a much higher priority for<br>
_: us than mandated audio description. Providing oral output of<br>
_: printed material would also not raise the subjectivity and<br>
_: standards problems inherent in producing audio description<br>
_: programming. We urge the FCC to put its focus on our need for<br>
_: news ahead of entertainment.<br>
_:<br>
_: 6. Other printed information. Many advertisements contain print-<br>
_: displayed information such as phone numbers and addresses. Some<br>
_: of these advertisements are carried on networks, but others are<br>
_: local. Just behind print- displayed emergency and news<br>
_: information, our experience is that blind people complain most<br>
_: about not being able to get the information printed on the<br>
_:<br>
_: screen during advertisements. This information is sometimes<br>
_: health- related. Sometimes it steers people to other sources of<br>
_: information, such as government agencies. Many blind people have<br>
_: reported calling stations only to find out that such information<br>
_: is not retained by the stations. Without the information being<br>
_: voiced as it is displayed in print visually, there is simply no<br>
_: way blind people can get the data.<br>
_:<br>
_: 7. Focus on needed information instead of networks. As noted<br>
_: above, the need for audio presentation of emergency, news, and<br>
_: other print- displayed information, is as likely to involve local<br>
_: stations as networks. Networks are the wrong target. Any proposed<br>
_: regulation addressed to meet our needs must focus on what<br>
_: information needs to be provided rather than on who is being<br>
_: regulated. Such an approach would cause all programmers,<br>
_: advertisers, and stations to think twice before presenting<br>
_: printed information without some other method of presenting it to<br>
_: their blind audiences.<br>
_:<br>
_: 8. Needs of Spanish- speaking blind people. Paragraph 30 of the<br>
_: NPRM notes that mandated SAP channel use for audio description<br>
_: would put blind users in competition with Spanish- speaking<br>
_: users. We would note that blind people constitute a cross-<br>
_: section of the society. Some Spanish- speaking Americans are also<br>
_: blind. We have no doubt that the vast majority of Spanish-<br>
_: speaking blind people would much prefer to have the SAP channel<br>
_: used to translate Englishlanguage dialogue into Spanish rather<br>
_: than to have it used for English- language description of sets,<br>
_: costumes, and the like.<br>
_:<br>
_: 9. Conclusion. We strongly recommend that the FCC refocus any<br>
_: proposed regulation to address first how the SAP channel and<br>
_: other means should be used to meet the need to provide voice<br>
_: output of emergency, news, and other print- displayed<br>
_: information. Only when these fundamental issues are resolved<br>
_: should the FCC turn to the secondary entertainment issues<br>
_: involving audio description. First things first. In addition, any<br>
_: such regulation should cover all programmers, not just a few<br>
_: network producers.<br>
_:<br>
_: Respectfully submitted, James Gashel<br>
_:<br>
_: Director of Governmental Affairs NATIONAL FEDERATION OF THE BLIND<br>
_:<br>
_:<br>
_: NATIONAL FEDERATION OF THE BLIND<br>
_:<br>
_: RESOLUTION 96- 04 WHEREAS, presentation of information by audio-<br>
_: visual means is now a vital part of modern life; and<br>
_:<br>
_: WHEREAS, audio description of visual images is a service that<br>
_: adds oral description of visual images to television and movie<br>
_: programs; and<br>
_:<br>
_: WHEREAS, audio description of visual images can be quite useful<br>
_: by adding to the entertainment value of the presentation for<br>
_: blind viewers; and<br>
_:<br>
_: WHEREAS, the Federal Communications Commission is considering the<br>
_: extent to which audio description should be required in<br>
_: television programming; and<br>
_:<br>
_: WHEREAS, although audio description may at times make the<br>
_: presentation more enjoyable, this fact alone does not necessarily<br>
_: justify a requirement by the federal government that virtually<br>
_: all audio/ visual programming must contain audio descriptions of<br>
_: visual images; and<br>
_:<br>
_: WHEREAS, a requirement by the federal government for audio<br>
_: description in virtually all television programming would place<br>
_: an undue emphasis on entertainment as an issue for the blind and<br>
_: tend to draw public attention away from the real and cruel forms<br>
_: of economic discrimination and exclusion of blind people from<br>
_: normal integration into society which exist: Now, therefore,<br>
_:<br>
_: BE IT RESOLVED by the National Federation of the Blind in<br>
_: convention assembled this fifth day of July, 1996, in the City of<br>
_: Anaheim, California, that this organization support voluntary use<br>
_: of audio description in television programming but oppose the<br>
_: imposition of audio description as a federal mandate; and<br>
_:<br>
_: BE IT FURTHER RESOLVED that, to the extent that a mandate is<br>
_: justified, we urge the Federal Communications Commission to<br>
_: require both audio and visual presentation of essential<br>
_: information for the public such as warnings of hazardous weather<br>
_: or other emergency conditions.</font>
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