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AMERICAN COUNCIL OF THE BLIND

January IO,2000
            I '

1155 15th Street, NW o Suite 1004 o Washington, DC 20005
Telephone (202) 467-5081 o Fax (202) 467-5085 o www.acb.org

            Crawford
       xecutive Director

Ms. Magalii Roman
Office of the S&reta~~~~J `;
Federal Communications Commission
445 Twelfth Street, S.W., TW-A325
Washington, D.C. 20554

Referencing: MM Docket No. 99-339 (Implementation of Video Description of Video
Programming.-- NOTICE OF PROPOSED RULEMAKING.)

   The American Council of the Blind (ACB) extends our deep appreciation and
congratulations to the Federal Communications Commission for your enlightened and
progressive notice of proposed rulemaking issued on November 18, 1999 in the matter of
video description.  In view of the major beneficial impact upon our national blindness
community of the promulgation of a video description rule, it is imperative that the
American Council of the Blind offer our expertise and assistance to the FCC in the form of
the following commentary.

Introduction 1.1.3

"Video description is typically provided through the use of the Secondary Audio
Programming channel so that it is audible only to those who wish to hear the narration.
The narration generally describes settings and actions that are not otherwise reflected in
the dialogue, such as the movement of a person in the scene. In this Notice of Proposed
Rulemaking, we propose to adopt limited requirements to ensure that video description is
more available so that all Americans can enjoy the benefits of television. We expect to
expand these requirements once we have gained greater experience with video
description."

   ACB supports the approach taken with emphasis on the expansion of video
described programming as soon as possible.

Introduction I 4.11

"In addition, the President's Advisory Committee on the Public Interest Obligations of
Digital Television Broadcasters has encouraged digital broadcasters to provide video
description."

   ACB recommends that video description become a base feature of digital
programming and that this objective be addressed in the proposed regulation sufficiently

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enough so as to secure video description as a baseline service within the digital
environment as it becomes the successor to analog.

Background II 9

"Technology. Video description can be either "open" or "closed." Open description is
provided as part of the main soundtrack of a program. As a result, no special equipment
is needed for a broadcaster or multichannel video programming distributor (MVPD) to
transmit the descriptions or for the viewer to receive them. The descriptions cannot,
however, be turned off."

  ACB supports the exploration of the delivery of video description through
alternatives to the secondary audio programming channel when the alternatives provide
the same availability and effective description service. The utilization of Radio Reading
Services to simulcast the audio and description track might be such an alternative. Other
evolving technologies such as web television or internet audio streaming when the
convergence of television and internet technology occurs; could also become a legitimate
alternative. These and other creative approaches would have to both be available to the
same audience with the same ease of use and effectiveness before they could replace the
use of the SAP channel.

Background II 10

"Closed description is provided on the Secondary Audio Programming, or SAP, channel.
The SAP channel allows for an additional audio soundtrack for a program, independent of
or separate from the monaural and stereophonic soundtracks. A secondary carrier, or
subcarrier, transmits the SAP channel audio soundtrack through a modulator. When the
SAP channel is used, a programming distributor transmits two separate audio tracks. The
second audio track is transmitted with the main program signal. For example, the SAP
channel as currently used by PBS for its video description is transmitted with the main
program signal from the network's master control facility and satellite distribution system
to the local station's broadcast facility and through the local transmitter. To accommodate
the additional soundtrack, changes may need to be made to some network and local
stations' plant wiring and equipment. At the local transmitter, the broadcast station or cable
operator must have the technical facilities to pass through the subcarrier signal to include
the SAP channel information."

   ACB recognizes that some adjustments will most likely need to be done, however,
we strongly encourage the reader of the foregoing language to not lose sight of the forest
for the technology trees. In short, the changes that will need to happen when they will be
in fact needed, are sufficiently small, inexpensive, and easily done to render them not a
major consideration.

Proposals and requests for comment III 20

"In this section, we outline a particular proposal of the kind that we envision for the initial
implementation of these rules. The proposal would require broadcasters affiliated with