Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 In the Matter of ) ) MM Docket No. 99-339 ) ) Implementation of ) Video Description of ) Video programming ) February 23, 2000 To: The Commission COMMENT OF THE METROPOLITAN WASHINGTON EAR AND MARGARET R. PFANSTIEHL, ED.D. Founder and President I am the founder and president of The Metropolitan Washington Ear in Silver Spring, Maryland. We operate a radio reading service and a dial-in newspaper and magazine service available throughout Maryland, Virginia, and the District of Columbia, plus an Audio Description Service available in major live theaters in the Washington D.C. area. All these services are free for blind and low vision people. The Audio Description Service is the first description service of any kind anywhere in the world to be formally established and regularly scheduled. Therefore, the day that the Federal Communications Commission announced its Notice of Proposed Rule Making concerning video description was truly a red letter day for me and my husband, Cody Pfanstiehl, who has worked with me in establishing the2 audio description movement here in this country and later transplanted to England, Scotland, Wales, Australia, France, and Spain. It all began with a telephone call in early spring, 1981 from Wayne White of Arena Stage, a repertory theater in Washington D.C. Arena Stage, in its desire to make performances accessible to all types of handicapped people, wondered if its newly acquired short range FM radio receivers used for the hard of hearing could also be useful to help low vision and blind people. They felt they did not have the staff or expertise to develop this type of program so they contacted me to see if I would be interested. I was. Arena Stage wanted a demonstration of "Audio Description", the name we chose for the service, before committing the theater to regularly scheduled described performances. It was obvious from the outset that verbal descriptions of essential visual elements could only be inserted during natural pauses in the dialogue. Because of this critical timing for the delivery of descriptions, it was also apparent that for live performances, the descriptions would have to be spoken by describers present on the scene rather than by prerecorded tapes. Prerecorded program notes, however, were practical. I looked over the roster of volunteers working with The Metropolitan Washington Ear for someone who could do a superb job, realizing that if the demonstration was not outstanding, the project would probably not move forward. I settled upon Cody Pfanstiehl, then the Director of Public Affairs for the Washington area Metro system. At that time, I knew him only slightly, but I strongly believed that he had the necessary "gift of gab" I was looking for.3 As expected, Cody did a wonderful job. Arena Stage was prepared to begin providing audio description the following fall. Thus the first regularly scheduled audio description service anywhere began in October, 1981 with a performance of G.B. Shaw's "Major Barbara". Cody and I worked together to devise methods to recruit and train volunteer describers. By spring of 1982, The Kennedy Center also wished to provide described performances. During the next few years, most of the major theaters in Washington D.C. and nearby Maryland requested volunteer describers from The Metropolitan Washington Ear. On January 1, 1983, Cody and I were married. This made Cody the “ultimate volunteer”. In the winter of 1982, we met with the president of PBS to discuss methods of providing descriptions for some of their programs such as The American Playhouse series and Nova. This was before SAP channels were available on TV sets. There was no practical method of delivering descriptions directly into people's homes via their television sets. However, it was considered important to be forward looking and develop and refine descriptive techniques. We produced descriptions for both The American Playhouse and Nova series, recording them in our Silver Spring, Maryland studios. Then, PBS synchronized our recordings onto their master video tape making it possible for blind and low vision people, in 18 cities, to receive the descriptions through their radio reading receivers while simultaneously tuning in the same program on their TV set. For the first time in history, blind and low vision people could sit down with sighted family members and friends and4 equally share in enjoying television without the necessity of a sighted person attempting to describe the visual elements on the screen. This method was very cumbersome and complicated, requiring an additional technical procedure at the network level which is unnecessary today when described programs can be accessed through the television set. When description becomes available ton many channels and on cable it will not be possible to use radio reading service receivers because they cannot switch from one channel to another; they are preset for one channel only. After the grant money ran out and synchronization was no longer possible, we fell back to airing the combination of the sound track plus the descriptions on a different night of the week over radio reading services. It became a glorified radio program. This was adequate for totally blind people living alone, but partially sighted people, or totally blind people wishing to view TV programs with sighted companions wanted descriptions to come from their TV sets. During the mid 1980's, the SAP channel began appearing on television sets. It was then that Barry Cronin, then with WGBH, the public television station in Boston, contacted us. They were interested in using the newly available SAP channel for descriptions for low vision and blind people. They learned of our work and asked us to join them in their endeavor. We had developed the art of description and had contacts with the blind and low vision community. They had the technology, organization, and funds to make it happen. In many respects it was a marriage made in heaven. At first, we helped WGBH with tests on the purely local level in the Boston area. Then, during the 1987-1988 season, The Metropolitan Washington Ear produced all the5 descriptions of the weekly American Playhouse series for WGBH. Everything was highly successful so WGBH began fund raising to begin a service which became the Descriptive Video Service (DVS). In December, 1989 in Boston, Cody and I trained the first group of describers for WGBH. The DVS service went on the air in January, 1990. Later that year, we trained a second group. At the time, we expected the growth of described programs would be somewhat comparable to the growth of closed captioning when it was becoming established. This never happened. Still, it was a tribute to the entire group that had been working on descriptive video, that I was awarded an Emmy in 1990 for leadership and persistence in the development and implementation of television for the visually impaired. While I was, and am, proud of that award, descriptive video remained a promise rather than a reality because it had yet to reach all but a tiny fraction of the blind and visually impaired. In the fall of 1995, we met with representatives of 5 of the major Hollywood studios. But we soon realized the extent of the industry's resolve not to extend their audience to the blind and low vision community as they were already doing with captioning for the deaf and hearing impaired community. We knew that without a mandate, there would be no progress from the motion picture industry or the broadcast industry. It was then that my husband and I began to contact various national organizations concerned with low vision, blindness and aging, inviting them to unite in a coalition to promote increased access to television and videos. Many more could be added to the coalition, but we needed only a cross section selection.6 In February 1997, the Coalition filed a report with the FCC outlining the state of video description and the needs and wishes of the low vision and blind community. The National Television and Video Access Coalition is also filing comments for the November 1999 NPRM. Meanwhile, the concept of descriptions for low vision and blind people was spreading throughout the theater and museum worlds. Cody and I received requests to train describers throughout the United States and as far as Australia. In 1985, we planted the seed of Audio Description in the UK where it flowered. The UK begins its mandatory described television service this spring. Museums such as The Statue of Liberty, Ellis Island, Wintertur, The Mashantucket Pequot Indian Museum, and The National Air and Space Museum, among many others, wanted to become accessible to blind and low vision people. We prepared descriptions for the first IMAX film "To Fly", recording the descriptions in the IMAX theater at The National Air and Space Museum while viewing the film. Subsequently, we have produced descriptions for many Park Service videos in various venues across the country. In training theater describers, it is our policy to prepare at least one or two of the trainees to train future describers. These second generation describers train others in Johnny Appleseed fashion to ever larger parts of the country. Audio Description in some form is now available in at least 25 states. I am aware of the need and power of descriptions on two levels. I have retinitus pigmentosa -- RP --, a gradually deteriorating eye disease which has taken me from the ability to read ordinary print ending in 1962 to my present condition, some residual7 vision remaining, but total dependence upon Braille or recorded information. In my younger years, I was able to visually track much of the action on a TV or movie theater screen, and could follow stage performances if I were seated in the first few rows. But as my vision lessened, I became increasingly frustrated with the lack of visual information available to me while watching TV or attending the theater. Also in the '60's, I was a Braille Resource teacher in a public school in Prince George's County, Maryland. I worked with blind children who were placed in classrooms with fully sighted classmates. Academically, they did very well but there were many gaps in their understanding of the visual world they lived in. So many things which people with normal vision see every day are so much taken for granted that they are never fully described to a blind person. But when plays, movies, films and/or museum exhibits are professionally described; a wealth of information becomes available. Blind children and adults are amazed at the prevalence and importance of body language in transmitting non-verbal messages. Descriptions of objects and settings also impart knowledge too often inaccessible. We forget how much we learn through simple observation. When this avenue is severely reduced or entirely cut off, misconceptions and misunderstandings are not uncommon. My husband and I once took a popular blind radio personality, an expert on the big band era, to a described performance of Forty Second Street. He was amazed to learn about all the visual actions taking place during the rendition of a song. He had imagined8 that people on the stage simply stood in place while they sang. Another very well educated person, a woman, was amazed to learn that stages often had many levels. As one blind friend succinctly put it to me, "If something isn't verbalized, it doesn't exist for me." Descriptions on television programs can help to level the playing field. Partially sighted or blind people who have had vision in the past want to hear as many details in the description as possible since they know what they are missing a great deal. However, many congenitally blind people at first actually believe they can totally imagine what is happening on the screen or the stage by merely listening to the dialogue. However, after they experience well crafted descriptions, a great many realize what they were lacking and no longer wish to attend performances or view television programs without descriptions. But there will always be a tiny minority of congenitally blind people who prefer to rely solely upon their imaginations. Many partially sighted people focus more slowly or have limited fields of vision. For this group, the descriptions actually make it possible for them to better use their remaining vision. When you know what to look for, sometimes you are able to see it more clearly. Millions of individuals of all ages and with many varieties of visual limitations will benefit from described television. The cumulative effect of described programs will better prepare children to cope in a sighted world. Older people will feel less isolated and removed from an activity which they enjoyed in younger years. I am aware that mandated descriptions will require extra work and small expenses. But I hope that instead of dwelling on the negative aspects, program producers and broadcasters alike will reflect upon the enormous benefits and enlightenment they9 can help provide to millions in increasing audiences who will be grateful to them. And they should remember that the people they help may one day include their family members, their friends, or even themselves. The Metropolitan Washington Ear and I, therefore, join the National Coalition in urging the Commission to adopt the proposed rules with the key modification set out in the Coalition’s Comments. The revisions suggested in those Comments are essential if our dream of making television programming truly accessible to the visually impaired is, at long last, to come true. Respectfully submitted, The Metropolitan Washington Ear By: ______________________________ Dr. Margaret R. Pfanstiehl, President ______________________________ Margaret R. Pfanstiehl