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


 MM  Docket  No.  99-  339 
 I  am  glad  to  take  this  opportunity  to  comment  on  FCC’s  proposal  to  mandate  audio  description  by 
 television  networks  and  stations  using  the  Secondary  Audio  Programming  (SAP)  function.  As  a  member  of 
 the  National  Federation  of  the  Blind,  I  voted  to  pass  a  resolution  in  1996  (96-  04)  which  opposes  federally 
 mandated  audio  description.  There  are  several  reasons  for  my  opposition. 
 Not  all  people  find  audio  description  useful.  In  fact,  some  people  find  it  annoying.  Since  there  are 
 no  standards  stipulating  which  images  should  be  described,  there  are  often  descriptions  of  unnecessary 
 information.  Thus,  I  prefer  to  use  other  clues  to  obtain  information  about  the  plot  or  characters  in  a  movie. 
 By  electing  not  to  use  audio  description,  pertinent  information  is  not  lost,  and  voiceovers  do  not  repeat 
 irrelevant  information.. 
 Before  mandating  description  for  entertainment  purposes,  other  information  pertaining  to  safety 
 should  be  accessible.  Severe  weather  warnings  or  emergency  information  scroll  across  the  bottom  of  a 
 television  screen.  Making  this  information  accessible  ought  to  be  a  priority  over  descriptions  in  movies  or 
 television  programs. 
 I  am  an  eighth-  grade  Spanish  teacher,  and  I  find  the  SAP  function  useful  to  me  in  several  ways.  I 
 can  turn  on  the  function  and  record  programs  in  Spanish  to  present  to  my  students.  Secondly,  I  use  the  SAP 
 function  for  my  own  enrichment.  Though  I  spent  time  in  Mexico,  I  find  that  teaching  level  1  is  not 
 sufficient  for  maintaining  my  fluency.  By  using  the  SAP  function  for  watching  Spanish  programming,  I  can 
 practice  the  skill  of  comprehending  Spanish.  If  the  SAP  function  covered  descriptions  of  movies,  I  could 
 not  utilize  the  channel  for  English-  Spanish  translations. 
 I  recommend  that  the  FCC  refuse  to  mandate  description  of  videos  and  movies  for  entertainment 
 purposes.  Since  thousands  of  blind  people  voted  to  pass  the  above  mentioned  resolution  at  the  1996 
 convention  of  the  National  Federation  of  the  Blind,  I  am  not  alone  in  this  opinion. 


 Respectfully  submitted, 


 Sheila  Koeng 
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