context->filename = 'n:\utility\503500258\5006314050\5006314050.pdf' *Pages 1--2 from n:\utility\503500258\5006314050\5006314050.pdf* BLINDED VETERANS ASSOCIATION 477 H STREET, NORTHWEST . WASHINGTON D. C. 20001- 2694 l (202) 371- 8880 March 23,200O Ms. Magalie Roman Salas, Esq. ofIiceoftheSecreuq Federal Commun& tions Commission 445 12* street, SW TW- 204B Washington, DC 20554 Re: MM Docket No. 99- 339 Dear Ms. salas: On behalfofthe Blinded Veterans Association (BVA), the only Congressionally Chartered Veterans Service Organ& ion exclusively dedicated to serving the needs of our nation’s blinded veterans, I feel compelled to respond to comments submitted to the NPRM by the National Federation of the Blind (NIB). While some of their arguments opposing mandated video description are cogent, the apparent attempt to represent all people who are blind must be challenged. Mandating the provision of this video description for people who are blind clearly falls within the purview ofthe Federal Communi cation Commission (FCC). It would not be necesxqtomandate descriptive video ifthe producers of motion pictures and prime time television programming voluntarily implemented this service. Numerous attempts by the blind community to sensitize producers regarding the interest and need for described video and obtain a commitment to voluntarily provide description have failed. There is no recourse but to mandate these services. With respect to the number of people who are blind or severely visually impaired who would be interested in having video description, no one organization can presume to speak for all the blind. Certainly there are blind individuals who may not care whether they have described video or not. However, there should be no requiremen t that 1000/ o of people who are blind express strong interest in this service before approval or mandates can be enforced. While not all people who are blind may want descriptive video, there are certainly suf5cient numbers that have a strong interest as well as a need for improved access to visual information. It is probably safe to say a majority of people who are blind would benefit from these services. This issue is too important to argue over numbers, resulting in inaction by the FCC. BVA holds a National Convention annually and for the past number of years one evening is devoted to a movie night featuring a descrii movie hosted by WGBH, a Boston PBS station. This event is always well attended. BVA’s members look forward to these movies each year. has adopted resolutions at conventions strongly supporting d& scriptive video. Additionally, BVA No. oi bpia r& d 661/ O UASCDE CHARTERED BY THE C ‘+ F THE UNITED STATES _ _ ---... .-._ . --__-.-. -. . “,..--- - 1 Thetimehascometomoveforwardwiththeproposedruleandmandatetheindustrytobegin providing described video programming. Clearly, the industry must address the real need fbr people whoare~ toknow~ isbeingscrdledarm> sstheTvscreen, especiallywhentheseinvolve safktyissues. other~ onssuchashavingsportscoresshownonthescreenwithoutv~ description is another issue that cert& ly should be addressed. However, primetime progrmming shouldhavepriorityatthistimeinasmuchasthetechnologyisalresdyavailable. Aithoughtherewili never be total unanimitywithintheblind community, we cannot allow difEerences to become major obstacles to improving access to visual infii for people who are blind or visually impakd. Executive Director Blinded Veterans Association 477 H Street, NW washingq DC 2ooo1 (202) 371- 8880 -,. __ _, _..” -.-__ .._ .__ ,__. - ^ -..____ ,- _.-- -.” ^ ---. .--- 2