[Missouri-l] MCB Sends Comments to the Federal Communications Commission

[Christopher Gray]

Hello to All:

Passing a law is one thing, but getting it implemented is equally difficult, 
some would argue more difficult.  For the 21st Century Communications Act, the 
FCC has the primary responsibility of implementing this ACt.  To help with this, 
they formed a committee to report back on equipment accessibility, video 
description, and emergency broadcasting.  That report was released by the FCC 
and comments were requested from organizations and individuals from the general 
public.

Following ACB's lead, MCB has sent comments to the FCC.  They are pretty 
self-explanatory and are included in the body of this message.

As a result of our comments, we have already been contacted by the National 
Association of Broadcasters.  They indicate that they would value our continued 
feedback, and rest assured they will get it!

All the best and happy reading,

Chris

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[letterhead]

The following comments are being submitted in response to the Video Programming 
Accessibility Advisory Committee report to the FCC. In these comments, we will 
first provide information about the Missouri Council of the Blind, then submit 
some general comments, then address concerns on accessible interfaces, video 
description, and emergency alert information.

Who We Are

The Missouri Council of the Blind is a consumer organization dedicated to 
improving the lives of blind and visually impaired people of Missouri and of the 
nation as a whole. We are the largest consumer organization of the blind in 
Missouri and represent over 700 members. We provide financial assistance to 
those in need, technology assistance grants and scholarships just to mention a 
few of our many programs and services.

General Comments

We are deeply concerned that a significant majority of the people who 
contributed to this report represent manufacturers and industry representatives. 
It should be noted that this industry has been one of the most hostile toward 
improving their ability to reach out to the blind and visually impaired 
community.  It is clear from this report that such resistance is still a 
dominant reality.  We urge the FCC to take this into account as they consider 
future actions in all of the areas provided in the VIPAAC report.

ACCESSIBLE INTERFACES

For almost two decades, we have witnessed a growing lack of accessibility to 
equipment surrounding television and video alternatives.  Often, those 
televisions that include the SAP channel cannot do so in a way that a blind 
person can access without sighted assistance.  In far too many cases, cable 
companies and similar carriers do not supply SAP information, particularly for 
audio description.  Set top boxes and DVRs completely exclude blind users in the 
United States.

This is not only unreasonable, but indicates a blatant disregard for this 
segment of customers.  Technology has existed for several years now that can 
make set top boxes and other similar equipment completely accessible through 
speech to a blind or visually impaired user.  SAP technology can hardly be 
considered new today, yet it is still often ignored or poorly carried around the 
country.

We strongly urge the FCC to hold manufacturers and providers accountable for 
accessibility in the equipment they provide.  It is imperative first that blind 
and visually-impaired users be able to make accessibility work in an achievable 
manner i.e. pressing a certain button on the box designated to enable 
accessibility.  Programming must be verbalized.  Video-described programming 
must be called out to viewer attention.  The full range of facilities in set top 
boxes and DVRs available to sighted users must be equally available to 
visually-impaired users including playback, recording, and accessing of movies 
and special programming available through each individual service provider.

Equally important to accessibility concerns is that there be a recognized 
standard to which industry be held accountable for accessibility.   The Missouri 
Council of the Blind requests and strongly urges the Commission to use the 
"effective communication" standard established by the Department of Justice in 
promulgating the Americans with Disabilities Act regulations.

Finally regarding accessibility of equipment, The Missouri Council of the Blind 
is disappointed at the recommendation that an additional two-year period be 
provided for the industry to begin providing accessibility to their equipment. 
We believe this is unreasonably long, particularly given that the law has 
already been passed over a year, and the direct knowledge the industry has had 
for many years about these problems.  This additional delay is simply a stalling 
tactic and we fervently hope the Commission will adopt a far less lenient 
deadline.

Video Description

Some users today of satellite and cable services can access video description 
through the SAP channel today regardless of where they live in the United 
States.  Sadly, most do not because they don't know how to do it.  The telephone 
service representatives of the provider don't even know what video description 
is, and so they cannot help these customers.  It is imperative that providers 
have clear and detailed instructions both on their websites and available in 
alternative formats upon request for their customers.

Second, we are concerned that there seems to be no mention of describing video 
when such video is provided through the  worldwide web. This is not only 
possible but readily available technology today and one can find described video 
even from amateurs on YouTube.  We feel this medium should be a part of the 
report and of FCC rulemaking.

Third, no mention is made in this report regarding the possible distribution of 
audio described content from companies such as NetFlix.  As such content becomes 
more available, we believe it is vital that customers of these companies be able 
to procure described material and know what is described and what is not in the 
catalogs of such companies.

Access to Emergency Information

The Missouri Council of the Blind is appalled that this report contains no dates 
for implementing a system to provide audio emergency information to people who 
are blind or visually impaired.  We live in a state that is no stranger to 
emergency, both small and large.  Tornado warnings, hale warnings, and other 
weather-related information is critical to the safety of our blind and 
visually-impaired members.  The FCC must create and enforce a meaningful and 
reasonable time period for the provision of audio emergency information by 
service providers.  In fact, we believe that the establishing of such deadlines 
should be the first priority of the FCC of all the items discussed in this 
report. People's lives depend upon it!

Of almost equal importance is that the report makes no concrete or feasible 
suggestion of how such emergency information can be made available.  Given that 
conversations on this topic have been ongoing since the 1990s, we find this 
reprehensible on the part of the entire industry.

Conclusion

The Missouri Council of the Blind finds this report very disappointing on a 
number of fronts.  We believe that industry domination has adversely affected 
the recommendations and has given an improper balance to the recommendations and 
timelines, when they exist, as a whole.  We urge the FCC either through its 
requirements based on this report or whatever other mechanism may be available 
to find a better balance than exists in this report.