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

[Gretchen Maune]

I am extremely glad MCB is taking action on this.  Thank you for doing so,
and thank you for the news.

Gretchen Maune

-----Original Message-----
From: missouri-l-bounces at moblind.org [mailto:missouri-l-bounces at moblind.org]
On Behalf Of Christopher Gray
Sent: Tuesday, June 19, 2012 11:27 AM
To: Missouri-l at moblind.org; Education and Welfare Committee
Subject: [Missouri-l] MCB Sends Comments to the Federal Communications
Commission

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

------------------------
[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.



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