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To the CRTC Public Notice CRTC 2000-155 Re: DVS

Date: 
Wednesday, December 1, 2004

VIA E-MAIL trANSMISSION: procedure@crtc.gc.ca

Ms. Ursula Menke
Secretary-General
Canadian Radio-Television and Telecommunications Commission
Ottawa, ON K1A 0N2

Dear Ms. Menke:

Re: Public Notice CRTC 2000-155

I: Introduction

The National Federation of the Blind: Advocates for Equality, (NFB: AE), is pleased to submit these comments on the above-mentioned application. Wile the NFB: AE does not object to any of the requirements currently contained in the above-mentioned Public Notice, it believes that additional requirements should be imposed on class I and Class II undertakings to carry programming with descriptive video (DVS) which may originate in Canada or the United States.

The NFB: AE requests that the Commission require any potential class I or II undertakings to broadcast the audio description of any Canadian or American prime time programming that is shown on any stations carried on its cable or satellite system when DVS is available. The US Federal Communications Commission (FCC) released new rules on the subject of audio narration which were adopted on July 21, 2000 and documented in MM Docket NO. 99-339. The FCC's ruling makes it clear that large American networks will be required to provide DVS for at least a portion of their prime time programming. Cable and satellite television service providers in Canada should be required to carry the DVS feeds from these American networks when they are available.

The NFB:AE further requests that the Commission require that programming originating on any community channel contain an audio version of any on-screen alphanumeric information in order that blind and other vision-impaired customers may gain equal access to this important information.

II: What is the NFB: AE

The NFB: AE is a national organization of blind, deaf-blind and vision-impaired Canadians. Founded in 1992, the NFB:AE's work focuses on advocacy and public education to expand the rights and opportunities for all blind, deaf-blind and vision-impaired Canadians to participate fully in all aspects of our society.

The NFB: AE has submitted briefs to this Commission in four prior proceedings dealing with cable rate increases sought by NBRS, the BCE Purchase of CTV, an amendment to a license held by Pelmorex and a request for funding by CNIB to support telephone access to its Information Centre for the Blind. In addition to these activities, NFB: AE has submitted materials and made presentations to a number of administrative tribunals and government departments on a number of other issues.

III: Why Is DVS So Important?

Television provides a broad range of information and entertainment to all Canadians. Currently, persons who are blind or vision-impaired are often denied the full benefits of such programming due to the visual nature of some of its content. The purpose of DVS is to minimize the effect of this current barrier that blind and vision-impaired Canadians currently face in accessing the same range of information as others who are able to see the television screen.

DVS is the audio description of key visual elements in programming inserted into natural pauses in the audio portion of a program. It is designed to make television programs more accessible to the many Canadians who have vision disabilities. Since television is one of the primary sources of news, information and emergency instructions and provides hours of entertainment each week for the majority of Canadians, the NFB: AE submits that it is in the public interest for the Commission to grant licenses to any class I or II undertakings that are prepared to make a commitment to provide audio description of their programming. This position is clearly supported by Sections 3(1)(I) and 3(1)(P) of the Broadcasting Act.

The NFB: AE submits that at a minimum, any class I or II undertaking should be required to comply with the terms set forth in the FCC's ruling on audio Narration released on July 21, 2000 by requiring able companies and satellite providers to carry programming with descriptive narration when such programming is available by licensed television stations. This should not impose a heavy burden on any licensees since they would be able to obtain the DVS feeds from American and other foreign broadcasting networks if these networks have already made arrangements to have the program described.

The NFB: AE also recommends adoption of the time periods proposed by the FCC for providing DVS access to television programming and asks that these time periods be implemented in Canada. The NFB: AE believes these time periods are reasonable and affordable for Canadian broadcasters.

Please do not hesitate to contact me if you have any questions, or require any further information.

Yours very truly,
 

John Rae
National Federation of the Blind: Advocates for Equality