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Broadcasting Public Notice 2005 -18

Friday, April 1, 2005

Ms. Diane Rheaume
Secretary General
Canadian Radio-television and
Telecommunications Commission
Ottawa, Ontario K1A 0N2 April 19, 2005

Dear Ms. Rheaume:

Re: Broadcasting Public Notice 2005 -18: Commission Requirements For The Pass-Through Of Video Description - Call For Comments On The Obligations Of Smaller Broadcasting Distribution Undertakings.


The AEBC is pleased to have the opportunity to comment on the Commission's call for comments on Pass-Through of Video Description. We shall take advantage of this opportunity to also comment on a number of other related issues of universal design that impact directly on making television more accessible to and usable by persons who cannot read conventional print, most particularly, Cablevision on-screen programming and on/off--screen controls. Simply stated, while gaining access to an increased range of described programming remains an important issue for the AEBC, we need to be able to access this programming, and this involves knowing it is available and being able to use the various controls on a remote, which are often vision driven.

The Alliance for Equality of Blind Canadians / L'Alliance pour l'Égalité des Personnes Aveugles du Canada (formerly National Federation of the Blind: Advocates for Equality), is a national, not for profit organization, whose work focuses on public education and advocacy on a wide range of blindness-related issues, to increase rights and opportunities for all blind, deaf-blind and partially sighted Canadians to participate fully in all aspects of Canadian society, including the full enjoyment of television programming.

The AEBC commends the CRTC and Canadian broadcasters for their past efforts in increasing access to television programming for Canadians with disabilities.

There are an estimated 666,500 blind and low-vision Canadians and 2.17 million print-restricted Canadians. These 2.8 million Canadians are unable to access print media for a variety of reasons.

Audio description and described programming, like closed captioning in the case of the hard of hearing, helps enrich the television experience by making television programming more accessible to and enjoyable by vision-impaired viewers. It does not, however, overcome all of our access issues.

The Broadcasting Act states, at paragraph 3 (1): "Programming accessible by disabled persons should be provided within the Canadian broadcasting system as resources become available for the purpose."

In its submission, the National Broadcast Reading Service (NBRS) indicates that several Canadian companies now offer description, and this competition has brought down the cost paid by producers for the description of programs from approximately $5,000 five (5) years ago to $1,500 today per hour of programming, yet the distribution of described programs remains inconsistent as detailed in the PN.

The PN notes that The Commission's current regulatory requirements are that all broadcasting distribution undertakings (BDUs) must pass through to subscribers all video description contained in the programming signals they receive from broadcasters. In the case of smaller BDUs, however, the Commission is aware that there are certain technical, operational and cost concerns associated with making the upgrades necessary to enable them to pass such programming signals through to subscribers. Unless a carrier can demonstrate that the needed changes would constitute "undue hardship," we believe these changes should be required within a reasonable, short span of time, not to exceed three more years and preferably sooner.

The Commission considers it an appropriate objective that all BDUs eventually pass through all described video programming to their subscribers. In this context, the Commission now asks the following questions regarding the most appropriate approach to achieving that objective in the case of all licensed Class 2 and Class 3 cable BDUs, MDS operators, and exempt BDUs: The AEBC supports this Commission "belief" and urges that this current review lead to meaningful and demonstrable progress.

What would be the impact if the Commission were to require all BDUs, licensed and exempt, to distribute all described video programming by a deadline of 1 September 2008? If it is mandated, we are confident that the industry would find a cost-effective way of achieving this objective. The history of providing captioned programming proves the point. All subscribers should bear the cost. We, as viewers who are blind, have to pay the full cost of television programming that is often far from being fully accessible to us, and this inequity must be eliminated.

Should exempt BDUs be subject to the same obligations and deadline as licensed BDUs? Yes. People who are blind live every wear in Canada, not just where there are Licensed BDS.

Should Class 3 BDUs be subject to the same obligations and deadline as Class 2 BDUs? Yes.

Should the obligations of BDUs owned by the largest multiple system operators, specifically Rogers, Shaw, Videotron or Cogeco, differ from the obligations of other BDU licensees? Yes, the implementation time frame should be shorter for these companies.

Should obligations for the distribution of video description take into account the source of the programming? For example, should local, over-the-air signals take precedence over distant signals? NO. For example, in Ottawa, Rogers switched to Detroit from Rochester for main American feeds. This was done apparently to make a good picture even better through HDTV, but it resulted in SAP no longer being available. Thus Descriptive Narration options were reduced substantially.

Should any new approach adopted by the Commission be implemented through amendments to individual conditions of licence or via amendments to the regulations? Regulatory requirements are always the AEBC's preferred option. Regulations provide a standard and eliminate the need to seek progress on a licence by licence basis. Regulations provide a rights'-based, customer service focus rather than a nice to be charitable approach.

Related Issues

While requiring the Pass-Through Of Video Description is extremely important to all vision-impaired television viewers, it would remove only one of a larger range of access barriers, which also must receive attention and elimination.

Additional access barriers include, but are in no way limited to:

  • A) Television listings: Nowadays, program listings are often provided on screen, but they are not voiced, and as such, are not usable by anyone who cannot read the screen;
  • B) Television design: Modern television sets are generally operated by a remote, which generally provides a number of visual menus, which are not accessible to persons who cannot read them. Thus, a new television may contain a SAP option, but the user may not be able to independently access it.


The AEBC thanks the CRTC for initiating this new proceeding, and we recommend the Commission consider the broad range of comments we have provided in this submission.

John Rae

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