CRTC report on audio description

Errors and omissions in a CRTC report on audio description

At time of writing (April 2001), the Canadian Radio-television and Telecommunications Commission is considering the renewal of the broadcasting license of CTV, the large Canadian for-profit TV network.

Hidden away on the hearing schedule page is a mention of a CRTC document, “Current Domestic and International Status of Descriptive Video.”

The report is all but secret. Despite the fact that thousands of documents, many of them of no interest whatsoever, are posted at the CRTC Web site, this one isn’t: You have to ask for it by E-mail.

This page provides the full body of the document for the public record and attempts to correct its many falsehoods and deceptions. If this is the best that researcher bureaucrats can come up with, taxpayers ain’t getting value for their money.

In the passages that follow, outright untruths are pointed out as Corrections, while Clarifications are offered where necessary. Since almost no sources are quoted, it is next to impossible to verify some of the document’s assertions.

The report is surprisingly badly-written and is atrociously edited; the original file, a Word for Windows document, looks like what it actually is: A report banged out by a bureaucrat who didn’t particularly care about the subject-matter.

Ongoing terminology offenses

One issue of fairness and accuracy dominates over all others. The CRTC, the majority of Canadian broadcasters, and many intervenors continue their ongoing ignorant misuse of the terms descriptive video and descriptive video service (with initial capitals or not) and DVS as pretended generic terms for audio description. In reality, there is one generic term for audio description, and it is audio description. (The FCC has enshrined the synonym video description through its rulemaking, a source of confusion we just have to live with.)

“Descriptive Video Service” and “DVS” (note the capitals) are registered servicemarks of the WGBH Educational Foundation. DVS has offices in Boston and Los Angeles and is a provider of audio description. “Descriptive video” and “DVS” are not generic terms. It is perhaps commendable that such terms have become pseudo-generic, like Kleenex or Xerox, but there has been no surrender of WGBH’s intellectual-property rights.

Further, DVS is not the only supplier of audio description by any stretch of the imagination. The use of “DVS” as a claimed generic term suggests that only the Descriptive Video Service does the work.

The CRTC document is particularly weasely and deceptive in its description of the Descriptive Video Service itself: “A PBS station, WGBH-TV in Boston, launched DVS in January 1990.” Yes, it launched DVS^SM, not DVS. The phraseology makes it sound like WGBH started up its own variation of a generic service instead of actually inventing audio description as it applies to television.

Current domestic and international status of descriptive video

Prepared by CRTC Staff, January 2001

EXECUTIVE SUMMARY

Introduction

The purpose of the attached report is to provide an international "snap shot" of the development of descriptive video. Descriptive video (DVS) refers to a means of making television, movies and other video programming accessible to blind or visually disabled viewers. It consists of verbal or audio descriptions inserted into natural pauses in the program’s dialogue, without interfering with the original audio of a program or movie.

Correction – Descriptions are usually delivered during pauses in dialogue. It is not at all uncommon, however, to describe over dialogue for limited moments. Typical example: The scene has changed and the dialogue would not make sense without telling the viewer, or a character’s voice changes for inaudible reasons (e.g., he’s holding a handkerchief to his bloody nose). The less-competent audio-describers, like AudioVision Canada, believe that description over dialogue should essentially never be done, but the goal of description is to make the entire program understandable, not to preserve every syllable of original speech.

The verbal descriptions can be permanently encoded and delivered as a separate audio component. This is typically done using the Second Audio Program (SAP) feature. SAP is standard on newer televisions and VCRs.

Clarification – Unlike caption decoders, which are required by U.S. law, there is no requirement for TVs or VCRs to receive Second Audio Program. Reception of SAP is standard in most new TVs and VCRs, but rarely in low-end models.

Canada

In 1991, Statistics Canada reported that 635,000 (2.8% of population) Canadians had a significant vision loss. The NBRS and the National Library of Canada estimate the number of print disabled consumers to be close to 3 million (9.5% of population). The mini series The Arrow was the first described program to be aired in Canada by the CBC. In Public Notice CRTC 1998-8, Additional National Television Networks, the Commission encouraged: ….broadcasters to introduce descriptive video as a means to make the broadcasting system more accessible to Canadians who are blind or who have low vision… Some broadcasters, including, Showcase, CBC, City-TV and TVO have conducted some trials in terms of broadcasting described programming.

United States

The United States is currently at the forefront of DVS. A PBS station, WGBH-TV in Boston, launched DVS in January 1990. Currently, PBS employs SAP to broadcast to some 169 stations which represents coverage to 85% of American television households. PBS has produced described versions of Canadian series such as Street Legal, Road to Avonlea and De Grassi High.

Correction – Street Legal was never described by DVS, or by anyone else, to my knowledge.

PBS receives funding for their DVS efforts through the US Department of Education. The total production cost is $4000 (US) per hour.

On July 21, 2000, the FCC adopted rules for video description on commercial television networks. Commencing in 2002, the four major networks in the top 25 markets will be required to broadcast a minimum of 50 hours per calendar quarter or 4 hours per week of DVS programming. These rules apply to analog television. The rules also include audio description of emergency telecasts.

The FCC estimates that up to 12 million persons (4.3% of population) in the United States have visual disabilities. Studies in the US indicate that 99% of blind consumers own a television.

There are currently 65 movie theatres in the US that provide audio described movies.

United Kingdom

The Broadcasting Act, 1996 mandates DVS for digital terrestrial broadcasters. The legislation states that digital channels must provide 10% of their programming with audio description by the 10th year of their licenses, starting in 1999. Currently, the digital terrestrial receivers employed in the UK do not have audio description reception capability. The United Kingdom represents the only country which is attempting DVS on a digital platform and it is experiencing some technical difficulties.

Estimates indicate that there are 1.7 million people (2.8% of the population) in the UK with visual disabilities.

Germany

Bavaria was the first region to broadcast DVS programming (1996). They also conducted some studies which found that 97% of blind consumers own a television and that 81% watch television regularly. ZDF, the second largest German broadcaster, has distributed audio described movies. ARD regional broadcasters have experimented with DVS. The German Association for the Blind and Visually impaired are responsible for DVS production. They estimate that the production cost for a 90 minute movie is in the range of $6000 to $10,000 (CDN).

Netherlands

The Media Act stipulates that the public broadcasting service should make its programs accessible for the total population. Holland intends to employ a technique of teletext in order to make its programs accessible for people with visual disabilities. According to plans, they are attempting to make all text and subtitles on television audible for persons with visual disabilities. The public network is targeting 20% of its programming. It is also contemplating descriptive video.

Other Countries

Italy reports employing an audio channel to transmit audio description simultaneously with television channels.

L’Association Valentin Hauy in France has been producing audio description for movies. France has also transmitted some DVS programming via SAP.

Current regulatory arrangements in Australia do not require broadcasters to provide audio description on television, however, the Australian government has issued a paper calling on comments on whether broadcasters should provide DVS.

Sweden has not done much to make television more accessible for blind consumers. However, Sweden was the first country in Europe to offer audio description in a movie theatre. This innovation dates back 20 years. Sweden was also the first country to introduce audio described theatrical productions.

Audetel

Audetel was a European consortium of regulators, consumer associations and broadcasters formed to research and develop DVS. Formed in 1991, they conducted research on the technology required to develop DVS. In addition, they examined the needs of blind viewers. In 1994, the BBC conducted trials using technology developed by Audetel. Audetel also published a newsletter which monitored the international development of DVS. The project was, however, superseded by the introduction of UK’s Broadcasting Act, 1996 which mandated DVS via terrestrial digital transmission in that country.

Introduction

The purpose of this document is to provide an international "snap shot" of the development of descriptive video within the realm of television. Media regulators from the United States, United Kingdom, France, Italy, Germany, Australia, New Zealand, Finland, Holland, Spain, and Sweden were contacted in the context of the research. In addition, WGBH/PBS in Boston, the American Council of the Blind, the National Broadcast Reading Service, the Canadian National Institute for the Blind, the Canadian Council of the Blind and the Royal National Institute of the Blind (UK) were contacted.

Descriptive video (also known as audio description or video description) refers to a means of making television, movies (particularly in the form of video) and other video programming accessible to blind or visually disabled viewers. Video description consists of verbal or audio descriptions of key visual elements, inserted into natural pauses in the program’s dialogue, without interfering with the original audio of a program or movie.

Correction – Descriptions are usually delivered during pauses in dialogue. It is not at all uncommon, however, to describe over dialogue for limited moments. (See previous correction.) Descriptions manifestly do interfere with the original audio or nobody could hear them.

The narration enhances understanding and enjoyment of a video program by providing verbal descriptions of essential visual elements such as settings, action, comparative size, gestures, body language, scene changes, graphics, subtitles and costumes. The verbal descriptions can be permanently encoded and delivered as a separate audio component interspersed with pauses in the program’s dialogue. Under this format, to receive video described programs on television a viewer must have either a stereo television or a stereo VCR that includes the Second Audio Program (SAP) feature. This SAP feature is standard on newer stereo televisions and video cassette recorders. It is also possible to purchase a relatively inexpensive receiver that will allow a viewer with a non-SAP television or VCR to receive audio description. It is also possible to employ open description.

As noted by journalist Katrina Onstad in the National Post:

as closed captioning is to the deaf, video description is to the blind: A described Casablanca comes with a narrative of the visual action, woven digitally in the soundtrack. The end result is an ongoing voice-over that might offer some helpful information most sighted people take for granted, such as: "Ilse gets on the plane.

Canada

The National Broadcasting Reading Service (NBRS) is a registered charity dedicated to improving access to print and visual media. Its major activity is VoicePrint, a licensed, free audio news and information (newspaper reading) service available via cable. They also point out that the demographics will certainly change as a result of an ageing population.

A 1991 post-Censal survey by Statistics Canada found that 635,000 Canadians identified themselves as having a significant level of vision loss, even when wearing eyeglasses. It should be noted that many people with low vision are reluctant to identify themselves as having low vision. This survey, conducted in 1991, indicated that 2.8% of the total population fell into this above-noted category. In terms of today’s population, that would represent approximately 884,600 people.

Dr. Donald H. Farrell, a member of the CNIB board has indicated that:

More than one in nine Canadians over age 65 and more than one in four over age 80 experience severe vision loss that cannot be corrected with standard eyeglasses. That translates into 2.7 million Canadians who can expect severe vision loss.

The NBRS estimates 666,500 blind consumers in Canada. In addition, the NBRS estimates that 2.17 million Canadians are print-restricted (i.e. includes those who can read using large fonts or corrective lenses). Furthermore, the NBRS notes that 2.8 million Canadians are unable to access print media for a variety of psychological, physiological or neurological reasons.

In the early 1980s, video description evolved as a technology that could make television viewing more meaningful for people with visual disabilities. In 1988, a parliamentary committee identified the need to adapt description to Canadian television. In 1995, the NBRS developed a cost-effective, description-production process.

Clarification – This assertion is pure public relations for NBRS. Accepted at face value, it single-handedly destroys broadcasters’ arguments that the cost of producing audio description is too high. Moreover, the maxim “You get what you pay for” comes into play here. AudioVision Canada may be “cost-effective” (i.e., cheap), but is their work any good? The answer is a clear no.

In January 1997, the CBC and the NBRS produced the first Canadian descriptive video broadcast. CBLT-TV, a Toronto-based television station, broadcast simultaneously the premiere of the regular and the described versions of its mini series, The Arrow.

Decision CRTC 90-93 (creation of NBRS)

Although this Decision did not directly deal with the issue of video description, it did lay the ground work for a reading service for visually disabled consumers. The Commission stated that it:

considers that the establishment, at the earliest date possible, of viable audio reading services in both official languages which would provide programming of benefit to blind, visually-impaired and print-handicapped persons as well as to many other potential listeners, to be not only in the public interest, but a matter of national importance.

Public Notice CRTC 1998-8 (Additional National Networks)

In the matter of descriptive video, the Commission stated:

The Commission notes the proposals made by NBRS that the Commission encourage broadcasters to introduce descriptive video services as a means to make the broadcasting system more accessible to Canadians who are blind or who have low vision. While recognizing that there may be significant technological and financial implications for broadcasters, the Commission supports, in principle, the development and gradual implementation of DVS. In this regard, the Commission notes and supports the cooperative efforts by the NBRS and the CAB to explore the issues and to find solutions to any problems that may be identified.

It should be noted that 5.5% of Canadians have a hearing disability. This represents approximately 1,650,000 Canadians. It should also be noted that the disabled communities tend to demonstrate a rivalry when it comes to accessibility issues. This rivalry is most acute between the blind and deaf communities, particularly since information or communication represents a major issue for both groups.

Correction – This is an outrageous exaggeration even if it is not an outright lie. Description and captioning serve mutually-exclusive audiences: Deaf people can’t hear audio descriptions and blind people can’t read captions. True enough, some hard-of-hearing people are also visually-impaired and require extra-large captions, but there is no true overlap, and indeed, essentially every PBS program and home video that DVS has described has also been captioned, a fact that has prompted no outcry whatsoever.

Deaf viewers are not more important than blind viewers, nor are they less important, nor are they more or less important than viewers who are neither blind nor deaf. In 20 years of accessibility work, I have never encountered an organization that advocated for more accessibility for their disability group at the expense of some other group. No one, for example, seriously believes that the way to increase the amount of description is to decrease the amount of captioning.

Nor are there ongoing disputes between blind people and deaf people on which is more important, description or captioning. Where is the “rivalry” the misinformed bureaucrats who authored this paper refer to? It’s quite correct to say that “information or communication represents a major issue for both groups,” but the specific access techniques couldn’t be more different, and anyway, taken at face value, if “information or communications represent a major issue,” isn’t that a source of commonality, not rivalry?

As a result of the advent of closed captioning on television, advocacy groups for the blind appearing before the CRTC have argued that 10% of broadcasting should be described.

Current regulatory approach

To date, the Commission has encouraged the development and gradual implementation of described video programming, while acknowledging that it may be premature to impose specific requirements, given the potentially significant technical and financial implications for broadcasters and distributors. The Commission also encouraged the industry to provide audio description of graphic information.

Correction – As is the persistent habit of the CRTC and Canadian broadcasters, the report continues to consider the reading aloud of onscreen type as some kind of entirely separate phenomenon. It is merely one activity under the larger umbrella of audio description. Reading relevant onscreen titles is a necessary part of A.D., but doing only that does not mean you are actually providing audio description.

Most recently, the Commission articulated its approach in the TV Policy (PN 1999-97), which stated:

Licensees are strongly encouraged to adapt their programming to include audio description wherever it is appropriate and take the necessary steps to ensure that their customer service responds to the needs of visually impaired.

With respect to descriptive video services (DVS), the Commission concludes that it is premature to impose specific requirements on licensees at this time. The Commission encourages licensees and the National Broadcast Reading Service to continue to cooperate in order to effect the gradual implementation of DVS.

The Commission, at licence renewal, will explore with licensees the progress that that has been made in meeting the needs of the visually impaired.

NBRS

One of the divisions of the NBRS is Audio Vision Canada, Canada’s only audio description production centre. Another NBRS division is Alternate Media Canada (AMC) which is responsible for evaluating technical solutions to NBRS’ needs and the marketing of technologies or facilities it develops. The start up funding needed to launch the audio description facilities was funded via a $500,000 contribution from Shaw Communications Inc. In addition, Human Resources Development Canada (HRDC) provided a grant to Canadian libraries in order that they may be a source for audio description services and products. Corporations have also provided financial support for individual video projects.

Starting on March 12, 2001, a CRTC decision will require the majority of distributors across Canada to distribute the programming service of VoicePrint for a maximum monthly fee of $0.01 per subscriber via Newsworld’s SAP. This decision will also ensure that VoicePrint is distributed on an easily identifiable channel. In this way, it can promote the service to Canadians who require the service as well as other potential listeners.

In the December edition of Broadcast Dialogue, Mr. John Stubbs, Director of Operations for the NBRS reports the following:

a proposal by BCE that is included in its benefits package associated with its proposed acquisition of CTV. BCE proposes to donate $2 million to NBRS to underwrite the production of described programming

Technical Aspects

The SAP capacity of a video transmission, whether an over the air or a cable television feed, is largely under-utilised in Canada. To date, the primary use has been to broadcast foreign language audio information. In Canada, fewer than half the television sets in operation are equipped to access the SAP signal. The other technological issue is that the SAP is normally activated by an on-screen visual prompt which is not easily usable by blind or visually disabled viewers. NBRS reports that it has developed a stand-alone, low cost (i.e. $100) and tuneable SAP receiver. The unit weighs less than one pound and is capable of accessing regular television or SAP signals, regardless of whether they are received off air or via cable.

Trials in Canada

City-TV has conducted a few trials of both open audio description and closed audio description programming. According to the station, it received a number of complaints about the openly described movies; whereas in terms of closed audio described movies, some viewers were not certain on how to turn on or off the SAP feature.

Clarification – Note that an unspecified “number” of complaints is advanced as a seemingly airtight reason not to provide description at all. I’ve watched open-described movies on CITY (all described, it must be noted, by DVS). They were clearly advertised as such upfront. Any movie on any big-city TV station will attract tens of thousands or hundreds of thousands of viewers. Even if a hundred people phoned in with a complaint (an extravagant estimate), the enormous majority of viewers obviously accepted the open description.

Further, Showcase has run a number of open-described movies with no advance warning whatsoever, and there is no evidence that its phonelines were flooded with the complaints of mortally-offended sighted people.

What’s more, early showings of open-described programs on the Family Channel (back when it was a pay service) elicited nothing but compliments, a source told me at the time. (More recent conversations with the Family Channel, however, contradict those earlier reports; the claim was that, as a pay service, nondisabled viewers demanded that none of that description nonsense clutter up the programming subscribers shelled out good money for. Family Channel is a regular specialty service now, and has been completely scared off running any described programming at all.)

TV-Ontario (TVO) has aired a described version of The Bell’s of St. Mary in cooperation with the NBRS. A radio station in Toronto ran a simulcast of the descriptive portion of the TVO presentation. TVO, as reported by the Canadian Association of Broadcasters, began exploring the possibility of describing some of its own programming. In a report published by the CAB, it was reported that TVO found that post-production costs of descriptive video were comparable to the original cost of the program production.

Correction – That may be true of live programming, but prerecorded programming cannot possibly cost TVO a mere $2,500 an hour, which is what AudioVision charges to describe a show.

CBC

The CAB also noted that the CBC is not equipped to deliver described audio in a closed format. The CBC does not currently broadcast in stereo, however this technicality may not close the door on described video on the CBC network. For some time it was believed that only TV stations producing a stereo service could generate a second audio program signal. The NBRS has noted that Modulation Services, Inc. has developed a SAP generator that allows any television station, stereo or otherwise, to exploit SAP technology. Furthermore, according to Suzanne Labarre, an engineer from the CBC, SAP audio transmission would be possible at the CBC despite the lack of stereo distribution. She notes that a certain amount of hardware would be required to make SAP a reality.

National Library Task Force

The National Library of Canada conducted a "Task Force on Access to Information for Print Disabled Canadians". The Vision: To support the realization of the right of all Canadians to timely, affordable and usable information, by developing a coherent plan of action, including sources of sustainable support, for those producing accessible information and providing appropriate services, using international standards and suitable technologies. Following consultations with print disabled persons, the Task Force issued a report on October 31, 2000.

Although the report focused primarily on print media, there was one recommendation concerning descriptive video. The NBRS submission sought an exemption from the Copyright Act for the adaption of cinematographic works for the community of print-disabled Canadians. The NBRS contends that access to video is no different from access to print and that the technology is now available to provide print-disabled Canadians with the information provided through video. The Task Force saw a short demonstration of a video with audio description. In turn, the Task Force issued the following recommendation(6): …recommends that Canadian Heritage seek an amendment to the Copyright Act to include exemption for the non-commercial narrative description of cinematographic works. The report indicates that 3 million Canadians fall within the definition of print disabled. It should be noted that this definition includes cognitively disabled and severely mobility disabled individuals.

United States

The Federal Communications Commission (FCC) estimates that up to 12 million persons in the United States have visual disabilities that cannot be corrected by ordinary glasses or contact lenses. In addition, 9 to 14% of the population 75 years of age or older have visual disabilities. Furthermore, the FCC feels that video description could also benefit secondary audiences of up to 1.5 million children between the ages of 6 and 14 with learning disabilities by capturing their attention and enhancing their information processing skills. In a study comparing the television viewing of the visually disabled and the general population, it was observed that 99% of the visually disabled owned a television, whereas 85% of this group owned a VCR and 81% rent/buy videos.

Currently, the United States is at the forefront of descriptive video. A PBS station, WGBH-TV in Boston, launched descriptive video in January 1990. The service is free and provides a national broadcast. A limited amount of programs are made accessible to persons with visual disabilities using the SAP channel technology. Narrative description is available on a select number of PBS’ series, including the following: Mystery!; The American Experience; Nature; Scientific American Frontiers; Mobil Masterpiece Theatre; NOVA; The Living Edens, and, Mr. Rogers’ Neighbourhood. According to WGBH, some 169 PBS stations provide descriptive video; this represents coverage to 85% of American television households. In addition, WGBH provides video description services to Turner Classic Movies and to Blockbuster Video. By providing description services to these two movie sources, they are providing narrative services to both current and classic movie titles. PBS will soon be opening a audio descriptive production centre in California in order to be in a closer proximity to the movie and television studios. Currently videos are shipped from Hollywood to Boston for the purpose of audio description.

Correction – “A audio descriptive production centre”: What the heck is that? DVS has operated an office in Los Angeles since early 2000. Given that this CRTC report is dated January 2001 and it claims to have involved consultation with WGBH, you’d think we’d have gotten this detail straight.

PBS anticipates a growth in the audio description, partly since they plan to increase their commitment and also due to the FCC ruling and the increased demand for audio described product. PBS notes that the total production cost of descriptive video is $6000 (CDN) per hour.

Correction – Funny, earlier in the report it is claimed that DVS charges $4,000 an hour. Which is true? (About $4,500 an hour, according to WGBH. A two-hour movie costs $9,000 to describe.)

PBS has a supportive Canadian audience. Many Canadians, whether they are blind or not, tend to support their respective PBS stations and many Canadian viewers who are blind or visually disabled tune into this service regularly. Furthermore, this service provides described versions of some Canadian series, such as Street Legal, Road to Avonlea and De Grassi High. These described Canadian series have not yet been aired on Canadian television.

Correction – Street Legal was never described by DVS, or by anyone else, to my knowledge. DeGrassi Junior High and DeGrassi High were also captioned by the Caption Center at WGBH (with results vastly superior to the wholesale desecration wrought by the National Captioning Centre and the Canadian Captioning Development Agency), but we didn’t get those better U.S. captions, either. Isn’t there a problem in general here? Also, why haven’t the many Canadian stations that telecast the DeGrassi series ever bothered to import the described version?

For its work in advancing the use of video description, the WGBH Foundation of Boston won the CNIB’s Winston Gordon Award for outstanding technical achievement of benefit to people with visual disabilities.

The United States Department of Education provides funding for descriptive video which includes both the WGBH Foundation and the Narrative Television Network. The U.S. government has committed $20 million annually for captioning and descriptive video.

No American commercial television stations are currently providing video description. However, through a partnership with WGBH, some described movies are available on Turner Classic Movies channel.

Correction – That sounds like a commercial television station to me.

Nostalgia Television’s Narrative Television Network has also presented some audio described vintage movies.

Correction – Virtually everything NTN describes is a vintage movie, and they’ve been doing it for years. “Some” movies? The catalogue is a couple of hundred strong at the present.

As noted earlier, Blockbuster Video stores are also providing some movie titles with narrative description. In addition, some recently released DVD movies include described audio tracks.

Correction – This is misleading in one case and false in another. There is no special or exclusive described-video line custom-made for Blockbuster; some video outlets merely sell DVS home videos. There are exactly three DVDs with audio description: Basic Instinct, T2, and Abraham and Mary Lincoln: A House Divided. Neither of the two feature films is “recently released,” and the Lincolns DVD is still not available to order at time of writing. Studios have hundreds of description sound files available for use on DVD (from DVS, NTN, the RNIB in England, and possibly other sources) and have ignored essentially all of them.

The FCC first considered video description when it issued a Notice of Inquiry on closed captioning and video description on December 4, 1995. The 1996 Telecommunications Act mandated the FCC to explore methods and timetables for phasing in video description. At that point, the FCC was suggesting that descriptive video should be implemented gradually. In addition, the FCC felt that the introduction of descriptive video could be tied in with the development of digital television.

On July 29, 1996, the FCC released a report which suggested that video description should be applied to new programming that is widely available through nationally distributed services and attracts large audiences (e.g. prime time entertainment series). On the other hand, the FCC noted that a lower priority for video description should be given to programming that is primarily aural in nature, such as newscasts and sporting events.

On January 13, 1998, the FCC released its second report on video description. It suggested that the implementation of video description should begin with the largest television markets and that video description should be imposed on the national networks since they would be in a better position to offset the production costs. The FCC also suggested a minimal amount of descriptive audio programming, however no exact numbers were specified. It was also suggested that a period of trial and experimentation would be beneficial since it would allow broadcasters to be more specific on the type of information to be described and the costs associated with video description and any other related matters.

On November 18, 1999, the FCC called for comments on its proposal requiring commercial television broadcasters in the top 25 television markets, and the largest national video programming distributors, to introduce video descriptions in their transmissions to allow viewers with visual disabilities to access television. FCC Notice of Proposed Rulemaking, it proposed that broadcasters affiliated with ABC, CBS, NBC and Fox should provide a minimum of 50 hours of described video per calendar quarter or four hours per week on prime time and/or children’s programming. In addition, the programming was marked to commence no later than 18 months from the effective date of the video description rules.

The FCC noted that the proposed rules were generally modelled after existing closed captioning rules. However, given that the technology is not similar, the FCC intended to proceed incrementally so as not to impose a significant burden on video programming distributors. The FCC identified that WGBH had been broadcasting described programming for over a decade with more than 1600 PBS programs, but also noted that less of 1% of overall television programming contained video description.

The FCC initially proposed to limit video description to analog broadcasters, but stated that it intended to apply the requirements to digital broadcasters in the future. It noted that while the flexibility inherent in digital technology may make the provision of video description even easier and less costly. It did not want to wait until the digital implementation was complete in order to introduce video description.

The FCC Notice of Proposed Rulemaking also requested comments on eventually applying video description rules to all video programming distributors, including TV broadcast stations, cable operators, direct broadcast satellite operators, home satellite dish providers, open video system operators, satellite master antenna television operators, and wireless cable operators using channels in the multichannel multipoint distribution service.

The FCC also asked for comments on the fact that SAP is employed in some markets for Spanish and other foreign language audio and how described video may conflict with this telecast. Furthermore, the FCC requested for comments on how emergency public safety messages, which scroll across the television screen, could be made accessible to persons with visual disabilities.

Clarification – Text that moves vertically is said to scroll. If it mores horizontally, it crawls.

The National Center for Accessible Media (NCAM) and the Coalition for the Blind recommended that the penetration level of 25 largest markets should increase incrementally to the top 200 markets by year four. In addition, the NCAM and the Coalition for the Blind proposed that over a 7-year period that all 22 hours of prime-time programming should feature audio description. It should be noted that these items were noted, but they were not considered in the FCC rules described below.

On July 21, 2000, the FCC adopted video description rules. It was ruled that commencing with the calendar quarter of April to June 2002, broadcasters affiliated with the major networks (i.e. as noted above) in the top 25 television markets will be required to provide a minimum 50 hours per calendar quarter or approximately four hours per week of described prime time and/or children’s programming. In addition, multichannel video programming distributors (MVPDs), such as cable systems, etc. with 50,000 or more subscribers will be required to provide video description for the same amount and type of programming on each of any or the top five national nonbroadcast networks they carry. Any broadcast station, regardless of market size, will be required to transmit any video description it receives from a programming provider if the broadcast station has the technical capability necessary to do so. Any MVPD will be required to pass through any video description it receives from a broadcast station or programming provider if the MVPD has the technical capability necessary to do so associated with the channel on which it distributes the programming with video description.

These new rules will apply to analog television. The FCC also ruled on broadcast stations or MVPDs that provide local emergency information as part of a regularly scheduled newscast, or as part of a newscast that interrupts regularly scheduled programming. The stations will be required to make the critical details of this information accessible to persons with visual disabilities. In addition, any broadcast station or MVPD that provides emergency information through a crawl or scroll will be required to accompany that information with an aural tone to alert persons with visual disabilities that the station or MVPD is providing this information. It should be noted that there have been "petitions for reconsideration" as it pertains to these new rules.

On July 26, 2000, America on Line (AOL) announced that it will make its software compatible with programs the blind use to convert digital information to speech or Braille. In turn, the National Federation of the Blind agreed to drop a lawsuit accusing AOL of violating the Americans with Disabilities Act.

Correction – The NFB did not “drop” its lawsuit; the case was put on hold for a year pending AOL’s promised upgrades.

Under the agreement, AOL will:

adopt a policy with guidelines for making AOL accessible to the blind and other people with disabilities;

make the next version of its software accessible to the blind; and,

ensure that other future AOL products are accessible to the blind.

There are currently 65 movie theatres in the U.S. that provide audio described movies. Twenty-five of these cinemas are commercial, whereas the remainder are comprised of IMAX theatres, theatres in both theme and national parks and Disneyland theatres.

United Kingdom

Estimates indicate that there are 1.7 million people in Britain with visual disabilities. This represents approximately 2.8% of the total population in the UK. The UK’s new digital terrestrial broadcasters must provide programming with descriptive audio later this year.

Under the Broadcasting Act, 1996 audio description on television was scheduled to have commenced in November of 1999. However, it was deferred to May 2000, and although broadcasters are currently conducting test transmissions, the receiving equipment is not yet available. The legislation states that digital terrestrial channels will have to provide 10% of their programming with audio description by the 10th year of their licence. This percentage will be achieved in 2% incremental increases in every second year. This legislation does not apply to digital satellite and cable operators. The United Kingdom is planning on issuing a white paper this autumn on communications’ reform. The Royal National Institute for the Blind (RNIB) has been campaigning for higher targets.

The digital terrestrial receivers employed in the UK do not have audio description reception capability. A module that fits into the common interface slot in receivers is presently being developed. This unit will carry the description audio signal. The module is expected to cost around $215 (Cdn). In the future, it is anticipated that the receiving capability will be built into set-top boxes and integrated digital television sets. The two soundtracks (i.e. the original program and the descriptive audio) are transmitted simultaneously. It is possible to transmit a mixed signal if a broadcaster has sufficient bandwidth and the receiver has sufficient capability.

British broadcasters (i.e. BBC, Channels 3, 4, 5 and Ondigital channels) are now transmitting audio description on a trial basis and in the next few months, approximately 40 visually impaired people will be able to receive these transmissions. Digital reception will be done via a set-top box, although some integrated digital televisions are available. The reception of the audio description for this interim service will not be via the module but via a second digital set-top box, with a special mixer, provided only for test purposes. Those viewers participating in this trial will be able to swap the second set-top box for a module, as discussed earlier, for further testing at the end of the year.

According to Mr. Neil Roberts, at the British Council Information Centre, the Independent Television Facilities Centre (ITFC) is responsible for the production of descriptive audio in the UK. Since its formation in 1975 as a technical facility, which serves specifically ITV. The ITFC reviews specifications, updates equipment and takes on new initiatives, including an ongoing staff training program. They are also responsible for closed captioning services. The ITFC will be opening the UK’s first audio description unit, providing services for ITV1, ITV2, Channel 4 and Film Four on Digital Terrestrial Television for this autumn.

Correction – IMS has done audio description in London for a year at time of this writing. The RNIB has described movies since 1994, most (if not all) of them done in-house.

Germany

IV. In Bavaria, the Bayerischer Rundfunk was Germany’s first (circa 1996) regional broadcaster to allocate a budget towards audio description. Approximately $100,000 was allocated for the audio description of several television programs. The Bavarian Blind Union has conducted some research with respect to audio description of German television. In 1997, a questionnaire was distributed to 2,600 visually impaired people aged 20 to 60 (i.e. the response rate was about 50%). Of this group 97% own a television and 81% watch television regularly. In addition, 90% of the respondents indicated that they would like some form of audio description. Interestingly enough, the respondents noted that they preferred audio description for films. Consequently in Germany, there has been open audio description on Bavarian television, developed in conjunction with the Bavarian Association of the Blind. The extent and amount of audio description is unknown at the moment.

ZDF, the second largest German broadcaster, has distributed audio described movies. ARD regional broadcasters have also experimented with audio description projects. Audio described programming is provided via the second audio channel of stereo television. It was anticipated that the introduction of digital television in Germany would lead to more private broadcasters showing interest in audio description. According to German authorities, digital television solves the technical problem of transmitting the extra audio soundtrack. Audio description can be received via a standard decoder.

In addition, the German Association for the Blind and Visually Impaired (DBSV) has been producing descriptive programming for certain television programs via the advent of audio descriptive movies. The first audio descriptive movie was broadcasted in 1993. By 1998, the DBSV initiated a project funded by the German government to provide audio description of various movie titles. The largest stumbling block for this group is funding. Currently the project is developing a training program for movie narrators in order to ensure high quality standards for movie narration. Typically, two narrators with no visual impairments work with a visually disabled person to produce movie titles. The production costs for a 90-minute film, which takes approximately five to seven days, are in the range of $6500 to $10,000 (Cdn).

Nearly all audio descriptive movies are produced by public broadcasters. Although SATELLITE SERVICES 1 and RTL, both private broadcasters, have produced some audio descriptive product. In 1998, the public broadcasting system produced and broadcasted over 20 video descriptive movies and 13 video descriptive serial programs. By 1999, the total amount of movies and serial programs had increased to 54. In the meantime, offerings have increased to the extent that, in the last three months, the public broadcasting system has produced 16 video descriptive movies and 6 video descriptive serial programs.

Similar to City-TV viewers’ complaints, satellite reception of audio described movies presents a technical problem. Audio description is also broadcast on one of the stereo channels. Viewers hear both the soundtrack and the narrative simultaneously. Consequently, many visually disabled viewers have difficulties adjusting their receivers or televisions, so that they may hear only the narrative. In addition, braille television guides, as well as regular guides, indicate programs featuring audio description. Information of video description can be assessed via videotext or via the telephone.

Netherlands

The Commissariaat voor de Media (Dutch Media Authority) reports that article 13 of the Media Act stipulates that the public broadcasting service should make its programs accessible for the total population. The Broadcasting Foundation of the Netherlands (NOS) has stated its intention to employ a technique of teletext in order to make its programs accessible for people with visual and hearing disabilities. According to its plans, the NOS will begin testing a technique of making subtitles audible for viewers who can not read conventional text (i.e. blind, illiterate and dyslectic consumers). The subtitles will be transferred to sound by a speech generator and will be encoded with the television signal. Decoders in the home will make the signal audible. The public network is targeting that 20% of their total programming will be accessible. The NOS is also contemplating audio description.

Other Countries

Reports of audio description on television in other countries are rather sketchy. In Italy, RAI used one of its audio channels to transmit audio description simultaneously with relevant television channels.

In France, l’Association Valentin Hauy has been producing audio description for several movies. In 1995, the municipality of Gaumont introduced the first movie theatre to feature audio described movies. France has also transmitted some audio described programs via SAP.

According to the CAB, current regulatory arrangements do not require Australian broadcasters to provide audio description on television. The Australian Department of Communications, Information Technology and the Arts issued a paper calling on comments on whether Australian broadcasters should provide audio description particularly since the conversion to digital broadcasting may provide an avenue to offer this type of on air service.

Nina Rosenkvist reports that Sweden has not done much to make television more accessible for blind or visually impaired viewers. There is a channel, which features a talking newspaper, and another television channel, which specializes in programming for viewers with hearing disabilities. Utbildningsradion is a channel specializing in educational programming and the majority of its programming is closed captioned for viewers with hearing disabilities. Sweden was the first country in Europe to offer audio description in a movie theatre. Sweden has featured audio description in movie theatres for almost 20 years. There are approximately 15 theatres in Sweden that offer audio description services for viewers with visual disabilities. In addition the Swedish National Theatre is one of Europe’s only touring companies to feature audio described performances. The company began to offer audio described performances in 1993.

In 1995, the European Audetel Project (see below) was discussed as a topic at a conference in Paris. This conference on audio description was arranged by the Association Hauy and featured delegates from Spain, Italy, France, Belgium and the UK. The delegates dealt with existing activities and future plans as far as audio description was concerned. At the time of the conference, only three of the above-noted countries had theatres that provide audio description, however all the countries at the conference reported on some video description being done in the realm of movies on videos.

Audetel

In 1991, the Independent Television Commission, the RNIB, the BBC and the ITV Network formed a consortium to research and develop the technology necessary to carry an additional sound channel into the home. This project was entitled the European Audetel project. The sound channel would enable the transmission of audio description.

In early 1992, work began on the technological requirements. The first step was to determine how audio description could be developed, along with the amount of information required to make programming accessible to persons with visual disabilities. Research was conducted with hundreds of visually disabled consumers to ensure that the audio description reflected their viewing needs and the type of voices viewers would prefer.

The technical research entailed the development and production of a prototype receiver. Fifty of these receivers were placed in the homes of visually television viewers. These viewers disabled were selected at random from a RNIB database of 60,000 visually disabled people. During four months in 1994, the BBC and ITV Network ran three to four hours of described audio programs per week. A wide gamut of programs was described during this test. They included: Coronation Street; The Bill; Cracker and Taggart. The test also included wildlife series, such as Realms of the Russian Bear. The Audetel test also featured several audio described movies, such as: Beetlejuice; Close Encounters of the Third Kind; Truly Deeply Madly and Black Widow.

The survey and data collected from the test group indicated that the addition of audio description was welcomed. The viewers noted that it was deemed to enhance the enjoyment of viewing television by visually disabled consumers. One of the more important facets of the described video was the description of facial expressions, especially when people’s emotions were crucial to the development of the plot.

The test was set up to evaluate the possibility of audio description for analogue terrestrial television. The test service employed half of a VBI line to transmit the audio description to a specifically designed sound-only audio receiver. In addition, the Audetel project included the publication of an annual newsletter. The newsletter featured articles about descriptive video in various countries. The Audetel project, however, was superseded by the introduction of digital television in Europe.