The following should be inserted into Section I.(D)(2) on page 4 of the April 7, 1998 proposal distributed by the Media Access Project.

(a) Create a mandate for broadcasters to take full advantage of new digital closed captioning technologies to provide the maximum choice and quality for caption viewers.

Historically, new communications technologies have been designed and developed without considering the needs of individuals with disabilities. Congress recognized the general failure of market forces to meet these needs when it enacted Sections 305 and 255 of the Telecommunications Act, requiring closed captioning on video programming and disability access to telecommunications products and services, respectively. Recently, the FCC issued regulations to implement Section 305, mandating comprehensive closed captioning of television programs over an 8-10 year transition period. In addition, since 1990, the Television Decoder Circuitry of 1990 has required that new television technologies, including digital technologies, be capable of transmitting closed captions to viewing audiences. Broadcasters should be required to take advantage of added bandwidth and other advanced features of digital technology to ensure the highest quality and maximum captioning choice for deaf and hard of hearing individuals. This will ensure that the captioning of the future is functionally equivalent to the picture and audio quality available to all Americans.

(b) Ensure access to digital streams for individuals with disabilities.

In addition to providing high definition and/or multiple streams of television programming, new digital compression technologies promise an array of alternative uses, including the rapid delivery of huge amounts of data, interactive educational materials, and other video subscription or non- subscription services. It is critical that the needs of individuals with disabilities not be ignored once again with the advent of these new technologies. Recent guidelines issued by the Architectural and Transportation Barriers Compliance Board and regulations proposed by the FCC implementing Section 255 of the Telecommunications Act, require manufacturers and providers of telecommunications products and services to provide access to their products and services by individuals with disabilities, with certain exceptions. These rules recognize that it is easier and less expensive to make products and services accessible when products and services are designed with access in mind. Among other things, these various mandates will require the provision of a text option for material that is presented orally and an audio option for material otherwise presented visually. Because the marketplace has typically failed to respond to the needs of individuals with disabilities, it is a logical extension of the access laws described above for the FCC to similarly require disability access to digital streams and to the various applications provided over those streams.

(c) Allocate sufficient audio bandwidth for the transmission and delivery of video descriptions.

Section 305 of the Telecommunications Act also recognized the benefits of video description of television programming, and directed the FCC to further examine the provision of this vital service for blind and visually impaired individuals. Video description consists of verbal descriptions of key visual elements in a video program which are inserted into natural pauses in the program's dialogue, without interfering with the original audio of the program. The narration provides access to visual information such as settings, gestures, action, graphics, subtitles, and costumes. The development of video description has been hindered by the analog TV standard, which permits delivery of descriptions via the secondary audio program channel only. In contrast, the digital standard offers multiple channels of audio, with significantly greater bandwidth, that can easily and inexpensively accommodate video descriptions. The Commission should set aside a portion of the digital audio bandwidth that permits the transmission and delivery of video descriptions. In order to ensure that Americans who are blind or visually impaired have equal access to video programming, a consistent, reliable, and mandatory audio standard of this nature is critical. If video description is subject to multiple and vaguely-defined formats, determined through market competition, costs to consumers and providers will be prohibitive and access will be seriously hindered.

In addition, the Commission should ensure that all manufacturers of digital TV receivers be required to support simultaneous multi-channel audio-decoding capability so that descriptions can be delivered separately from a programÆs main audio. Such dual decoding capability will require less bandwidth -- as it will not need to include the main program audio as well -- and will reduce the costs of the description process because professional audio mixing of sessions will not be necessary.

(d) The FCC should allocate sufficient bandwidth for the transmission and delivery of Radio Reading Services.

Through Radio Reading Services, blind and visually impaired individuals have been able to receive the content of newspapers, periodicals and books. However, the subcarrier radio space typically used for these services has increasingly been threatened. Setting aside a tiny fraction of bandwidth for the distribution of radio reading signals will have a minimal impact on the provision of digital television, but provide a significant benefit for the populations that have come to depend on these vital services.