In comments filed May 27, ACA asked the FCC to clarify that the video description rules will apply only to cable systems that serve 50,000 or more subscribers. ACA's clarification would replace proposed language that would have effectively reduced the number of small cable systems eligible for a legal exemption.
In the months ahead, the FCC is expected to roll out regulations implementing the Twenty-First Century Communications and Video Accessibility Act (CVAA), which includes mandates to provide brief narrations to video programming for the benefit of the blind and visually impaired. Initially, the FCC is planning to require 50 hours of video description per calendar quarter during prime time or on children's programming on each of the top five national non-broadcast networks.
ACA asked in its comments for the FCC to relax its scheduled compliance timeline by moving the start date for compliance monitoring to the 4th quarter of 2012. Relaxing the scheduled compliance timeline will help ensure a smooth roll-out of video description, ACA said.
ACA also sought an exemption for cable systems that are not technically capable of providing a third audio stream to accommodate video descriptions. Many ACA members provide analog broadcast service by converting the digital signal to analog to their subscribers, occupying two audio streams. Many ACA members also continue to rely on legacy set-top boxes and these set-top boxes cannot provide more than two audio channels to subscribers.
Lastly, ACA urged the FCC not to embrace strict standards so as to make it more difficult for small cable operators to assert they do not have the "technical capability" to comply with the regulations. Simply put, the FCC must continue to recognize that some cable operators may not have the technical capability necessary to pass through video descriptions immediately.
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