Blind Citizens Australia

Submission regarding the temporary trials of 3D TV and other emerging technologies

14October 2010

Manager

Operational Policy for Allocations and Licensing

Australian Communications and Media Authority (ACMA)

P.O. Box Q500, QueenVictoria Building, NSW 1230

Via email:

Prepared by Jody Holdback and Jessica Zammit

Contact:

Jody Holdback

National Advocacy Officer

Blind Citizens Australia

National Office

Level 3, Ross House

247 – 251 Flinders Lane

MELBOURNE VIC 3000

Phone: (08) 8298 6398

Email:

About us

Blind Citizens Australia is the peak national consumer body of and for people who are blind or vision impaired. Our mission is to achieve equity and equality by our empowerment, by promoting positive community attitudes and by striving for high quality and accessible services which meet our needs. As the national peak body, we have over 3100 individual members, 16 branches nationwide; in metropolitan, regional and rural locations and 13 affiliate organisations that represent the interests of Australians who are blind or vision impaired.

Introduction

Blind Citizens Australia acknowledges that the ACMA discussion paper, in the main, refers to the trial of 3D technology as its core focus. It is our concern as the peak consumer organisation that significant attention is being directed towards the trial of 3D technology to the detriment of core and viable access technologies such as audio description. The following submission is in response to ACMA’s interest in assessing the demand for access to the temporarily available spectrum for purposes other than 3D.

While Blind Citizens Australia appreciates that there may be other uses of the spectrum, we assert trials of audio description must be at the forefront. Put simply, audio description can mean the difference between television viewing or inaccessible television viewing. This ‘difference’ has far reaching implications not only on social inclusion but on market factors such as program ratings, advertising revenue and product awareness, with a substantial market share untapped due to inaccessibility.

Australian Bureau of Statistics (ABS) data[1] indicates that in 2007-2008 at least 412,700 people[2] aged 65 years or under were blind or vision impaired in Australia. Of these, approximately 61,000 were estimated to be totally blind or legally blind. Legal blindness in Australia is defined at 6/60 or a visual field of less than 10 o. These statistics relate to vision loss which cannot be corrected by corrective lenses or treatment.

Blindness is also strongly correlated with ageing. Access Economics estimates the numbers of people who are blind or vision impaired to be higher again than the figures presented by the ABS, with 2009 estimates suggesting that over 575,000 Australians aged over 40 had vision loss, with 70% of this population aged over 70 years of age (approximately 402,500)[3].

In March 2009, Roy Morgan released findings which suggested that people aged over 65 years of age spend 26.2 hours watching television per week[4]. Looking exclusively at over 70s and applying the statistics obtained from Access Economics, this would equate to approximately 10,545,500 hours of potentially lost viewing by people who are blind or vision impaired in this age group.

This is the same programming which is watched and enjoyed by the Australian public, but is largely inaccessible to people who are blind or vision impaired. This figure does not take into account the remaining demographics, with millions more hours potentially lost and unwatched.

Whilst 3D TV may provide additional choices in entertainment, this technology is unlikely to provide the same potential market benefit and heightened levels of social inclusion. Extending this point, the trial of 3D can be rightly viewed as an item of luxury rather than a core service which must be delivered in this timeframe.

What is Audio Description?

Audio Description is the descriptive narration of prominent aspects of visual elements of a TV program, movie, DVD, performance or other media, allowing access for people who are blind or vision impaired. It may be pre-recorded and delivered as an option for television programs, cinema or DVDs, or it may be performed live for events such as theatrical performances or sport. Audio description was developed in the US during the early 1980s.

As a comparison, captioning services for people who are deaf or hearing impaired have been available on Australian television since 1982. To date, there is no audio described content on Australian television. It is our assertion that captioning and audio description is conceptually the same in the information it delivers to each disability group. In essence, audio description allows a person who is blind or vision impaired to fully enjoy entertainment that is freely available to the Australian population, to partake in information access and recreation and to be able to interact with their peers in all arenas.

How is Audio Description created and broadcast?

An audio describer watches the program to ascertain what material needs to be described and the appropriate time for the description to be inserted. Specialised software is used to record the description which allows the program’s sound to be lowered when the describer is describing material and raised again when the original program resumes.

For the person who is blind or vision impaired to hear the audio description on television one of two methods are required to stream the material:

1. Broadcast mix streams two streams of the same program. The first is the regular programwhilst the second stream has the audio description mixed in and must be watched as an ‘open’ audio described program.

The first stream of the regular program takes approx 192 bits/sec. The other stream with the audio description mixed into the program also takes approx 192 bits/sec for delivery. Therefore, the delivery size of the two programs would double. A person, however, must choose which stream they wish to watch as they are only able to view one of these two streams at any given time[5].

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2. Receiver mix is different in that the second stream only carries the audio description and not the regular program. Along withthe audio description are promptsto allow the primary program to be lowered and raised at the appropriate time[6].

The second stream of the receiver mix only takes approx 64 bits/sec compared to 192 bits/sec (broadcast mix) – together,the combined size is just over half the size of Broadcast mix. This option requires less bandwidth to stream the regular program with the audio description[7].

An additional benefit to usingreceiver mix is the programs are mixed within the individual unit, either digital television or set top box and therefore can be switched on and off as required. This provides a ‘closed’ audio description service via a red button method, which is similar to captioning services.

The use of receiver mix is preferable for audio description users, as this allows flexibility at the receiver’s end. The volume of the audio description can be raised above the primary audio and the audio description can be passed through a headsetso the user can hear the audio description track of the program while others in the room hear the standard audio track.[8]

In the UK, audio description is receiver-mixed for digital free to air transmissions and broadcast-mixed for cable and satellite services. A large number of digital TVs and set-top boxes on sale in the UK can now access audio description.[9]The software used in these set top boxes can be included in equipment for the Australian market and there are also a number of televisions which are already receiver mix capable.

While we appreciate the ultimatedecision to use broadcast mix or receiver mix lies with ACMA, it is imperative people who are blind or vision impaired are consultedduring all parts of a trial to ensure that the production of audio description meets the needs of the people who will ultimately be using the service.

Many countries such as the UK, US and Canada already audio describe two of Australia’s long running dramas, Neighbours and Home and Away and more recent dramas such as Packed to the Rafters. Despite the production of these programs occurring in Australia, there is currently no move to audio describe these programs. This, in effect, is excluding Australians who are blind or vision impaired to enjoy, as it were, home grown television shows that clearly are able to be audio described for viewing. Other programs which are produced and audio described overseas also have the capability of being purchased, with audio description adapted for Australian television.

In addition to this submission, we recommend that ACMA read the submission prepared by Media Access Australia which further supports the trial of audio description on commercial television.

Availability of Audio Description

As the above mentioned countries are already well established in their use of audio description (with New Zealand starting trials in 2011)[10], Australia is now well behind other Western countries of the same calibre. This is also true when comparing audio description available via other mediums.

Audio description in Australian cinemas is set to rise, with a groundbreaking deal reached between the major cinema chains and disability groups in July 2010. By 2014, 100% of major cinema chain complexes will air content which is audio described and captioned for people who are blind, vision impaired, deaf or hearing impaired. In total, this will amount to 242 accessible screens around Australia. In addition to this agreement, there are 12 independent cinemas around Australia who also have accessibility features installed for use in their cinemas. Thisis leading the way for cinema access around the world.

Many theatrical performances in each state of Australia are also audio described, providing increased access to recreational activities within Australia.

Whilst audio description in cinema and in theatres increases recreational opportunities, it does not address timely information access. Cinema and theatrical performances are unable to provide people who are blind or vision impaired with daily news broadcasts, breaking news, emergency information, documentary programs, sporting programs, ongoing drama programs and much more which is only available via television viewing.

Legal underpinnings

Access by people with a disability to goods, services and facilities is protected under Section 24 of the Disability Discrimination Act 1992 (Cth)[11]. Free to air television would fall within this definition, leaving the industry open to complaints of discrimination on the basis of disability where television remains inaccessible. This is particularly pertinent where investment is made for new technologies without consideration of the needs of people with disabilities.

Internationally, the United Nations Convention on the Rights of Persons with Disabilities protects the individual rights of people with disabilities, with Australia a signatory to the Convention and the Optional Protocol.Participation in cultural life, recreation, leisure and sport is protected in Article 30, Section 1[12] which states:

1. States Parties recognise the right of persons with disabilities to take part on an equal basis with others in cultural life, and shall take all appropriate measures to ensure that persons with disabilities:

b) Enjoy access to television programmes, films, theatre and other cultural activities, in accessible formats

Blind Citizens Australia asserts that the availability of temporary bandwidth presents the Federal Government with an opportunity to meet their obligations under Australian legislation and the UNCRPD. It would be irresponsible to allow this opportunity to be bypassed in favour of 3D TV.

Recommendations

As ACMA is planning possible changes from the current Mpeg 2 frequency to Mpeg 4, it is imperative audio description is trialled on Channel B to ensure that audio description has a continuous place once the digital switchover program has been completed.

We recommend that:

  1. ACMA draw on their powers under the Broadcasting Services Act 1992 to make spectrum in the broadcasting services bands available for temporary periods and use this for the trial of audio description.
  2. Television stations to provide ongoing audio description service to commence no later than the end of the digital switch over in 2014.
  3. ACMA to enforce targets for audio description through each of the licenses obtained by the free to air stations.
  4. Channel B to be the medium to which audio description can be trialled using different equipment via both open and closed audio description, with a preference to receiver mix.
  5. Consultation is undertaken with all stakeholders to ensure the chosen equipment and the end services are user friendly for people who are blind or vision impaired. Without the use of Channel B and communication with stakeholders, this project would only move further backwards, causing frustration and alternative action between relevant parties.

This submission is available in alternative formats (large print, Braille, audio CD, email and on data CD on request) to be accessible to people who are blind or vision impaired.

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[1] Australian Bureau of Statistics (2009) National Health Survey: Summary of Results; State Tables, 2007-2008 (Reissue). Cat. No. 4362.0 Canberra: Commonwealth of Australia

[2]Total does not include people with blindness or vision impairment living in the Northern Territory

[3]Access Economics (2010) Clear focus: The economic impact of vision loss in Australia in 2009. Canberra: Access Economics for Vision 2020 Australia.

[4]Roy Morgan Press Release Article 853, March 04, 2009, online at

[5] Audio description background paper, Micul Chris, online at description s-and-other-resources

[6] Refer to Note 5

[7] Refer to Note 5

[8] For a detailed description of the user benefits of receiver-mixed audio description, see the BBC R&D White Paper ‘Audio Description: what it is and how it works’, online at

[9] For a full list of equipment available in the UK that can receive audio description, see RNIB’s website: description iofilm/television/audio description tv/Pages/audio_description_tv.aspx

[10] For more information go to

[11] Australian Government, Disability Discrimination Act 1992, online at

[12] United Nations, United Nations on the Rights of Persons with Disabilities, online at