Copyright 2000 Federal News Service, Inc.
Federal News Service
February 17, 2000, Thursday
SECTION: PREPARED TESTIMONY
LENGTH: 709 words
HEADLINE:
PREPARED TESTIMONY OF DAVID NOBLE PRESIDENT OF INTERNATIONAL ASSOCIATION OF
AUDIO INFORMATION SERVICES (IAAIS)
BEFORE THE
HOUSE COMMITTEE ON COMMERCE TELECOMMUNICATIONS SUBCOMMITTEE
BODY:
Thank you for the opportunity to submit
a written statement for the record on behalf of the member stations of the
International Association of Audio Information Services (IAAIS), a group of non-
profit services for blind, legally blind, visually impaired, and other disabled
populations.
In the United States alone there are more than 100 services
offering print access to an estimated 1.2 million Americans. These subcarrier
services are typically low budget, non-profit organizations that engaged
volunteers in every aspect of operations and management. They are true,
grassroots organizations that listen carefully to the voice of their community.
Thank you for the opportunity to comment on the Federal Communications
Commission's (FCC) plan to establish a new low power FM radio
service.
While we support the goals contained in the Report and Order
establishing LPFM stations, we remain concerned that the introduction of LPFM
may be detrimental to the people who depend on radio reading services.
Specifically, we believe that interference may disrupt service and we seek a
process to resolve potential interference.Daily services from our member
stations keep elderly blind and visually impaired residents in touch with their
communities. They are better able to live in their own homes, maintain
independent lifestyles, and contribute to rather than live off of society. With
daily news they can initiate conversations and offer opinions rather than sit at
home alone and lonely. Editorial pages encourage them to be involved in the
community. With local event listings, they can plan trips for themselves or
their family. At election time, they hear the candidates' qualifications read
and make informed choices in the voting booth. When interference makes listening
impossible, all these benefits are gone. There is no other service available.
Because subcarrier delivered reading services are at 92 or 67khz they
are more fragile and more subject to interference. Since 1976 when C. Stanley
Potter founded the first reading service in Minnesota, interference and poor
reception in the secondary contour has been a part of subcarrier services
history. The Association remains greatly concerned that its members will not
have the ability or means to have interference acted upon quickly enough in a
low power FM world without appropriate protections.
IAAIS members are for the most part, unable to keep an engineer on staff
for budgetary reasons. As the Commission knows, the subcarrier stations do not
hold a broadcast license. They provide programming to main channel operators who
hold the license. What standing will a reading service have in an interference
situation? Most main channel operators are also non-profit, public stations. The
cost to hire appropriate personnel to monitor and prosecute interference would
bankrupt a typical reading service and threaten the financial health of the main
channel public station.
It has been argued that reading services should
avail themselves of the low power opportunity and "snap up" LPFM licenses to
replace their fragile subcarrier signals. This is not economically feasible. The
cost to operate the low power station and the range restrictions low power
imposes are both detrimental to the listeners, and that's where IAAIS concerns
come full circle.
The FCC has long recognized that reading services for
the blind need protections and in fact, the FCC has helped to create regulations
that make reading services possible. Now reading services need continued
protection, especially in a FM band that is "tighter" than ever before. IAAIS is
relieved that 1st and 2nd channel protections remain intact and thanks the
Commission for hearing IAAIS members' concern and acting accordingly. However,
we are concerned that future FM subcarrier would not have the same protections
from LPFM as existing services.In grade "B" contours, where no protections exist
at all, reading services and other subcarrier services will be the first to
experience interference from neighboring LPFM stations.
Although
increasing diversity of programming and ownership is important, the FCC must not
pursue these goals to the detriment of existing service for the blind and
print-impaired.
END
LOAD-DATE: February
18, 2000 
