For the past several months, we’ve been treated to regular updates on the status of the new digital broadcast system, IBOC, or in-band, on-channel. As the FCC and Congress discovered during the debate over low-power FM, including as many broadcast interests as possible is smart. Ibiquity, to its credit, has been feeding us information all along, and now that we have a ruling from the commission, it looks as if everyone is ready to leap into the digital stream.
However, there is a whole lot of work still to be done on the new system. For AM, we don’t know about night-time service, and on the issue of additional data channels, we have no test results on interference to the main carrier, subcarriers or even adjacent signals.
For commercial radio, this might mean the difference between a quick adoption of the new system and a DTV-like rollout, taking years to get off the ground. For reading services for the blind or visually impaired, the availability of additional data capacity at the time of implementation is essential.
With a change of this magnitude, the new system should do it “right” the first time. Any system that goes into place now must provide for the needs of all Americans, and that means people with disabilities too.
Benefits to all
IAAIS, the International Association of Audio Information Services, a member-based association of reading services for blind and visually impaired persons worldwide, stated in its comments to the FCC that a system that includes the capacity for additional datastreams benefits everyone.
It’s not just smart for the community and public radio operator, it’s smart for commercial radio. If manufacturers and broadcasters all agree to utilize the capacity for additional programming feeds from day one, let’s look at some of the benefits:
* Faster adoption of the new system by consumers who want to receive the additional program material, data service or auxiliary information.
* The cost to adopt IBOC drops sooner for broadcasters and consumers.
* Additional audio/data services on commercial radio begin generating income to offset the cost of adopting the digital system.
* Increased justification for Congress to fund public radio’s digital conversion, because new services are being offered to a more diverse audience.
Of course, the first hurdle is exactly what so many of us said in comments to the commission. We need a clear standard. The new transmission system and digital receivers must include the use of secondary audio programming at the time of implementation, not in some far-off future.
For reading services on SCA, we proposed that the commission must require stations transmitting a reading service on its subcarrier to include the reading service when the transition to digital is implemented for the main channel.
The current FM IBOC does not offer subcarrier users such as radio reading services a good digital solution in its Hybrid Mode. At present, the only digital solutions available to us would involve a station devoting some of its bandwidth to auxiliary data use, using 80 kbps instead of the standard 96, for example. In a highly competitive market, this is unlikely.
The second possible solution is the use of “Extended Hybrid Mode,” where a larger chunk of spectrum is devoted to the digital signal. The lack of a digital home for reading services is of concern because the hybrid phase could last for many years.
Ibiquity has not thoroughly tested this mode of operation and admits that some interference is likely to some analog radios. Further, both these approaches presuppose a disability friendly radio receiver exists that could decipher the additional data capacity.
No digital home?
Without a predefined standard, the solution for digital supplemental program carriage is unlikely at best. That would mean millions of Americans who are blind and disabled and who now rely on reading services on SCA must suffer additional interference to the already fragile signal until the hybrid mode is over and full digital broadcasting commences.
Not having a digital home for reading services increases the risk that advocacy groups in the disability community will mobilize and seek legislative redress to the issue.
Conversely, with more programming streams in the digital signal – public and commercial – it makes better sense to manufacture radios that are able to “hear” all the streams, giving incentive to even more consumers to purchase the new digital radios, including millions of Americans with disabilities.
This is a golden opportunity for the commission to make a “home” for the nation’s reading services. Ever since the phase-lock-loop made the use of a subcarrier minimally viable for receiving audio, subcarrier space has been targeted for commercial use. Only radio reading services have “gone the distance” and made a broadcast service work on SCAs. No other group has used the subcarrier technology to serve the public interest for more than 30 years.
Commercial ventures have come and gone, eventually giving up on the admittedly poor signals as not viable for commercial use. However, each time the forays into SCA space have damaged or eliminated services for people who are blind or visually impaired.
Imagine how dedicated the listeners of reading services must be to endure static and crosstalk, short receiver supply and, in some cases, regular outages. Reading services will be facing even greater pressure to clear out SCA spectrum space for commercial interests now that a digital datastream promises to make that space more robust and have higher fidelity.
Reading services should not be pushed off the air in the new digital system, nor be the only analog service that sounds “worse” without a digital stream to compensate for the loss. The advancing technology should not close doors, effectively isolating people with disabilities by stealing their access to information.
For instance, the intent of 82-1 and similar rules protecting reading services which use subcarriers on public stations should be applied in the new digital system to ensure that such services are not swept away in a rush to increase revenue or recover digital conversion costs.
Finally, the consumer radios in a digital world must be manufactured under the principle of “Universal Design.” IAAIS supports the idea of universal design, as do the American Council of the Blind, the American Foundation for the Blind, the National Federation of the Blind and other organizations that have been outspoken advocates for including the needs of people with disabilities in the design stages of a new consumer product.
IAAIS is pleased to have had its concerns receive the recognition of the commission, most notably in the joint statement issued by Commissioners Abernathy and Martin. We agree with their characterization of the new digital receiver as capable of interactive services.
Reading services could be the national showcase for accessible design and interactive digital radio products on the largest scale yet, if the FCC enforces Section 255 of the Telecommunications Act, which requires such products to be usable by people with visual or other disabilities. Making radios accessible is readily achievable. There are no digital radios for the average American home in mass production. The time for designing in talking displays, tactile markings and other time-tested accessibility features is now.
But back to the business issues. Requiring universally accessible design of digital radios eliminates the “chicken and egg” issue inherent to introducing the IBOC system, and promotes early public buy-in to the new technology. All consumers will have an incentive to buy new radios if there are digital streams available on the new radios that they never could hear before. There are millions of Americans who have disabilities. And, because universal design will speed the public’s adoption of a new technology, broadcasters will enjoy a larger audience of “digital listeners” sooner.
IAAIS took a proactive approach to meet with the commission staff regarding IBOC, much as it did with low-power FM, because both issues could negatively impact the IAAIS member stations’ ability to serve blind, legally blind, visually impaired and otherwise print-handicapped Americans. IBOC does not have to negatively impact reading services for the blind and visually impaired population, so let’s take the time to figure out how to do this right.
In comments to the NRSC Report, IAAIS asked the commission to protect reading services on SCA. If the hybrid mode and extended hybrid mode tests show that it will be impossible for the commission to protect reading services in the transition to digital, then let them find for all reading services a place to exist where they can deliver access to news and information without having to buy expensive special receivers and where the services will be able to grow and serve the vast population of people who cannot read because of a disability.