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									                  DCITA REVIEWS
                    OF DIGITAL
                TELEVISION POLICY

     Submission to
   DCITA Reviews of
Digital Television Policy

      30 July 2004


Introduction .................................................................................................... 3
Regulation of Content on Multichannels ......................................................... 3
Implications for captioning .............................................................................. 4
Practicable Tests ............................................................................................ 4
Other Related Captioning Issues ................................................................... 5
    Additional Free-to-air Channel .............................................................. 5
    Captioning Quality ................................................................................ 5
    Digital regional TV ................................................................................ 6
    Consultation .......................................................................................... 7


A.     About the Deafness Forum .................................................................... 8


Under the Broadcasting Services Act of 1992, the Department of
Communications, Information Technology and the Arts (DCITA) is required
before January 1 2005 to review several aspects of its digital broadcasting
policy. One aspect being reviewed is whether the simulcasting restrictions
currently in place on free-to-air channels should be amended or repealed.
This matter has particular implications in terms of the captioning obligations
under which free-to-air broadcasters currently operate. The Issues Paper
released by DCITA for this review (and available to download on the web at,,0_1-2_10-3_483-4_118686,00.html) makes
specific reference to captioning in the section titled ‘Regulation of content on
multichannels’. While comment has not been sought regarding captioning
issues, the Deafness Forum believes those issues must be addressed and,
therefore, offers the following comments for DCITA consideration as part of
the reviews.

Regulation of Content on Multichannels

The DCITA Issues Paper states:

At present, the simulcast rules together with the restrictions on
multichannelling have meant that the rules applying to the analog channel
automatically carry across to the digital channel.

If simulcast requirements remain in place, the rules that apply to content on
the analog service automatically apply to the digital service. However, if
simulcast requirements are relaxed, consideration needs to be given to what
content rules apply to the digital version of the service.

If multichannelling was to be permitted, consideration would need to be given
to how content provided on these channels should be regulated. There would
be scope for applying different rules to the ‘main’ (or simulcast) channel to
those rules applying to the ‘multichannels’ (being secondary or niche channels
expected to have a smaller audience base).

Requirements are placed on broadcasters about the nature of the content
shown and the time and circumstances under which the content can be
shown. These include requirements relating to protection of consumers,
captioning requirements and children’s and Australian content requirements.
It could be expected that conditions placed on broadcasting content for the
protection of consumers (eg. relating to tobacco advertising) would apply to

It is also arguable that captioning requirements should apply equally to
multichannels as to the ‘main channel’ so that people who have a hearing
disability are not disadvantaged. However, there may be some practical
issues which need to be considered such as whether it is practicable to
caption several program streams live eg. if multichannelling of a sports event
were permitted.

                                                                        Page - 3
Implications for captioning

Particular issues that arise in relation to captioning on multichannels include:

   If simulcasting restrictions were relaxed, whether the current requirement
    for broadcasters to caption all prime time and current affair shows would
    still apply to both analog and digital services. Deafness Forum suggests
    that consideration be given to making captioning of analog TV a pre-
    condition to getting a digital license.

   Similarly, if simulcasting was not required of free-to-air high definition
    television (HDTV) broadcasts, whether the current requirement for
    broadcasters to caption all prime time and current affair shows would still
    apply to both standard and high definition digital services

   If multichannelling was allowed for free-to-air broadcasters, whether
    current captioning requirements would apply to each channel individually,
    or to the service provided by the broadcaster as a whole.

   How, if any of the above changes were to take place, the revised
    captioning requirements would be regulated.

Practicable Tests

In practical terms, one multichannel station has already been captioned,
following the requirements of the captioning regulations. For the duration of its
existence from the beginning of November 2001 until the end of June 2003,
all news and current affairs and prime time content on the ABC’s digital
multichannel, FlyTV, was captioned.

The issue of resources for the provision of captioning in a multichannel
situation needs to be considered. Although there hasn’t been sustained
multichannelling of programs such as sports a similar situation, which
replicates the multichannel environment, already exists. The captioning of
AFL is one example. Channel Ten in Melbourne broadcasts the entire AFL
game, even if it runs overtime. If a game does run overtime, the live AFL
broadcast is being captioned for Victorian viewers whilst the news is being
captioned for Channel Ten viewers in other states.

It can also be argued that the issue of what is practicable has already been
resolved in the original captioning regulations. This led to the captioning
quotas being set at all of prime time and all news and current affairs
programs. There have been no noticeable issues with the provision of these
captioning services, with the exception of some regional news broadcasts
(although these are about stations committing resources to captioning rather
than an absence of captioning organisations to provide the service). In fact,
since the captioning regulations were put in place, the free-to-air broadcasters
have negotiated increases to the captioning quotas via a HREOC agreement.
Finally, there has been a noticeable increase in the number of captioning
organisations in Australia, which suggests that there are more than enough

                                                                          Page - 4
resources to provide the volume of captioning contemplated under
multichannelling and other digital services.

The Deafness Forum’s view is that captioning must apply to multichanneling.
In the case of multichanneling several camera angles with the same voiceover
it would be possible to parallel-stream the captions on the multi channels, at
little extra cost. In the case of multichanneling different programs, each
program should be captioned.

In addition, the free-to-air TV stations have agreed with HREOC to continue to
increase their captioned programming, culminating in 70% of all broadcasts
between 6:00 am and midnight being captioned by calendar 2008. That
equates to a daily average of 12.6 hours of captioned programming per
channel per day on free-to-air. Deafness Forum does not recollect there being
any restriction in the agreement to the primary channel and holds the view
that any new channel should abide by the agreement.

It is noted that the PAY TV stations also have recently agreed to caption 20
(now) and 40 (later) channels of their service. While that agreement falls far
short of the expectations of Deaf and hearing impaired viewers and is
significantly lower than legislated requirements in other territories such as
Canada, Ireland, the United Kingdom and the United States, it does mean that
the PAY TV stations are also commencing captioning.

Other Related Captioning Issues

Additional Free-to-air Channel

There is a need to look at the proposed 4th commercial TV network that's
mooted about starting up. What would be the captioning requirements for
that? Presumably it would not automatically be covered by the current
agreement with HREOC. A requirement to provide captioning at the same
levels as have been agreed by existing free-to-air channels should be part of
the licensing conditions for any new free-to-air TV network.

Captioning Quality

Standards in the Broadcasting Services (Digital Television Standards)
Regulations 2000 are quantitative in nature and do not address quality. While
viewers have historically enjoyed good quality captioning, produced primarily
by the Australian Caption Centre and the Seven Network, recent captioning
by some regional stations has been decidedly substandard, to the extent that
in many cases those stations effectively do not provide any access to the
program for Deaf or hearing impaired viewers.

Following consultations with the deafness sector, Deafness Forum developed
a proposed Captioning Quality Code of Practice that it would like to see
adopted by all captioning providers and broadcasters, as well as
manufacturers of DVDs, videos and movies with captions. In respect to TV
broadcasters this includes all metropolitan and regional broadcasters, and all

                                                                      Page - 5
free-to-air and PAY-TV broadcasters. The Deafness Forum then submitted
the proposed Code to the broadcasting industry, and others, for adoption as a
regulatory reference for the quality of captioning.

At this point in time various deafness sector organisations, three captioning
companies, and one DVD manufacturer have endorsed the Code of Practice.
One movie company has advised that it would be delighted to work with
Deafness Forum to introduce a voluntary Code of Practice. The Commercial
TV Association, the Regional Broadcasters Association and ASTRA (the PAY-
TV association) have all given in principle support to the proposed code, and
various individual TV stations have taken some action to improve the quality
of their captioning. It is understood that when ABC TV recently called for
tenders for its captioning services, it specified that tenderers should meet the
standards in the proposed Code of Practice.

It is Deafness Forum’s view that minimum quality standards must be upheld,
otherwise access will be jeopardised. At the very least, these standards
should ensure that:

      a captioned program must be captioned in its entirety;
      the captions should appear as synchronously as possible with the
      information should accurately convey what is presented in the audio.

The Deafness Forum believes the Australian Broadcasting Authority is the
appropriate organisation to set and police standards for captioning in a similar
fashion to the way it currently polices children’s standards, and proposes that
the Broadcasting Services Act be amended to enable the Australian
Broadcasting Authority (ABA) to do this.

Digital Regional TV

The DTTB rollout is taking longer than expected and there is even doubt as to
whether all regional stations will rollout. In March 2004 Deafness Forum wrote
to the Australian Broadcasting Authority seeking clarification of the regulatory
requirements regarding rollout. The response advised that licensees are
regulated individually, rather than as part of a network. It also indicated that
the ABA’s responsibility is to approve rollout plans. The response did not even
acknowledge Deafness Forum’s concerns regarding the implications for
captioning of local content.

Where rollout has not occurred there is no captioning at all of local content.
Those stations should be required to caption now. In particular, the Deafness
Forum holds the view that all local content, particularly news and current
affairs, must be captioned as a matter of urgency. The Forum proposes that
the Broadcasting Services Act be amended to set a latest rollout date for all
stations and to set a date by which captioning quotas must be met (even prior
to DTTB rollout).

                                                                        Page - 6
Deafness Forum holds the view that all new televisions and digital set top
boxes sold should be required to have teletext capability. If digital television is
still a long way off for some regional areas then at least viewers in those
areas must have access to a wide range of choice of TV sets with Teletext
capability. The more televisions and set top boxes that are available with
Teletext capability, the more Australians will be reached by TV broadcasters.


The Deaf and hearing impaired communities are not generally consulted by
the ABA. Is there a consumer consultation committee to the ABA that should
include representatives captioning users? When the National Working Party
on Captioning was operating a representative from the ABA attended all of its
meetings, so it was aware of the needs of the Deaf and hearing impaired
communities. There is now no arrangement to ensure the ABA ascertains the
views of caption users. The Deafness Forum is the peak national body
representing the Deaf and hearing impaired communities of Australia, which
constitute the majority of caption users, and it would welcome the opportunity
to provide regular advice to the ABA regarding captioning issues.

                                                                           Page - 7
                                                                    ATTACHMENT A



Deafness Forum is the peak body for deafness in Australia. Established in early 1993
at the instigation of the Federal government, the Deafness Forum now represents all
interests and viewpoints of the Deaf and hearing impaired communities of Australia
(including those people who have a chronic disorder of the ear and those who are


The representational base of the Deafness Forum is divided into five Sections:

a) Hearing Impaired Section - persons with a hearing loss who communicate
   predominantly orally,

b) Deaf Section - i.e. the Deaf Community - those persons who consider themselves
   to be members of that community by virtue of its language (sign language known
   as Auslan) and culture,

c) Ear Disorders Section - persons with a chronic ear disorder (such as Tinnitus,
   Meniere’s Disease or Acoustic Neuroma) and

d) Parents section - parents or legal guardians of persons who are Deaf or hearing

e) Service Providers section - service providers to the Deaf and/or hearing impaired


The Deafness Forum exists to improve the quality of life for Australians who are
Deaf, have a hearing impairment or have a chronic disorder of the ear by:

   advocating for government policy change and development
   making input into policy and legislation
   generating public awareness
   providing a forum for information sharing and
   creating better understanding between all areas of deafness.


As at 30 June 2004, the Deafness Forum had 74 organisation members and 155
individual members. It also regularly consults with all other known organisations
operating in the deafness sector that are not amongst its membership, so that it is
adequately equipped to effectively represent the interests of its entire constituency.

                                                                                Page - 8
Systemic Advocacy

Deafness Forum undertakes systemic advocacy at the national level on behalf of its
constituency. Some examples of systemic issues pursued are:

   an adequate supply of affordable Auslan interpreters to meet demand in all key
    areas of life, including education, employment, medical services and justice.

   an alternative to the GSM digital mobile phone network, in order that people with
    hearing aids could continue to use mobile phones after the analogue system was
    phased out.

   a voluntary Code of Practice for the hotel, motel and accommodation industry
    regarding the provision of access facilities of importance to Deaf and hearing
    impaired guests and staff, such as emergency equipment and procedures that
    ensure safety in the event of emergencies (e.g. fire), captioning on TVs and
    volume control on telephones.

   a standard relating to the quality of captioning provided on TV broadcasts,
    movies, videos and DVDs.

   affordable access to hearing health services for low income adults, including
    improved Medicare and private health insurance benefits.

   adoption of hearing health as a national health priority.

Other systemic issues currently on the Deafness Forum’s agenda may be found on
its Website.

Major Ongoing Projects

Hearing Awareness Week

Deafness Forum co-ordinates the national aspects of Hearing Awareness Week, held
annually in the final week of August. It determines the theme for each year (in
consultation with members), develops and makes available posters and other
promotional material, identifies the types of events that local groups might organise,
arranges the production and screening of community service announcements on TV,
and maintains a Website which includes information on events and a variety of
resource material.

Educational Scholarships

Deafness Forum awards up to five scholarships annually to Deaf and hearing
impaired persons undertaking post-secondary study. The key target groups are
students from rural and remote areas, from non-English speaking backgrounds and
from the indigenous community. The scholarship funds may be used for a wide
variety of purposes, including tuition and text materials, but not for services deemed
to be the responsibility of the educational institution under the Disability
Discrimination Act 1992 (such as Auslan interpreters). The purpose of the
scholarships is to provide financial assistance to facilitate and enhance participation
in post secondary education and increase the number of Deaf and hearing impaired
students attending post secondary education courses.

                                                                                Page - 9
National Deafness Sector Summits

Deafness Forum conducts regular national deafness sector summits. These events
are designed to enable representatives of the many organisations working in the
deafness sector to discuss national issues, assist develop sector policy positions,
identify needed actions and plan advocacy campaigns designed to achieve the
needed actions. Three summits have been conducted to date, the last of those in
May 2004. The current intention is to conduct such summits every second year in

Libby Harricks Memorial Orations

Deafness Forum conducts regular Orations in memory of, and to honour, its founding
Chairperson, Libby Harricks - a profoundly deaf achiever. The orations are aimed to
create greater public awareness of the hearing problems associated in the broadest
sense with the Deafness Forum’s constituency, to publicise the Deafness Forum’s
national role and to highlight the work done on behalf of the Deaf and Hearing
Impaired community by voluntary groups throughout Australia. Six Orations have
been held since 1999, all delivered by people who are experts in their fields. All
Orations have been published as monographs in order to reach wider audiences, and
some have been released also as captioned videos. The current intention is to
conduct future Orations as integral parts of National Deafness Sector Summits or
other significant Deafness Forum events.

Captioning Awards

The Deafness Forum has introduced an annual awards program to recognise
achievements in relation to captioning, with the purpose of helping promote the
extension of captioning. The Awards will be presented at a luncheon or dinner event
on the day of the Deafness Forum’s Annual General Meeting each year
(commencing in 2004). The six awards to be offered each year are:

   Best Community Achievement (the Roma Wood OAM Community Award).
   Best New Captioning Initiative.
   Special Captioning Achievement.
   Most Consistent Use of Captioning.
   Best Promotion of a Captioned Video/DVD or Movie Screening.
   Best Promotion of Captioning Facilities.

Community Involvement

The following pen pictures of the Deafness Forum’s current Board members and key
staff demonstrate the broad extent to which that group of people are involved with the
specific deafness sector and the broader disability sector. It is these involvements, as
well as the Deafness Forum’s own activities and consultative processes, that ensure
the Deafness Forum is consumer-driven and well able to effectively represent the
interests and concerns of the entire deafness sector, including:

   people who have a hearing impairment
   people who are oral deaf
   the signing Deaf community
   people who have a chronic ear disorder
   the DeafBlind community
   parents who have children from one of the above groups in their families

                                                                               Page - 10
Margaret Robertson (current Chairperson)

Margaret has been a Director of the Deafness Forum since October 1999, and was
elected as Chairperson in October 2002. She lives in Parkville, Victoria and was
elected as a Director by the Hearing Impaired Section. She has a progressive,
sensorineural hearing loss and has been reliant on hearing aids for nearly 20 years.
She also uses various other techniques to assist her communicate. These include
assisted-listening devices, captioning and speech reading. Her professional life was
spent as a Psychologist and she worked in university counselling for 23 years, eight
as the Director of a Counselling Service. She is now retired but her interest continues
in promoting a cognitive-behavioural approach to rehabilitation for hearing loss and
tinnitus. She has a history of involvement with community organisations, in particular
Better Hearing Australia Victoria where she has served on the Committee of
Management since 1997. She also provides articles, workshops and training
programs on rehabilitation and counselling topics to self-help groups in the sector.
She also served as a member of the Victorian Government’s Reference Committee
for the Redevelopment of Services for Deaf and Hearing Impaired people. Margaret
currently represents Deafness Forum on the Hearing Services Industry Forum.

Ruth Fotheringham (current Deputy Chairperson)

Ruth has been a Director of the Deafness Forum since October 2002. She lives in
Seven Hills, NSW and was elected as a Director by the Hearing Impaired Section.
She has had a hearing loss for over 30 years and acquired a cochlear implant in
2002. She joined Better Hearing Australia in 1972 and is still an active member,
being on the Committee of Management for BHA Sydney. She also is a member of
the Blacktown City Council Disability Access Advisory Committee and the Deafness
Council of NSW Committee. Ruth previously has been a member of the Australian
Hearing Services Steering Committee for Expanded Service Delivery, the
Commonwealth Government’s Hearing Services Advisory Committee and the
External Review Panel for the NSW TAFE Audiometry Certificate Courses. She also
has a wider interest in people with disabilities, having worked as a Social Educator
for people with an intellectual disability prior to retirement. She currently represents
the Deafness Forum on the Board of the Australian Federation of Disability

Kathy Challinor

Kathy has been a Director of the Deafness Forum since October 2002. She lives in
Tamworth, NSW and was elected as a Director by the Ear Disorders Section. She
has Tinnitus and a mild-to-moderate hearing loss herself. She has extensive
experience in hearing assessment and knowledge of hearing difficulties arising from
her employment as a Clinical Nurse Consultant Audiometrist for over 20 years. Kathy
has a particular passion about noise injury prevention in rural communities and the
need for appropriate hearing services in rural and remote Australia. She has been
involved in the development and delivery of a Graduate Certificate in Audiometry
Nursing, which is offered through TAFE to registered nurses throughout Australia
from 2003. Kathy is involved in the professional organization for Nurse Audiometrists.
in. She is also a member of both Self Help for Hard of Hearing and the Australian
Tinnitus Association (NSW) and a counsellor for ATA.

                                                                              Page - 11
Jo Quayle

Jo has been a Director of the Deafness Forum since December 2002. She lives in
Echuca, Victoria and was appointed as a Director to represent the Parent Section.
One of her children has a severe bi-lateral sensory neural hearing loss. He
undertakes his studies as a mainstream student with the assistance of a trained
Teacher of the Deaf (Visiting Teacher Service) and a trained note taker. Jo has been
involved with the Parents of Hearing Impaired Children Victorian Federation since
1992 and has been its President for three years. She has served on a reference
committee that fine-tuned the establishment of Deaf Infolink throughout rural and
regional Victoria, for the Victorian Minister for Human Services. She is a member of a
reference group with the Office of School Education in Victoria to assist with an
analysis of government support and services provided for Deaf and hearing impaired
students in Victorian government schools.

Veronica Pardo

Veronica has been a Director of the Deafness Forum since October 2002. She lives
in Melbourne, Victoria and was elected as a Director by the Service Provider Section.
She is currently employed by Deaf Children Australia. Previously, Veronica has held
positions relating to Auslan curriculum, Deaf studies and sign language research.
She has a passionate interest in empowering people and is committed to working
proactively to achieve systemic social change in a way that benefits service users
and affords them self-determination to direct that change.

Therese Pierce

Therese has been a Director of the Deafness Forum since October 2003. She lives in
Melbourne, Victoria and was elected as a Director by the Deaf Section. She has
been the Principal at Victorian College for the Deaf since 1999 and is only the
second deaf principal in 121 years. She studied in Perth, Melbourne and
Washington, D.C. and earned degrees in education, special education, counselling
and administration. In 1988 Therese participated in the first Deaf Civil Rights
Movement in Washington, D.C. She has a wide range of professional experiences in
Australia, USA and New Zealand and is a strong advocate for bilingual education for
students who are Deaf or hearing impaired.

Lee-Anne Sargeant

Lee-Anne has been a Director of the Deafness Forum since October 2003. She lives
in Ballarat, Victoria and was elected as a Director by the Service Providers Section.
She is a clinical audiologist with experience in the diagnostic, rehabilitative and
community education areas of audiology. She has a personal involvement with the
many issues that surround hearing loss, reflecting the fact that she has two
congenitally deaf sisters. She has a strong commitment to promoting better
information, access and acceptance of hearing loss in the community. She has
conducted ongoing liaison and working relationships with the Wimmera Hearing
Society, Better Hearing Australia and the Association of Disability in Ethnic
Communities. Her experience in the community education area is extensive and she
has been involved in national awareness raising through Hearing Awareness Week
campaigns each year since 1999.

                                                                             Page - 12
Gary Kerridge

Gary has been a Director of the Deafness Forum since October 2003. He lives in
Ballarat, Victoria and was appointed as a Director to represent the Deaf Section. He
is currently employed at the University of Ballarat developing strategies to enhance
post-secondary options for students with disabilities. He has previously worked in a
support role for three Deaf aboriginal students in a classroom setting, developing
programs that promoted positive mental health for young people who are Deaf,
hearing impaired, blind, vision impaired and deafblind, and as a Case Manager for
Deaf and hearing impaired children and their families. He has been involved with the
National Mental Health Education Project for Young Deaf people.

Bill Hick

Bill has been a Director of the Deafness Forum since October 2003. He lives in
Engadine, NSW and was appointed as a Director to represent the Ear Disorders
Section. He has had a long involvement in the building industry, as a bricklayer and
TAFE teacher. He is currently self-employed and semi-retired. In 1997 Bill wrote a
TAFE (NSW) guide on the correct use of a brick saw, which included a chapter on
hearing protection and Tinnitus. Since 2001 he has visited TAFE colleges on behalf
of he Australian Tinnitus Association (NSW), talking to students about noise-induced
hearing loss and noise-induced Tinnitus. To date, he has spoken to over 1,000
students and teachers. The main aim of this program is to inform about the risks from
exposure to excessive noise, how physical damage occurs and how to protect
hearing. Bill is also a regular contributor to the ATA (NSW) Newsletter and Bulletin
Board, as well as newspapers and community radio.

Gail Smith

Gail has been a Director of the Deafness Forum since March 2004. She lives in
Coolum, Queensland and was appointed as a Director to represent the Parent
Section. One of her children is deaf. She is very motivated to provide the best
educational outcomes for her daughter. Gail has previously worked as an Auslan
interpreter. She attended the 2000 ANZCED Conference.

Brian Rope OAM

Brian has been Chief Executive Officer and Company Secretary of the Deafness
Forum since April 1996. He has an extensive history of involvement with community
organisations, in particular the Councils on the Ageing at both ACT and National
level. He was awarded an OAM in 1992 for his services to the community. He has
worked in the general disability sector for over a decade. He was a Deafness Forum
representative on the National Caucus of Disability Consumer Organisations until it
ceased to operate and was a member of the working group that established the
Australian Federation of Disability Organisations. Brian is also Deputy Convenor of
the Disability Discrimination Act Standards Project, a member of the Attorney-
General’s Working Party on DDA Standards and a Deafness Forum voting
representative to the Australian Council of Social Service.

Robyn Swadling

Robyn has been the Deafness Forum’s part-time (6 hours per week) Administrative
Officer since February 2002. She has an extensive history of involvement with church
organisations and their activities. She also has experience of providing support
services for students with various disabilities, through the Australian National

                                                                            Page - 13
University’s Disability Support Unit. When not working for the Forum, Robyn is
employed elsewhere as a medical typist.

Kirsten Preece

Kirsten has been a Policy & Project Officer of the Deafness Forum since October
2002. She has immediate family members with deafness, Tinnitus and Meniere’s
Disease. She has an extensive history of paid and voluntary work with a variety of
church and community organisations. Those involvements have included being an
English language tutor and teacher, a direct care worker and a nursing aide. She has
undertaken a review of a disabilities service, taught English to Japanese students
with disabilities and advocated for children, youth and people with disabilities. Kirsten
is currently a member of the Christian World Service committee and its International
Programmes sub-committee, and a member of the Uniting Church Assembly
Theology and Discipleship Reference Group. She is currently on extended leave.

Linda Tregonning

Linda has been Policy and Projects Manager of the Deafness Forum since January
2004. She has previously been employed in a number of other associations,
including the Pharmaceutical Society of Australia, Certified Practicing Accountants
Australia and the Institution of Engineers Australia. Her roles with those associations
have included responsibilities in the areas of office management and professional
development. Linda completed a Certificate in Association-Management Program at
the Mt Eliza Business School of Monash University in 1998. She has had an
extensive involvement with the Canberra Philharmonic Society for more than 25
years in a range of voluntary administrative, committee and performance roles. She
was granted Life Membership of the Society in recognition of her contributions.

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