TV Captioning Part 2 – Act Now to Improve Captioning
30 10 2005TV Captioning Part 2 – Act Now to Improve Captioning
By Cheryl Heppner, 10/24/05
Many people who were unable to attend NVRC’s 10/22/05 workshop on TV Captioning asked us to share the information. Part 1, which was sent on 10/23/05, gave a quick recap of the laws and regulations related to captioning on TV, followed by a list of challenges we face.
The second part of the workshop was about taking action. We now have an opportunity work to fix some of the problems with captioned TV. Let’s tackle them by sending comments to the Federal Communications Commission (FCC )about potential changes in the captioning regulations. You do not need to be deaf or hard of hearing to send comments. Poor caption quality affects everyone. Friends and family members also know how important high quality captions are to building reading skills and vocabulary, and how they enable us to enjoy television together instead of turning TV watching for education or entertainment into a frustrating experience. And sometimes, even without hearing loss, people depend on captions in noisy places or to watch TV when the kids are sleeping.
Background
In 2004, Telecommunications for the Deaf and Hard of Hearing (TDI) drafted a Petition for Rulemaking to address many issues that affect caption quality and how complaints are handled. NVRC worked with TDI for approximately six months on the petition. The petition gives references to several documented complaints about problems with captioning, and includes copies of the complaints in an appendix. Most, if not all, of these complaints were originally received by NVRC; the individuals who sent them gave permission for them to be used.
The final petition was signed by TDI, National Association of the Deaf, Self Help for Hard of Hearing People, the Association of Late-Deafened Adults, and the Deaf and Hard of Hearing Consumer Advocacy Network. It was submitted to the FCC on July 23, 2004.
The FCC reviewed the petition and decided that our requests merited action. In July 2005, it released a Notice of Proposed Rulemaking, which was recently published in the Federal Register. The notice talks about our consumer petition and asks for comments to answer a number of questions. The deadline for the comments to be received by the FCC is November 10, 2005. If you miss this deadline, there is a second chance to meet the deadline 15 days later on November 25, 2005 to send “reply comments”.
The National Cable & Telecommunications Association sent comments to oppose our consumer petition when it was filed, but the National Association of Broadcasters did not send in any comments, nor did any other businesses or trade organizations that would be affected by changes to the captioning regulations.
Things to Remember
When writing your comments, you should include:
- Why changes to the caption rules are important to you (your experiences are helpful)
- What changes you suggest to improve closed captioning qualityIt is also REQUIRED that you provide:
- Your full name and addressYou can start your comments with an example or two that show how captions have helped you, or could help you.
What to Comment About
The FCC’s Notice of Proposed Rulemaking asks a number of questions. Some of them can only be answered by people involved in captioning and distributing the programs – broadcasters, captioners, etc. Nine of the questions are best answered by us, the people who watch TV captioning. NVRC has pulled these out, and after each question we have included the position taken in the petition submitted to the FCC by TDI and other consumer organizations. You can comment on all of these questions, or choose to comment only on some. If you feel there are other important issues related to caption quality and the complaint process, you can comment about those too. Here are the questions:
1. Do you think there should be standards for the non-technical quality of closed captioning?
Our petition requested:
The FCC should adopt standards; no program should be considered “captioned” unless it meets minimum standards for completeness, accuracy, readability, synchroncity with the audio.
You can comment on what you think should be included in standards, such as: accuracy, spelling, grammar, punctuation, placement of captions, timing, identification of nonverbal sounds, style of captions (pop-on or roll-up), verbatim or edited for reading speed, type of font.
You can also comment about whether you think the standards should be different for pre-produced or live captioning.
2. Do you think there should be a different process to take care of technical problems with captioning immediately?
Our petition requested:
The FCC should establish and maintain a database with updated contact information for video programming distributors and providers, enabling consumers to quickly locate who to call with a complaint – name, address, TTY/toll free phone number, fax number, e-mail address. It should be updated within 7 days of any changes.
3. Do you think there should be a change in the complaint procedure for captioning?
Our petition requested:
The FCC should adopt a captioning complaint form (an example was provided in the petition to give a standard way to report problems)
The FCC should change the complaint rules to require responses to complaints on quality issues within 30 days. Currently it could take up to 4 months if a consumer submits a complaint at the beginning of a quarter.
4. Do you think the FCC should set a penalty for captioning that is missing, dropped, garbled, inaccurate, etc.?
Our petition requested:
The FCC should establish fines. We suggested a base $8,000 per infraction, the same as the fine for children’s television programming requirements.
5. Do you think “video program distributors” (broadcast, cable, satellite) should be required to file compliance reports about the amount of closed captioning they provide?
Our petition requested:
The FCC should require compliance reports and do audits to ensure the effective implementation of captioning requirements.
6. Do you think the requirement for realtime captioning of TV news programs should be expanded beyond the “top 25” markets?
Our petition requested:
The FCC should extend the ban against using electronic newsroom technique (ENT) beyond the “top 25 television markets” (detailed in our Part 1 email). We need the news not just at home but when we travel, and captions provided through ENT leave out much of the most important information we need – weather and travel updates, live interviews and field reports.
7. Do you think that filing of electronic requests for exemption from the closed captioning rules should be permitted?
Our petition did not address this issue. We are not sure how electronic requests for exemption would be structured. What we want is an easy way to learn about these requests so we can file in opposition if we disagree, and a way to reduce delays in processing them. In the past, requests for exemptions often weren’t acted on for months or years. While waiting for the FCC’s decision on their petition, the petitioners were allowed to continue to provide programs without captions.
8. Do you think there should be a procedure to prevent and remedy technical problems?
Our petition requested:
The FCC should require continuous monitoring by video program distributors or providers – and routine checks of their equipment — to ensure that technical problems are remedied promptly and efficiently. We also asked that the FCC require video programming distributors to reformat edited or compressed captioning. This would prevent one of the common problems: programs being rebroadcast which haven’t been reformatted are often erroneously labeled as captioned in program guides. We also noted that software is now available to extract captioning data before video compression and reinsert it afterwards.
9. How do you feel about disclaimers we sometimes see on TV that say the provider is not responsible for the correctness of the captions?
Our petition says
The FCC should uphold its requirement that programming distributors be held responsible for captioning, not the captioning agency. (NVRC hopes this would help discourage those programmers who are driving down caption quality by contracting for captions based on cost, not quality – and would also encourage them to monitor the captions).
How to Submit Your Comments
The FCC is very security conscious. Mail that is sent to their office is routed to a facility where it goes through a security check, which can delay its arrival for days or weeks. You can hand deliver your comments to another FCC office in DC, but you will be required to remove any envelope before entering the building. If you mail or deliver your comments, you must also send the original with 4 copies.
The easiest way is to send your comments is to type them in your word processing program and then cut and paste them to a form at the FCC website. You will be able to submit comments as long as 2-3 pages this way. Try it and let me know how it goes. If you have problems, send me your comments along with your full name and address and I will try to submit them for you – cheppner@nvrc.org. Any comments you send become public information and are available for other people to read. If you have time, you may find it helpful to search at the FCC website for comments that other people have submitted. They may give you ideas about what you want to support or not support.
INTERNET FILING
File online at: http://gullfoss2.fcc.gov/ecfs/Upload/
Select Closed Captioning – Docket 05-231 by clicking the circle to the left of it and then and press your Enter key
Fill in all the boxes with your full name, address, and an e-mail to reach you
Cut and paste your comments to the comment box, or write them directly in it. If you make a mistake, you can click the box at the bottom right that says “Clear Cover Sheet”. When you are finished, click the box that says “Send Comment”. It’s as simple as that.
You can also submit comments by attaching a file, but it’s a little more complicated
http://gullfoss2.fcc.gov/prod/ecfs/upload_v2.cgi
Proceeding – type 05-231
Select: Name
Type your name
4, 5. Skip
6. Type your email address (optional)
7. Type your mailing address
8. Type your city
9. Type your state
10. Type your zip code
11. Skip
12. Select: Comment
13. SkipYou will then be asked which program your comments are being sent in. select that, and then click the box to attach your file.
BY MAIL
First class, express or priority mail. Send one original, 4 copies.
Federal Communications Commission
445 12th Street SW
Washington, DC 20554HAND DELIVERY
Send one original, 4 copies. Open from 8 am to 7 pm.
Remove from any envelope BEFORE entering building.
FCC Secretary
236 Massachusetts Avenue NE, Suite 110
Washington, DC 20002© 2005 by Northern Virginia Resource Center for Deaf and Hard of Hearing Persons (NVRC), www.nvrc.org.
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