CEA and Telecommunications for the Deaf and Hard...

that render captions, according to comments filed in docket 11-154 (http://bit.ly/1bWbMzp). A manufacturer requirement is the last step to making sure every link in the supply chain of closed captions is held responsible for making them work, said TDI. Video programming distributors are already required to maintain timing data, and the commission has an open proceeding on quality standards for TV closed captions. “The Commission should complete the chain of accountability for synchronization problems by requiring apparatuses to render captions according to the timing data included with video,” said TDI. “If every step of the delivery chain is covered by a synchronization requirement, consumers will finally be able to seek remedies when problems occur.” CEA said such rules would improperly assign the blame for caption sync problems to manufacturers. “A synchronization requirement for apparatus would implicitly assume that consumer devices somehow introduce synchronization issues into caption decoding, but CEA is unaware of any such behavior,” said CEA. If the commission does pass a rule, it should require devices to render captions according to the timing data included with the video programming, said CEA. “This ‘do no harm’ standard would mean that if a device receives properly captioned content, then it would have to appropriately decode and display, or pass through, the content and captions.” Improperly timed captions wouldn’t function on such devices, CEA said. “Viewing media with unsynchronized captions is as disruptive for a viewer who is deaf or hard of hearing as watching media with an unsynchronized audio track is for a hearing viewer,” said TDI. The consumer group said caption rules for removable media players are necessary because such devices are increasingly reliant on HDMI connections. “Because the current HDMI standard does not support the pass-through of caption data, captions cannot be viewed using an HDMI-only player if the player does not render the captions,” said TDI. However, CEA said DVD and Blu-ray already support subtitles for the deaf and hard of hearing, and therefore already comply with the 21st Century Communications and Video Accessibility Act. “Because streamed media is increasingly prominent in the consumer marketplace, additional regulations on removable media players will simply raise costs for consumers and hasten the decline of removable media technology,” said CEA. The association and copy protection company Advanced Access Content System Licensing Administrator both also argued against a proposal in the FNPRM that would require removable media players to include an analog connection to properly display captions.