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Disability Advisory Committee Sees Challenging Path to Better Captioning

The FCC’s Disability Advisory Committee approved a report Tuesday on best practices for sending and receiving captioning files so captioning associated with full-length programming remains available regardless of the distribution method. The vote came in the last meeting of the current cycle of the DAC. Like all other meetings during this cycle, it was held virtually. The report wasn’t immediately released by the FCC.

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Commissioner Geoffrey Starks said the report points to the need for improved captioning. “This is a dynamic time in the media marketplace,” Starks said. “We have more content creators than ever, from traditional studios to up-and-coming websites to individuals,” he said: “More players than ever are distributing the content from traditional broadcasters and MVPDs to a profusion of streaming services, and then consumers are receiving the media on more devices than ever.”

The commission’s goal must be to ensure “captioning associated with programming to be available regardless of the distribution method or device,” Starks said.

Writing the report proved more difficult than expected, said NCTA’s Kyle Dixon, chair of the IP Captioning Files Transmittal Working Group. The group found both technical and “human and organizational process challenges” to better captioning. The technical challenges may be easier to address, he said.

The same content may be distributed in multiple ways, “thus requiring different processes and technical specifications for related captioning,” Dixon said, citing a challenge: “The process does not always proceed smoothly from left to right in terms of from caption creation to display to consumers. In some cases, despite best efforts, some steps may need to be repeated."

Captions are initially created "either internally or by using a vendor and an individual program may be distributed in multiple ways, so the captions may need to be converted to multiple different formats and specifications,” Dixon said. “It’s not as simple as, in the word processing context, cutting and pasting language from one document to another,” he said. Sometimes captioning is embedded with the video “and sometimes it’s essentially a sidecar or a separate file that rides along with the video,” he said: “If a content distributor offers programming to consumers in more than one way, it may receive more than one video or caption format for the same programming or other content.”

One recommendation is that content providers “do things such as develop internal policies and procedures to test pass-through of captioning throughout their distribution chains … to help ensure the consistency of captioning availability across video platforms and devices,” Dixon said. The FCC can encourage app stores, captioning vendors and distribution platforms “to promote education, awareness and documentation of development and use of accessible video technologies,” he said. The commission can also “help educate video creators at all levels about the importance of treating captioning as an integral part of the creative process,” he said.

Chairwoman Jessica Rosenworcel said the FCC has been active on disability issues, and she plans to recharter the DAC for another two-year term. She also welcomed the captioning report. “It is my hope that this will expand the amount of captioning available and I want to thank everyone who worked on it for all of their input on this draft recommendation,” she said.

The current DAC has been productive despite the limitations imposed by the COVID-19 pandemic, Rosenworcel said. “At the FCC we are committed to identifying how the laws before us help us to promote greater accessibility,” she said: “More than that, we are committed to working with anyone in Congress who wants to extend the laws we have to do services so that everyone, everywhere, gets the ability not just to have functional equivalency, but to fully participate in modern civic and commercial life.”

The FCC needs to be part of a “whole of government” effort on addressing problems faced by people with disabilities, said Commissioner Nathan Simington. “We can work arm in arm with the rest of government to ensure that our efforts magnify those taking place elsewhere,” he said. “The commission has done great work to bring down the costs in the [Telecommunications Relay Services] fund and to better align compensation with the cost of provision of services,” he said.

Starks said broader problems remain. “Media frequently does not accurately reflect our society,” he said. About 25% of the U.S. population lives with a disability, but research shows only 3.1% of characters on screen are represented as disabled, he said. “Real advancements have been announced here since I last spoke on the issue, but, of course, I expect more hard work to be done,” he said. Starks also raised the issue at a meeting earlier this year (see 2202240064). DAC last met in June (see 2206280060).