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The Changing Role of Closed Captioning for PEG Channels

Part I of our interview with Carol Studenmund.

In recent years, the FCC has been adding new rules expanding closed captioning requirements to online video. To understand the implications of these new rules and how they affect various markets, Government Video recently spoke with Carol Studenmund owner of LNS Captioning in Portland, Ore. and chair of the Mount Hood Cable Regulatory Commission in Oregon. This is Part I of the interview.

Government Video: How are the new FCC rules affecting companies that provide closed captioning services?

Carol Studenmund

Carol Studenmund: The new FCC rules deal with “Best Practices for Caption Quality,”approved by the FCC in February 2014. The Best Practices shine a spotlight on the quality of the captions with regard to accuracy, timeliness of display, position of display, and completeness of the captions. That last quality has to do with making sure the entire program is captioned, not just certain segments. The roles of all the parties responsible for ensuring the captions meet all these criteria now are defined in the best practices—from the captioner creating the captions, to the TV station, the cable company, and in the end to the viewer watching the program. With all parties involved in delivering quality captions to viewers across the country, television stations, networks, and PEG providers now pay much closer attention to a caption provider’s quality history when selecting a vendor. And viewers know where to go on the FCC’s website to provide feedback in the form of a complaint about the lack of captions or the placement of the captions covering up the score on a game.

The Communications and Video Accessibility Act of 2010requires any television content with captioning which is first shown in a broadcast environment must be able to show the captions when the content is subsequently displayed on the internet. Viewers now come to rely on captioning when watching video on the internet. Of course captions are used by people with hearing disabilities. People learning to read English – from small children to grown-ups, to immigrants in our country learning a new language – use captioning for literacy purposes, and those captions must be of high quality to be useful.

GV: How are PEG channels–which have lower budgets than the commercial television stations in their markets–adapting to this change?

Carol: PEG channels’ budgets may appear to provide an exemption from FCC captioning rules. But the Americans with Disabilities Act (ADA) applies to Title II entities, also known as state and local governments. And captioning is considered an approved method of providing access to people with hearing disabilities under the ADA. There is not a budget restriction on ADA accommodations, unless the cost is too much of a burden.

Some PEG providers assume the size of the organization will provide this ADA exemption. However, when reviewing such a request for exemption, the Department of Justice will look at the budget of the entire institution, not the budget of a small bureau or business unit. And that institution could be a city, a county, or the entire State of California. The cities and counties that contract with us spend anywhere from $10,000 to $55,000 per year on captioning services. The DOJ would look at the entire city or county budget in deciding if $10,000 for ADA accommodations was a burden or not.

GV:Is the current equipment from companies that manufacture closed captioning products making it easier for closed captioning and television channels to provide more captioning, now across two mediums?

Carol: The main piece of equipment needed to provide closed captioning is the caption encoder. The newer HD caption encoders have two outputs. One output can send closed captions to the broadcast feed of a county commission meeting, and the second output can send open captions to the internet feed. The feed sent to the internet will show the open captions any time a citizen goes to the county’s website to watch the county commission meeting. You can find more complicated ways to meet these needs, but this is a nice and simple way to accomplish the task.

Of course, video file storage comes into play for rebroadcast purposes. We have seen the technology improve over the last few years, making it easier to capture the caption data in the video file and preserve it intact for later rebroadcast.

GV: Which party tends to innovate and bring closed captioning to the next level first?The FCC, television channels, or closed captioning providers?

Carol: It would be easy to say the FCC leads the way, with its federal eye on the needs of the disabled community. However, in my opinion, it is up to the viewers to let the FCC know what they want in their television experience. When the viewers speak up, the FCC listens, as do stations and networks. It’s all about the viewers. According to a 2011 Johns Hopkins study on the occurrence of significant hearing loss in the general population, 7.8 percent of people from 12 and up in age have a hearing disability that prevents them from participating in school or work without accommodation. That doesn’t begin to count those of us who have trouble hearing in a noisy situation, which brings the numbers to over 12% of the population. If you’re not reaching those folks because they can’t read captions on your program, you’re missing a lot of viewers.

In Part II we will discuss new developments in the captioning world for PEG operators as well as some advice for PEG operators on choosing a captioning service.