Little Support For Text-To-Speech Requirements in Emergency Alert Accessibility Rule Proposal Comments
Multichannel video programming distributors and CEA urged the FCC not to require “video programming apparatus” to include text-to-speech technology to make emergency alert information provided in on-screen “crawls” and messages more accessible to the blind and visually impaired. In comments submitted to the agency this week, there was little support for a text-to-speech mandate. “Even if text-to-speech technologies were reliable, it is unnecessary to require an apparatus to make textual information through audible use of the text-to-speech software,” AT&T said (http://xrl.us/bn68by). But parties generally supported using the secondary audio programming (SAP) channel to provide accessible alert information.
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DBS companies said requiring distributors to carry all SAP channels could pose some capacity problems. DirecTV carries the SAP streams of only the top four network affiliates and PBS stations in each market, it said. “If hundreds of broadcasters suddenly begin using a secondary audio stream only to provide emergency information, DIRECTV would not have the capacity on its spot beams to include all streams,” it said (http://xrl.us/bn68b6). “It would need to dedicate an entire audio stream full-time for each station regardless of how little it would be used.” Many stations don’t provide SAP streams, the company said.
Dish Network raised a similar concern. “Dish may not have the necessary capacity on its spot beams to support SAP service for all local broadcast stations in a given market,” it said (http://xrl.us/bn68b8). “Any new regulatory requirements must account for satellite capacity constraints of DBS operators and should allocate sole responsibility for generating the audio version of the message with the local broadcast station or its programming partners."
Cable operators already pass through secondary audio streams for purposes of video descriptions, and they can continue to do so if broadcasters use that stream to describe on-screen emergency messages, NCTA said (http://xrl.us/bn68ck). It opposed any text-to-speech technology mandate for set-top boxes because boxes “play no active role in making the information audible,” the association said. “They simply are used to locate the appropriate stream when instructed to do so by the consumer."
CEA urged the FCC not to apply aspects of Internet Protocol captioning rules to this proceeding. The group has petitioned the commission to reconsider those IP captioning rules, and said now the agency’s interpretation of elements of the 21st Century Communications and Video Accessibility Act were overbroad. “Although the Commission is apparently seeking consistency between the new rules at issue in this proceeding and the rules of the IP Captioning Order, different statutory provisions govern the various requirements,” CEA said (http://xrl.us/bn68df). It urged the commission not to adopt any technical requirements regarding text-to-speech. And it pushed for a two-year phase-in of the rules following their publication in the Federal Register because of the rules’ complexity.
NAB supports using SAP to provide audio emergency information delivered by on-screen messages, it said (http://xrl.us/bn68do). But it said it’s important to balance the competing uses of secondary audio channels “including for video description and foreign language audio.” The new rules should also make sure that broadcasters’ “aural emergency messages are not overridden by aural messages based on an MVPD’s crawl,” it said. NAB estimated it will take 18-24 months for equipment to be developed to meet whatever requirements the FCC adopts, then another 12-18 months for broadcasters to buy and install that equipment. NAB suggested stations in the top-25 markets, which are the markets that already have a SAP, get three years to come into compliance with the rules after their publication in the Federal Register. Stations in those markets without a SAP, and stations in smaller markets, should get another six months to comply, NAB said. “Broadcasters will work aggressively to meet or exceed these deadlines."
A group of advocates for the deaf and blind urged the commission to consider emergency alert accessibility for those who are both blind or visually impaired and deaf or hard of hearing (http://xrl.us/bn68ek). “Neither video crawls or secondary audio streams are universally accessible” to that population, said the American Association of the Deaf-Blind, National Association of the Deaf, Rehabilitation Engineering Research Center on Telecommunications Access, and Telecommunications for the Deaf and Hard of Hearing. They proposed providing alerts through both a secondary audio channel and closed captions.