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‘Do No Harm’ Standard?

CEA, TDI Spar Over IP Video Captions

CEA and Telecommunication for the Deaf and Hard of Hearing (TDI) disagree -- in comments filed by the groups in the FCC’s proceeding on closed captioning for video delivered over Internet Protocol -- whether subtitles for the deaf and hard of hearing (SDH) are sufficient under closed captioning requirements. The commission issued a further NPRM requesting comments in the proceeding in July (http://bit.ly/1bWbMzp). TDI and consumer electronics groups also sparred over whether device manufacturers should be required to make products that synchronize closed captions with IP video. “TDI misunderstands the technology in arguing that standard closed captioning formats ‘provide apparatus with the necessary timing data to accurately synchronize captions with video,'” said CEA.

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The 21st Century Communications and Video Accessibility Act (CVAA) requires that users be able to alter the size and color of closed captions, something the subtitles used in removable media like DVDs and Blu-ray can’t do, said TDI. “Without that functionality, viewers who need to adjust the appearance of captions cannot do so, effectively making SDH inaccessible,” said TDI. Being able to change caption size and color is important because it allows viewers to read captions no matter the background of the video behind them, said captioning expert Larry Goldberg, director of public-TV station WGBH Boston’s National Center for Accessible Media. Goldberg was part of the group that originally made recommendations on FCC IP closed captioning policy. SDH also doesn’t work using the standard caption decoder the deaf and hard of hearing use with broadcast TV, Goldberg said. “They're not in a data format you can feed to the caption box, you have to go in and find the subtitle track,” he said.

Because DVDs and Blu-ray players already support SDH, “there is no need to impose additional requirements in order for these devices to meet the CVAA’s baseline captioning requirements for removable media,” said CEA. It said the CVAA regulations for captions don’t specifically mention removable media players, and leave room for “alternate means” of meeting the requirements. Requiring removable media players to render captions would involve requiring them to include analog output, which would add cost to Blu-ray players and endanger their copy protection, CEA said. The Entertainment Software Association said any imposition of captioning rules on DVD players should account for the fact that DVD is “a legacy technology” in a “marketplace shifting toward streamed content."

TDI has said the FCC should require manufacturers to build products that synchronize video over IP to captions (CD Nov 6 p14), but in comments Thursday said it agreed with a CEA proposal for a “do no harm” standard that would mean devices are required to pass through or display captions that are already properly formatted. However, the two sides disagreed whether such syncing is always possible and whether devices are ever the source of syncing problems. “In the absence of sound evidence that a significant synchronization problem exists, the Commission should not risk chilling innovation by adopting an apparatus synchronization requirement,” said CEA. “A synchronization requirement would simply hold manufacturers accountable for faithfully implementing a caption rendering engine that conforms to the standard,” said TDI. Regulations that improve IP video are important to “open media for Americans who are deaf or hard of hearing, fulfilling the purpose of the CVAA,” said TDI.