On July 9, 2014, HLAA and Consumer Groups (Telecommunications for the Deaf and Hard of Hearing (TDI), National Association of the Deaf (NAD), Association of Late Deafened Adults (ALDA) and others), filed comments with the FCC on their Quality Captioning Proceeding, We urged the FCC to adopt minimum quality standards for live and near-live programming, including heightened standards for re-fed programming and end-of-program cutoffs, and address the critical issue of captions obstructing text. We also urged the FCC to ensure a level playing field for video programming distributors (“VPDs”) by making non-broadcast distributors subject to the same rules for the use of the Electronic Newsroom Technique (ENT).
The Consumer Groups also asked the FCC to revisit and eliminate several exemptions from its rules, including for new networks and those making less than $3 million a year, late-night programming, advertising, locally produced, non-news programming, interstitials, promotional announcements, and public service announcements. We recommended establishing standards for technical equipment checks, the rapid resolution and forwarding of consumer complaints, and outage reporting. Finally, we urged the FCC to ensure that the equipment used by consumers to access video programming, including next-generation 3D and UltraHD televisions, is designed with closed captioning in mind and facilitates easy access to caption configuration options.
Then, on August 8, 2014, HLAA and other Consumer Groups filed Reply Comments with the FCC in response to other comments filed. We urged the Commission to, among other recommendations, ensure that video programming distributors’ pass-through and customer service obligations meet the highest of standards, including routine technical equipment checks, robust outage reporting, and rapid and comprehensive resolution of consumer complaints, including beginning-to-end contact with consumers even for complaints about problems that are not their responsibility. We also urged the Commission to press forward with robust improvements to caption quality for live and near-live programming, including early audio delivery for captioners, a narrowed scope of near-live programming, and caption improvement obligations for re-fed live and near-live programming.