Update: Provide Your Input to the FCC in Support of HLAA’s Internet Captioning Comments
New Deadline: November 1, 2011
The 21st Century Communications and Video Accessibility Act of 2010 (CVAA) requires the Federal Communications Commission (FCC) to issue final regulations mandating closed captioning of some of the video programming delivered over the Internet by January 2012. The FCC issued a Notice of Proposed Rulemaking (NPRM) in September.
On October 18, 2011, HLAA joined six other consumer organizations who worked hard together to respond to the FCC’s NPRM. The Comments were filed by Telecommunications for the Deaf and Hard of Hearing (TDI) with HLAA, National Association of the Deaf (NAD), and Association of Late-Deafened Adults (ALDA), among others, joining. The Technology Access Program at Gallaudet University (TAP) and the IT-RERC at Trace Center, University of Wisconsin-Madison also signed onto these comments.
In our comments, consumer groups emphasized the need to promote equal access to video programming on the Internet. We urged the FCC to ensure quality captions for Internet-delivered programming, accountability for online video distributors, and integration of accessible technology in devices used by consumers to view video programming.
A complete copy of this filing can be found at: http://fjallfoss.fcc.gov/ecfs/comment/view?id=6016846205
The FCC received comments from a variety of organizations, individuals and companies, including AT&T, the Consumer Electronics Association (CEA), WGBH National Center for Accessible Media, Google, Verizon, CTIA – the Wireless Association, Microsoft, the Motion Picture Association of America, National Association of Broadcasters, and the Telecommunications Industry Association. The combined comments total over 350 pages of discussion on the topics raised by the FCC.
What can you do? File Reply Comments by November 1
We have had several HLAA State Organizations and individuals contact us asking if they too should file comments. The deadline for initial comments has passed, but individuals, chapters or state organizations who are interested in weighing in can do so by filing reply comments – but there is a very short time for rely comments: they are due November 1.
Reply comments typically provide responses to the comments posted. Review the Commission’s website on this filing if you are interested in seeing what others have filed. Your reply comments can support or oppose any comments posted there: http://fjallfoss.fcc.gov/ecfs/proceeding/view?name=11-154
For those HLAA constituents who prefer a quick and easy method, we suggest you simply send a letter to the Commission saying:
I am a person with a hearing loss who depends on captioning on television and over the Internet. I support the comments filed by TDI, NAD, HLAA and other consumer groups. http://fjallfoss.fcc.gov/ecfs/comment/view?id=6016846205
If you wish to spend more time, you can review all 53 pages of our filing and comment on whatever section is important to you. You can also support our filing by sending a brief letter to the Commission raising one or more of the following issues.
First drafts of CVAA covered not only programming that was once aired over television, but programming that was similar to television programming, but went directly from production to the Internet, skipping television altogether. We’re beginning to see that already, with soap operas that can’t make it on TV heading for Internet viewing.
If you agree: Let the Commission know you support the filing of TDI, NAD, HLAA and other consumer groups, and that you are very disappointed that CVAA covers only programming that that has been aired over TV and then subsequently viewed over the Internet.
The Comments HLAA signed onto also noted that often the quality of captions coming from television may not be accurate. We stated that captions on programming delivered over the Internet should be at least the same quality as those on television: “Anything less than captioning parity between that two types of delivery would fall short of the CVAA’s guarantee of equal aces for consumers who are deaf or hard of hearing to the increasingly important world of Internet video content. (Comments of TDI, et al., at page 9)
Consumer groups also urged the Commission to encourage video programming distributors to improve captions where possible. (Comments of TDI, et al., at page 11) Many of us have seen captions that are out of sync with the audio, garbled or positioned so that they interfere with other information on the screen. Whenever it is possible to correct these and other mistakes, we believe that those mistakes should be corrected.
If you agree: Tell the Commission you believe captions should be at the very least the same quality as that shown on television, and that where captions can be improved when delivered over the Internet, they should be improved.
Or you might chose to make it clear to the Commission that the complaint process for consumers should be as easy as possible.
Consumer groups urged the Commission to allow consumers to send complaints to the video distributor, the Commission, or both. (Comments of TDI, et al., at page 34) Consumer groups also urged the Commission to ensure that the video distributor prominently displays detailed contact information for complaints. (Comments of TDI, et al., at page 39)
If you agree: Tell the Commission you believe that the complaint process should be as easy as possible for consumers. They should at the very least allow complaints to go to the video distributor and the Commission. And it should be very clear where the consumer should be able to send those complaints.
How to file Comments or Reply Comments with the Federal Communications Commission
- Go to Commission Electronic Comment Filing System (ECFS) where you can read more about filing comments with the FCC
Click the third bullet that says:
Submit a Filing: The standard form for submitting filings to ECFS if you want to send Word, PDF, or Excel files.
- If you are ready to submit a comment, and don’t wish to read more, you can go directly to file your comments
Filling out the “Submit a Filing” form
- Proceeding: the number for this filing is: 11-154
- Contact info: Your name email address. No need to include Lawfirm name if you are filing as an individual or group. Note that all information will be publicly displayed on the FCC website
- Details: chose “Reply to Comments”. Do not click “Exparte Presentation” or fill out “file number”
- Address: Complete your address as the “filer”
- Documents: Click the browse button to find and attach your document. If you wish to give a name to your document, fill out “Custom Description”
- When you are finished, click “Continue”
You should get a response from the Commission indicating that you have successfully filed your comments.