FCC Closed Caption Quality Rules and Recommended Practices

What the new rules mean for Broadcasters

Defines basic methodes for judging caption quality
- This was not well-defined prior to the new R&O!
Accuracy
- The captions reflect the words in the audio precisely
- Punctuation, spelling, proper names all correct
- Captions include sound effects, music, speaker names
Synchronicity
- The captions line up in time with the audio track
Completeness
- The program must be captioned from beginning to end
- The captions should not cut out at commercial breaks
- Includes unscripted news segments and weather
Placement
- The captions don’t block news tickers and text
- The captions don’t block faces or “essential action”

Consumer complaint initiates process
Program distributors are directly accountable to FCC
- Cable & satellite providers, OTA broadcasters
Program providers certify compliance to distributors
Captioning agencies certify compliance to providers
Details “Best Practices” for each step in the chain

Captions are Not Just for Speech
- In addition to transcribing dialog, captions MUST:
  - Describe sound effects and music cues
  - Include song lyrics when possible
  - Identify off-screen speakers
- This means voice recognition systems aren’t enough!
Use High-quality Audio for Live CC
- Telephone lines have low latency, but poor quality
  - Leads to transcription errors
- Satellite/MPEG audio return adds 3-4 seconds delay
  - R&O cites 3 seconds TOTAL target CC latency
- IP-based systems like iCap is optimal
  - less than 1 second latency
  - High quality VOIP signal
  - More captioner control
Screen Positioning is Important
- Capption display must not be overlapping:
  - Scoreboards, new graphics, tickers and crawls
  - Speaker faces and other action cruicial to understanding
- Live aptioners often work without video feedback
- iCap Video popular for out-of-market captioners
All News Segments Need Captioning
- Stations outside top 25 markets often use ENT for CC
  - This can leave field reports and weather uncaptioned
  - Problem specifically highlighted in 2014 R&O
  - Some consumer groups want ENT CC banned completely

Enter CC text into newsroom teleprompting system
- Requires transcription of field reports after the fact
Hire live closed captioning service for whole program
- Contracts often assume 30-minute blocks
- May seem prohibitively expensive for many stations
Stitch CC to short clips on file server before air time
- Deliver small clips of work to captioners over iCap network with FilePro Live, includes automatic proxy transmission
- Get better rates and better results by captioning pre-air

April 30, 2014
- Minor revisions including changes in exemption procedure
June 30, 2014
- Changes related to ENT captioning practices
January 15, 2015
- Implement / certify remainder of Best Practices
- Record keeping of monitoring and maintenance
- Many VPDs already requesting Best Practice certifications!

New rules try to balance industry, consumer concerns
- Adds clarity to basic question “what counts as captioning?”
- So far, little extra formal reporting required
- Deadlines are tight for changes, especially for ENT
Best Practices mostly describe current approaches…
- Most broadcasters already following the bulk of the standard
  - Especially networks, O&Os, top 25 DMA
- Some improvements may be just equipment upgrades
- Smaller market stations mostly concerned about live CC OPEX
Rules may continue to evlove in next few years

Upgrade to iCap from a modem-based live system
- All software included with EEG HD encoders
- Better audio, logging, reliablility, monitoring, and Video
DE285 if you need better 608/708 monitoring
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CCPlay FileProLive for near-to-air CC delivery
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