FCC Closed Caption Quality Rules and Recommended Practices

What the new rules mean for Broadcasters

Non-Technical Quality Standards

  • 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”

2014 FCC R&O Approach

  • 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
  1. 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!
  2. 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
  3. 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
  4. 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

Options For Short News Clips

  • 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

FCC Regulation Deadlines

  • 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!

FCC Regulations Review

  • 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

Shopping List?

  • 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
    • Selectable 608/708 logging, full ANC packet analysis
  • CCPlay FileProLive for near-to-air CC delivery
    • Your choice of service providers, no proxies, no hassle