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ARCHIVED - Broadcasting Notice of Consultation CRTC 2011-489

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Additional reference: 2007-54, 2011-489-1 and 2011-489-2

Ottawa, 15 August 2011

Call for comments on proposed French-language Closed Captioning Quality Standards

The Commission calls for comments on proposed French-language Closed Captioning Quality Standards filed by the French-language Closed Captioning Working Group. The Closed Captioning Quality Standards are sets of standards (one for each official language market) that address the quality of closed captioning provided by Canadian television broadcasters. The deadline for comments is 14 September 2011. The deadline for replies is 26 September 2011.

The Commission notes that the proposed English-language Closed Captioning Quality Standards will be considered in a separate process also announced today.

Once approved by the Commission, all television licensees will be required to adhere to the closed captioning standards through conditions of licence that have been or will be applied at the time of licence renewal or approval of a new licence.

Introduction

1.      In Broadcasting Public Notice 2007-54, the Commission set out a new policy on closed captioning that required all television broadcasters, including third-language broadcasters, to caption 100% of their English- and French-language programs over the broadcast day. The Commission also directed the broadcasting industry to establish two closed captioning working groups (CCWGs), one for the French-language television market (FL-CCWG) and one for the English-language television market (EN-CCWG).

2.      The Canadian Association of Broadcasters (CAB), on behalf of the broadcasting industry, coordinated the establishment of both CCWGs. These groups included representatives from private and public television broadcasters, distributors, consumer and advocacy groups representing persons who are deaf or hard of hearing, and captioning providers. Commission staff also attended the working group meetings as observers on an as-needed basis.

3.      The purpose of the CCWGs was to develop and implement measures to improve the quality of closed captioning in Canada, including the development of standards in English and French that address significant concerns raised by users of captioning over the poor quality of captions, including both consistently and style issues.

4.      The Commission also asked the CCWGs to develop concrete, workable solutions in regard to particular aspects of captioning quality, including reducing errors and technical problems (such as dropped or garbled captioning) or captioning that is cut off by commercials. The overall objective of the CCWGs, as set out in Broadcasting Public Notice 2007-54, was to establish captioning standards that would become conditions of licence for broadcasters, thereby ensuring consistent and reliable captioning quality throughout the Canadian broadcasting system.

5.      The CCWGs first submitted proposed closed captioning standards to the Commission during the proceeding initiated by Broadcasting Notice of Public Hearing 2008-8/Telecom Public Notice 2008-8. Following the close of that proceeding, the Commission issued Broadcasting and Telecom Regulatory Policy 2009-430 (the Accessibility Policy), in which it considered that the proposed standards submitted by the CCWGs were incomplete and required further attention. The Commission directed the CCWGs to file, for Commission approval, revised and completed standards addressing the following areas:

6.      In the Accessibility Policy, the Commission also directed the FL-CCWG to do the following:

7.      In the present notice, the Commission is seeking comments on, among other things, the appropriateness of the proposed standards for the French-language market.

8.      The Commission has placed documents relating to the development of the proposed closed captioning quality standards on the public record of this proceeding. These documents have been placed on the Commission website at www.crtc.gc.ca and include the following:

Final report – French-language Closed Captioning Working Group

9.      On 18 March 2011, the FL-CCWG submitted its final report to the Commission, in which it stated that it had reached consensus on the proposed standards. The working group’s report divided the standards into two categories: (1) “mandatory standards” that should be imposed as conditions of licence, and (2) “universal standards” that it suggested are more appropriately considered as best practices or guidelines and that should not be imposed as conditions of licence (henceforth to be known as guidelines/best practices). 

10.  The mandatory standards proposed by the FL-CCWG address the following:

11.  The guidelines/best practices as submitted by the FL-CCWG touch on areas such as how to caption false starts, utterances and repeated words; the appropriate number of captioning lines (for example, when to display two or three lines); how to divide a long sentence when using pop-on captions; the appropriate use of spaces; and the appropriate use of colour, italics and upper and lower case letters.

12.  The Commission also notes that, while the FL-CCWG was asked by the Commission to develop standards for digital broadcasting, the working group submitted that the issues relating to the provision of captions in a digital environment are related to the distribution of captions by broadcasting distribution undertakings, as well as user knowledge of the new digital technologies. It submitted that the standards it has proposed would therefore apply regardless of whether programming is provided in an analog or digital format.

13.  The FL-CCWG recommended the continuation of working group activities in order to ensure the success of the standards. The specific propositions are set out below.

Call for comments

14.  The Commission calls for comments on the appropriateness of the proposed Closed Captioning Quality Standards for the French-language television market and any related action that should be taken in the future. The Commission notes that all French-language television licensees will be required to adhere to these closed captioning standards, once approved by the Commission, through conditions of licence that have been or will be imposed at the time of licence renewal or approval of a broadcasting licence for a new service. In light of the discussion above, the Commission seeks comments in regard to the following:

a)      the appropriateness of distinguishing between mandatory standards and guidelines/best practices;

b)      the appropriateness of the content of the mandatory standards and guidelines/best practices proposed by the FL-CCWG;

c)      whether any of the guidelines/best practices should be considered mandatory standards;

d)      whether additional standards are needed;

e)      the appropriateness of the follow-up actions proposed by the FL-CCWG as they relate to 1) the accuracy rate; 2) the definition and calculation of an error; 3) children’s programming; and 4) an overall review of the standards;

f)       whether further action is required for the following:

g)      if further action is proposed, whether the mandate of the working group should be extended for these purposes or if an alternative approach should be adopted.

15.   The Commission notes that in Broadcasting Notice of Consultation 2011-488, also issued today, it calls for comments on the Closed Captioning Quality Standards proposed by the EN-CCWG for the English-language television market.

Procedure

16.  The new Canadian Radio-television and Telecommunications Commission Rules of Practice and Procedure (the Rules of Procedure) set out, among other things, the rules for the content, format, filing and service of interventions, and the procedure for filing confidential information and requesting its disclosure. Accordingly, the procedure set out below must be read in conjunction with the Rules of Procedure and its accompanying documents, which can be found on the Commission’s website under “CRTC Rules of Practice and Procedure.” The Commission notes that Rule 26(2) sets out the requirements as to form, content and service of interventions.

17.  The Commission invites interventions that address the issues and questions set out above. The deadline for interested persons to file interventions is 14 September 2011. Parties may file a reply on or before 26 September 2011.

18.  Parties are reminded that, in accordance with the Rules of Procedure, if a document is to be filed or served by a specific date, the document must be actually received, not merely sent, by that date. A document must be filed with the Commission by 5 p.m. Vancouver time (8 p.m. Ottawa time) on the date it is due. The Commission takes no responsibility for postal delays and will not notify a party whose intervention is received after the deadline date. Late interventions will not be considered by the Commission and will not be made part of the public file.

19.  Interventions must be filed by sending them to the Secretary General of the Commission by only one of the following means:

by using the
 [Intervention/comment/answer form]

or

by mail to
 CRTC, Ottawa, Ontario K1A 0N2

or

by fax at
 819-994-0218

20.  Submissions longer than five pages should include a summary.

21.  Electronic submissions should be in HTML format. Alternatively, Microsoft Word may be used for text and Microsoft Excel for spreadsheets.

22.  Each paragraph of the submission should be numbered. In addition, where the intervention is filed by electronic means, the line ***End of document*** should be entered following the last paragraph of the document, as an indication that the document has not been altered during electronic transmission.

Important notice

23.  All information that parties provide as part of this public process, except information designated confidential, whether sent by postal mail, facsimile, e-mail or through the Commission’s website at www.crtc.gc.ca, becomes part of a publicly accessible file and will be posted on the Commission’s website. This information includes personal information, such as full names, e-mail addresses, postal/street addresses, telephone and facsimile numbers, and any other personal information parties provide.

24.  The personal information that parties provide will be used and may be disclosed for the purpose for which the information was obtained or compiled by the Commission, or for a use consistent with that purpose.

25.  Documents received electronically or otherwise will be put on the Commission’s website in their entirety exactly as received, including any personal information contained therein, in the official language and format in which they are received. Documents not received electronically will be available in PDF format.

26.  The information that parties provide to the Commission as part of this public process is entered into an unsearchable database dedicated to this specific public process. This database is accessible only from the web page of this particular public process. As a result, a general search of the Commission’s website with the help of either its own search engine or a third-party search engine will not provide access to the information that was provided as part of this public process.

27.  The Commission encourages parties and interested persons to monitor the record of the proceeding, available on the Commission’s website, for additional information that they may find useful when preparing their submissions.

Examination of documents

28.  A list of all interventions will also be available on the Commission’s website. The list is accessible by selecting “View all proceedings open for comment” from the “Public Proceedings” section of the Commission’s website and clicking on the “Interventions/Answers” link associated with this notice.

29.  The public may examine public interventions and related documents at the following Commission offices during normal business hours.

Location of Commission offices

Toll-free telephone: 1-877-249-2782
Toll-free TDD: 1-877-909-2782

Les Terrasses de la Chaudière
Central Building
1 Promenade du Portage, Room 206
Gatineau, Quebec
J8X 4B1
Tel.: 819-997-2429
Fax: 819-994-0218

Regional offices

Metropolitan Place
99 Wyse Road
Suite 1410
Dartmouth, Nova Scotia
B3A 4S5
Tel.: 902-426-7997
Fax: 902-426-2721

205 Viger Avenue West
Suite 504
Montréal, Quebec
H2Z 1G2
Tel.: 514-283-6607

55 St. Clair Avenue East
Suite 624
Toronto, Ontario
M4T 1M2
Tel.: 416-952-9096

360 Main Street
Suite 970
Winnipeg, Manitoba
R3C 3Z3
Tel.: 204-983-6306
Fax: 204-983-6317

2220 – 12th Avenue
Suite 620
Regina, Saskatchewan
S4P 0M8
Tel.: 306-780-3422

403 – 4th Avenue South-West
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Calgary, Alberta
T2P 3N2
Tel.: 403-292-6660
Fax: 403-292-6686

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Vancouver, British Columbia
V6B 1C1
Tel.: 604-666-2111
Fax: 604-666-8322

Secretary General

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