Closed Captioning Problems Highlighted in FCC NPRM

July 26, 2005
In response to a Petition for Rulemaking filed by Telecommunications for the Deaf (TDI) the FCC released a Notice of Proposed Rulemaking (CG Docket 05-231) examining the closed captioning rules, specifically compliance and quality issues related to closed captioning. While the NPRM does not address RF signal quality issues, it does highlight technical problems in the way closed captioning data is distributed.

The NPRM listed the following problems identified as frequently occurring in the TDI petition:

  • Captions turn off ten minutes before the end of national network programming.
  • Captions disappear one hour into a two-hour movie.
  • Captions are absent, although TV programming schedules label the show as captioned.
  • Captions are illegible, including white boxes and overtypes.
  • Captions appear on a national program in one locality but not another.
  • Captions are missing from repeats of previously aired captioned programming or are scrambled and unreadable.

Compliance with DTV caption rules was also discussed. The results of a recent nationwide sampling of locally broadcast DTV programming showed that 35 percent of the local DTV stations failed to provide any closed captioning and only 20 percent provided captions that were in compliance with the FCC's caption decoder rules (47 CFR Section 15.122), according to TDI
  • . WGBH's National Center for Accessible Media conducted the study, although the date of the study is not mentioned. The TDI petition reports it was conducted "recently," which would imply a date in early to mid 2004, before the deadline for DTV stations to offer EIA-708 closed caption. It would be interesting to see how much that number has changed in the year following the study. TDI suggested the FCC establish punitive measures, such as fines, for noncompliance with closed captioning rules to create a financial incentive for video programming distributors or providers to comply with FCC closed captioning benchmark requirements, with each hour of programming below the applicable benchmark being counted as a separate violation.

    If you are responsible for closed captioning at your facility, I recommend you review the Notice of Proposed Rulemaking (CG Docket 05-231). For background information and comments filed prior to the issuance of the NPRM, go to FCC Search for Filed Comments and enter "RM-11065" in box 1, proceeding. Go to the end of the listings and scroll down to the bottom entry. This is the TDI petition for Rulemaking. Note that the cover letter, Petition and exhibits are separate links. A summary is available in the FCC News Release FCC Launches Review of Closed Captioning Rules.
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