NAB: No Justification for New Caption Quality Metrics

The proposition of new rules are “unnecessary” and would put “undue burdens” on broadcasters.
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WASHINGTON—While the FCC is seeking comments on whether new rules should be implemented to measure the quality of live closed captioning, the National Association of Broadcasters took the opportunity to shoot down the notion entirely.

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In its reply comments to the commission in regard to the petition (RM-11848), NAB said that “such rulemaking is unnecessary because the existing caption quality standards and best practices, coupled with an extensive compliance program, have yielded high-quality captions. The record does not justify the requested change in approach to ensuring caption quality.”

The NAB details how when the 2014 Caption Quality Order was established the FCC rejected caption quality metrics that would have required video programming distributors to monitor and compare live closed captioning against a quantifiable standard, citing it as an “undue burden.” Instead, the caption quality standards and best practices were created.

“The existing caption quality standards, best practices and compliance program have successfully ensured high-quality captions,” the NAB writes. “NAB finds no justification in the record to change course by imposing an uncertain, inflexible metrics-based scheme. At a minimum, the requested proceeding is far from ripe, given the nascent nature of the Captioning DRRP’s project.”

The Radio Television Digital News Association also filed comments opposing the petition.

“RTDNA agrees with NAB that a change in course at this time is premature and would prove to be counterproductive,” the comments read. “RTDNA respectfully submits that (1) closed captioning has markedly improved under the current best practices framework; (2) a metrics-based system for assessing caption quality would be unduly burdensome to RTDNA’s members and undermine the integrity of their news operations; and (3) premature rules governing the use of automatic speech recognition (ASR) technology would stymie ongoing innovation in closed captioning technology.”

“News organizations and local stations continue to make great strides toward increasing the accessibility of local news and public affairs programming to the deaf and hard of hearing community,” RTDNA continues. “To be sure, there is still work to be done. … The commission’s approach is working, and there is no evidence to suggest that a metrics-based enforcement scheme would do anything but impede progress. Moreover, the commission should leave the industry free to evaluate new captioning techniques within the context of existing best practices.”

More comments regarding this petition are available on the FCC website.