MVPDs, NAB Disagree Over Caption Quality Responsibilities For Programmers
If the FCC makes video programmers partly responsible for closed caption quality, it shouldn’t require those programmers to certify to the FCC that their captions meet the standards, said Comcast, DirecTV, NCTA and Charter Communications in separate comments posted online…
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in docket 05-231 Wednesday. The comments were filed in response to an FCC further NPRM requesting comment on proposals to require programmers to submit certification and contact information to the FCC if responsibility for closed caption quality is partly shifted to them, as the FCC considered last year. The lack of a certification requirement in that instance would “confirm that each party is solely and directly responsible for compliance with its own obligations,” said DirecTV. If the responsibility isn’t shifted, the commission should continue to require the certification, Charter said. Requiring programmers to certify that they're in compliance would be a useful way of ensuring that programmers are aware of their responsibility, said a joint filing from Telecommunications for the Deaf and Hard of Hearing and numerous other consumer groups representing the hearing impaired. A certification requirement would “alert VPDs and the Commission that a problem may be afoot when a programmer fails to provide a certification,” said the consumer groups. The American Cable Association and Verizon also both supported a certification rule. “Not requiring video programmers to provide certificates creates enforcement issues and uncertainty for VPDs and for consumers about the specific practices of individual video programmers.” Most of the MVPD commenters and the consumer groups were in favor of requiring programmers to make their contact information available to help with the resolution of captioning problems. NAB disagreed with both certification and contact information requirements. "It is not rational or efficient to encourage consumers to contact a VPP [video programming provider] first,” said NAB. Programmers mostly don’t distribute programming and “are not in a position to readily identify potential captioning issues through the distribution chain,” NAB said. An unintended consequence of a contact information rule would be to turn VPPs into “call centers” for pay-TV providers, which NAB said are more often responsible for captioning problems. “Ultimately, the burden of requiring all VPPs to coordinate and file captioning contact information outweighs any benefit,” NAB said.