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October 3, 2011
TV Tech Check

FCC Proposes Rules Requiring Captioning of Video Programming Delivered via the Internet

On September 19, the FCC released a Notice of Proposed Rulemaking (NPRM) seeking comment on a number of proposed new rules that implement provisions of the Twenty-First Century Communications and Video Accessibility Act of 2010 (CVAA) that mandate closed captioning on certain video programming delivered using Internet protocol (“IP”). As mandated in the CVAA the FCC has proposed rules that will require closed captioning on IP-delivered video programming that was published or exhibited on television with captions after the effective date of the new rules. The CVAA required the FCC to adopt the new rules no later than January 12, 2012.

The NPRM does not delve into substantive technical matters surrounding how to create and deliver captions for IP-delivered programming and proposes not to specify a technical standard in the Rules. However, the NPRM generally endorses recommendations contained in a report issued by the Video Programming Accessibility Advisory Committee (“VPAAC”). See TV TechCheck from January 17, 2011. Among other things this report recommends that:

  • The fundamental performance objective is that regardless of how the captioned video is transmitted and decoded, the consumer must be given an experience that is equal to, if not better than, the experience provided as the content was originally aired on television.
  • The industry use of SMPTE 2052-1:2010 Timed Text Format (SMPTE-TT) as the standard caption-data encoding format for delivery of IP-captions. However the report notes that there are other technologies available.
  • The NPRM principally seeks comment on a number of proposals such as:

  • Requiring video programming owners to send required caption files for IP-delivered video programming to video programming distributors and video programming providers along with program files;
  • Requiring video programming distributors and video programming providers to enable the rendering or pass through of all required captions to the end user; and
  • Procedures by which video programming providers and video programming owners may petition the Commission for exemptions from the new requirements based on economic burden;
  • Establish a mechanism to make information about video programming subject to the CVAA available to video programming providers and distributors, by requiring video programming owners to provide programming for IP delivery either with captions, or with a certification that captions are not required for a stated reason;
  • Not to treat a de minimis failure to comply with the new rules as a violation, and permit entities to comply with the new requirements by alternate means; and
  • Adopt procedures for complaints alleging a violation of the new requirements.
  • The FCC also proposed the following schedule of deadlines by which:

  • All prerecorded and unedited programming subject to the new requirements must be captioned within six months of publication of the rules in the Federal Register;

  • All live and near-live programming subject to the new requirements must be captioned within 12 months of publication of the rules in the Federal Register; and

  • All prerecorded and edited programming subject to the new requirements must be captioned within 18 months of publication of the rules in the Federal Register.
  • Comments on the NPRM are due to the FCC by October 18, 2011 and reply comments are due Friday, October 28, 2011. A copy can be found here on the FCC’s web page.

     



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    Registration Open

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    VSB Measurements Seminar plus 8VSB Specialist Certification Exam Review

    Friday, October 28 2011 6:00 - 9:00 p.m. (Exam Review)
    Saturday, October 29, 2011 8:30 a.m. - 5:30 p.m. (Measurements Seminar)
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    There will be no TV TechCheck on October 10. TV TechCheck will return on October 17.


    The October 3, 2011 TV TechCheck is also available in an Adobe Acrobat file. Please click here to read the Adobe Acrobat version of TV TechCheck.



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