[lg policy] Canada: CRTC Approves Standards for French-language Closed Captioning
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Sat Dec 3 15:24:45 UTC 2011
CRTC Approves Standards for French-language Closed Captioning
The CRTC has approved the mandatory standards for French-language
closed captioning set out in the appendix to this regulatory policy.
The Commission further directs the French-language Closed Captioning
Working Group to submit an updated version of the standards by 7
January 2012 to reflect the changes identified in this policy, as well
as to ensure that the mandatory standards are clearly identified as
The Commission will address the issues of enforcement, monitoring
compliance and whether the mandate of the FL-CCWG should be extended
at a later date. The Commission called for comments on the quality
standards for French-language closed captioning proposed by the
French-language Closed Captioning Working Group. The Commission
received comments from a number of parties and one reply.
The Commission recognizes that the report submitted by the FL-CCWG was
a consensus report. As such, the Commission has generally accepted the
proposed standards. Specifically, the Commission accepts the FL-CCWG's
proposed mandatory standards for the positioning of captions on the
screen, the speed of captions and the use of hyphens and chevrons, as
set out in the appendix to this policy. However, after examining the
public record for this proceeding, the Commission considers that it
must address the following issues:
Should there be a distinction between mandatory standards and best
What is an appropriate lag time for captioning?
What is an appropriate accuracy rate?
What is an appropriate timeframe within which to expect the
correction of errors in live programs prior to rebroadcast?
Should there be a mandatory standard for the captioning of emergency alerts?
The Commission will not be addressing how the mandatory standards will
be enforced, how monitoring should take place, who should be
responsible for monitoring and whether the mandate of the FL-CCWG
should be extended. Rather, the Commission will address these issues
at a later date.
The FL-CCWG identified the following areas where it considered
mandatory standards could be imposed on broadcasters:
positioning of captions on screen;
accuracy rate, including correcting errors in the rebroadcast of
speed of captions, including in children's programming;
emergency alerts; and
hyphens and chevrons (speaker identification).
The Aboriginal Peoples Television Network, the Canadian Broadcasting
Corporation and Pelmorex Media Inc. supported a distinction between
best practices and mandatory standards. The Canadian Union of Public
Employees, the Syndicat des communications de Radio-Canada and SOVO
Technologies Inc., a provider of closed captioning, submitted that all
of the proposed standards and best practices should be considered
mandatory, with the exception for CUPE with regard to the proposed
mandatory standards and best practices relating to emergency alerts,
which are discussed later in this policy. The Centre québécois de la
déficience auditive (CQDA) submitted that all of the standards should
be considered mandatory, but that broadcasters should be provided a
level of flexibility during the first half of the new licence term. V
Interactions Inc. (V Interactions), however, submitted that all of the
standards should be applied as best practices. No parties suggested
that any individual best practice would be more appropriately
categorized as a mandatory standard.
The Commission considers that mandatory standards, by their very
nature, should be achievable, measurable and enforceable and that the
mandatory standards proposed by the FL-CCWG meet this criterion, as
well as address the main areas of concern of the user-group
communities, such as accuracy rate, speed of captions and captions
that block other on-screen information. By contrast, best practices
are more qualitative. In the Commission's view, the remaining
standards categorized by the working group as best practices deal with
more stylistic issues. Accordingly, the Commission finds it
appropriate to make a distinction between mandatory standards and best
practices, as proposed by the FL-CCWG.
Lag time is the term used to identify the delay that occurs between
the time a word is heard and the corresponding caption appears on
screen. When the lag time is too great, captions are no longer in sync
with what is happening on screen, making it extremely difficult to
follow the story, identify the speaker or remain engaged in the
program. The FL-CCWG proposed the following mandatory standard
For live programming, the lag time between the audio and the captions
must not exceed five seconds, averaged over the program.
The CQDA supported the proposed mandatory standard for lag time. SOVO
also supported the proposed mandatory standard, stating that the
five-second lag time could even be shortened for live scripted
programming since the script is provided ahead of time. SOVO further
submitted that there should be a maximum eight-second lag time for all
live programming. Pelmorex, however, submitted that the proposed
mandatory standard should apply only to live scripted programming. It
argued that a maximum lag time for live unscripted programming, such
as interviews from remote locations or fast-paced live reports during
severe weather events, should be considered a best practice.
Bell Canada submitted that if the Commission were to impose a
mandatory standard, an exception should be made for live sports
programming. Specifically, it argued that a standard lag time should
be a best practice for live sports programming given the nature of
such programming, with its rapid commentaries, the fact that there are
several conversations happening at the same time, the volume of
foreign proper names and surnames and the different terminologies used
for different sports.
APTN submitted that ensuring a lag time of five seconds or less would
be challenging for many broadcasters.
The Commission notes that although Bell and Pelmorex raised concerns
with respect to the proposed standard lag time, neither party proposed
a different standard for Commission consideration. The Commission
further notes that SOVO indicated that the five-second standard is
reasonable for live unscripted programming and that this is arguably
the most difficult type of programming to caption. The Commission also
notes that SOVO is a key provider of voice recognition captioning in
Quebec and that Bell stated in its submission that SOVO is the company
it has engaged to caption live sports on its specialty service Le
Réseau des sports.
It is the Commission's view that Pelmorex and Bell have not provided
sufficient evidence for the Commission to deviate from the FL-CCWG
recommendation. The Commission considers that the averaging of lag
time over the length of the entire program provides sufficient
flexibility to account for instances where the lag time may be longer
due to the nature of the audio being captioned. Further, with respect
to SOVO's suggestion to shorten the proposed lag time for scripted
programming and establish a maximum eight-second lag time for all live
programming in combination with a five-second average for unscripted
programming, it is the Commission's view that such an approach is
overly complicated. The Commission considers that the working group's
proposed single standard for all live programming is clearer.
In light of the above, the Commission approves the mandatory standard
proposed by the FL-CCWG. A mandatory standard to this effect is
included in the appendix to this policy.
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