Australian Broadcasting Corporation
submission to
Department of Broadband, Communications and the Digital Economy
Access to Electronic Media for the Hearing and Vision Impaired Discussion Report
February 2010
2
Introduction
The Australian Broadcasting Corporation (ABC) welcomes the opportunity to comment on the Department of Broadband, Communications and the Digital Economy (DBCDE) discussion report:
Access to Electronic Media for the Hearing and Vision Impaired.
The ABC’s policy and approach to promoting access to its services and content via electronic media was outlined in its June 2008 submission to the Access to Electronic Media for the Hearing and Vision Impaired discussion paper. The goal of universal access is one which remains at the core of public broadcasting and the Corporation recognises the importance of providing all Australians with access to content that informs, entertains and that enriches their lives.
The ABC’s long standing commitment to improving access to electronic media for the deaf and hearing impaired community through closed captioning remains strong. It has consistently increased the amount of captioned content on ABC1 and with the advent of digital multi-channelling has significantly expanded its captioning service.
The Report identifies a range of key media access issues for consideration. The Corporation believes that the most effective mechanisms for addressing the medium to long term issues identified in the discussion report is through a consultative framework including representatives of the deaf and hearing impaired community, visually impaired community, broadcasters and relevant public agencies.
With regard to the shorter term issues, and specifically the regulatory framework applying to captioning levels and standards, the ABC maintains that both broadcasters and the community require regulatory certainty.
Discussion
Captioning levels on television
The ABC recognises it is important for Australians to have access to the content it provides. In keeping with that belief, the ABC provides high levels of captioning on ABC1, ABC2 and ABC3. It meets all of the captioning requirements set out in clause 38 of Schedule 4 of the Broadcasting Services Act 1992 (BSA). Moreover, the Corporation has committed to staged increases in captioning on its main service, ABC1 as part of an agreement with the Australian Human Rights Commission (AHRC) granted under the Disability Discrimination Act 1992 (DDA). The Corporation has consistently met the specified targets. Further, the ABC has steadily increased the level of captioning provided on ABC2 and has begun captioning programs from the outset of broadcasting its new children’s service, ABC3.
The commitments made under the AHRC process will see at least 85 percent of program hours captioned on ABC 1 by the end of 2011. Almost 14,000 hours of programming with closed captions were broadcast on ABC 1 and ABC 2 in 2009. With the launch of ABC3, the ABC will broadcast over 18,000 hours of captioning programming in 2010 on its broadcast services. The ABC has recently
3 announced that it will begin broadcasting a 24 hour continuous news channel. ABC planning
envisages that a significant proportion of that service will be captioned from the first day of broadcast.
However, cost and spectrum availability are becoming increasingly significant issues for the delivery of television captions. The cost implications are discussed below. A further issue is the spectrum required to deliver accessibility services, as such services require further bandwidth in addition to that required for the delivery of the audio and video component of broadcast services, and for program and related information (electronic program guides). While the delivery of a single service, such as captioning a television broadcast, does not require a large amount of spectrum, the
accumulated requirement for a number of services has major implications. It is important that consideration of this issue is made in planning for the future use of spectrum and media accessibility services.
Cost of captioning broadcast content
The ABC has previously estimated the cost of captioning 100 per cent of broadcast content on four channels at over $12 million per annum. Over five years, captioning 100 per cent of existing and planned ABC television content would cost an estimated $60 million.
Should captioning requirements be increased to include new channels or new platforms (e.g.
online), the costs will increase proportionately. In addition, any requirement to include Audio Description (AD) would further significantly increase the cost (see below).
While the ABC is committed to captioning its television programs, it is also cognisant of the balance that must be drawn between captioning and the availability of resources and access to adequate funding. Further the ABC must consider in any proposal to extend captioning, be that across the multi channels or onto other platforms, the most efficient allocation of resources to improve accessibility to ABC services and content.
The ABC believes that a staged increase in captioned content on its television broadcast platform provides a balanced way forward for both the ABC and its viewers.
An appropriate media access framework including a consultative forum involving broadcasters, representatives of the deaf and hearing impaired community, the visually impaired community and relevant public agencies would provide a basis for negotiation of captioning targets that reflect audience needs and the costs involved particularly for new services. Such a framework and
consultative forum would provide a platform to discuss the technical and resource issues that need to be addressed in order to caption content on other platforms.
As a starting point, the captioning levels agreed between industry and the AHRC as part of the exemption process should form the basis for any update of the BSA captioning targets.
4 Regulatory Framework
As noted in the discussion report, the competing obligations of the BSA and DDA create an uncertain regulatory environment for broadcasters and viewers. In its 2008 submission the ABC identified this as the major issue for resolution, identifying the “need to give certainty to the community and to broadcasters so that there is a clear set of rules for the delivery of captioned content in electronic media”1. The ABC would welcome clarification of the intended relationship between the two competing pieces of legislation in relation to captioning. If it is intended that the BSA override the provisions of the DDA in relation to captioning, the BSA should be amended accordingly.
Alternatively, if the intention is that the BSA be subordinate to the DDA, it should be amended to include a guidance note to that effect.
The targets set through the negotiation of exemptions to the complaints process under the DDA far exceed those set by the BSA. Further updating the BSA to include new targets would not address the problem of competing regulatory objectives enshrined in separate legislation.
An important issue for the Corporation is to ensure that adherence to the targets set and agreed by broadcasters, viewers and/or Government are not then open to challenge under a different
regulatory scheme.
Quality of Captions
The ABC appreciates the importance of quality as well as the quantity of captioning available to deaf and hearing impaired viewers.
As stated above, the ABC supports the development of a consultative media access framework with representation from all stakeholders. The ABC believes such a forum would facilitate the finalisation of the existing draft quality guidelines. The draft quality guidelines should be implemented and given a chance to work before any consideration is given to imposing mandatory arrangements.
Provision of emergency, disaster or safety information
The report notes that the Government will consider mandating captioning or subtitling of all pre- produced emergency, disaster or safety announcements broadcast on television and introduce a voiceover requirement for essential information such as contact numbers. The ABC has developed guidelines to make its television services more accessible for people who are deaf with hearing impairment or are blind or have a visual impairment. For example, Editorial Policies aim to make television and online services accessible to audience members who are blind or have a visual impairment by “ensur[ing] that material provided in text format on the screen will also be provided
1 ABC Submission, DBCDE Access to Electronic Media for the Hearing and Vision Impaired Discussion Paper, June 2008.
5 in audio”.2 The policy also states that, “closed caption content will be clearly marked when program information is provided to the media or when captioned programming is promoted. Where
possible, open caption advice will be provided if technical problems prevent scheduled closed caption … Addresses to the nation and events of national significance will be transmitted with closed captioning”3.
Captioning on the Internet and on Emerging Platforms
It has been the ABC’s experience that developing captioning solutions for online media is neither straightforward nor inexpensive.
It is incorrect to say that programs that include certain access features such as closed captioning in one platform, such as television, can simply carry those features onto other platforms, such as online.
The prospect of extending the parameters of the ABC’s captioning service onto platforms beyond television broadcasting raises a number of complex technical, rights management and funding issues.
Any consideration of captioning for non-television services must take account of the considerable technical complexity and differences between alternative platforms and applications. The use of the terms “online” and “over the internet” are sometimes used as “catch alls” for a great number of quite different services. The ABC believes research is required into the technical, capital and operational cost and legal issues associated with making online content more accessible.
Technical Issues
As noted in the discussion paper, different platforms encode captioned files in different formats. For this reason, the caption files that are used with a television broadcast would be incompatible with content that is delivered online using one of the many available applications (e.g. Quicktime, Flash etc).
In order to caption content that is provided in another format, the broadcaster would need to either:
re-caption the entire program; or
obtain the original caption files in an appropriate format and develop a means of integrating them into the program file.
Both options present financial and technical problems for broadcasters. The first option may in effect double the costs of captioning. And given the range of online applications available a number of solutions would need to be developed to address the different formatting issues that will arise
2 ABC Editorial Policy, section 11.15.2
3ABC Editorial Policy, section 11.15.1
6 with each platform. The second option requires that the broadcaster identify the most suitable file format, or formats depending on the provider, and then develop a means of accurately integrating them into the program. This would be a technically complex and expensive exercise especially for new, emerging or niche services.
The display of captions online also requires the development of new functionality within each online video player. There are a number of such video players in use and there is no established industry standard or specification across such functionality. This adds another level of technical complexity.
Given the success and continued growth in usage of its iView service, the ABC has recently decided to develop a closed caption service for the iView player. The ABC intends to caption content for iView that was provided with captions in prime time (as screened from 6pm to midnight) on ABC1 and ABC2based on the second option described above.
The ABC has begun testing of the various options for integrating captioning into its prime time iView programming. The ABC has also entered into discussions with captioning providers to scope the range of captioning file formats available and the cost of obtaining them. The ABC intends for this service to be operational by the end of the first quarter 2010.
Rights Issues
While technically very difficult, it is possible in some circumstances to extract text files from broadcast content in order to re-purpose those files for use on other platforms. However, many of the rights secured by broadcasters explicitly exclude the extraction and altering of files or the rendering of content for other platforms or devices. In order to caption content on other platforms broadcasters will need to secure additional rights. If they are available they will be at additional cost.
Hence even if technology solutions could be developed across platforms, legal rights would not necessarily cover the same content.
Audio Description (AD)
The Report notes that the Government is considering a trial of AD on the ABC. The ABC does not currently provide AD services and has no plans at this stage to introduce a permanent AD service.
There are a number of issues to be addressed in considering an AD broadcast trial. In conducting any trial, clear objectives and assessment criteria would need to be agreed. Detailed financial, workflow, process and technical analysis will be required before there is a more accurate understanding of what is required to undertake an AD trial. Furthermore legal questions which arise in relation to possible actions brought under the Disability Discrimination ACT (DDA) need to be adequately clarified before any trial could proceed.
7 AD Technical Issues
As noted above a number of technical issues need to be addressed in relation to AD. Australia has two digital television standards developed by Standards Australia:
AS 4599.1-2007: Digital television – Terrestrial broadcasting – Characteristics of digital terrestrial television transmissions; and
AS 4933.1-2005: Digital television – Requirements for Receivers Part 1: VHF/UHF DVB-T television broadcasts.
Although not mandated by ACMA, AS 4599.1-2007 specifies digital terrestrial television (DTT) transmission requirements, including video, audio and data coding, transport stream characteristics, channel coding and modulation system to be used. It is based on the European digital video
broadcasting terrestrial (DVB-T) transmission standard. Neither the Australian transmission nor the receiver standard mandates specifications for supplementary audio services such as AD.
The digital receiver standard AS 4933.1-2005 provides receiver manufacturers with technical specifications and requirements that enable the successful reception of transmissions complying with AS 4599.1-2007. The standard identifies minimum essential requirements for reception, demodulation and decoding of television broadcasts complying with the Australian implementation of DVB-T. It also provides additional information and recommendations regarding implementation if other features are included in equipment design.
While the Australian receiver standard specifies that if several audio channels in the same or different formats are present in a program service, there should be a menu option that allows users to select the audio stream they prefer, the ease with which the additional audio can be accessed varies widely between receivers. It may not be supported by all devices.
Given the complexity of these issues, the ABC has concerns that a closed AD trial may be inaccessible to the Australian community. Further testing of broadcasting and receiver equipment and
comprehensive field tests should be undertaken to determine this accessibility issue.
Spectrum availability issues
As noted above, providing accessibility services increases the spectrum required to deliver each television channel. The delivery of a closed audio description service utilises a separate broadcast signal which further increases this additional spectrum requirement for DTT delivery. In the case of closed AD, the ABC is aware of requirements for up to 256 kbps per additional audio channel.
The additional bandwidth requirement for AD services is of concern to the ABC. A closed AD trial for even one channel would present difficulties for the ABC, especially as at a time when spectrum issues must be addressed in relation to the ongoing quality of the ABC’s digital multi-channels, the regulated requirement to provide HD and the capacity to meet future broadcasting demands.
Resolving the spectrum issue is critical to developing any AD trial proposal. Further, the Corporation believes it is essential to consider the longer term implications of a trial, particularly the issue of how spectrum could be identified to address media accessibility for multiple distinct services.
8 Availability of AD content and audio describers
While AD files are often available (at a cost) for programming acquired by the ABC from overseas, there are few trained audio describers in Australia currently. Some AD work is done for theatres, events and DVD. Until demand for AD services is established, the number of trained audio describers is likely to remain small.
Cost issues
The cost of AD files for programming acquired by the ABC from overseas is estimated to be in the region of $500 to $1,000 per hour. In the absence of an established domestic AD production capability, the creation of AD files for Australian programming—a clear long-term ambition of any trial—can be expected to be considerably higher.
The ABC also notes that, unlike captioning, where advances in speech-recognition technologies have the potential to reduce costs over time, AD is an intensive process that can only be performed by a human operator. While the costs of AD can be expected to reduce as a specialised market for AD services develops, the need for human audio describers creates a distinct floor beneath which the cost of AD cannot drop.
The ABC notes that the level of interest and demand for AD broadcast is untested in Australia.
Trial proponents see such a process as a means for developing awareness.
Trial Proposal
Notwithstanding these issues, the ABC is willing to further investigate the feasibility of a limited trial of AD.
There are likely to be additional costs, including capital expenditure associated with the broadcast of AD content. The ABC will therefore require funding to meet the costs of conducting an AD trial.
The ABC is aware that should such a trial proceed and be successful, it is likely to raise questions about the cost of delivering an ongoing service, spectrum availability and the legal issues regarding AD.
Non Broadcast media - DVDs
The ABC makes non-broadcast media, such as DVDs, available through ABC Commercial, which is responsible for the creation, licensing and marketing of consumer products and services relating to the Corporation’s programming and Charter activities. These are available through ABC Shops, ABC Centres, ABC Shop Online and other retail outlets.
Since 2005, the ABC has included captions in new DVDs it produces, with the exception of some DVDs for pre-school children. The ABC incurs significant costs to make these features available, but does so in order to better meet the needs of the deaf and hearing impaired community.
9 The ABC considers the availability of captioned features on DVD products acquired for retail outlets.
When DVD titles are sourced from overseas, the ABC obtains captioned DVDs where available. The difficulty faced by the ABC is that some DVD titles are unable to be sourced with captions for sale.
The ABC works closely with suppliers to encourage the production and importation of DVDs with captioning features. The ABC actively requests suppliers provide DVDs with captioning features over an identical title without these features.
The ABC notes that the Government is considering consulting with stakeholders to develop a voluntary industry standard regarding the provision of captioning and audio description of DVDs where these are already available and also the labelling of DVDs that have captioning and audio description. The ABC would expect to participate in such consultation.
Conclusion
The ABC is committed to continuing to ensure that its services on a range of platforms are widely available to all Australians, including those with disabilities. This commitment involves continued, staged increases in the amount of captioning provided on its broadcast services; a commitment that will see almost 20,000 hours of captioning delivered across its 4 channels by 2011. It will also see the extension of captions to the ABC’s iView service during 2010. Further, the ABC is willing to
investigate a broadcast trial of Audio Description, subject to addressing funding and spectrum availability issues.
The discussion report indicates the Government is considering a review of captioning and audio description on electronic media in Australia in 2013. The ABC believes is a good approach and would provide an opportunity to assess the operation of various digital platforms and accessibility of content. Given the development of the NBN and the proximity to the end of the digital switchover period it would also be an appropriate time to set future media accessibility targets.
