Lily Bond, 3Play Media, Marketing Manager, offers up an analysis of the current state of captioning requirements, how they will evolve over the next two years, and much more in the following white paper.
The FCC has worked hard to build upon their closed captioning rules for video programming, including live and pre-recorded sports broadcasts in English or Spanish. A flurry of updates and regulations recently took effect and many more are on their way. This brief will provide you with a compilation of all the FCC updates that affect producers and distributors of sports video content, as well as upcoming deadlines and resources for compliance.
It is important to note that as of now, any video in a distributor or provider's library that previously appeared on TV with captions must be captioned within 30 days. On March 30th, 2016, videos must be captioned within 15 days of being placed online. The regulations described in this brief apply to all online sports programming that previously aired on television with captions, in accordance with the CVAA. We will also take you through the FCC's exemptions for closed captioning.
New Quality Standards for Closed Captioning
On February 20, 2014, the FCC released a declaratory ruling regarding content quality for closed captioning of video programming. This was a much-needed clarification about quality standards across platforms. Although the FCC ruling applies specifically to television, the FCC states in their report that quality standards for television closed captioning are of increasing importance because they dictate the standard for online video, as well: the passage of the Twenty-First Century Communications and Video Accessibility Act of 2010 (CVAA) requires that online video that previously aired on television have captioning of at least the same quality as when such programs are shown on television.
Thus, the FCC's new content quality standards impact not just sports programs on television, but also rebroadcasts on the Internet.
So what are the new quality standards? Basically, the new rules address four aspects of quality: accuracy, synchronicity, program completeness, and placement. The FCC believes that these components are essential in ensuring accessibility. Let's take a look at each of these more carefully.
Caption Accuracy
The FCC states: In order to be accurate, captions must match the spoken words in the dialogue, in their original language (English or Spanish), to the fullest extent possible and include full lyrics when provided on the audio track. More specifically, they require captions to include all words spoken in the order spoken (i.e., no paraphrasing). This also means that the captions must use proper spelling, spacing between words, capitalization, and punctuation.
Further, they differentiate that accurate captions must convey the tone of the speaker's voice and intent of the content. The goal here is for captions to maintain the impact of the performance so that the overall message is not lost on the viewer. The FCC also includes that captions of nonverbal information (e.g., whistle blowing, crowd reactions, and speaker identification) must be provided if they are to be considered accurate.
Caption Synchronicity
The FCC states: In order to be synchronous, captions must coincide with their corresponding spoken words and sounds to the greatest extent possible. It also denotes that the captions must occur at a speed that can be read by viewers. And, if a sports program is edited for rebroadcast, it requires that captions be reformatted to provide accurate synchronization.
Program Completeness
Here, the FCC states: In order for a program's captions to be complete, captions must run from the beginning to the end of the program, to the fullest extent possible. Many people have complained that captions drop off in the middle or before the end of programming, despite efforts on the part of the Commission to minimize this issue. Now, any program that does not include captions up to its conclusion will be in violation of these standards.
Caption Placement
In response to complaints that some captions obscure important information, the FCC states that captions should not block other important visual content on the screen including, but not limited to, character faces, featured text (e.g., news updates, graphics, and credits), and other information that is essential to understanding a program's content when the closed captioning feature is activated.
For example, if you are watching a football game and there is text in the bottom of the screen that gives the score, down, and field position, closed captioning cannot be placed over this text, as it would obscure essential information.
The new guidelines go on to require that captions not run off the edge of the screen and that the text be sized appropriately for legibility.
How Accurate Is Accurate?
Most vendors that provide pre-recorded sports programming (when a program is produced in advance and then captioned before airing) propose caption accuracy rates that are almost perfect. At 3Play Media, our average measured accuracy is 99.6%, and we guarantee over 99%, even in cases of poor audio quality, multiple speakers, difficult content, and accents.
The FCC's standards do allow some leniency for captioning live sports events: Although we recognize the need for a slight delay in the delivery of captions for live programming, the delay in the presentation of live captions should be kept to a minimum, consistent with an accurate presentation of what is being said and the overall goal of ensuring that captions enable viewers to follow the program.
It is important to note that even before these new standards, it was possible for live programming to be captioned at a high rate of accuracy. For instance, the US House of Represe
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Lily Bond, 3Play Media, Marketing Manager, offers up an analysis of the current state of captioning requirements, how they will evolve over the next two years, and much more in the following white paper. 
