141 Langton Street

Jacana

3047

Fax 9 309 3979

e-mail: Ian_Boucher@fc.ausom.net.au



12 August 1999



General Manager

Film and Online Content

Department of Communications, Information technology and the Arts

GPO Box 2154

Canberra. ACT. 2601.



Dear Sir / Madam,



Please find my responses to the Discussion of Options paper on 

the Review into the Closed Captioning Requirements of the Broadcasting Services



Act 1992.



My reaction overall is that the paper does not do justice to 

the evidence provided by the many submissions, particularly those 

submissions by the captioning providers and the national Working party on 

Captioning.



I put it to you that the submissions by the broadcasters, via FACTS and

individually,  have not given clear evidence that there are serious financial 

or technical problems that restrict or delay the introduction and expansion 

of captioning services when digital transmissions begin.



I want to comment on particular sections of the Options paper 

that help support what I am saying. (attached)



Thank you for letting me reply, and I hope that you are able 

to clearly understand  my response and ensure the user community's needs

(Deaf Australians) are strongly reflected in the final document.



Sincerely,



Ian Boucher







Response to Options Paper -

'Review into captioning requirements of the BSA 1992.



2.9	Exemptions list or phase-in schedule and implications of 'real and 

demonstrated difficulties broadcasters face in implementing the captioning 

requirements'.



There is no evidence that we are aware of any difficulties in captioning 

programs. We have already witnessed the successful production of closed 

captioning Australian-made (either via Australian Caption Centre and 

Channel 7),  overseas adapted captioning (Line 21), open captions on SBS, 

live to air captioning (by various broadcasters) in sport, important events 

and political debates, etc. Channel 7 has announced it will caption the 

2000 Olympics, a mammoth task, yet the Seven network clearly believe they 

can provide this service.



The Australian Caption Centre submission also states that there is the 

technology to assist regional networks with captioning their programs.



Therefore any real and demonstrated technical difficulties are 

un-substantiated.





2.10 - 2.12   USA and UK captioning phase-in program



With the USA and UK, they are in fact phasing in to achieve captioning of 

all programs.



We should be including a similar process with total captioning by 2005 as 

recommended by the National Working Party on Captioning. It is financially 

and technically achievable.





2.13 Live unscripted programs, sport and news updates



There can seriously be no argument to support any difficulties broadcasters 

have with 'live unscripted programs, sport and news updates'.



We already have seen plenty of evidence through live programs that have 

been successfully captioned, despite no script such as AFL Grand Finals, 

AFL Brownlow medal count, Princess Diana's funeral, Election debates, John 

Farnham's 50th Birthday concert and the forthcoming 2000 Olympics. We know 

there are plenty more to list.



The broadcasters argument is baseless.





2.14 Captioning Costs and exemption of certain programs.



Costs - captioning does cost money. However, with our understanding of the 

captioning costs in comparison to the overall production costs per program, 

captioning costs is minimal.



Given the broadcasters annual profit margin, total captioning costs does 

not make sufficient impact to warrant any unfair hardship concerns.



Exemptions - I take strong offence to the suggestion that Deaf TV viewers 

do not want or are not interested in the audio component of live sport. The 

audio content (captioned) is vital to an appreciation of the totality of 

the sporting exhibition.



The same goes for Deaf people those who appreciate music and wish to access 

the verbal component. This was recently demonstrated with the John Farnham 

50th birthday concert being captioned.



It is our right, like all other people who can hear to enjoy and appreciate 

television and captioning the audio component is an essential part of 

providing the access to the television program.





2.15	Regional stations and costs



The Federal government provided broadcasters with a free digital television 

licence as part of the deal to incorporate captioning in their programs.



The Council believes that whilst there are obvious costs associated with 

provision of captioning to the programs, these overall costs are minimal 

and do not make sufficient dents into their profit margins.



In fact, the reverse is more likely possible. As accessible captioned 

programs are provided, Deaf viewers will watch their programs thus 

improving the TV ratings. Ratings positively impact on income received from 

advertising which goes to the broadcasting station.





2.18	Level of captioning



As stated in 1998, Channel 7 already provided 87% of prime time programs 

with captions and the ABC providing 60%. This demonstrates that technical 

and financial issues have no impact.



We expect that all TV Broadcasters are more than capable of providing 

similar achievements to that of Channel 7 by 2001 and it is clear that 100% 

is attainable without seriously impacting on profit margins in the next few 

years.





2.19   BSA ss. 4(2)  Phase-in period / exemptions



I re-state that there is no clear evidence of any unnecessary or 

burdensome technical or financial issues confronted by broadcasters in 

relation to captioning of TV programs.



The imposition argument is contradicted by the performance and willingness 

of Channel 7 to provide captioning to 87% of their prime time programs and 

also caption live-to-air sporting programs such as the AFL Grand Final and 

the forthcoming 2000 Olympics.



There should be No phase-in period or exemptions, except as recommended by 

the National Working Party on  Captioning.









3. Options



I am not happy with the Options (1 - 4) as listed as they do not do 

justice to what is currently provided and what is possible with little 

technical or financial burden.



However, Option 1 standard comes the closest and I would strenously oppose 

that 'live sport'  and lyric (vocal) music be exempted.





I do not make any comment on Options 2-4 as I do not support them.





4.4    Legislative amendments to caption programs outside of prime time.



I re-state that I support the National Working Party on Captioning goal 

that all  programs be captioned by 2005.



Clearly, broadcasters are influenced by the community and others as to what 

program go to air and what is captioned. Channel 7's decision to caption 

the Sydney 2000 Olympics is a good example of community and other pressures 

encouraging them to do so.



Standards need to illustrate what the community wants and in this case, 

they need to be mindful of  what Deaf Australians want. The National 

Working Party on Captioning reflects Deaf Australians views.



4.5   Australian Drama



It is my understanding that all Australian drama programs are currently or 

have been captioned.



There should be no diluting of this achievement.





4.6	- 4.7    Children's programming



I support the National Working Party on Captioning's view that all 

children's programs should be captioned by 2002.





4.9 - 4.10	Definition of News and Current Affairs



I support the need for 'news and current affairs' to be defined.



I believe that not only prime time news and current affair program, but 

also early morning news and current affairs (eg; Today show) and news 

updates / bulletins held thorough-out the day, should be captioned.





4.11- 4.15     Presentational Issues



In regards to presentation standards for captioning, a code of practice 

should be adopted and agreed to. This will ensure that all captioning is 

presented in high quality, accurately and professionally.





4.16	- 4.17    Captioning functionality of TV receivers



I re-state as a matter of urgency and ensuring the effectiveness of 

captioning being accessible to all Deaf Australians on all television 

receivers, that all receivers include the capacity to decode captioning 

data.



I ask that this standard for captioning functionality  be mandatory on all 

digital receivers.





4.18 - 4.21   Review

I support a review before December 31, 2003. This provides broadcasters 

with ample time to ensure they are achieving the performance required by 

the standards and allow for quick reflection and re-assessment in relation 

to technology change, etc.





Thank you.



Ian Boucher