EXTERNAL EMAIL:[ADP-List] FCC seeks comments on expanding the CVAA #takingaction


Sheila Styron
 

Robert,

I would be interested in reading your comments if you care to share them here. I want to comment but don’t want to just write something like I want everything to have description, and I want just as much description as there is captioning, though this is what I feel like writing. LOL!

 

 

 

Sheila Styron, ACTCP
Blindness Low Vision Specialist II

The Whole Person
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From: ADP-List@... <ADP-List@...> On Behalf Of Robert Kingett
Sent: Thursday, April 8, 2021 10:48 AM
To: ADP-List@...
Subject: EXTERNAL EMAIL:[ADP-List] FCC seeks comments on expanding the CVAA #takingaction

 

CAUTION: This email originated from outside the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.

This is a chance to expand audio description requirements to include streaming services.

I already filed my comment this morning. All links are below, and emails if you need help filing.

On April 7, 2021, the Commission released a Public Notice to invite public comment on whether any updates are needed to the rules implementing the Twenty-First Century Communications and Video Accessibility Act (CVAA). Most of these rules have been in effect for many years, and many of them have not been revisited recently, some since initial adoption. Given changes in technology and industry practices, as well as taking into account consumer experiences, the Commission seeks comment on whether there is a need to update these rules.

Comments Due: May 24, 2021

Reply Comments Due: June 21, 2021

Interested parties may file comments by accessing the Electronic Comment Filing System

All filings must reference GN Docket No. 21-140.

The easiest way to put that in with a screen reader is just include the, 21-140, in the form, then enter browse mode, then click the link below the edit field that will input the correct number.

People with disabilities who need assistance to file comments online may request assistance by email to FCC504@....

Here's a link to the actual request online, also containing files in multiple formats.

https://www.fcc.gov/document/fcc-seeks-comment-fulfillment-cvaa


 

My comments were accepted! That was fast! Anyway, the text of my comment is below.

Audio description rules in the CVAA should be expanded to include streaming video providers and ensure audio description is transferred across platforms.

The 21st Century Communications and Video Accessibility Act, CVAA, doesn’t address the growing need for audio description regarding streaming video and video on demand services streamed over the internet. The CVAA needs to be expanded to include provisions that would ensure audio description is maintained across internet streaming services.

Audio description is a professionally produced audio track that describes key visual elements in a movie or TV show in between natural pauses in the soundtrack. A few internet streaming services provide audio description for original content, and obtain third party tracks wherever possible, but the inconsistency and disorganization of this process causes existing audio description tracks to disappear or not be negotiated when licensing the content.

Currently, the FCC rules require local TV station affiliates of ABC, CBS, Fox, and NBC located in the top 60 TV markets to provide 87.5 hours per calendar quarter (about 7 hours per week) of audio-described programming, of which 50 hours must be prime time and/or children's programming and 37.5 hours may be any type of programming shown between 6:00 a.m. and midnight.

Very few of the existing audio description tracks make it to streaming services. In most cases, audio description tracks created for broadcast and feature films don't make it to any streaming service without lawsuits, tying up judges, costing the judicial system more than $75,000 when judges could be handling other cases.

All nonexempt full-length video programming delivered using Internet protocol must be provided with audio description if the programming is published or exhibited on television in the United States with description.

Audio description isn't that expensive to produce. regarding the costs to program owners, providers, and distributors of creating video-described content, the maximum cost of creating video-described programming remains consistent with the Commission’s 2017 estimate of $4,202.50 per hour, while the cost of described pre-recorded programming can be as low as $1,000 per hour. If audio description tracks were shared across platforms, then this would help keep costs low for everybody involved.

I urge you to amend the AD provisions in the CVAA with a Legislative rule. The FCC must propose a new rule that preserves audio description tracks across platforms.


Tina Hansen
 

I like that. I know there’s been a good deal of discussion regarding the use of text to speech technology for audio description. While some, like me, are opposed to the use of TTS, others either feel grateful for any description, are neutral about it, or they just don’t care. Do you think that the use of professional voice actors should be part of the standard? I know some won’t care about this, but I feel uncomfortable with audio description using TTS unless it was very specific, narrowly focused or targeted to something that was not designed to last. Personally, I believe voice talent is a must for audio description of mass media shows, regardless of whether they’re on broadcast TV or streaming platforms. Should we insist on this requirement for going forward? Thanks.


 

While I hate TTS AD in entertainment, I didn't put a requirement to have human narrators in my comment, but you can! TTS AD is here to stay and we need to figure out how to use it effectively so studios will understand that it won't be good, culture wise, to use TTS AD. It's not going away, but if I required the FCC to add into the CVAA that human narrators be used, I feel like the CVAA would never be expanded.

Plus, TTS AD can be good for low income people that want to make their videos accessible. So, like I said, TTS AD is not going away, we have to learn how to navigate around it.

But if you wanna put that in your comment, knock yourself out. I won't put it in future comments.


Margie Donovan
 

I wish to make my comments known re TTS. Just last week, I had to listen to something on JAWS, and when a human reread it, I found that I missed a lot. This was in the work of a committee and most if not all of us felt using JAWS was not nearly as good as the human reader. Now that I say this, it is important that you know the reading had to do with selecting candidates.

 

I tell this story because many of us would have selected another candidate based on JAWS. After hearing the human reader, we all voted for another candidate. This clearly tells that TTS is nowhere near what a human voice cand portray.

 

We need to educate the public about the significant difference. I would go for the gusto and ask for what works for us. We should also advocate for what works for us and not just settle as we are concerned that this would seriously impact us on getting more ad.

 

As an example,, it would be like a person who is deaf trying to read the caption on TV, but the screen is always very blurry.

 

Margie

 

“Happiness is a by-product – the extra dividend of giving without any demand for a return.”    

 

From: ADP-List@... <ADP-List@...> On Behalf Of Robert Kingett
Sent: Thursday, April 8, 2021 4:59 PM
To: ADP-List@...
Subject: Re: EXTERNAL EMAIL:[ADP-List] FCC seeks comments on expanding the CVAA #takingaction

 

While I hate TTS AD in entertainment, I didn't put a requirement to have human narrators in my comment, but you can! TTS AD is here to stay and we need to figure out how to use it effectively so studios will understand that it won't be good, culture wise, to use TTS AD. It's not going away, but if I required the FCC to add into the CVAA that human narrators be used, I feel like the CVAA would never be expanded.

Plus, TTS AD can be good for low income people that want to make their videos accessible. So, like I said, TTS AD is not going away, we have to learn how to navigate around it.

But if you wanna put that in your comment, knock yourself out. I won't put it in future comments.