A large number of submissions were made from Deaf and hearing impaired representative groups, blind and vision impaired representative groups, industry, media access groups, and individuals. Issues discussed included the captioning and audio description (AD) of televised and online content, multichannels, and emergency and advertising information. You can read the submissions at the DBCDE website. Below are summaries of submissions by representative and industry groups.
Most submissions called for regulatory certainty surrounding legislative requirements of access to media. At present, there is some crossover between access requirements contained in the Broadcasting Services Act 1992 (Cth) and the Disability Discrimination Act 1992 (Cth).
Representative Groups
Deaf and hearing impaired groups included the Deafness Forum of Australia (DFA) and Deaf Australia (DA), the Deafness Council of Western Australia (DCWA) and the Parent Council for Deaf Education (PCDE). The DFA believes that 2013 is too long to wait for a follow-up review. All groups support captioning targets of 100% of all programming (not just 6.00am to 12.00 am), both for free-to-air and subscription television. The groups believe that current captioning requirements of primary free-to-air channels should be required of digital multichannels immediately after analog switch-off.
The groups noted that caption quality is a major issue, stating that ‘poor quality captions are as bad as no captions at all’. The groups do not support a voluntary industry standard for AD and captioning of DVD and Blu-Ray content, as one already exists, which the DFA believes is largely ignored. The DCWA disagreed with the Report that the refurbishment of cinemas for access is a purely commercial decision, and that cinema access is greatly important. The DFA and DA noted that it is imperative that emergency information be captioned. The PCDE stressed the importance of captioning of film and online content for education.
Blind and vision impaired groups included Vision Australia (VA), the Australian Blindness Forum (ABF), Blind Citizens Australia (BCA), the Royal Society for the Blind (RSB), and Vision 2020. The groups strongly welcomed the Report’s call for a trial of AD on the ABC. Indeed, BCA called for free-to-air and subscription television providers to be required to provide the same levels of AD as they are of captioning, and for ACMA to be empowered to enforce these requirements. VA and the ABF called for technological developments in the area of accessibility, including overseas, to be closely monitored and implemented by media providers. The RSB noted that cost should not be a barrier to providing access, and that ‘Good Design is good design for all’.
VA called for regulation of minimum standards for DVD and cinema AD and captioning. VA and Vision 2020 highlighted the need for the refurbishment of any cinema to include making that cinema able to provide captions and AD, and for cinemas to have minimum AD requirements. VA called for all DVDs which are captioned or audio described overseas to be just as accessible on their Australian release, and for all publicly funded Australian films and DVDs to be compulsorily accessible.
Industry Groups
Free TV Australia, the industry body of commercial broadcasters, opposed both any minimum requirements for AD of television content and 100% captioning requirements on primary channels. Free TV also opposed the development of a captioning quality code of practice, and of requirements to caption online audio-visual content. Free TV suggested that emergency information should be made available both visually and audibly, but that strict requirements should not be imposed on broadcasters. Free TV suggested that multichannels not be required to meet current captioning requirements until full analog switch-off.
The ABC remains committed to achieving universal access on its programming, and has consistently met and exceed its minimum captioning requirements. The ABC stated that, to caption 100% of programming would cost $12 million. Although suggesting that captioning of online content may incur new costs, the ABC has begun offering some captioning on its iView programming. The ABC suggests that it may experience difficulty in providing AD, as this requires additional spectrum space as well as any associated costs with producing or acquiring AD for programming. The ABC has a policy of providing open captions on emergency broadcasts if technical issues prevent the transmission of closed captions.
The SBS meets its current minimum captioning requirements of English-language programming, and provides English-language subtitles for most of its non-English programs. The SBS believes that requiring AD on its online content would be prohibitive, and welcomed a government-funded trial of AD on broadcast programming, and noted that its multilingual content could pose further issues for AD.
The Australian Subscription Television and Radio Association (ASTRA), the industry body for subscription television providers, believes that subscription television is similar in nature to commercial free-to-air multichannels. As such, it believes that subscription television should be treated differently to primary free-to-air channels, and have lower access requirements. ASTRA is opposed to providing AD, but some subscription channels have begun ‘investigating’ AD. ASTRA is opposed to providing captioning and AD on online content.
Google remains committed to achieving universal access to its online content, and has recently developed ‘Auto-cap’—automatic captioning of (some) YouTube videos. Google, however, opposes legislative requirements for online access. Telstra is generally supportive of making online content more accessible, and suggests that any funds provided by Screen Australia to caption and audio describe audiovisual content for cinema and DVD release also be used to provide captioning and AD suitable for that content to be made available online.
The Australian Visual Software Developers Association (AVSDA), an industry body representing video and DVD distributors and copyright owners, does not believe that it should have to work with representative groups to promote access. AVSDA, while supportive of providing closed captions and AD on major titles, does not support being required to provide accessibility features on other, smaller titles.
All submissions can be downloaded from the DBCDE website.
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