Some of the points ASTRA makes in its letter are as follows:
· In its application, ASTRA argues that “an obligation to caption all programming on all channels would be financially prohibitive”. To determine if this is the case, the AHRC asked for details of the applicants’ profit and expenditure on captioning for 2009/2010. ASTRA decline to give details of profits, arguing that these are highly confidential, and notes that the various channels on FOXTEL have different owners and operate under different business models. ASTRA notes that fully captioning a channel across 24 hours would cost at least $1.75M per annum, and even half that figure would be financially prohibitive.
· ASTRA rejects the proposal put forward in several submissions that it should spend 1% of its annual turnover on captioning.
· ASTRA has clarified how the various captioning level percentages it has proposed were arrived at for each channel.
· In response to the suggestion made in some submissions that its proposals could lead to less captioning on some channels, ASTRA notes many channels currently exceed their minimum levels, and no channels have decreased captioning since the first exemption was granted.
· ASTRA has reiterated why it believes 26 channels should be exempt from captioning requirements.
· In response to submissions asking if there are any plans to provide captions on the FOXTEL download service, ASTRA says that it is not technically possible to do this at the moment.
· ASTRA submits that the system of reporting caption levels annually should be maintained, as reporting quarterly is unnecessary and would be an unreasonable burden.
· Responding to the proposal that new channels which begin broadcasting during an exemption period should not have to apply for a separate exemption, ASTRA notes the extra time and work this would involve.
ASTRA’s letter can be read in full on the AHRC website.
Top of page