Deaf Australia and the Deafness Forum of Australia noted that the multichannels are currently required to meet the same captioning provisions as the ‘main’ channels once digital switchover takes place in each region. Deaf Australia noted that the broadcasters have been aware of this for many years and have had ample time to prepare for it. Deafness Forum emphasised that any requirement for captioning imposed on broadcasters forms part of their commercial business decisions as much as any other production cost, and that there is therefore no reason to reduce captioning requirements. Both groups noted that there are no technical reasons why multichannels cannot provide captioning to the same extent as main channels, given that Channel 7 captioned all of the 2008 Beijing Olympics. They also noted that one in six Australians have a hearing impairment and benefit from captioning, thus forming a lucrative market for broadcasters. The groups emphasised that the granting of any exemptions from captioning requirements would contradict the Government’s commitment to social inclusion, and fail to meet its requirements under the United Nations Convention of the Rights of Persons with Disabilities.
The Australian Communications Consumer Action Network (ACCAN) submitted that the current caption requirements for the main channels should apply once digital switchover takes place in a region, and that, over time, captioning should increase to 100% of program hours.
Michael Lockrey, a hearing-impaired television consumer, submitted that the current captioning requirements for main channels be imposed upon all multichannels from June 2010. He noted that any exemptions granted to broadcasters would further exclude the Deaf and hearing-impaired community from the rest of society, contravening the Government’s policy to promote social inclusion.
Blind Citizens Australia (BCA) emphasised the need for audio description on Australian television, and called for audio description to be mandated in the Broadcasting Services Act 1992 to the same extent as captioning, and for all publicly funded Australian programming to be audio described.
Free TV Australia, which represents the free-to-air television networks, believes that regional broadcasters have special business models which would make it difficult to meet captioning requirements. Free TV noted that multichannel broadcasters spent significant resources on developing business models for multichannels, but suggested that captioning requirements would force them to restructure their business models.
The Australian Subscription Television and Radio Association (ASTRA) wants regional broadcasters to be exempt from captioning requirements until full switch-off. ASTRA believes that regional broadcasters would find it very difficult to meet captioning and Australian content requirements if the metropolitan broadcasters do not have to meet them. This is because they rely on metropolitan broadcasters for most of their captioned content.
The ABC has committed to achieving 100% captioning over time. At present, they caption 90% of ABC1 programming, nearly 90% of ABC2, and 80% of ABC3. The ABC, however, suggested that it would be unfair for some regional broadcasters to be required to meet captioning requirements whilst others were not, and therefore suggested that captioning requirements be pushed back until 2013.
SBS noted that SBS ONE complies with current captioning requirements for free-to-air television, as well as providing English subtitles on the majority of its foreign-language programs. SBS suggested that SBS TWO would be commercially unviable (in the short term) if it were required to meet current captioning conditions. SBS called for captioning requirements to be withheld on multichannels until the end of the switchover period.
National Indigenous Television (NITV) stated that it would welcome further Government funding to meet any captioning requirements; without such funding, NITV noted that captioning requirements may preclude its operation.
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