How to file a captioning complaint with the Federal Communications Commission

The Federal Communications Commission (FCC) encourages feedback from television viewers. According to the FCC, a complaint is a form of feedback, and the Commission wants feedback from viewers. Any television viewer who cares about captioning quality is encouraged to file a complaint whenever they see poor captioning, and you can easily file a complaint from the fcc.gov website.

Many television stations are now using machine captioning or simply the teleprompter as opposed to human captioning. Several companies provide machine captioning to the television stations. These companies and their products are IBM (Watson), ENCO (enCaption3 and 4),  Link (ACE Encoders), and EEG (Lexi).

To file a complaint, we suggest you focus on accuracy, which is one of the four tenets of captioning quality established by the FCC in 2014 (the others are synchronicity, completeness, and placement).

To be accurate, captions must reflect the dialogue and other sounds and music in the audio track to the fullest extent possible based on the type of programming. Accuracy also requires captions to identify the speakers. We find that automatic captioning violates this standard in many ways:

  • Punctuation: Machine captioning provides limited, or wrong, punctuation.
  • Speaker identification: Machine captioning does not identify speakers with >> or names, often including captions from multiple speakers in the same line.
  • Lyrics and sound effects: The FCC Caption Quality best practices clearly state that lyrics and sound effects must be included when measuring accuracy. Engines don’t.
  • Proper nouns:  Proper nouns are a problem with many engines, especially those engines not properly trained.

When you watch television programming, keep these criteria in mind and make notes of any errors in these areas that you see. When possible, try to take photos or record video on your phone to upload with your complaint. In the complaint form provided by the FCC, you will be asked to elucidate the errors and mistakes that you see. You may also attach a screen shot or video showing what you are making a complaint about.

When you open the complaint form provided by the FCC, you need to fill in the following fields:

  • Your email address
  • Subject of the complaint (e.g.: [Station] does not meet FCC quality standards)
  • Description of the complaint (detail the specific instances)
  • Accessibility issues (choose “Closed Captioning on TV” for TV programs)

Once you choose your accessibility issue, additional fields will appear. Those with an asterisk are mandatory.

  • *Preferred method of response: The FCC and the station have to respond to your complaints. This will allow you to choose what medium they use to do so. Your options are email, fax, letter, other, relay service, telephone, and TTY.
  • Name of company complaining about: Enter the name of the specific station.
  • City of company complaining about: Enter the city in which the station is located. For national feeds, you may need to look up the station online.
  • State of company complaining about
  • ZIP code of company complaining about
  • Phone number of company complaining about
  • *Date of your issue: you must enter an actual date, even if the problem is continuous.
  • *Time of your issue
  • *Your TV method (cable, satellite, fiber, internet, over the air)
  • *Name of subscription service (your cable company)
  • TV channel
  • Call sign
  • Network
  • Name of TV program
  • *City where program was viewed
  • *State where program was viewed
  • *Your first name
  • *Your last name
  • *Address 1
  • Address 2
  • *City
  • *State
  • *ZIP
  • *Phone
  • *Filing on behalf of someone? (yes/no)
  • Attachments: Include here any photos or video you may have taken of the captioning errors

After you complete and submit the complaint to the FCC, the FCC will evaluate the complaints and contact you if more details are provided. After this, they generally reach out to the programmer or TV station. At that point, the station may also contact you to compile their response to the FCC. This can take 30-60 days. When you receive these responses, please forward them to NCRA’s Government Relations Manager Matt Barusch at mbarusch@ncra.org, for record keeping.

NCRA believes that machine captioning is not ready for live television programming or any other live events. We know the companies behind this technology will keep working to improve their products. NCRA is committed to providing the best possible access for people who are deaf or hard of hearing.

FCC’s Disability Advisory Committee meeting announced

The Federal Communications Commission’s Disability Advisory Committee meets on October 3. NCRA’s Government Relations Manager Matthew Barusch; NCRA Board Member Steve Clark, CRC; and NCRA President Sue Terry, FAPR, RPR, CRR, CRC, will attend this meeting and will raise the issue of Sinclair Broadcast Group using IBM Watson Captioning. If you are planning to attend this meeting in Washington, D.C., next week, please contact Matthew Barusch at mbarusch@ncra.org for important information!

Read more.

Online live and near-live captioning deadline nearing

JCR: Journal of Court Reporting, TheJCR.com, JCR WeeklyTVTechnology.com posted an article on June 23 written by Heather York of VITAC, about the FCC requirements mandating that all live or near-live programming on television be captioned when delivered via internet protocol, which take effect July 1.

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Groups seek captioning assurances from FCC

JCR logoMultichannel.com reported on May 12 that a host of groups serving the deaf and hard-of-hearing community have asked the Federal Communications Commission to make sure that closed captioning requirements carry over to the voluntary rollout of the ATSC 3.0 next gen transmission standard.

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NCRA represented at FCC subcommittee

Photo by Greg Elin

NCRA’s Matthew Barusch, Manager of State Government Relations, represented the Association at the Federal Communications Commission’s (FCC) Disability Advisory Committee (DAC) meeting on March 21. NCRA is a representative member of the Video Programming and Technology Transitions subcommittees for a two-year term. This is the second time the Association has served on this committee. Nearly two dozen other parties representing a number of companies, nonprofit organizations, and individual consumers are serving on these subcommittees.

According to Barusch, the Video Programming Subcommittee will issue recommendations on seamless video captioning and video description.

“NCRA will work with the Video Programing Subcommittee to identify issues associated with the transmittal and receipt of captioning and video description files by video programming providers and distributors during the transition from analog to IP communication transmission,” he explained.

The Technology Transitions Subcommittee will examine issues related to real-time text.

“NCRA is thrilled to have the opportunity to provide input on the FCC’s rulemaking regarding this matter. The transition to IP communication transmission presents challenges to members of the captioning community, and I look forward to working with the DAC on addressing these issues,” he added.

The FCC established the DAC in December 2014 to provide advice and recommendations to the Commission on a wide array of disability issues within its jurisdiction. According to the FCC, the DAC provides a means for stakeholders with interests in accessibility issues to exchange ideas, facilitate the participation of consumers with disabilities in proceedings before the FCC, and assist the FCC in educating the greater disability community and American with Disabilities Act-covered entities on disability-related matters. The Committee is expected to keep the FCC apprised of current and evolving communications issues for people with disabilities. Other subcommittees include Communications, Emergency Communications, and Relay/Equipment Distribution.

Pittsburgh court reporter speaks out about new rules and demand for captioning services

jcr-publications_high-resNCRA member Constance Lee, RPR, owner of Constance Lee & Company, Pittsburgh, Pa., was quoted in a press release issued Jan. 10 about the expected increase in demand for captioning services as a result of recent programming rules issued by the Federal Communications Commission.

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NCRA re-appointed as representative on FCC Committee

Photo by Greg Elin

Photo by Greg Elin

NCRA has been named to serve a two-year term as a representative member on the Federal Communications Commission’s (FCC) Disability Advisory Committee (DAC). The appointment was announced Jan. 5 and marks the second time NCRA has been named as a representative.

NCRA joins nearly two dozen other parties representing a number of companies, nonprofit organizations, and individual consumers serving on DAC’s Technology Transitions and Access to Video Programing subcommittees.

The FCC established the DAC in December 2014 to provide advice and recommendations to the Commission on a wide array of disability issues within its jurisdiction. The DAC is slated to remain active for two years, with meetings of the full committee and four subcommittees to begin next week.

According to the FCC, the DAC provides a means for stakeholders with interests in accessibility issues to exchange ideas, facilitate the participation of consumers with disabilities in proceedings before the Commission, and assist the Commission in educating the greater disability community and American with Disabilities Act-covered entities on disability-related matters. The Committee is expected to keep the Commission apprised of current and evolving communications issues for persons with disabilities. Other subcommittees include Communications, Emergency Communications, and Relay/Equipment Distribution.

Matthew R. Barusch, NCRA’s Manager of State Government Relations, who will represent the Association, said the Access to Video Programming Subcommittee will address televised emergency information, closed captioning, video description, and equipment designed to receive, play back, or record video programming.

“Serving on the second chartered DAC is consistent with NCRA’s appointment on the first charted DAC. This appointment allows NCRA to continue to have a voice in FCC recommendations related to captioning and how it will meet the needs of the deaf and hard-of-hearing community,” Barusch said.

The first meeting of DAC’s new term is tentatively set for March 21 at the FCC’s headquarters in Washington, D.C. Additional tentative meeting dates include mid-June and mid-October.

NCRA Kindle Fire winner announced

By Jennifer Late

More prizes available for membership renewal

A record number of members have renewed their 2017 membership in October. These renewals were driven in part by a chance to win a Kindle Fire.

NCRA membership renewal Kindle Fire winner

The lucky winner for October 2016 is Karla Jagusch, RPR, of Overland Park, Kan. She has been a court reporter for over 38 years, 36 of which she has been an official court reporter for the First and Tenth Judicial Districts of the State of Kansas. Karla explains why she renewed her membership: “I feel it is important and my obligation to support the association that supports me as a court reporter.”

Photo by: Erik Araujo. Used and adapted with permission via Creative Commons

Renew before Dec. 1 and be entered to win

Members still have a chance to be rewarded for renewing before Dec. 1. NCRA will give away an upgraded Premium Plus listing on the online NCRA Sourcebook. Any Registered, Participating, or Associate member who has renewed before Dec. 1 will have their name entered into a drawing for this upgraded listing for January through December 2017.

NCRA continues to work for its members

  • Online skills testing: Whether you are just starting testing for your RPR or going for your CRC or another advanced certification, you can now complete your skills tests from the comfort of your own home. With more opportunities to test, you will be able to achieve your certification goals faster and increase your earning potential.
  • CRC Workshop & Certification: Based on member demand for more training in the field, NCRA created the new Certified Realtime Captioner program designed just for captioners.
  • FCC Captioning Quality Standards: NCRA’s Government Relations team has been working with the Deaf and Hard of Hearing Alliance and the Federal Communications Commission to develop new captioning quality standards.
  • Increased online education opportunities: NCRA has expanded its first-class educational programming via webinars and e-seminars vetted to ensure they meet the needs of the marketplace. New online webinars and e-seminars are added each month for members to purchase, view, and earn CEUs.
  • Exhibiting at the ABA TechShow: NCRA has been advocating for you with judges, attorneys, paralegals, clerks, and other legal professionals. With a focus on what your certifications mean and the value of realtime, NCRA is raising the overall awareness of the profession with the people who matter.
  • For CLVS members: A stronger CLVS emphasis was added to the NCRA Convention & Expo, helping videographers network directly with the court reporting membership. By popular demand, new seminars and webinars were created to help CLVSs stay on the cutting edge of technology.

NCRA membership cards

In an effort to embrace technology, NCRA will continue our practice of sending only electronic membership cards to members via email. Members can expect to receive their membership card within approximately four weeks of renewing if they have a valid email address and have not previously opted out of Constant Contact email messaging.

Jennifer Late is NCRA’s Membership & Marketing Manager. She can be reached at jlate@ncra.org.

Latest closed caption rules effective Sept. 22

TVTechnology.com reported on Aug. 29 that the most recently adopted closed captioning rules from the Federal Communications Commission go into effect Sept. 22. The effective date applies to the Closed Captioning Responsibilities Order, which was adopted by the FCC in February. The order, an amendment to existing closed captioning rules, delineates the responsibilities for closed captioning services and outlines complaint procedures.

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NCRA submits comments to the FCC on qualified captioners

On March 15, Adam Finkel, NCRA Director of Government Relations, submitted comments to the Federal Communications Commission in response to a report filed by the National Association of Broadcasters (NAB) and Telecommunications for the Deaf and Hard of Hearing, Inc. NCRA’s comments corrected an assumption that there are not enough captioners to cover media markets outside of the top 25. Among other points, Finkel pointed out the availability of training (including NCRA’s new Certified Realtime Captioner certification) and that some captioners are unable to accept work despite being qualified due to the inconsistent transition between POTS lines and the IP lines. “Like the consumer groups and NAB, NCRA shares the goal of ensuring high-quality captioning,” Finkel stated in the comments.

Read more.