In response to Colorado Law’s Petition for Declaratory Rulemaking, Jocelynn A. Moore, NCRA’s Director of State Government Relations, has submitted the following public comment to the Federal Communications Commission:
NCRA supports this petition with regard to the topic of Automatic Speech Recognition (ASR). Additionally, we are aware that the quality of captioning remains a critical issue and look forward to working with our consumer partners regarding this specific concern. Further, NCRA and our Captioning Committee members would like to note that positive changes are occurring in the way that captioning is currently processed. This is due, in large part, to the best practices standard that our Captioning Committee advocated for before the FCC and which was ultimately implemented in 2015. For instance, due to this standard, our captioners have had more access to advanced material, including scripts and lyrics, than they had prior to 2015; access to more advanced material improves caption quality. Lastly, NCRA is committed to improving the quality of captioning and feels the FCC complaint process could better encourage viewers who use captioning to file complaints and provide feedback to the FCC.
The petition, filed by the Colorado Law Technology Law & Policy Clinic, asserts that the FCC’s “best practices standard” that already applies to human captioners should also be equally applied to ASR technologies. The Clinic also recommends that the FCC should investigate ASR technology to ensure that its captions are equal to human captioning. The “best practices standard” says:
Captioning quality will now be measured via four non-qualitative measures:
- Accuracy – the captions “accurately reflect what is in the program’s audio track by matching the dialogue, music, and sounds, and identify the speakers”;
- Synchronicity – the captions “are delivered synchronously with the corresponding dialogue and other sounds at a speed that can be read by viewers”;
- Completeness – the captions “are complete for the entire program”;
- Placement of the captions – the captions “do not obscure important on-screen information and are not obscured by other information on the screen.”
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