1. 21st Century Communications
and Video Accessibility Act (CVAA)
Legislation, Responsibilities, Compliance in the US
Andrew Sachs Jennifer Knutel
VP. Product Management Sr. Dir of Marketing
Volicon and this webinar are not to be construed as providing legal advice.
Please consult your own lawyer for legal advice.
2. Agenda
• Background on Accessibility
• CVAA and FCC Report and Orders
• Video Description & Closed Captions for IP
– SMPTE-TT
– Who is affected
– How to be in compliance
– Deadlines
• Volicon contribution for compliance
• Q&A
3. Background on Accessibility
• Communications Act of 1934
– Radio to Communications (FRC to FCC)
– “[communication] made available to all people ”
– Decency, Affordability, Accessibility,
• Closed Captions – 1993 CEA-608
– 13” and larger screens to have CC decode
• Amended by “Telecomm act of 1996”
– Focus on content not standard
– MVPDs must caption
• 2002 – DTV CC requirements
– CEA-708 from 608
4. Background on Accessibility
• PAL (Europe) evolved with TeleText
– Data Service plus Caption type capability
– Handled multitude of languages and characters
– Not widely mandated
• DVB settled on DVB Subtitles
– Main purpose to handle all languages
– Any characters – pictures or UNICODE
• not just alphabet based
– Practically – Pictures, not characters
– Does not describe scene
• Not focused on accessibility
– Subtitles not same as Captions
5. CVAA and FCC Report and Order - Summary
• CVAA passed by Congress in 2010
• Title I – Broadband (IP) delivered Products and Services
accessible to people with disabilities
• Title II – Make it easier for people with disabilities to view
consume content
• Two FCC Actions so far
• FCC 11-126 - Aug 2011 - Descriptive Video Service (DVS)
• Rules p38 Appendix B
• FCC 12-9 - Jan 2012 – Captions on IP Video content
• Rules p81 Appendix B
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6. Descriptive Video Service
• FCC 11-126 – Descriptive Video Service (DVS)
• Reinstated rules originally knocked down in court in 2002
• Descriptive Video -“…is the insertion of audio narrated
descriptions of a television program's key visual elements into
natural pauses in the program's dialogue”
• Why? – “…makes video programming more accessible to
individuals who are blind or visually impaired.”
• Who? -
• Top 4 Networks – ABC, NBC, CBS, Fox
• MVPDs (cable, IPTV, sat) with > 50k subs
• On top 5 non-broadcast (cable) networks
• Pass through DVS on Top4 Networks
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7. Descriptive Video Service
• FCC 11-126 – Descriptive Video Service (DVS)
• When?
• July 1, 2012- Rules in place
• October 2012 – compliance mandated
• What? - 50 hours of prime-time or children’s programming
with DVS per quarter
• Practically DVS implementation – SAP channel
• Linear /VOD Programming – an additional audio channel with
DVS and audio track together
• Looks as another audio channel with slightly more speech content.
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8. Closed Captioning of IP Video - Summary
FCC 12-9 Jan 2012 - Report and Order
• Regulating IP Delivered Content
• IP much more encompassing than just INTERNET
• Basically any new video service uses IP
• Regulatory First – FCC regs on internet
• Regulating content delivered by technology
• “But also delivered over broadcast
• Extends intent of CC to new devices and services
• Evolution of TV services necessitated evolution of
regulations
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9. Closed Captioning of IP Video – Who
• New Definitions for a New Video World
• Video Program Owner (VPO) – company that licenses
content to VPDs for IP distribution of content.
• Video Program Distributor/Provider (VPD/VPP) –
company that licenses content from the VPO and
makes it available to the consumer using IP technology.
• IP Technology is pretty encompassing
• EVERY OTT delivery mechanism is using IP –
somewhere in the delivery chain, .
• Mobile video, STB, IPAD, 3 screens, connected,
disconnected?
– Uncle Sam wants You!
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10. Closed Captioning of IP Video – Who
• Who is not affected?
• Professional and Commerical
– Ironic, but Volicon is not obligated
• Display only Devices –
– Screen in Bar, Taxi, elevator
• Technically Not Feasible by device
– Pretty high hurdle to show here
– Better not have any downloadable SW
• Other Venue/use Exemptions -
– must apply to FCC for exemption
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11. Closed Captioning of IP Video – SMPTE-TT
• 608 and 708 are no longer valid
• Specific to Analog or Digital broadcast TV in US
• IP has many, many delivery formats –
– Don’t want to specify the internet
• What if we regulate how captions they are handed off?
• When we get to compliance – SMPTE-TT is key!
• Video Program Originators – VPOs
– Generate content with SMPTE-TT formatted captions
• Video Programming Delivery – VPDs
– Generate captions from content with SMPTE-TT
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12. Closed Captioning of IP Video – SMPTE-TT
• SMPTE profile of W3C Time Text Markup Language
• Standard SMPTE 2052-1:2010 –
• Handles CC 608, CC 708, DVB-Subs, WST (World TT)
• Preserves many critical elements of CEA-708
– Position, transparency, font, color, timing, ..
• SMPTE-TT VPO VPD Interchange Standard
• Widely in use today
• Two modes
– Preserve – keep the look and feel of the originating formats
– Enhance – normalize look and feel to be uniform on target
device
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13. Closed Captioning of IP Video – Content
• “Delivered to Consumer” content only
• Not regulating professional video content
• Content delivered by MVPD or broadcaster
• Drives content to have captions in the first place
• Archived content subject to rules once it is ‘re-aired’ on TV
• Captions same or better quality than original
• Completeness, Accuracy, Timing, Placement
• Full length content – not short clips.
• Foreign Content –
• Required if originating country required captions/subtitles
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14. Closed Captioning of IP Video – Compliance
• VPO Regulations
• VPOs are normally not regulated, regulation is light
– It always starts that way
• Determine which content is subject to regulation
– Content that is broadcast
• Produce SMPTE-TT for regulated content
– Same quality or better than CC that is broadcast
• Provide VPD/VPP with certification of what is regulated
– Asset based documentation of any non-compliance
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15. Closed Captioning of IP Video – Compliance
• VPD/VPP Regulations
• Must pass through SMPTE-TT when provided by VPO
• Ensure devices can render this SMPTE-TT content
– Delivery standard is NOT regulated, just interchange format
• Must Retain VPO certifications for up to 1 year
– Have to deliver to FCC in response to inquiry
– SMPTE-TT + Certifications VPD Safe Harbor
• It is your “Get out of dealing with the FCC card”
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16. Closed Captioning of IP Video – Complaints
• Very Similar to Closed Captions Complaint process
• Written, consumer oriented,
• 30 days to complain
• VPD/VPO has 30 days to respond
• Certifications from VPO will determine where complaint
lands
– Complaint process starts October 2013
• Rules enacted much sooner
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17. Closed Captioning of IP Video - Deadlines
• Again, only applies to content that is also broadcast
• Depends on Content Type
• Pre-recorded and not edited for Internet – July 2012
• Live or Near-live and not edited for Internet – Jan 2013
• Edited for Internet content July 2013
– Again, complaint process starts October 2013
• But the VPD/VPO can be technically non-compliant earlier
• Allows time for ecosystem to get into compliance
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19. How does Volicon help with CVAA?
• Ability to provision multiple audio channels
• Observer Analog, SDI, TS
• DVS SAP channel in addition to
• Monitor main and DVS channels, export any
– Uniform Source for CC feed for repurposing
• Observer Logger already stores and indexes CC
• Able to export content (clips or programs) with CC
• Aligned by programs
– Based on As-Run-Log import from automation system
– Typically already integrated in logger installations
20. Q&A
Andrew Sachs Jennifer Knutel
VP. Product Management Sr. Dir of Marketing
andrew@volicon.com jennifer@volicon.com
Please contact us for
additional product information
21. For more information please
contact us (info@volicon.com)
+1 781 221 7400
Andrew Sachs Jennifer Knutel
VP. Product Management Sr. Dir of Marketing
andrew@volicon.com jennifer@volicon.com
Volicon and this webinar are not to be construed as providing legal advise.
Please consult your own lawyer for legal advise.
