AEEMA’s Comments in relation to Issues Paper on Captioning Television Programmes.

 

 

This is a response to the Issues Paper distributed on 30/10/98 to AEEMA for comment.

Digital Television.

As Digital television broadcasting is to begin on 1st January 2001 there are a number of important points to be made in relation to calls for decoders to be included in receivers and the introduction of digital TV.

Firstly, referring to the point made previously about design. If the analog receivers have not been designed for teletext they will need to be redesigned. If the legislation is changed to mandate decoders in all receivers this work will need to be conducted at the same time as digital receivers are being developed. Manufacturers would be forced to spend valuable resources updating obsolete analog technology instead of developing new digital technology. This is an unacceptable impost on the industry.

Secondly, DVB specifies two ways that could be used for captioning. One is specifically for closed captioning, being subtitle bitmaps and quite some work has been done to develop fonts that are easy to read. The other is teletext which was included as a compatible system with existing analog TV. Clearly the one designed to carry captions is the former. Broadcasters, however, may elect to use the latter as they will be required to simulcast PAL and Digital TV and it may be easier for them to do this. It is our understanding that free to air broadcasters will initially elect to transmit captions via page 801 through teletext, however, over an undetermined period of time they will change to the subtitle bit map method. This means that if legislation mandated receivers to decode captions both systems will need to be present in the receivers to avoid legacy issues.

Because of the nature of digital TV, reception of captions in digital receivers will have the same coverage as the vision content thus avoiding the types of reception problems faced with analog receivers.

One point not covered is the potential for multichannel audio in DTV to provide audible description tracks for the visually impaired. It seems that the argument used to substantiate that indirect discrimination exists in not broadcasting captions is also valid to scene descriptors for the visually impaired for DTV with multiple audible channels.

Conclusion

It is AEEMA’s view that if receivers are to contain decoders as a mandatory requirement that this should only apply to Digital receivers and that the nature of captioning in the Digital broadcasts should be determined to give receiver manufacturers sufficient time to design the receivers.