Action Needed: FCC Caption Quality Standards Certification
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Please email ClosedCaptioning@pbs.org a link to the page on your station site where your caption certification statement is posted.
View a sample statement at video.pbs.org, and feel free to copy and customize this statement to fit your local station.
Starting March 16, 2015, all closed caption files on broadcast and online must comply with the FCC's new quality standards for: accuracy, synchronicity, completeness, and placement.
The new FCC rules for closed caption quality (which go into effect on March 16, 2015) set forth qualitative standards for the accuracy, completeness, placement, and synchronicity of captions. The rules also require programmers to provide a certification of compliance to any distributors to which it supplies programming. The certification can attest to the fact that the programming either complies with the FCC’s quality standards, adheres to the FCC best practices, or is exempt from the captioning rules. The FCC allows this certification to be done through a widely available method for expediency (like a website).
PBS is now making such a certification available on our website near the bottom of the following page: http://video.pbs.org/cc-info.html. This is intended to cover the NPS programming that we provide to stations.
For local station programming, we will need stations to provide a certification that any content they upload to COVE going forward complies with or is exempt from the quality requirements. This can be done in one of two ways:
Add a public notice on your station website. In this case, please reply to this email with a direct link to its location.
Email ClosedCaptioning@pbs.org and indicate that your station complies with, or is exempt from, the quality requirements.
Please let us know if you have any additional questions.
What Does This Mean?
Stations are responsible for adhering to the new requirements and providing online captions of "at least the same quality" as those used for broadcast programming. Quality standards details are included at the end, for reference.*
Compliance certification is required under FCC rules from all video programmers, including stations. The SPI team will be available to help. More details to come, but this can be done in one of two ways:
Stations can display a certification on their website. We are happy to provide a sample.
Station can submit a certification to PBS by e-mail. If a station website update is not feasible by January 15, 2015, we can handle certification via a one-time email, with whomever is responsible for the station's closed caption compliance.
With regard to placement, caption text must not cover critical visual content, such as faces, sub-titles, banners, lower thirds, CGs, on-screen graphics, etc. In these cases, the source caption file must be formatted to display the corresponding segments on a different part of the screen, prior to being uploaded to COVE.
By default, the caption display position is in the bottom, center. If critical video content is not covered when captions are displayed at the default position, then no placement information is necessary within the caption file.
Please note: COVE will not validate for caption quality compliance. The system will only preserve caption placement formatting in the station source files, if it is provided.
COVE will continue to support a wide variety of caption file formats, except SRT, which does not handle placement settings. See the full list of supported formats, as well sample caption files containing placement information.
*Caption quality standards details:
(for more detail see Section 4.3 of the PBS Technical Operating Specification for Program Submission available in the Program Guidelines and Policies)
Preserve and display spoken words or song lyrics in their original language (English or Spanish), in the proper order.
Proper names and places cannot be replaced or paraphrased, except when necessary to resolve time constraints.
Proper spelling and use of homophones, punctuation, capitalization, tense, singular/plural forms, and number representation (symbols vs. words).
Intentional slang or grammatical errors should be preserved.
As much as possible, provide non-observable information, including speaker identity, music, sound effects, and audience reaction.
Ensure caption text is legible and displayed with spacing optimized for readability.
Caption text display must be synchronized with the audio to the greatest extent possible.
Caption display speed must be optimized for readability.
Captions must be provided for the entirety of the program, to the greatest extent possible.
Caption text must not cover critical visual content. Examples include: character faces, sub-titles, credits, news updates, banners, lower thirds, CGs, on-screen graphics, etc.
Caption text must not be cut off or positioned to overlap lines.
Optimize caption font size for readability.