As of January 1, 2016, all "straight lift" clips of any length created as COVE Assets will require closed captioning. “Straight lift” clips are defined as clips that “contain a single excerpt of a captioned television program with the same video and audio that was presented on television.” As always, the closed captioning rules only apply to content that has been broadcast on television with closed captions, not to digital-only material. In addition, clips posted prior to broadcast do not require captions – until the episode is broadcast. After the content is broadcast, the clip must either be captioned or removed from COVE (i.e., taken down, unpublished, or expired).
It is the producer's responsibility to ensure captioning compliance.
The COVE Asset creation process will be updated to require closed captions for clips. If a clip is being posted without captions, then the producer must enter a written justification. If a clip is posted without captions because it is prior to broadcast, the producer is responsible for ensuring that the clip expires (is no longer viewable) once the program has been broadcast with captions, unless the producer promptly adds captions to the clip.
Two types of clips do not have to be captioned until later deadline: montage clips (January 1, 2017) and clips from live or near-live programming (July 1, 2017). A “montage” clip is an online file containing video “taken from different parts of a captioned full-length TV program or from different captioned TV programs.” “Live programming” is video programming “shown on television substantially simultaneously with its performance.” “Near-live programming” is video programming that is “performed and recorded less than 24 hours prior to the time it was first aired on television.”
Interstitials and promotional announcements continue to be exempt from captioning on broadcast television, so they do not need to be captioned online as long as they are not captioned when broadcast.
Additional documentation about closed captioning and adding them visit the PBS documentation page on How to Add Closed Captioning Files. For questions regarding FCC compliance related to your station and local productions, seek advice from your station's general counsel. Close caption questions related to PBS Digital products email your Digital rep or the SPI team.