These comments are in response to Broadcasting Notice of Consultation CRTC 2011-489 regarding a claimed captioning standard in French.
This intervention is permanently located at the address:
The proposed “standard” must be rejected.
The document perpetuates Francophone separatism and superiority. For decades, French-language broadcasters have advanced spurious claims about the intricacy and uniqueness (and, by extension, superiority) of their language as excuses not to caption. French is no more difficult to caption than English; anyone who thinks that gender agreement, accented letters, and a few more homophones makes the task harder knows nothing about linguistics.
Prerecorded programming has been captionable since the minute closed-captioning went on air. French-language broadcasters were using not one but two variations of real-time stenography 20 years ago, but deliberately killed it off to perpetuate the lie that French programming is too hard to caption. (Now they’re using two versions of speaker-dependent speech recognition, only one of which works, to argue that not all live shows can be captioned.)
The existence of a separate French-language working group perpetuates three myths:
That French captioning and English captioning are two different things. (They aren’t; they’re just captioning. I view this as an inversion of Francophones’ inability to differentiate captioning and subtitling.)
That French is so complex a language that everyone needs extra time to make captioning work.
That French captioning requirements are different from English ones.
In case this isn’t clear: Francophones, French-language broadcasters, and French captioning aren’t special, different, or better. (If anything, the latter two are worse.)
I also note that this ostensible working group cannot even get its act together enough to cite which dictionary should be used as a spelling reference.
Neither the CRTC nor the working group consulted with anyone. There were no meetings or hearings, conducted with interpretation in English, French, ASL, and LSQ, to discuss what the Commission urgently desires to rubber-stamp into law. Posting a zip file of Word documents on an unusable government Web site does not amount to real consultation.
It isn’t a standard in the first place. It’s a Microsoft Word document banged out by what is literally a secret cabal of industry insiders. The document wasn’t tested, wasn’t vetted by researchers or the public, and is completely unproven. The only things bureaucrats understand are MS Word documents, PDFs, and top-posted E-mails; this “proceeding” had two of those three and fails as a claimed standard of any sort.
You can’t learn to caption via MS Word. A written document is useless in training anyone to caption. It’s equally useless in requiring or banning certain actions. Captioning can barely be described in writing, let alone specified. The only viable way to even discuss captioning is in an environment with running video available, ideally in person.
A legitimate captioning standard, which this is not, involves all of the following:
Review of existing research
New research, with results published, ideally in peer-reviewed journals
Extensive discussion with researchers, viewers, practitioners, and everyone else, conducted online and in person, among other methods
Development or collection of test video files and of captioning samples
Development of written documentation
Publication and vetting of all the above
Testing in real-world environments for one year, with specific research conducted on success and failures
Republication and re-vetting
Development of a training and certification program for practitioners
As listed here, the French working group has done one of these tasks and is not qualified to carry out any of the others.
This alleged standards document couldn’t even include one real picture of captioned TV.
The secret, invitation-only membership guarantees results that are friendly to the same broadcasters who have screwed this up for a full generation. The entire membership of the working group is given – without personal names – as follows:
Centre québécois de la déficience auditive
Québecor Media inc., au nom de Vidéotron SENC
Groupe TVA inc.
That’s four broadcasters, three of whom loathe captioning and evade their responsibilities at every turn (Astral, Québecor, TVA), one interest group, and a captioning lobby group that functionally no longer exists.
The working group is – literally and figuratively – an industry cabal. The working group is made up of cowards afraid to sign their names to their own “standard.” The working group, especially in the form of its chair, Sylvie-Catherine Croteau, lacks the intellectual honesty even to include existing captioning houses in its roster. I know for a fact one such captioner applied for membership on the committee and was refused.
Essentially, the tobacco industry is writing regulations on the sale of cigarettes. Nobody took a bribe, but the configuration of the committee is structurally corrupt and one-sided and could not possibly produce an adequate result. So it didn’t.
Committee members have not been shown to know the first thing about captioning. Because the working group, abetted by its friend the Commission, is keeping group members’ names secret, we have no way of determining their fitness for the task. Based on experience but with no knowledge of their identities and expertise, I assume that committee members from the broadcasters are hacks and ringers whose entire purpose is to derail the process and water down whatever “standard” might emerge.
In this important public process, it is up to the working group and the CRTC to prove me wrong. I’m not holding my breath.
This process failed already. The Commission and working-group members know full well that this approach – a secret cabal banging something out in MS Word, which the CRTC then attempts to impose by law – failed miserably before. It can’t possibly succeed. It too is beset by structural failings, as already documented here. This is not a standardization process; it’s an industry-led rubber-stamping process.
Taking one more run at something that failed the last time is no way to determine policy for people with disabilities, who have important legal rights.
This is yet another collusion between broadcasters and the CRTC to squelch the Open & Closed Project. For five to seven million bucks, the Open & Closed Project would by now have researched, completed, vetted, tested, and published entire standards for captioning and audio description and set up certified training programs.
Martine Vallee, her colleagues at the CRTC, and her department’s BFFs in the broadcasting industry have spent the better part of a decade deliberately impeding our efforts to raise a pittance of money and do this properly. In the meantime, broadcasters have been eating each other for lunch in transactions worth 800 times as much as what we needed to run the whole project.
We would have solved this problem by now. You aren’t equipped to do so, and haven’t.
This entire “standardization” process is a non-starter and will result in a complaint to the Canadian Human Rights Commission alleging unequal treatment on the basis of disability. That in itself will torpedo the process. And don’t worry: Everyone with any authorial or editorial role in creating these failed standards will be identified and named as a respondent.
These “standards” are no such thing and will never be implemented.