Joe Clark: Media access

You are here: joeclark.orgCaptioning and media access
CRTC
Findings

Updated 2001.07.15

Captioning and audio description
on new Canadian channels

(Have a look at the intro page first)

This page provides documentation of broadcasters’ commitments to captioning and audio description for digital specialty channels licensed by the CRTC in December 2000.

Update, 2002.01.23: The CRTC cleverly rejiggered its Web site, but in the worst possible way, destroying essentially every URL previously published. None of the CRTC links below will actually work. At this point in our economic history, it is not worth it for me to fix them all, particularly since I quote the actual relevant text. Blame gormless government bureaucrats. I certainly do.


Letter grades

(See criteriaFull details below)

Station name Commitment Requirement
CC A.D. CC A.D.
Biography ChannelB minus F B minus F
BookTelevisionB minus F B minus F
Canadian Documentary ChannelB minus F B minus F
ConnectB plus F B plus F
FashionTelevisionD F C F
Health Network D F D F
Independent Film ChannelB minus F B minus F
Issues ChannelC F C F
Land & SeaB minus F B minus F
LCN AffairesC F C F
MenTV B minus F B minus F
Perfecto, La ChaîneC F C plus F
PrideVisionB minus F B plus F
Réseau Info SportB B plus B plus B plus
TechTV CanadaB minus F B minus F
Télé Ha! Ha!B minus F B minus F
13th StreetB plus C B minus C
13ième rueB minus F B minus F
WisdomB minus F B plus F
Women’s Sports NetworkB minus B plus B minus B plus

Full details

Biography Channel

ApplicationDecision – Contact: Peter Kovacs
CC commitmentCommentsGrade

50%, 55%, 60%, 70%, 80%, 85%, 90%

Starts at only 50%, but ramps up to 90%. No mention of quality standards, let alone improving them.

B minus

A.D. commitmentCommentsGrade

As a service that will appeal to a wide audience, we recognize that some of Biography Canada’s target audience could be visually impaired. It is our intention to ensure that as many Canadians as possible, including blind or low-vision Canadians, are able to share in the information, issues and experiences presented on Biography Canada. Whenever possible, and where available and applicable, we will do our best to acquire programming that has descriptive video programming. This enhanced programming will be available to viewers by selecting, through the setup feature of their digital set-top boxes, an audio stream that includes the added descriptions. Rogers intends to consult regularly with the National Broadcast Reading Service to understand the evolution of descriptive video and to do everything possible to communicate to our viewers the availability of this feature and how to access it.

Let’s see. Biography will “acquire programming that has descriptive video programming.” Nice and recursive, that. Virtually the only biographical programming with audio description (not “descriptive video”) is old American Experience episodes, and given that Canadian broadcasters are too cheap to license original American captioning on old programming, how are we to expect Biography to bother shelling out the bucks for the A.D. track?

“Whenever available and applicable”? Just when is audio description not applicable? Biography Channel, reflecting typical Canadian broadcasting cluelessness, fails to understand that “the setup feature of their digital set-top boxes” works for sighted people only. Since Biography actually brings this issue up, presumably they have a fix for that problem. Don’t they? (After all, Biography is a Rogers Cable venture. They also deal in set-top boxes.)

“Consulting” with the National Broadcast Reading Service will do nothing but entrench its own appallingly inept description practices. What is “the evolution of descriptive video”? First of all, Descriptive VideoSM is someone else’s service mark, and just what kind of “evolution” are we waiting for?

Isn’t this another way of saying “We intend to do nothing whatsoever for seven years, and, when our license comes up for renewal, plead that ‘DVS’ has not ‘evolved’ sufficiently for our service”?

F

CC requirementCommentsGrade

With respect to service for the hearing-impaired, Biography plans... to closed caption at least 50% of all programming during the first year of operation. That amount will increase gradually, and by the seventh year of operation, a minimum of 90% of all programming on Biography will be closed captioned. The Commission expects the licensee to fulfil its commitments.

Parrots the applicant’s plans. No mention of quality standards, let alone improving them.

B minus

A.D. requirementCommentsGrade

With respect to the provision of descriptive video service (DVS) for the visually- impaired, the licensee indicated that wherever available and applicable, it will acquire programming with DVS. The enhanced programming will be available to audiences through the digital set-top box. Rogers indicated that it intends to consult regularly with the National Broadcast Reading Service to understand the evolution of DVS and to do everything possible to communicate to subscribers the availability of this feature.

The Commission requires Biography to be technically equipped to deliver described video programming and to fulfil the commitments included in the application. In addition, the Commission encourages the licensee to provide audio description of visual information wherever possible, and to provide described video programming as outlined in Public Notice 2000-171.

Swallows whole the applicant’s mealy-mouthed refusal to provide audio description. The applicant dictated to the regulator. The dialogue went like this. Biography Channel: “We won’t do audio description. And you will affirm our refusal.” CRTC: “OK by us. We don’t understand this ‘descriptive audio captioning service’ any more than you do.”

F

[Back to top]

BookTelevision

ApplicationDecision – Contact: Ron Keast
CC commitmentCommentsGrade

35%, 40%, 45%, 55%, 65%, 80%, 90%

As is typical of anything vaguely linked to CHUM Ltd., BookTelevision shows its contempt of captioning by starting out with a puny 35% (well less than half). In fact, for the first three years, less than half the broadcast day will be captioned. In the 21st century. Now, that’s progress. And, naturally, no mention of caption quality, let alone improving it.

B minus

A.D. commitmentCommentsGrade

BookTelevision will meet the needs of the visually impaired to at least the same extent as LTA does currently with its other program services. With these services, LTA addresses the needs of the visually impaired by designing programming to be accessible to visually impaired television users. We meet this need by ensuring that graphics and visuals are as large and clear as possible and that, whenever possible, on-screen text is accompanied by voice-overs that provide a concise summary of information presented visually. As well, phone numbers are supplied verbally as well as visually when possible so that viewers may access more information, where applicable. We are currently implementing practices that will ensure more consistency in this regard.

LTA, as part of the CHUM Television group, is currently working on the following initiatives, which should be of assistance to the visually impaired:

  • inclusion of a maximum amount of audio information on our web sites, especially for scheduling information;
  • collaboration with advertising industry to encourage them to include audio for phone numbers and web sites and other pertinent information in ads
  • provision of audio for “emergency” announcements or crawls. LTA is currently the designated broadcaster of the Emergency Broadcast System (EBS) for the province of Alberta. EBS information is provided both visually and on audio.

We have participated, with CHUM Television, experimenting with audio description for entertainment programming, and continue to explore feasibility and financial viability for implementation. Our estimates suggest that description is an order of magnitude many times more costly than captioning, and the potential audience significantly lower. We do however continue to monitor developments, to continue to participate with CAB to examine audio description at the industry level, and we remain prepared to air described programming made available at reasonable cost. Moreover, we will ensure that the necessary SAP equipment is installed, should described programming become more feasible in the future.

“Meet the needs of the visually-impaired to at least the same extent as LTA does currently”? That bad, huh?

BookTelevision appears to believe that voicing onscreen type is all you need to do to ensure access. Indeed, access will not happen if you don’t voice onscreen graphics, but that is only part of the picture.

Further, it is an outright lie to claim that any CHUM Ltd. channel voices onscreen print. CHUM bases entire programs and networks (e.g., QueerTelevision, StarTV, and of course CablePulse24 with its so-called dense screen) on unvoiced onscreen type. It makes for a nice visual package, but it is inaccessible. And at no time ever has any CHUM station made a true effort to read out that print. Why would they? That would queer the whole system.

In short, LTA is lying when it claims it will increase the verbal rendition of onscreen graphics. It will never happen. But because the CRTC is even more clueless than the Canadian broadcast oligopoly, the CRTC bought it hook, line, and sinker.

The previous provision of audio description by other CHUM channels (apparently only CITY-TV) is of course dubbed an “experiment,” as though referring to smoking a joint at age 15 or messing around with Bruce the quarterback after practice one afternoon. Audio description does not require “experimentation.” It is a proven system, though AudioVision’s practice of it is reprehensible and inept.

F

CC requirementCommentsGrade

BookTelevision has committed to... ensur[ing] that, beginning in the first year of operation, 35% of all programming will be closed captioned. That amount will increase gradually over the licence term, and in the seventh year of the licence term, the minimum to be closed captioned will be 90%. The Commission expects the licensee to fulfill its commitments.

Parrots the applicant’s plans. No mention of quality standards, let alone improving them.

B minus

A.D. requirementCommentsGrade

With respect to descriptive video service (DVS), the licensee indicated that it will meet the needs of the visually-impaired to the same extent as LTA does currently with its other programming services. It will design programming to be accessible to visually-impaired television users by ensuring that graphics and visuals are as large and clear as possible, and that, when possible, on-screen text is accompanied by voice-overs that provide a concise summary of the information presented visually. Phone numbers will also be supplied verbally, as well as visually, whenever possible. LTA also noted that, through its involvement with the CHUM group of companies, it is currently working on the development of other initiatives which will assist the visually-impaired.

The Commission requires BookTelevision to be technically equipped to deliver described video programming and to fulfil the commitments included in the application. In addition, the Commission encourages the licensee to provide audio description of visual information wherever possible, and to provide described video programming as outlined in Public Notice 2000-171.

Reiterates the applicant’s plans, as though the applicant were dictating to the regulator, which is, in fact, the case.

F

[Back to top]

Canadian Documentary Channel

ApplicationDecision – Contact: Deborah Beatty
CC commitmentCommentsGrade

50%, 60%, 70%, 80%, 80%, 90%, 90%

Starts at 50%, ramping up to 90% (one year earlier than required). No mention of quality standards, let alone improving them.

B minus

A.D. commitmentCommentsGrade

Approximately one million Canadians suffer some degree of vision impairment. Their ability to “watch” and enjoy television programming is directly related to teh degree of this impairment. In several appearances before the CRTC in the past two years, the National Broadcast Reading Service Inc. has asked the Commission to take whatever measures it can to encourage Canaidan broadcasters to initiate the provision of a descriptive video service (DVS), accessible to the Canadian vision-impaired community. DVS works by taking a program prior to broadcast, developing a written narrative of key visual elements on the screen, and recording these and blending them with the original soundtrack in an audio package that does not interfere with the original dialogue or sound effects available to the general audience. The DVS service is delivered to vision-impaired viewers using an audio subcarrier.

One of the partners, CBC, has already provided three DVS broadcasts to date that we produced as a cooperative venture between CBC and AudioVision Canada, a division of NBRS, which provided the DVS material free of charge to the Corporation. The Canadian Documentary Channel will explore with NBRS and AudioVision Canada how more programs such as The Arrow, Anne of Green Gables, and Big Bear, which have already been broadcast on a DVS basis by th CBC, can serve as the forerunners of additional documentary programs which can be incorporated on a regularly-scheduled basis into the Canadian Documentary Channel service over the license term.

Wow. The CBC really took the bull by the horns, airing fewer than five series with descriptions they got for free (and didn't particularly promote, either). And we’re going to use that as some kind of forerunner? At this rate, by the year 2008 the Canadian Documentary Channel will also have aired fewer than five shows with audio description. Care to lay odds that they will be reruns of the original CBC programs rather than anything new? That, after all, would cost money.

Also: Really nice touch to explain how audio description works. Did you also explain how Web sites work in the Interactivity section of the application? It would surely be unfair to view that section as padding and grandstanding.

F

CC requirementCommentsGrade

The licensee committed to... ensur[ing] that 50% of the programming on the Canadian Documentary Channel will be closed captioned in the first year of operation. That level will increase gradually, and by the final year of the licence term, 90% of the programming will be closed captioned. The Commission notes these commitments, and expects the licensee to fulfil them.

Reiterates the applicant’s plans as though reading from a script. No mention of quality standards, let alone improving them.

B minus

A.D. requirementCommentsGrade

With respect to descriptive video service (DVS), the licensee stated that the CBC has already provided three DVS broadcasts, produced as a co-operative venture between the CBC and AudioVision Canada, a division of National Broadcast Reading Service, which provided the DVS material free of charge to the Corporation. The Canadian Documentary Channel will explore with AudioVision how DVS programs can be incorporated into the new service’s schedule on a regular basis.

The Commission requires the Canadian Documentary Channel to be technically equipped to deliver described video programming and to fulfil the commitments included in the application. In addition, the Commission encourages the licensee to provide audio description of visual information wherever possible, and to provide described video programming as outlined in Public Notice 2000-171.

Parrots the applicant’s plans. Question for our esteemed Commissioners: Just what is there to “explore”? We’re not talking about adding Smell-o-Vision™ to television here. Audio description has been in use on broadcast television for 12 years. Just what is the holdup?

F

[Back to top]

Connect

Application apparently not online – Decision – Contact: Drew Craig
CC commitmentCommentsGrade

60%, 65%, 70%, 75%, 80%, 85%, 90%

Starts out above 50%. Inches kind of cautiously toward 90%. No mention of quality, let alone improving it.

B plus

A.D. commitmentCommentsGrade

The applicant is committed to working with the National Broadcast Reading Service Inc. and others to seek the development of industry-wide cooperative solutions to the concerns of blind or vision-restricted Canadians.

Certainly the most insulting and dismissive malarkey of all digital-specialty-service applicants whose networks begin with the letter C. (It’s not quite as breathtaking as the gall we’ll see in some other applications.) What “industry-wide cooperative solutions”? Apart from putting AudioVision out of business, given their proven track record of incompetence, the provision of audio description is merely a question of paying for it. No “industry-wide cooperative solutions” necessary. It’s ready to go in the here and now. What’s the holdup?

(Well, the answer is obvious: Audio description costs money, but then again, so does an entire new specialty service, and the fact that blind subscribers are paying for a service they cannot fully understand apparently counts for nothing. What does count, evidently, is the expense involved in making TV accessible. That expense might reduce corporate profits, thus threatening the lease on the 930 Turbo and the cottage up north. Admit it: Greed keeps you from providing accessible television. Even though your viewers are already paying for it.)

F

CC requirementCommentsGrade

The licensee... has made a commitment to ensure that at least 60% of all programming in the first year of the licence term will be closed captioned. That commitment will increase by 5% each year, until, in the seventh year of the licence term, at least 90% of all programming on Connect will be captioned. The Commission notes the licensee's commitments, and expects the licensee to fulfil them.

Parrots the applicant’s plans. No mention of quality standards, let alone improving them.

B plus

A.D. requirementCommentsGrade

With respect to descriptive video service (DVS), the licensee is committed to working with the National Broadcast Reading Service Inc. and others, to seek the development of industry-wide co-operative solutions to the concerns of blind or vision-restricted Canadians. The Commission requires Connect to be technically equipped to deliver described video programming and to fulfil the commitments included in the application. In addition, the Commission encourages the licensee to provide audio description of visual information wherever possible, and to provide described video programming as outlined in Public Notice 2000-171.

Blatant parroting of the applicant’s dismissal of the reality that audio description is already here and viable, AudioVision Canada’s rank incapacities notwithstanding.

F

[Back to top]

FashionTelevision

ApplicationDecision – Contact: Peter Miller
CC commitmentCommentsGrade

In view of the still relatively sparse penetration of digital services and the corresponding likely his/her level of use of older recorded material, it is impossible to project the percentage of programming that will be captioned over the term of the license. Many programs may not have been originally produced with captioning, or prints of those programs may not be available containing captioning. In addition, program licensing agreements (and Canadian copyright legislation) do not generally permit alteration of programs, including addition of closed captioning.

However, as a first priority, the service will caption all elements of originally produced new programming. Acquired newer programs should more readily be captioned. CHUM is making monetary commitments to captioning as follows:

[$45,000/year, years 1 through 6; $55,000, year 7]

What shocking chutzpah. I could just plotz. Years after the CRTC required wealthy broadcasters to provide 90% captioning by certain deadlines, CHUM has the gall to say, in effect, “To hell with your requirements. It’s gonna cost us too much.”

And of course the copyright argument is bogus. When licensing a program for broadcast, simply include the right to caption it in the license. The assumption here – and it is a false one – is that the CRTC, or someone else, expects FashionTelevision to caption someone else’s copyrighted programming without permission. Now, whoever said that, exactly?

Everything boils down to money with CHUM. Things boil down to money so consistently that, despite CRTC requirements to the contrary, all CHUM will promise to do is spend a certain trivial amount of cash each year on captioning, which could very easily disappear due to creative accounting. Contemptible. And, for that matter, contemptuous. (The fact that the 22-year-old girls with poli-sci degrees currently butchering CHUM’s in-house programming know as much about captioning as Donovan Bailey knows about macramé seems not to have entered the discussion.)

D

A.D. commitmentCommentsGrade

CHUM Television’s street-front, inclusionary approach to television welcomes the participation of all. Our various stations, complete with Speakers Corner, are designed to be accessible to the visually impaired.

CHUM Television’s news and information programming is designed to be accessible to visually impaired television users, by ensuring that graphics and visuals are as large and clear as possible and that, whenever possible, on-screen text is accompanied by voice-overs that provide a concise summary of information presented visually. Where applicable, phone numbers are supplied orally so that, viewers may access more information. We are currently implementing practices that will ensure even more consistency in this regard, across all CHUM stations.

We have experimented with audio description for entertainment programming, and continue to explore feasibility and financial viability for implementation. Our estimates suggest that description is an order of magnitude more costly than captioning and the potential audience significantly lower. Accordingly, we do not believe that specific commitments to audio description are realistic at this time, particularly for digital services. We do however continue to monitor developments, and remain prepared to air described programming made available at reasonable cost.

Further contempt from the glorified accountants at CHUM. First of all, Speakers Corner cannot accommodate a wheelchair user, and all its instructions are in print only, making it inaccessible to two disability groups – a far cry from “welcom[ing] the participation of all.”

CHUM trots out the old we-experimented-with-grass-audio-description-in-college-but-we-came-to-our-senses shibboleth. It doesn’t work here, either. Audio description was experimental in 1988. It is a proven, capable access technique now, irrespective of AudioVision Canada’s risible incompetence in writing and delivering descriptions.

And, as ever, CHUM can find lots and lots of cash to start up entire new specialty networks, complete with launch and schmooze parties, but suddenly comes up all poor when paying subscribers are concerned. Bit of a contradiction here, don’t you think?

And, of course, we deal yet again with the blatant lie that CHUM stations ever bother to voice onscreen text, or that such will ever really be done.

F

CC requirementCommentsGrade

The licensee committed to... spend a minimum of $325,000 over the licence term on closed captioning. It stated that since some older recorded material would be used, it would be impossible to project the percentage of programming that will be captioned over the term of the licence. CHUM did, however, commit to caption all elements of originally produced new programming and the Commission notes the licensee’s commitments. It expects[,] however, that by the end of the licence term a minimum of 90% of FashionTelevision’s programming will be closed captioned.

The CRTC, as usual taking its orders from industry, completely buys CHUM’s lies and diversions, but, in its quisling, milquetoast way, “expects” CHUM to reach the same captioning targets other English-language telecasters have to meet. One supposes that requiring such captioning levels would make CRTC staff unpopular, ruining their chances for lucrative job postings in the broadcast industry once they abandon the sinking CRTC ship.

C

A.D. requirementCommentsGrade

With respect to descriptive video service (DVS), the licensee stated that it has experimented with audio description for entertainment programming, and continues to explore the feasibility and financial viability of its implementation. While it does not believe that specific commitments to DVS are realistic at this time, due both to cost and limited potential audience, CHUM continues to monitor developments, and is prepared to broadcast described programming when available at a reasonable cost.

In the shorter term, the licensee will make its programming accessible to visually-impaired subscribers by ensuring that graphics and visual elements are as large and clear as possible, and that on-screen text is accompanied by voice-overs that provide concise summaries of information presented visually, including, where applicable, telephone numbers.

The Commission requires FashionTelevision to be technically equipped to deliver described video programming and to fulfil the commitments included in the application. In addition, the Commission encourages the licensee to provide audio description of visual information wherever possible, and to provide described video programming as outlined in Public Notice 2000-171.

Shocking, almost fellative subservience to CHUM’s diversionary tactics, and a baldfaced admission that the CRTC believes audio description serves too few people to be worth the money. (Funny, those people are already paying to receive the channel. Why aren’t they permitted to gain full enjoyment of the programming?)

F

[Back to top]

Health Network

ApplicationDecision – Contact: Phyllis Yaffe
CC commitmentCommentsGrade

10%, 10%, 10%, 30%, 45%, 50%, 90%

Even by the standards of avarice and hatred of anything involving accessible media made notorious by the Canadian broadcast industry, starting a new network in the year 2001 with 10% captioning comes as a slap in the face. That's two and half hours a day, which could conveniently be sandwiched between, say, 0330 and 0600 hours. We won’t see majority captioning until year seven, when captioning will effectively double from the previous year.

Quickie question for Phyllis Yaffe: Why should any captioning viewer bother watching your network at all, let alone in year seven, when you’ve shown such disregard for their needs? And everyone knows that Alliance Atlantis has tons of cash to afford captioning; indeed, Alliance has its own squad of 22-year-old girls with poli-sci degrees desecrating programming on other networks. (In many cases, desecrating programs previously captioned elsewhere, like Da Vinci’s Inquest, Liberty Street, and Prime Suspect.) This is what Alliance really thinks of its viewers.

D

A.D. commitmentCommentsGrade

As we begin transmitting our digital service we will be in a position to begin experimenting with alternative uses of the digital data stream. We have in the past experimented with Descriptive Video on Showcase and will continue to do so as the subscriber demand dictates.

You don’t need to wait for digital transmission to begin using A.D.; it works just fine in analogue, thank you very much. Still, these are digital services. We know you “experimented” with acid in college, but you might as well just quit trying to snow us with the line that you “experimented” with a proven access technology before.

“As the subscriber demand dictates”? The demand is already there. You are simply choosing to ignore it. And keep your own words in mind: These are paying subscribers. You are knowingly disenfranchising this clientele.

F

CC requirementCommentsGrade

[T]he licensee... has made a commitment to ensure that 10% of all programming in the first three years of operation will be closed captioned. That minimum will increase each year, and in the seventh year of the licence term, at least 90% of all programming on the Health Network will be closed captioned. The Commission notes these commitments, and expects the licensee to fulfil them.

10% captioning is effectively nothing, and the CRTC authorizes it as though taking orders from a leather-clad master. Or, in this case, a kilt-clad master, or that person’s lieutenant.

D

A.D. requirementCommentsGrade

With respect to the provision of descriptive video service (DVS) for visually-impaired persons, the licensee stated that “as we begin transmitting our digital service, we will be in a position to begin experimenting with alternative uses of the digital data stream. We have in the past experimented with Descriptive Video on Showcase and will continue to do so as the subscriber demand dictates.”

The Commission requires the Health Network to be technically equipped to deliver described video programming and to fulfil the commitments included in the application. In addition, the Commission encourages the licensee to provide audio description of visual information wherever possible, and to provide described video programming as outlined in Public Notice 2000-171.

How appalling to find CRTC nabobs simply cutting and pasting an applicant’s own excuses and passing it off as regulation.

F

[Back to top]

Independent Film Channel

ApplicationDecision – Contact: Catherine Tait
CC commitmentCommentsGrade

Commitment is unclear in online documents. A later E-mail stated:

“50% in the first year of the licence term and ramping up to 90% in year 7.”

Starts at 50% and increases to 90%. No mention of quality, let alone improving it. (Every Salter St. production has had miserable captions, Lexx particularly so.)

B minus

A.D. commitmentCommentsGrade

Nothing listed. The question appears to have been deleted from the original CRTC form. A later E-mail stated:

“The licensee will work in conjunction with other broadcasters and the National Broadcast Reading Service in order to effect the gradual implementation of more audio descriptions of programming in keeping with the Commission's policy as outlined in Public Notice CRTC 1999-97. In particular, in negotiating arrangements the licensee will request that all programming will be audio captioned [sic].”

Oh, dear. These poor people really do not understand what audio description is. They seem to think it has something to do with captioning. Independent Film Channel can do all the “requesting” it wants, but the only way to guarantee described programming is to pay for it yourself. (It is your responsibility. You are the broadcaster.) I am working on the assumption that Salter St., by virtue of its new entry into television networks, can be rehabilitated.

F

CC requirementCommentsGrade

[T]he licensee committed to... ensure that 50% of the programming on the IFCC will be closed captioned in the first year of operation. That level will increase gradually, and following the fifth year of the licence term, 90% of the programming will be closed captioned. The Commission notes these commitments, and expects the licensee to fulfil them.

Reiterates the licensee’s commitments as though taking orders. No mention of quality, let alone improving it.

B minus

A.D. requirementCommentsGrade

With respect to descriptive video service (DVS), the licensee indicated that it will work in conjunction with other broadcasters and the National Broadcast Reading Service to effect the implementation of more audio descriptions of programming. In particular, in negotiating acquisition arrangements, IFCC will request that all programming be audio-captioned [sic].

The Commission requires the IFCC to be technically equipped to deliver described video programming and to fulfil the commitments included in the application. In addition, the Commission encourages the licensee to provide audio description of visual information wherever possible, and to provide described video programming as outlined in Public Notice 2000-171.

I’m just loving this one. Here we have incontrovertible proof that:

  • The CRTC refuses to place any description requirements on broadcastsers. (We knew that anyway, of course.)
  • The Commission doesn’t even bother to think up its own wording when excusing broadcasters, who are wealthy enough to start up entire new TV channels, from providing an access service that’s been around for 12 years.
  • The CRTC is acting on autopilot to such an extent that it copies and pastes applicants” own errors, thus making them its own.

Way to go, protectors of the Broadcasting Act!

F

[Back to top]

Issues Channel

ApplicationDecision – Contact: Martha Fusca
CC commitmentCommentsGrade

35%, 45%, 50%, 60%, 70%, 80%, 90%

Starts well below half, and majority captioning doesn’t kick in until year four. No mention of quality, let alone improving it.

C

A.D. commitmentCommentsGrade

Although much of television is a medium to be enjoyed by a viewer, many of the programs on Issues Channel may also be enjoyed by the visually impaired. With the assistance of the National Broadcast Reading Service and its many branches, Issues Channel will investigate the feasibility and possibilities of bringing issues and debate to our visually impaired audience. Since the whole idea of Issues is to debate and discuss, we believe many of our program strands can and will be enjoyed by those with visual impairment.

We will also experiment with our daily flagship program and once we have achieved some level of success, we will move into other strands of programming that may provide a greater challenge.

A whole forest of malapropisms here:

  1. Television is for “viewers.” Translation: “If you can’t see, why the hell are you wasting our time tuning in to the Issues Channel? We’re unclear on the concept, and you‘re probably not our kind of people anyway.”
  2. Evidently talk shows require no audio description. This, at least, is the insinuation.
  3. Here we go with the “experimenting” meme once again. Is this the same kind of experimenting that sees you trying on Mom’s wedding gown, with matching pearl choker? What is the need for “experimentation” when audio description has been part of television for a dozen years?

In any event, Issues Channel quite possibly does not understand that it has committed itself to describing its “daily flagship program.” God help us all if AudioVision does it.

F

CC requirementCommentsGrade

To assist viewers with hearing impairments, the licensee... has made a commitment to ensure that at least 35% of all programming in the first year of the licence term will be closed captioned. That commitment will increase each year. In the seventh year of the licence term, at least 90% of all programming on the Issues Channel will be captioned. The Commission notes these commitments, and expects the licensee to fulfil them.

Authorizes and reiterates Issues Channel’s refusal to provide majority captioning for years. No mention of quality, let alone improving it.

C

A.D. requirementCommentsGrade

The licensee has stated that, “with the assistance of the National Broadcast Reading Service and its many branches, The Issues Channel will investigate the feasibility and possibilities of bringing issues and debate to our visually impaired audience.”

The Commission requires the Issues Channel to be technically equipped to deliver described video programming and to fulfil the commitments included in the application. In addition, the Commission encourages the licensee to provide audio description of visual information wherever possible, and to provide described video programming as outlined in Public Notice 2000-171.

More outright replication of the applicant’s declarations.

F

[Back to top]

Land & Sea

ApplicationDecision – Contact: Deborah Beatty
CC commitmentCommentsGrade

50%, 60%, 70%, 75%, 80%, 85%, 90%

Starts out at 50%; ends up at 90%. No mention of quality, let alone improving it.

B minus

A.D. commitmentCommentsGrade

Land & Sea will install the necessary audio lines within our facilities to prepare for service to the visually impaired as/when programming becomes available. We will take special care during all news/information programming to ensure that all information is presented with the needs of the visually impaired in mind.

More than just “news/information” programming requires accessibility, and no one places any trust whatsoever in Corus’s ability to keep “the needs of the visually-impaired in mind.” This will probably end up meaning “Well, one time we read a phone number out loud and said ‘for those of you with vision difficulties.’ ”

There is already a way to serve the needs of the visually-impaired: Audio description. Don’t try this at home, folks. The network deals with country issues, but there is no homegrown alternative. At all.

F

CC requirementCommentsGrade

The licensee committed to... ensure that 50% of the programming on Land and Sea will be closed captioned in the first year of operation. That level will increase gradually, and by the final year of the licence term, 90% of the programming will be closed captioned. The Commission notes the licensee’s commitments, and expects the licensee to fulfil them.

Copies Land & Sea’s commitments – blindly, as it were. No mention of quality, let alone improving it.

B minus

A.D. requirementCommentsGrade

With respect to descriptive video service (DVS), the licensee stated that “Land and Sea will install the necessary audio lines within our facilities to prepare for service to the visually impaired as/when programming becomes available. We will take special care during all news/information programming to ensure that all information is presented with the needs of the visually impaired in mind.”

Another lazy bureaucrat in Hull does a drag-and-drop in Microsoft Word and calls it governmental oversight. Would this bureaucrat care to define what “[keeping] the needs of the visually impaired in mind” actually means?

F

[Back to top]

LCN Affaires

Application apparently not online – Decision – Contact: Serge Desroses
CC commitmentCommentsGrade

45%, 50%, 50%, 60%, 70%, 80%, 90%

As we will see with all channels affiliated with TVA, an outright dismissiveness to accessibility is the norm. We start out below 50% captioning and don’t reach a majority level until year four. Nice. No mention of quality, let alone improving it.

C

A.D. commitmentCommentsGrade

Pour le premier terme de la licence, le plan d’affaires ne permet malheureusement pas de faire de plan à ce titre.

Baldly states “We ain’t gonna do it.”

F

CC requirementCommentsGrade

The licensee made a commitment to close caption [sic] at least of 45% of all programming on LCN Affaires during the first year of operations. This percentage will increase gradually, to a minimum of 90% of all programming in the seventh year of operation. The Commission expects the licensee to fulfil its commitments.

The CRTC takes its orders from the top, as usual.

C

A.D. requirementCommentsGrade

The licensee indicated that it will have the necessary equipment to provide descriptive video service. The Commission encourages the licensee to provide audio description of visual information wherever possible, and to provide described video programming as outlined in Public Notice 2000-171.

And, continuing to take orders from its industry masters, the Commission happily rubber-stamps the applicant’s refusal to provide any description at all.

F

[Back to top]

MenTV

Application apparently not online – Decision – Contact: Serge Desroses
CC commitmentCommentsGrade

50%, 50%, 50%, 60%, 70%, 80%, 90%

Sits at a begrudging one-half level for three full years. No mention of quality, let alone improving it.

B minus

A.D. commitmentCommentsGrade

We have no plans on this matter in the first license term.

“We ain’t gonna do it.”

F

CC requirementCommentsGrade

[T]he licensee will... ensure that a minimum of 50% of all programming in the first three years of operation will be captioned. That minimum will increase by 10% in each subsequent year, and in the seventh year of the licence term, at least 90% of all programming on MenTV will be captioned. The Commission notes these commitments, and expects the licensee to fulfil them.

Restates the applicant’s plans. No mention of quality, let alone improving it.

B minus

A.D. requirementCommentsGrade

With respect to the provision of descriptive video service (DVS) for visually-impaired persons, the licensee stated that it has no plans for the implementation of DVS during the first term of licence. Nevertheless, the Commission requires Men TV to be technically equipped to deliver described video programming. In addition, the Commission encourages the licensee to provide audio description of visual information wherever possible, and to provide described video programming as outlined in Public Notice 2000-171.

MenTV: “We ain’t gonna do it.” CRTC: “Whatever. Next!”

F

[Back to top]

Perfecto, La Chaîne

ApplicationDecision – Contact: Michel Arpin
CC commitmentCommentsGrade

35%, 40%, 45%, 50%, 60%, 65%, 75%

As is entirely typical of CHUM’s contempt for accessibility requirements, captioning starts well below 50% and doesn’t reach majority status until year five.

C

A.D. commitmentCommentsGrade

Cette question a fait l’objet d’un examen par le Conseil dans le cadre de sa politique télévisuelle canadienne (Avis public CRTC 1998-44). Les intervenants avaient alors fait état des difficultés techniques et des coûts associés à l’implantation de service aux malvoyants, dont le service vidéo numérique (SVD [sic]). Ils ont notamment sousligné le travail nécessaire à l’insertion d’une narration descriptive des éléments visuels d’une émission tout en respectant la trame sonore originale de l’émission et les importants coûts reliés à ce type de production.

Cependant, MusiquePlus entend participer avec les membres de l’industrie, dont les radiodiffuseurs et les producteurs, afin de surveiller les développements technologiques permettant d’adapter la programmation aux personnes malvoyantes.

Not only does Perfecto perpetuate the typical CHUM argument that accessibility cuts into our ability to pay for schmooze parties, they betray their contempt for and ignorance of basic facts. What is «le service vidéo numérique (SVD)»? Just fill us in on that one point. What is it?

F

CC requirementCommentsGrade

Over the licence term, the licensee plans to spend $592,000 on captioning. It made a commitment to caption, during the broadcast day, at least 35% of the programming of Perfecto, La Chaîne during its first year of operation. This percentage will gradually increase in the following years to reach at least 75% in the seventh year of operation. The Commission expects the licensee to fulfil this commitment, and encourages it to caption 90% of the programming aired during the broadcast day by the end of its licence term.

The Commission continues to take its orders from industry, ignoring its own requirements and permitting CHUM, unique among Canadian broadcasters, to simply set a piddling dollar value on its captioning plans. Some redemption in “encouraging” CHUM to hit 90%.

C plus

A.D. requirementCommentsGrade

The licensee also indicated that it will have the equipment necessary to broadcast descriptive video service (DVS). The Commission encourages the licensee to provide audio description of visual information wherever possible, and to provide described video programming as outlined in Public Notice 2000-171.

Yet another restatement of official government disenfranchisement of paying subscribers who require a well-established access technique to enjoy programming they’re already paying for.

F

[Back to top]

PrideVision

ApplicationDecision – Contact: Robert Malcolmson
CC commitmentCommentsGrade

90% by end of license term

First years’ captioning is unclear.

B minus

A.D. commitmentCommentsGrade

Nothing listed. The question appears to have been deleted from the original CRTC form. A later E-mail states:

“I am writing you back to let you know that we are currently working on a business strategy and we may be contacting you within the next month or so.”

PrideVision is in over its head and probably won’t ever make it to air anyway. Apart from the inexperienced and undercapitalized management and its location in the gay mecca of Hamilton, it will be next to impossible to find tough-guy technical staff who will work for a gay network. It is not surprising to learn that the question of audio description prompts befuddlement from a PrideVision functionary.

F

CC requirementCommentsGrade

As part of its application, the licensee committed to... ensure that a minimum of 90% of its programming will be closed captioned. The Commission expects the licensee to fulfil this commitment.

Appears to require 90% captioning from year one.

B plus

A.D. requirementCommentsGrade

The Commission requires PrideVision to be technically equipped to deliver described video programming. In addition, the Commission encourages the licensee to provide audio description of visual information wherever possible, and to provide described video programming as outlined in Public Notice 2000-171.

The Commission refuses to direct this rudderless ship. Somebody ought to.

F

[Back to top]

Réseau Info Sport

Two applications to choose from: first, second – Two decisions to choose from: first, second – Contact: Gérald Frappier
CC commitmentCommentsGrade

60%, 65%, 65%, 70%, 70%, 75%, 75%

Starts above 50% but maxes out at only 75%.

B

A.D. commitmentCommentsGrade

CTV étant intéresssée à offrir un service aux malvoyants, ses haut dirigeants ont rencontré les représentants du National Broadcast Reading Service pour connaître les besoins des Canadians ayant une déficience visuelle. Sur une base continuelle, les dirigeants de CTV évaluent aussi les exigence financières et techniques pour fournir des descriptions sonores de la programmation télévisée.

Depuis 1986, certaines stations de télévision de service public américaines offrent le Service d’audio-vision. À l’heure actuelle, moins de 1% de toute la programmation télévisée contient des commentaires oraux. Face aux demandes visant à améliorer la Service d’audio-vision aux États-Unis, la Federal Communications Commission (la FCC) a récemment émis (le 18 novembre 1999) un avis d’ébauche de règles. Dans cet avis (MM Docket No. 99-339), la FCC a demandé qu’on lui soumette des commentaires concernant une proposition selon laquelle les télédiffuseurs commerciaux des 25 plus importants marchés de télévision devraient offrir un minimum de 200 heures par année de descriptions sonores dans leur programmation.

Sensible au besoin d’offrir une programmation accessible aux personnes handicapées, CTV continuera de surveiller d’évolution des services d’audio-vision en Amérique du Nord. CTV fera tout son possible pour acquérir les droits d’audio-vision lorsqu’elle achètera les émissions devant être diffusées surle Réseau info-sport. Au terme de la licence, CTV s’engage à diffuser 100 heures par année de descriptions sonores.

Unduly wordy recapitulation of the entire history of audio description, but there’s a firm commitment: 100 hours a year. That means every year, including year one.

B plus

CC requirementCommentsGrade

The licensee has made a commitment to close caption [sic] at least 60% of Réseau Info Sports’ programming during the broadcast day for the first year of operation. That amount will increase gradually during subsequent years to reach at least 75% in the seventh year of operation. The Commission expects the licensee to fulfil this commitment and encourages it to reach 90% of all programming broadcast during the broadcast day by the end of the licence term.

Rubber-stamps the applicant’s plans, offering further “encouragement” to attain 90%.

B plus

A.D. requirementCommentsGrade

The licensee indicated that it would have the necessary equipment to provide the descriptive video service (DVS). During the licence term, the licensee has undertaken to broadcast 100 hours of audio descriptions each year. The Commission expects the licensee to fulfil this commitment. In addition, the Commission encourages the licensee to provide an audio description of visual information wherever possible, and to provide described video programming as outlined in Public Notice 2000-171.

Endorses the 100-hour-a-year commitment, which, it must be reiterated, applies to all seven years. What’s this about “encourag[ing] the licensee to provide an audio description of visual information wherever possible”? I suppose this means “Read out onscreen type.”

B plus

[Back to top]

TechTV

ApplicationDecision – Contact: Peter Kovacs
CC commitmentCommentsGrade

50%, 55%, 60%, 70%, 80%, 85%, 90%

Starts at only 50%, but reaches 90%. No mention of quality, let alone improving it.

B minus

A.D. commitmentCommentsGrade

As a service that will appeal to a wide audience, we recognize that some of ZDTV Canada’s target audience could be visually impaired. It is our intention to ensure that as many Canadians as possible, including blind or low-vision Canadians, are able to share in the information, issues and experiences presented on ZDTV Canada. Whenever possible, and where available and applicable, we will do our best to acquire programming that has descriptive video programming. This enhanced programming will be available to viewers by selecting, through the setup feature of their digital set-top boxes, an audio stream that includes the added descriptions. Rogers intends to consult regularly with the National Broadcast Reading Service to understand the evolution of descriptive video and to do everything possible to communicate to our viewers the availability of this feature and how to access it.

Well, we see that Rogers did a cut-’n’-paste of its own with its noncommitment. And, to restate the previous question: How are blind people supposed to navigate the visual menus of the set-top boxes Rogers will itself provide?

F

CC requirementCommentsGrade

TechTV has committed to... ensur[ing] that, in the first year of the licence term, 50% of all programming will be closed captioned. That level will be increased gradually, and in the final year of the licence term, 90% of all programming will be closed captioned. The Commission expects the licensee to fulfil its commitments.

Rubber-stamps the licensee’s commitment. No mention of quality, let alone improving it.

B minus

A.D. requirementCommentsGrade

As part of its application, TechTV also committed to pursuing the acquisition of programming with descriptive video service (DVS), and to consult with the National Broadcast Reading Service on the implementation of DVS. The Commission requires techTV to be technically equipped to deliver described video programming and to fulfil the commitments included in the application. In addition, the Commission encourages the licensee to provide audio description of visual information wherever possible, and to provide described video programming as outlined in Public Notice 2000-171.

Mealy-mouthed endorsement of the wealthy applicant’s refusal to spend money on description.

F

[Back to top]

Télé Ha! Ha!

Application apparently not online – Decision – Contact: Serge Desroses
CC commitmentCommentsGrade

50%, 50%, 50%, 60%, 70%, 80%, 90%

Starts at only 50% and stays there for three full years. Does end up at 90%. No mention of quality, let alone improving it.

B minus

A.D. commitmentCommentsGrade

Compte tenu de l’incertitude du lancement des services en numérique dans la marché francophone, nous n’avons pas de plans spécifiques à cet effet pour le premier terme de la licence.

No plans at all. If there is such uncertainty in the marketplace, why are you launching an expensive new channel? Won’t that take a chunk out of your stock portfolio, or perhaps force your kids into public school?

F

CC requirementCommentsGrade

The licensee made a commitment to close caption [sic] at least 50% of the programming of Télé Ha! Ha! during the first year of operation. This percentage will increase gradually over subsequent years to reach at least 90% of the programming broadcast over the broadcast day in the seventh year of operation. The Commission expects the licensee to fulfil these commitments.

Rubber-stamps the rather measly captioning commitment. No mention of quality, let alone improving it.

B minus

A.D. requirementCommentsGrade

The licensee also indicated that it will be technically equipped to deliver described video programming. The Commission encourages the licensee to provide audio description of visual information wherever possible, and to provide described video programming as outlined in Public Notice 2000-171.

Wholesale confirmation of the licensee’s refusal to describe.

F

[Back to top]

13th Street

ApplicationDecision – Contact: Charlotte Bell
CC commitmentCommentsGrade

100% all seven years

Hey, not bad. No mention of quality, let alone improving it.

B plus

A.D. commitmentCommentsGrade

13th Street commits to providing descriptive video for all documentaries and other programming as appropriate for any subject matter of particular concern for the visually impaired.

13th Street shall paternalistically decide which programming will be “of particular concern” for the blind. Funny, all evidence shows that blind and visually-impaired viewers have tastes similar to sighted people’s. But, as far as Global is concerned, blind people only need to fully understand programming related to blindness. A tad patronizing, don’t you think?

C

CC requirementCommentsGrade

13th Street has committed to... ensur[ing] that, throughout the licence term, 100% of all programming will be closed captioned. The Commission notes the licensee’s commitments, and expects it, at a minimum, to caption at least 90% of all programming during the broadcast day, by the end of the licence term.

The rote inflexibility of CRTC thinking is highlighted here: We’ve got a broadcaster willing to exceed even maximum requirements, and all the Commission can come up with is “We expect you to meet our maximum, not yours.”

B minus

A.D. requirementCommentsGrade

13th Street has also committed to providing descriptive video service (DVS) for all documentaries and other programming as appropriate for any subject matter of particular concern to the visually-impaired. The Commission requires 13th Street to be technically equipped to deliver described video programming and to fulfil the commitments included in the application. In addition, the Commission encourages the licensee to provide audio description of visual information wherever possible, and to provide described video programming as outlined in Public Notice 2000-171.

Approves the licensee’s paternalism.

C

[Back to top]

13ième rue

Application apparently not online – Decision – Contact: Serge Desroses
CC commitmentCommentsGrade

50%, 50%, 50%, 60%, 70%, 80%, 90%

Starts at 50% and stays there for three full years. Does eventually arrive at 90%. No mention of quality, let alone improving it.

B minus

A.D. commitmentCommentsGrade

Compte tenu de l’incertitude du marché francophone pour les services numériques, nous n’avons pas de plan à cet effet pour le premier terme de la licence.

More with the “uncertainty.” If things are that uncertain, why roll the dice and launch an entire network?

F

CC requirementCommentsGrade

The licensee committed to close caption [sic] at least 50% of all programming in the first year of operation. That amount will increase gradually, and by the seventh year of operation, a minimum of 90% of the programming broadcast during the broadcast day will be closed captioned. The Commission expects the licensee to fulfil these commitments.

Restatement of the licensee’s commitment. No mention of quality, let alone improving it.

B minus

A.D. requirementCommentsGrade

The licensee indicated that it will have the equipment required to provide descriptive video service (DVS). The Commission encourages the licensee to provide audio description of visual information wherever possible, and to provide described video programming as outlined in Public Notice 2000-171.

Applicant says: “Things are too unsettled for the entire sector, let alone for description. Sorry.” CRTC says: “Well, we”ll give you a license and let you risk millions of bucks all the same. But no problemo with the blind stuff.”

F

[Back to top]

Wisdom

ApplicationDecision – Contact: Fil Fraser
CC commitmentCommentsGrade

90% by the end of the license term

Not clear what initial years will show from the application documents. No mention of quality, let alone improving it.

B minus

A.D. commitmentCommentsGrade

Nothing listed. The question appears to have been deleted from the original CRTC form. The printed application reads as follows:

The provision of described video remains an expensive proposition. Given the relatively low revenues expected to be generated by this service, it will not be in a position [sic] to make a commitment to provision of described programming, unless the descriptions are already available with individual programs. We will make all efforts to find such programs and if they become avialable will promote their scheduling through promotions with the National Broadcast Reading Service (NRBS [sic]) and the Canadian National Institute for the Blind (CNIB) as well as promotion on the channel and on Vision TV. Clearly, if technology becomes available that makes described video affordable for the service, we will make use of it to make our programming more accessible to a wider audience.

The perennially impoverished Vision TV comes up with enough cash for a whole new network, but can’t find a few extra thousand for description. What’s wrong with this picture? I thought Vision and Wisdom were the caring, socially-aware, values-based networks.

F

CC requirementCommentsGrade

Wisdom committed to... ensur[ing] that, beginning in the first year of operation, 50% of all programming would be closed captioned. That amount will increase gradually over the licence term, and in year four the minimum to be closed captioned will be 90%. That minimum will remain in effect for the remainder of the licence term. The Commission notes the licensee’s commitments, and expects them to be fulfilled.

Aha. I guess we’re starting out at 50% after all. No mention of quality, let alone improving it.

B plus

A.D. requirementCommentsGrade

With respect to descriptive video service (DVS), the licensee stated that it will: “make all efforts to find [described video] programs and, if they become available, will promote their scheduling through promotions with the National Broadcast Reading Service (NBRS) and the Canadian National Institute for the Blind (CNIB) as well as promotion on the channel and on Vision TV.” The Commission requires Wisdom to be technically equipped to deliver described video programming and to fulfil the commitments included in the application. In addition, the Commission encourages the licensee to provide audio description of visual information wherever possible, and to provide described video programming as outlined in Public Notice 2000-171.

Do CRTC paper-shufflers earn overtime for retyping broadcasters’ copy? Here, the Commission actually provides a verbatim quotation of the refusal to commit to description.

F

[Back to top]

Women’s Sports Network

Two applications to choose from: first, second – Two decisions to choose from: first, second – Contact: Rick Brace
CC commitmentCommentsGrade

30%,40%, 50%, 60%, 70%, 80%, 90%

Very low captioning commitment, not reaching majority until year four. Attains 90% eventually. No mention of quality, let alone improving it.

B minus

A.D. commitmentCommentsGrade

The Women’s Sports Network (WSN) is unique to other programming genres with regard to its ability to provide descriptive video. By the very nature of live event sports programming, which engages both play-by-play commentary, as well as expert analysis, much of WSN’s programming will be readily accessible to the visually impaired upon launch of the service. All live sports events on the service will include commentary and analysis on the action.

In addition, WSN will take advantage of existing training programs in descriptive video for commentary and production staff, to familiarize them with the special needs of the visually impaired. These techniques will be incorporated into WSN’s programming. Descriptive Video Service (“DVS”) has been broadcast by some public television stations in the United States since 1986. Today less than 1% of all television programming contains video description. In response to requests to enhance the availability of video description in the United States, the Federal Communications Commission (the “FCC”) has recently (November 18, 1999) issued a Notice of Proposed Rulemaking. In Notice of Proposed Rulemaking (MM Docket No. 99-339), the FCC has asked for comments on a proposal that the commercial broadcasters in the top 25 television markets provide a minimum of 200 hours per year of described video programming.

WSN will be sensitive to the need to provide programming that is accessible by the visually impaired and we will continue to monitor the developments in the provision of descriptive video service in North America. WSN will make every effort to acquire the rights for descriptive video when it acquires programming to be broadcast on Women’s Sports Network. WSN commits to broadcast 100 hours a year of described video programming by the end of the licence term.

Play-by-play does not constitute audio description. Don’t believe me? OK, try this: Just from listening to the play-by-play commentary of a hockey game, can you tell me what Mario Lemieux looks like? What colour are the seats? What does the mascot look like? Whose logos are imprinted in the ice? on the boards? How do the teams’ uniforms differ?

(How different are play-by-play and audio description on live television? Very different. Read how: Audio description vs. play-by-play commentary on live TV.)

WSN cannot possibly expect us to believe its tough-guy on-air announcers will go to all that trouble. (Actually, we can expect WSN to become a female-dominated announcer gulag, in the way that female commentators on TSN are permitted to call only women’s hockey.)

Still and all, the 100-hour-a-year commitment is praiseworthy. It does, of course, apply to all years, including the very first.

B plus

CC requirementCommentsGrade

The licensee has committed to... close caption [sic] at least 30% of the programming on WSN in the first year of operation. That level will increase by 10% each year, resulting in a minimum of 90% of programming to be closed captioned in the seventh year. The Commission expects the licensee to fulfil these commitments.

Endorses the initial low captioning level. No mention of quality, let alone improving it.

B minus

A.D. requirementCommentsGrade

WSN noted that most of its programming will be readily accessible to the visually-impaired upon launch since all sports events broadcast will include commentary and analysis. The licensee also stated that it would make every effort to acquire the rights for descriptive video when it acquires programming. WSN further made a commitment to broadcast 100 hours a year of described video programming by the end of the licence term.

The Commission requires WSN to be technically equipped to deliver described video programming and to fulfil the commitments included in the application. In addition, the Commission encourages the licensee to provide audio description of visual information wherever possible, and to provide described video programming as outlined in Public Notice 2000-171.

Endorses the plans for real audio description, but, troublingly, also endorses the ill-conceived plans for fake audio description.

B plus