Joe Clark: Media access

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Intro: Captioning and audio description on new Canadian channels

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Updated 2001.07.15

Captioning and audio description on new Canadian channels


(Or skip to the findings)

On 2000.12.14, the CRTC licensed 21 “digital specialty channels” – that is, new TV stations that will be distributed by digital methods, like satellite dishes and digital cable converters. (See announcement.)

In a previous article, I explained that the CRTC was all set to blow it yet again on requiring meaningful quantities of accessible programming, and was certain to ignore the issue of quality. (Canadian captioning and audio description are, on the whole, appalling. Audio description particularly.)

My predictions were largely vindicated.

The digital marketplace

Digital distribution of TV signals is underdeveloped in Canada. The highest estimate I’ve ever read of the number of households that can receive a digital signal is 600,000, with a wildly optimistic estimate of five million in five years’ time. Launching a new speciality channel has never been much of a risk in Canada (in fact, they are a license to print money), but the difference here is that relatively few viewers can even pick up the signal. These networks won’t be available on regular cable systems.

Nonetheless, if broadcasters are willing to sink millions into new TV channels, presumably they’ll be just as willing to make sure their programming is accessible to the entire audience. Remember, these are not “free” off-the-air networks. You have to pay to get them. If you are blind or deaf or rely on captioning or audio description for any other reason, you’re paying the same fee as everyone else.

Viewer rights

At a minimum, you deserve the following:

  1. Basic access to the majority of the network’s programming. This means most shows have to feature captioning and audio description – that’s most shows for all the years of the license, including Year One.
  2. Consistent with the CRTC’s 1995 requirements, by the end of the seven-year license term 90% of programming should be captioned and described. (Yes, described. The CRTC made no such requirement, as I’ll explain shortly, sticking instead to captioning, but this review expands on government minimums.) To provide access for 90% of your programming, in effect you have to provide access for everything, but the 90% requirement takes truly unavoidable circumstances into account.
    • French networks are an interesting wrinkle. Their max figure is 75% captioning, not 90%. The ostensible reason? The French market is smaller. If it’s that much smaller, then broadcasters shouldn’t be starting up entire new networks.
    • If the French-language industry refrained from inaugurating whole new networks (hey, it’s supposed to be a limited market!), then we could live with the reduced 75% cap. But they’re not, choosing to spend money on new stations. Doing so obviates the rationale for the lower cap. Accordingly, we should expect 90% captioning from French networks.
  3. A level of quality that meets or exceeds U.S. standards, and certainly exceeds prevailing standards in Canadian analogue TV. In particular, captions must be as well-written, well-edited, well-timed, and well-placed as leading U.S. captions, and audio descriptions can be no worse than those provided by the Descriptive Video Service at WGBH.

Getting the shaft by the CRTC

The CRTC decided, very quietly and without fanfare, that no broadcaster would be required to describe programming. At all. Even though audio description has been around since 1988 and is a proven access technique. By the end of these new license terms, in 2008, a full twenty years will have passed since the dawn of A.D. on American television. We’re already behind in Canada. The CRTC has given broadcasters license to disenfranchise blind and visually-impaired viewers for most of the next decade, and has implicitly excused all existing broadcasters for their refusal to provide regular described programming.

Can you say lost generation?

(In case you’re interested, the quiet CRTC decision is here, and reads: “The Commission has decided not to impose specific obligations at this time.... At the time of licence renewal, all licensees will be asked to report on their efforts to make their programming more accessible to the visually-impaired.”)

Taking orders from industry

It gets worse. The CRTC is supposed to be a regulator, but in virtually every license approval here, it merely reiterated the “commitments” of the broadcaster – no matter what those were.

If you said you’d caption 10% of your programming and describe nothing (an actual example), then fine, we’ll take that. If, on the other hand, you promised to caption 100% and describe 100 hours a year (no one actually offered that combination), that would be OK, too.

Greedy broadcasters were surely slapping their foreheads and muttering “D’oh!” when it dawned on them that they could have lowballed their promises and gotten them rubber-stamped.

In case this seems too pernicious to believe, it isn’t. The CRTC simply copied and pasted the actual words of the broadcast applicants, sometimes including errors in the original.

The findings

On the next page, you’ll find a series of tables providing:

  1. A quickie letter grade given to each broadcaster for its commitments to captioning and audio description. I also grade the CRTC and its requirements.
  2. Extracts from the actual applications and decisions giving broadcaster commitments and CRTC requirements.
  3. Links to the original application and decision documents. In another sign of disregard for accessibility, nearly every single application is online at the CRTC Web site in the form of a zip archive or a Microsoft Word document, and most exceed 300 K in size. Filenames within the archives are usually incomprehensible. Good luck digging out whatever useful information there is. (Some applications are not even online, despite having been filled out on computers.)
  4. Contact names and E-mail addresses taken from the public record. Feel free to write the networks directly.
  5. Comments on everything.


  • The table document uses a printer-ready format, given that many of you will prefer to print the whole shebang to read it.
  • Like all my new uploads, the page validates as proper XHTML 1.0, so it will not be incompatible per se with any browser or screen reader.
  • It makes extensive use of titles to provide an additional level of information on various entries. Unfortunately, I realized after the entire layout was done that a different layout would make the document sound better in a screen reader, but I know that it works more or less tolerably as-is.
  • Tables have been left liquid. They will expand and contract as your browser window does. Tables following one another may not have the same column widths. You shouldn’t be concerned.
  • If the page exhibits problems in Netscape 4, get a new browser; in 2001 I no longer make accommodations for that cœlecanth of a program, which cannot interpret HTML or stylesheets properly. Every platform on which Netscape 4 runs now offers standards-compliant alternatives, not all of them involving getting into bed with Microsoft.
  • The page is pretty big (about 150 K).
  • Some passages are given in the original French, encoded properly in the HTML.

Letter grades

Judging criteria:

  • For captioning
    • To score an A of any kind, you must promise majority captioning for all seven years, commit yourself to 90% or 100% captioning before year seven, and commit to improved quality standards. (No broadcaster received an A.)
    • To score a B of any kind, you must promise 90% captioning by year seven. You earn a B plus by promising majority captioning in all seven years.
    • C and D are reserved for broadcasters with half-arsed captioning plans, or for those who deliberately ignore the CRTC’s 90% requirement. You score an F if you never actually reach majority captioning and ignore other requirements. (No broadcaster received an F.)
  • For audio description
    • To score an A of any kind, you must promise majority description for all seven years, commit yourself to 90% or 100% description before year seven, and commit to improved quality standards. (No broadcaster received an A.)
    • To score a B of any kind, criteria exactly parallel to those used in captioning could not be used. Given that next to nobody was willing to do any description at all, a commitment to a meaningful quantity of described programming merited some level of B, usually with a few caveats. The jump between A and B is much larger here than with captioning.
    • C and D are reserved for broadcasters with half-arsed description plans. You score an F if you refuse to describe at all.
  • For the CRTC: You gain points if you require more than what the applicant suggests. You may lose points if you buy into broadcaster lies.

The “DVS” bugbear

The CRTC and Canadian broadcasters are so clueless about audio description that they don’t even know what to call it. What are some of the variations we find?

  1. “Descriptive video”: A registered service mark of WGBH in Boston, which admittedly WGBH has not taken many pains to defend. Broadcasters and the CRTC have no more right to call audio description “descriptive video” than they have to call it “Tampax” or “Singapore Airlines.”
  2. “Audio captions”: I especially liked this one, from Salter St. Films. God help us when they have to deal with actual captioning. (What will they call that? “Descriptive closing”?)
  3. «Service de vidéo numérique,» or digital video service. Very nice. Works even better with the acronym SVD. (What happened to the N?) «Service d’audio-vision» is another cutie.

None of this should be surprising. After all, the monopoly provider of audio description in Canada, the risibily incompetent AudioVision, operates under the same name as another A.D. organization in the U.S., even after having been warned repeatedly that their name infringes on this and other common-law and registered trademarks.

I’m only going to say this once: There is one, and only one, generic term for audio description, and it is audio description. You get to use the term Descriptive Video Service if you use all three words, if it applies to work by the Descriptive Video Service, and if you have permission.

So on with the show.
Proceed to the dissection! →