The FCC should limit broadcaster use of real-time...

Commission set a hard limit requiring programming recorded more than double its length prior to its airing -- e.g., two hours before the airing of a one-hour program -- to be captioned offline,” said TDI. Offline captions should be held to a higher standard than real-time ones, and contain proper punctuation and capitalization, TDI said. However, all captions should be held to high standards for synchronization, readability and completeness, TDI said. To improve captioning standards, the FCC should create metrics for measuring their quality, TDI said. The consumer group proposed a formula that rates accuracy as the number of words captioned minus the number of errors, divided by the number of words in the dialog, multiplied by 100. For offline captions measured with this formula, “the accuracy threshold should be 100% in nearly all circumstances,” TDI said. The consumer group said it would support a phase-in period of three years for captioning to reach that level of accuracy. The FCC should also phase out the use of electronic newsroom technique (ENT), TDI said. ENT captions are captions created for newscasts from a pre-written script or teleprompter, and therefore don’t capture breaking news or unscripted dialogue. Continuing its use in smaller markets would prevent hearing-impaired consumers in those areas from receiving “equal access to breaking news, on-scene, and weather reporting,” TDI said. ENT may also be responsible for a shortage of qualified captioners, TDI said. Stations that found adding live captioning to be “an untenable economic burden” could request waivers from the FCC, TDI said.