Programmers, VPDs Dispute Caption Responsibilities

NPRM asking if programmers should have to keep contact information or caption quality certifications on file at the FCC. But many filers touched on the larger question of whether programmers should share caption quality responsibility with distributors. VPDs have a “direct business relationship with viewers” and a local business presence, the programmers said. “Imposing a compliance certification requirement on programmers effectively would reverse the compliance burden which VPDs have borne for nearly 20 years,” the programmers said. Comcast’s comments also focused on the responsibility question. VPDs aren't responsible for most caption problems, it said. “Comcast’s experience does not support claims that VPD equipment is at fault for the vast majority of captioning issues.” AT&T said shared responsibility would obviate the need for programmers to file certifications with the FCC. Shifting the burden and requiring certifications “would not be effective in improving the viewing experience for deaf and hard of hearing viewers or promoting the efficient resolution of consumer complaints,” PBS said. CenturyLink said it supported both the certification requirement and proposals to make programmers partially responsible for caption problems. The FCC should "allow the recently-adopted Best Practices to take effect and work with industry to improve captioning quality before making any determination that mandatory certification filings will make a meaningful difference for consumers," NAB said. "Yet another abrupt shift in captioning rules only serves to discourage industry investment in effective captioning solutions."