Subtitles for VOD, whose responsibility is it anyway?

UK based charities behind the #SubtitleIt campaign received a letter from Ed Vaizey, Minister of State for Culture and the Digital Economy. It was not the response that the campaign had hoped for.

Action on Hearing Loss have summarised:

Mr Vaizey has told us that, during autumn 2015, Department for Culture, Media and Sport officials met with platform operators, content providers and broadcasters, and that the discussions gave clarity into the problems limiting the availability of access services and what’s needed to improve provision levels.

The Minister has concluded that a lot has been achieved by broadcasters, content providers and platform operators towards increasing the provision of subtitles, and that “the 2013 commitment is being met”. He states that the introduction of legislation and the prescription of targets “could have a detrimental impact on what the sector has shown it is able to achieve on a voluntary basis”. In short, he has refused to take decisive action to end the digital exclusion faced by people with hearing loss due to the lack of subtitles.

SOURCE: Action on Hearing Loss – Government decision on subtitles, April 2016

And the crux of the issue:

Mr Vaizey states that it was “encouraging to hear that several players throughout the supply chain of access services are working together” to overcome problems that limit the availability of access services.

In reaching this opinion Ed Vaizey has ignored the evidence of the regulator, ATVOD. They reported that a “stalemate” persists between the broadcasters (content providers) who provide the programmes (e.g. ITV and UKTV) and the set top box operators (platforms) who pull together content from lots of different providers (e.g. Sky and Virgin), and a lack of clarity about whose responsibility it is to make content accessible.

SOURCE: Action on Hearing Loss – Government decision on subtitles, April 2016

This issue keeps cropping up. Whose responsibility is it?

Netflix who do subtitle the majority of its content have published an article on their subtitling workflow. It’s interesting to read how Netflix tackles the problem of different devices requiring different formats, and how different languages can sometimes require different rendering capabilities that may not always be available on the device being used by the end user, and how before all of that is tackled, quality control checks are put in place. They have chosen to take on much of the responsibility in the sense that if a content provider does not provide a subtitle file in the correct format, they have invested in systems to overcome the problem and solve the problem of different devices requiring subtitles in different formats (phones, tablets, smart TVs, PC etc) The industry has made similar steps in this regard to with agreeing industry standard subtitling formats (such as EBU-TT which the UK regulator recommends is adopted). BBC iPlayer have also subtitled content as the “norm” for years and have very detailed guidelines documented here. I haven’t found many other articles on this subject, but it would appear the iTunes platform in the US have taken responsibility – sort of. It’s not that the platform is saying it will take responsibility to provide closed captioning, but iTunes (US) will remove content supplied by providers if they have failed to include a closed captioning file. It’s an interesting tactic, but its a move that I feel reflects regulatory requirements in the US, rather than a bold statement from Apple that they will only accept accessible content. (If anyone disagree’s with this conclusion – please do comment).

VOD subtitles – whose responsibility is it?

So, back to the question, whose responsibility is it, and what is the right way to ensure accessibility via subtitling and captioning is implemented for VOD services? It’s a question the FCC in the US asked, and also recently answered. The UK VOD industry currently does not have this clarity, and the regulator cannot set it. In the interest of full transparency I should point out to those who are reading who may not be aware, I’ve been employed by a broadcaster, and a platform in my career so far. Whilst I have some insight into the differing workflows – it doesn’t make the answer to the question any easier except to say if both work together (that is a platform makes sure it has no barriers to access and can support accessibility features, and a broadcaster can provide those features (e.g. provide subtitle files / audio description files with its video content), it can be solved. I don’t necessarily think its and either/or answer here. The responsibility probably lies with both. Yes, there are challenges which some broadcasters will face more than others, and there are some platforms that will find it easier to do than others (for various reasons: do they make their own programmes, do they buy them from other content providers, do they control the full end-to-end chain? Has the platform been built to support accessibility features or do they have to tackle that first? etc) But it is absolutely technically possible for any VOD service to provide an accessible service. We know that, there are good guys who have been doing this for ages. The question is, how time-critical is this goal considered to be by either one of these parties? If it even is a goal for those services which are not accessible? Why not set a (regulatory) target – no goal is ever reached without setting a deadline. And whatever well-meaning action is currently being taken by VOD services that are planning to add accessibility features, if you need them, the progress certainly does not feel fast enough. And that is why Action on Hearing Loss are continuing their #SubtitleIt campaign, encouraging anyone who relies on subtitles to enjoy VOD services to contact their TV providers. The charity will also be targeting those working in the VOD industry by giving a talk at the VOD Summit taking place in London next month.

A look back at 2015

2015 saw a lot of accessibility advocacy around subtitles/captioning and audio description with some great victories. This is by no means a complete list but it does summarise some of the highlights for me.

Amazon Instant Video UK finally started added subtitles to their VOD service after some great advocacy which had its origins in the Love Subtitles campaign.  In 2014, there were no subtitles at all, and by the end of 2015, approximately 50% of its content is subtitled (see ATVOD report detailed later in this article). Let’s hope that percentage figure continues to rise in 2016 .

Marvel’s Daredevil on Netflix

Netflix US / UK found itself the target of an advocacy campaign to add audio description to its content after it released an original series about a blind superhero Daredevil based on the Marvel comic book character of the same name without making it accessible to blind and visually impaired viewers. Thanks to the efforts of The Accessible Netflix Project,  there was a pretty fast response from Netflix in releasing audio description tracks for this series and more on its platform.

The Action On Hearing Loss #SubtitleIt! campaign succesfully obtained a public comittment from Sky that it would increase the amount of  subtitled VOD content on it’s services by summer 2016 following a petition from Jamie Danjoux. I think a lot of people will be watching this one closely and look forward to seeing the comittment being met in 2016.

All of these campaigns are far from over and many are continuing their advocacy into 2016. The #SubtitleIt campaign just published a useful summary of ATVOD’s final report  (before being taken over by Ofcom) into the Provision of Access Services published at the end of 2015.

There were many other interesting publications around accessibility in 2015:

• Action on Hearing Loss published the results of its survey into the state of VOD accessibility in the UK called Progress On Pause.
• RNIB published the results of trial involving blind and visually impaired members using an audio description app called MovieReading.
• Stagetext published the results of its research and development using new technology called CaptionCue to produce live captioning of live theatre performances.
• BBC R&D published a whitepaper on Responsive Design for Personalised Subtitles.
• HBB 4 All published its report into New approaches to Improving the Quality of Media Accessibility Services on HbbTV.
• Ofcom published its final 4th report into measuring the quality of live subtitling on live TV. Amongst a wealth of statistics was an interesting snippet of information about  a possible technical solution for some live UK TV channels and live subtitling latency. A solution referred to as using ‘switchable delays’. I have been lucky enough to see a clip of this from tests and the results do indeed look very promising so I hope that this will be implemented.

There were many other successful advocacy and awareness campaigns in 2015.

I had great fun taking part in the UK’s first #CAPaware week launched by Stagetext to celebrate its 15th birthday which amongst many activities that week included tweeting alongside watching a captioned play from Digital Theatre.

Turn On The Captions Now  was a campaign that successfully passed a local city law in Portland, Oregon USA which states that all public televisions in public areas such as bars and restaurants must have closed captioning switched on. The Portland: Turn On The Captions Now! group have since published a website that includes instructions for turning on closed captions and advice for Portland residents on how to request captions if they spot non-compliance.

American Airlines showed everyone how not to respond to a query on social media to a request for closed captioning to be made available on their in-flight entertainment.  It lead to a Twitter campaign with the hashtag #DeafInTheAir

But it wasn’t just airlines, Braam Jordaan was successfull in getting the White House to make its video content accessible with a campaign predominantly on Twitter using the hashtag #WHccNow

.@whitehouse Please add captions to videos posted on social media! #WHccNow More info: https://t.co/zpPSnDlB3b pic.twitter.com/cGXvLmHLtR

— Braam Jordaan (@braamjordaan) December 10, 2015

In fact it seems when it comes to social media, (whisper it carefully, I don’t want to jinx it) but it seems that the knowledge that subtitling and captioning your video media leads to other benefits outside of accessibility is starting to become mainstream. Video marketing websites have been quick to report research showing that adding subtitles can increase the video completion rate and  the video share rate. I for one have noticed more and more videos on social media with auto-play *and* open subtitles.  I hope that this trend continues as it can only lead to more accessible content online for everyone. Roll on 2016…

 

#SubtitleIt campaign and other UK regulatory news

Earlier this year Action on Hearing loss created a survey to gather the experiences and thoughts of subtitle users access to video on demand (VOD) services in the UK.  The results have been published and the report titled Progress on Pause is well worth a read.

It’s part of the #SubtitleIt campaign which is a joint effort from multiple UK charities that wants to see VOD accessibility regulated as a mandatory requirement as is currently the case in the UK for linear TV.  Individual advocates alongside the charities efforts has resulted in some success so far including a statement from Sky to commit to increasing their on demand subtitled content.

The deadline to ask your MP to back the bill is November 2015.

The campaign is far from over however. For any legislation to become a reality, it needs support from MPs. If you do not see your local MP listed here please write to them asking them to back the bill. (Note this also includes other important accessibility features such as audio description and signing). Please don’t miss the deadline.

From 1st January 2016, ATVOD will no longer exist as a co-regulator and its responsibilities will be carried out by Ofcom

In other regulatory news that effects VOD services in the UK, the regulatory body Ofcom announced that it would take over the role of ATVOD:

The regulation of ‘video-on-demand’ programme services is being brought fully within Ofcom to sit alongside its regulation of broadcast content.

The move follows an Ofcom review to ensure regulation of broadcast and on-demand content remains as effective and efficient as possible for the benefit of consumers, audiences and industry.

The review included the current co-regulatory arrangements for video-on-demand services. These can include catch-up TV and on-demand services on the TV and the internet. Ofcom designated the Authority for Television On Demand (ATVOD) in 2010 as a co-regulator to take the lead in regulating editorial content for video-on-demand services.

Following the review, Ofcom has decided that acting as sole regulator for video-on-demand programmes is a more effective model for the future than having two separate bodies carrying out this work. This will create operational efficiencies and allow editorial content on video-on-demand to sit alongside Ofcom’s existing regulation of broadcasting.

SOURCE: Ofcom brings regulation of ‘video-on-demand’ in-house

This (in my opinion) is good news. It means a far less confusing regulatory model and that all TV will sit under the same regulator.   Ofcom recently published its results into access services on UK TV for the first six months of 2015.  With Ofcom to take over the duties of ATVOD in 2016, wouldn’t it be great if we could have the same level of transparency on how each VOD service is performing with more regular (and legally required) statistical reporting on levels of access services here too?

CSI TV Accessibility Conference 2014 – Live subtitling, VOD key themes

CSI TV Accessibility Conference 2014

Earlier this month the CSI TV Accessibility Conference 2014 took place in London. I had hoped to be able to give a more detailed write up with a bit of help from the transcript of the live captioning that covered the event but I’m afraid my own notes are all I have and so I will summarise some of the interesting points made that I think will be of interest to readers here. It will not cover all of the presentations but it does cover the majority.

i2 Media Research gave some statistics surrounding UK TV viewing and the opportunities that exist in TV accessibility. Firstly, TV viewing is higher in the older and disabled population. And with an ageing UK population the audience requiring accessibility features for TV is only going to increase.

Andrew Lambourne, Business Director for Screen Subtitling Systems had an interesting title to his presentation: “What if subtitles were part of the programme?” In his years of working in the subtitling industry he questioned why are we still asking the same questions over recent years. The questions surround the measurement of subtitling quality, and if there is incentive to provide great subtitling coverage for children. He pointed out that in his opinion funding issues are still not addressed. Subtitling is still not a part of the production process and not often budgeted for. Broadcasters are required to pay subtitling companies,and subtitling costs are under continued to pressure (presumably to provide more, for less money). It is a sad fact that subtitling is not ascribed the value it deserves. With regards to live subtitling there is a need to educate the public as to why these errors occur. This was a repeated theme in a later presentation from Deluxe Media. It is one of the reasons I wrote the #subtitlefail! TV page on this blog.

Peter Bourton, head of TV Content Policy at Ofcom gave an update and summary of the subtitling quality report which was recently published at the end of April. This is a continuing process and I’m looking forward to comparing the next report to this first one to see what changes and comparisons can be made. The presentation slides are available online.

Senior BBC R&D Engineer Mike Armstrong gave a presentation on his results to measuring live subtitling quality. (This is different to the quantitative approach used by Pablo Romero and adopted by Ofcom to publish its reports) What I found most interesting about this research is that the perception of quality by a user of subtitles is quite different depending on whether the audio is switched on whilst watching the subtitled content. Ultimately nearly everyone is watching TV with the audio switched on and this research found that delay has a bigger impact on perception of quality compared to the impact of errors. The BBC R&D white paper is available online.

Live subtitling continued to be a talking point at the conference with a panel discussion titled: Improving subtitling. On the panel was Gareth Ford-Williams (BBC Future Media), Vanessa Furey (Action On Hearing Loss), Andrew Lambourne (Screen Subtitling Systems), and David Padmore (Red Bee Media). All panelists were encouraged that all parties – regulators, broadcasters, technology researchers are working together to continually address subtitling issues. Developments in speech recognition technology used to produce live subtitles has moved towards language modelling to understand context better. The next generation of speech recognition tools such as Dragon has moved to phrase by phrase rather than word by word (the hope being that this should reduce error rates). There was also positivity that there is now a greater interest in speech technology which should lead to greater advancements over the coming years, compared to the speed of technology improvements in the past.

With regards to accessibility and Video on Demand (VOD) services it was the turn of the UK’s Authority of Television Video on Demand (ATVOD) regulatory body to present. For those that are unaware, ATVOD regulate all VOD services operating in the UK except for BBC iPlayer which is regulated under Ofcom. In addition because iTunes and Netflix operate from Luxembourg, although their services are available in the UK, they are outside of the jurisdiction of ATVOD. There are no UK regulatory rules that say VOD providers must provide access services, but ATVOD have an access services working party group that encourage providers to do so as well as draft best practice guidelines. I cannot find anywhere on their website the results of a December 2013 survey looking at the statistics of how much VOD content is subtitled, signed, or audio described which was mentioned in the presentation. If anyone else finds it please comment below. However, in the meantime some of the statistics of this report can be found in Pete Johnson’s presentation slides online. What has changed since 2012 is that this survey is now compulsory for providers to complete to ensure the statistics accurately reflect the provision. Another repeated theme, first mentioned in this presentation is the complexity of the VOD distribution chain. It is very different for different companies, and the increasing number of devices which we can choose to access our content also adds to the complexity. One of the key differences for different VOD providers is end-to-end control. Few companies control the entire process from purchasing and/or creating content for consumers to watch right through to watching the content on a device. So therefore who is responsible for a change or adaptation to a workflow to support accessible features and who is going to pay for it?

I should also mention that the success of a recent campaign from hard of hearing subtitling advocates in getting Amazon to finally commit a response and say that they will start subtitling content was mentioned positively during this presentation. You may have read my previous blog post discussing my disappointment at the lack of response. Since then, with the help of comedian Mark Thomas, who set up a stunt that involved putting posters up on windows of Amazon UK’s headquarters driving the message home, Amazon have committed to adding subtitles to their VOD service later this year. See video below for the stunt. It is not subtitled, but there is no dialogue, just a music track.

You can read more about this successful advocacy work on Limping Chicken’s blog.

Susie Buckridge, Director of Product for YouView gave a presentation on the accessibility features of the product which are pretty impressive. Much of the focus was on access features for the visually impaired. She reminded the audience that creating an accessible platform actually creates a better user experience for everyone. You can view the presentation slides online.

Deluxe Media Europe gave a presentation that I think would be really useful for other audiences outside of those working in the industry. Stuart Campbell, Senior Live Operations Manager, and Margaret Lazenby Head of Media Access Services presented clear examples and explanations of the workflow involved in creating live subtitles via the process of respeaking for live television. Given the lack of understanding or coverage in mainstream media, this kind of information is greatly needed. This very point was also highlighted by the presenters. The presentation is not currently available online but you can find information about live subtitling processes on this blog’s #SubtitleFail TV page.

A later panel discussed VOD accessibility. The panelists acknowledged that the expectation of consumers is increasing as is the volume and scale of complexity. It is hoped that the agreed common standard format of subtitle file EBU-TT will resolve a lot of these issues. This was a format still being worked on when it was discussed at the 2012 Conference which you can read about on this blog. The UK DPP earlier this year also published updated common standard subtitles guidelines.

Were any of my readers at the conference? What did you think? And please do comment if you think I have missed anything important to highlight.

Subtitles and Captioning – Regulatory requirements update part 2 and adding business value

As a follow-up to my previous post, I am going to discuss recent reports specific to UK broadcasters which are regulated by Ofcom.

Last month the charity Action on Hearing Loss published the results of a survey carried out at the request of Ofcom to investigate the quality of subtitles seen on UK linear television. The results for me were not that surprising:

The highest percentage of problems experienced with subtitles were in relation to news programmes, with nearly half of respondents reporting this as a problem in our survey. Entertainment programmes received 18% of complaints and drama programmes received 16%. Around one eighth of respondents complained about subtitles during a sports programme. A high proportion of these programmes are likely to have at least some live subtitling.

SOURCE: Action On Hearing Loss – Research – Getting The Full Picture

Of the live subtitling more than half the complaints were about delay and time lag between speech audio and the subtitles on screen. Again, not surprising. If you want to make subtitles completely unusable – being out of sync with the audio is the way to do it! What the survey does not cover and what I would be interested to see is how Ofcom as a regulatory body could measure the quality of subtitles that broadcasters provide on a regular basis. I have written about this in more detail in CSI User Experience Conference 2012 Part 2 – Live Subtitles & measuring quality.

Ofcom have published the full year 2012 TV Access Report. The table illustrates the percentage of programmes certain channels are required to subtitle. The good news is that with the exception of ESPN, channels have met their required quota and some have done even better and exceeded it.

The percentage of content that Ofcom require broadcasters to subtitle is based on the individual channels total audience share. This means that smaller channels are not legally required to provide subtitling and therefore those channels don’t even appear in the report. Is this right? I recently had a conversation via twitter with a TV viewer unhappy that the SyFy channel has not subtitled a brand new and exclusive show called Defiance. Take a look at the tweets I collated at Storify: UK broadcasters linear and VOD TV channels not subtitled.

In response to a complaint about lack of subtitles SyFy wrote:

Under current Ofcom regulations channels are obligated to provide access services according to their size. The bigger the channel, the more they must provide. On this basis we are not currently required to provided subtitles on SyFy, and unfortunately as the costs involved in creating those versions are high, we therefore cannot do so at this time.

SOURCE: @topofthetree

First off, it is good that SyFy sent a reply to the query (some channels don’t even bother with that). The answer is of course not what those of us who require subtitles to follow a programme want to hear. Whilst SyFy are correct with regards to regulations it the last sentence I question. The costs are high. Well yes there is a cost to subtitle a programme, but cost is relative. How expensive is creating subtitles for viewers compared to the costs spent on the UK marketing campaign promoting the series? I for one haven’t failed to notice the billboard posters promoting the series – the money was found for that. So here is my opinion:

Really what SyFy is saying is that they have not chosen to budget the cost because it’s not legally required. This is a real shame SyFy because you can spend as much money as you want on promoting the show but having chosen to not provide subtitles, you’ve lost potential audience members before you’ve even began. How silly is that? It’s a kick in the teeth to see the publicity and the posters knowing full well you can’t tune into the premiere even if you wanted to because no subtitles are available! And here’s another thing, the value added by providing subtitles stays with that programme throughout its run on the TV channel. The marketing does not! Once this series has premiered, all that money spent on publicity, done, finished. If you choose to also spend money on providing subtitles, they can be used again and again and again every time the programme airs (and lets face it almost every linear TV channel out there has an awful lot of repeats) that is surely value for money right there? SyFy state they hope to provide subtitles in the future. Given the points I have made in this article, I ask SyFy and similar smaller channels, what are you waiting for?

Going back to Storify: UK broadcasters linear and VOD TV channels not subtitled and a response from Sky with regards to no subtitles being provided on their VOD (Video On Demand) service:

The technology used in providing subtitles for TV broadcasts is different for On Demand. Unfortunately it is not possible to just transfer these over as different versions have to be created…We are investigating options at the moment to increase the availability of subtitles On Demand but we cannot at this point confirm when this will be available.

SOURCE: @Shelle02

Unlike linear TV channels, VOD is regulated by ATVOD (Authority for Television On Demand) in the UK (except for BBC iPlayer), and unlike Ofcom they currently have no power to compel VOD channels to provide subtitles. I have written about this in more detail in CSI User Experience Conference 2012 Part 1 – Subtitling & Video On Demand Services.

VOD is growing, in size and complexity. And with that comes technological challenges in providing the service, and access services. But here’s the thing, the content provider who solves the access issue in working out how to provide subtitles for VOD services, much like the SyFy example will be adding business value. According to an article by Red Bee Media, there are four ways add value to VOD:

WHERE DOES VALUE GET ADDED?

In my view, value for Video On Demand is added in four areas:

1) Of course, the majority of the value is in the content creation and is generated when the item is first made. This, after all, is the reason content is purchased, watched, saved, shared and rewatched. This value drives all other values.
2) Additional value can be added during content manipulation. For example when a French movie is translated and localised for German audiences.
3) Content transcoding adds value by ensuring content will play on an end device like a tablet.
4) The last value-add is the ability to return consumption, demographic and interaction data to content and platform owners to generate additional value, which includes simple upselling like “if you like this, you’ll like that…”. Also, given that 64% of Generation X and 74% of Generation Y use a second screen while watching TV, metadata gives us the ability to synchronise second-screen content with first-screen action.

SOURCE: Red Bee Media – How Do We Handle The Growing Complexity In VOD

Looking at (2) above, content manipulation includes adding subtitles for the deaf and hard of hearing, not just translation surely? Looking at (4) subtitles can be used as a metadata source to assist a broadcaster with its workflows. Subtitle files are a data source – it contains valuable editorial information (i.e. all of the spoken dialogue) for that programme with a time stamp. This data could be used for search functionality to pinpoint exact parts of a programme where ‘x’ might be mentioned, potentially saving hours of time for a human to manually look for such instances. For more information on metadata’s use in VOD read An Introduction to Video Metadata and CSI User Experience Conference – Part 4 – Access business models. For VOD channels operating online there is also the added benefit that subtitles and captions give to video SEO. I have written about examples of this in Captioning, subtitling and SEO and the second screen and if you want more information on this subject taken a look at 3 Play Media blog series on Video SEO.

In conclusion then, adding subtitles provides access benefits and business value to broadcasters. Providing access is not a punishment because you’ve reached a certain audience percentage (linear TV), it’s a way to increase audience reach in the first place. Why wait until Ofcom tell you it is a legal requirement? And for VOD, it is no different. The quicker solutions are found for the technological issues in adding subtitles the quicker you can add business value and extend audience reach. The VOD service that does this, is the one that will get my money and customer loyalty.

CSI User Experience Conference 2012 Part 1 – Subtitling & Video On Demand Services

CSI User Experience Conference 2012: TV Accessibility

Last week I had the pleasure of attending the CSI User Experience Conference 2012 in London during which many panel discussions and presentations were given on a wide range of issues relating to access to broadcast. Panelists and speakers were from broadcasters, companies providing access services, regulators, and representatives from disability and advocacy groups. You can find details of all the panelists and speakers and download a full transcript of the days events here.  In this first post about the conference I will focus on some of the points and issues raised that relate specifically to subtitling and non linear, video on demand broadcast. Any regulators discussed here refer to those based in the UK. 

Non linear television comprises about 2 or 3% of total TV viewing in the UK and is regulated in the UK by ATVOD – The Authority for Television On Demand (with the exception of BBC iplayer which is regulated by Ofcom). Part of the regulatory duties is to encourage service providers to ensure they make their services progressively more available to people with disability relating to sight and hearing. However as of this date of writing, unlike the broadcast regualator Ofcom, ATVOD don’t have any legal powers to compel service providers to do this. Why the heck not? Interestingly throughout this conference broadcasters and access service providers expressed a desire to see access provided regardless of legal requirements or further regulation. Video on demand and other non linear TV services are in their infancy compared to linear TV and this is one of several reasons as why little video on demand content is subtitled. ATVOD are working with stakeholders to identify the barriers to provision. Here is what Pete Johnson, Chief Executive of ATVOD said on this subject:

Now obviously some of those barriers are simple commercial ones did costs money, its a nascent industry, there are lots of different outlets which will require different solutions, and so some of that will emerge over time. But its also clear that there are some technical barriers as well, for example around the lack of standardisation of subtitling files that are required by different platforms in order to make subtitles appear. One of the things we have done is brought together a working party which includes the DTG, so joined up thinking here, representatives of the various charities and service providers to try to see if we can get some standardisation so that a content provider who is providing a programme asset to a range of different platforms and outlets can provide one asset – one subtitle file for example, and know that that can be played out across the different platforms. At the moment a content provider might have to write a whole range of different subtitling files in order to make that play out across the different platforms. We’re also encouraging the platforms themselves, especially the set-top box operators to make sure that their next generation box can handle subtitling and audio description, and signing in a manner that some of the current generation don’t.

One of the other interesting points raised, is from a regulatory point of view even if there was stronger UK legislation to provide access services on video on demand content, some of the largest video on demand services accessed in the UK, such as iTunes and Netflix – these are not within UK jurisdiction. They are within Luxembourg’s jurisdiction. Kevin Carey, Chair of Technical Committee, World Blind Union and chair of the UK’s RNIB in response to this point made an excellent suggestion as to what needs to change to get around this issue:

If you made it statutory and its perfectly possible to too do this, even if Amazon is based in Luxembourg you still make a UK payment with a UK based credit card. If you legislated that it was the person who collected the payment responsibility for the accessibility, regulatory flight on this issue would not be possible. So the key to this in the long run is who collects the money. That will take care of the services part of it.

ATVOD has published the results of its 2012 survey of the levels of provision of signing, subtitling audio description on regulated VOD services. The aim is to reveal the level of provision and allows people to take a view on whether this level of provision is sufficient, if the rate of improvement is sufficient year on year and also to identify those who are making progress and those who are not. With regards to subtitling the news is positive. In 2011 just 4 regulated services told ATVOD they were providing programmes with subtitling, but this year that has increased to 12. Signing has also increased from 0 in 2011, to, 2 service providers saying that they now provide some signed programming. However the progress with audio description services remains static between 2011-2012 with 2 service providers saying they provided some audio described programmes. What is really depressing however is the fact that so few services providers chose to respond to the survey in the first place. This is something Chief Executive Pete Johnson is concerned about. He said:

We’re also considering whether to make responses to future surveys. On provision compulsory. We have the power to issue a demand for information under The Communication Act. One of the things I found disappointing this year was although we have 81 service providers providing 200 services, the overwhelming majority over 80% didn’t respond which is disappointing and I think we highlight in our report those who we asked who didn’t respond. I wonder can we perhaps ask why they didn’t respond. We also want to consider with stakeholders whether there are opportunities to highlight best practice and I am very pleased to be able to put those slides up to say that the likes of 4 On Demand (4OD) and Channel 5 and ITV and STV are actually making process in this area I hope that it will encourage those that weren’t able to feature on those slides to make themselves appear next year.

The complete ATVOD survey of Provision of Video on Demand Access Services- 2012 Report can be found here.