Back upFCC: Closed Captioning over IP (IPCC)

2012/5/14 1Confidential

Summary of Report & Order for IPCC•  Released:  January 13, 2012 

– Covers implementing Sections 202 and 203 of the Communications and Video Accessibility Act of 2010 (“CVAA”).

• Compliance Date:  January 1, 2014– Expects manufacturers begin efforts 30 days after the Report & Order is published.

• Grace Period : Two years (approximately)• Technical Requirements: SMPTE TT 2052-1:2010: “Timed Text Format

– This is a safe harbor interchange & delivery format – Expects manufacturers will adopt use of SMPTE-TT,” RP 2052-10-2010 (2010) for

conversion of CEA-608 caption data.– Expects a similar recommended practice regarding the conversion of CEA-708 data to

SMPTE-TT to be developed.

2012 2013 2014

Final Rules released 13 January 2012

Compliance Date: 1 January 2014

2012/5/14 2Confidential

Summary of Report & Order for IPCC

• Covered Devices:  Internet connected televisions,  and any video player, including Blu-Ray and other removable media devices

– Interfaces• All video outputs of covered apparatus shall be capable of conveying from the source device to

the consumer equipment the information necessary to permit or render the display of closed captions.

• HDMI complies since the law allows pass-through of open captions. – Encourages HDMI LLC to update specifications to carry caption data to sink devices

• Exempt Devices: “Display-Only” devices, e.g., computer displays; professional video equipment, movie theater equipment); Third-Party Software: 

– Manufacturers of covered apparatus not responsible for third-party software downloaded by users

• Achievability: The Order uses the ACS Order’s four-part test of achievability• Waivers: Only unique, fact specific waivers and denies blanket waivers• Penalties:  $10,000 Forfeiture for Violations of the IP Captioning Rules:  

– Adopts a flexible, case-by-case approach to forfeitures and declines to adopt either a baseline or minimum forfeiture amount

• Complaints: Adopts a simpler consumer-oriented process– Administered by Consumer and Governmental Affairs Bureau

2012/5/14 3Confidential

IPCC Status:

• The carriage mechanism for IPCC is not defined– The FCC deferred this to a future industry standard– Companies involved in the VPAAC are expected to lead a joint

standardization activity between CEA and SMPTE. • This is define the carriage mechanism for SMPTE TT. • The date and project schedule has NOT been announced.

• The FCC is not involved in the standardization activity. – The FCC will not “bless” a particular standard.

• This is according to language in the FCC’s Report & Order for IPCC.

• Industry will promote the standard as the “preferred” carriage mechanism– No guarantee that all service providers will use the standard

2012/5/14 4Confidential

VPAAC Working Groups

• WG 1 – Closed Captioning Over IP

• National Association of the Deaf, Disney co-chairs• Report submitted 11 July 2011

5SEL Government Affairs2012/5/14 Confidential

IP Closed Captioning – Definitions

• Video programming owner (VPO)

• licensor

• Video programming distributor (VPD)

• makes programming available to end-user

• “Full-length” video programming only

• Rules do not apply to “clips” or “outtakes”• Rules do not apply to “consumer generated media”• Rules do not apply to programming shown only on foreign

channels

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IP Closed Captioning – Obligations of Video Programming Owners and Distributors

• Obligations of VPOs (Content Providers)

• Establish “mechanism” for identifying covered programming with VPDs• Send program files to VPDs with captions, according to schedule• Quality must equal television captions• Interchange “safe harbor” – SMPTE TT 2010

• Obligations of VPDs (Content Providers/Authoring studios providing BD-Live network services)

• Establish “mechanism” for identifying covered programming with VPOs• Render or pass through all required captions to end user• Maintain quality of captions• Make available contact information for consumer complaints

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IP Closed Captioning – VPO + VPD Deadlines

•  

8 SEL Government Affairs

If the video programming is . . . It must be delivered via IP with captions if it is shown on television with captions on or after . . .

pre-recorded programming that is not edited for Internet distribution

30 September 2012

live or near-live programming (performed and recorded less than 24 hours prior to the time it was first shown on television)

30 March 2013

pre-recorded programming that is edited for Internet distribution (substantial edits required)

30 September 2013

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IP Closed Captioning – VPO + VPD Deadlines

•  Library content

• video programming that is already in the VPD’s library before it is shown on television with captions

9 SEL Government Affairs

If the video programming is shown on television with captions . . .

It must be delivered via IP with captions within . . .

on or after 30 March 2014 and before 30 March 2015

45 days after it is shown on television with captions

on or after 30 March 2015 and before 30 March 2016

30 days after it is shown on television with captions

on or after 30 March 2016 15 days after it is shown on television with captions

2012/5/14

Confidential

IP Closed Captioning – Hardware/Software, plug-in Clients deployed by VPDs Deadline

• Clients deployed by VPDs

• Software, plug-in, or hardware

• Must render or pass through closed captions if deployed new or updated after 30 September 2012

• Various affected parties (Apple, Amazon, Microsoft, Dish Network, DirecTV) are considering an appeal of this obligation

• Appeal must be filed by 30 April 2012

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IP Closed Captioning – Hardware/Software Clients not deployed by VPDs Deadline

• Hardware/software client compliance deadline – 1 January 2014

• Physical devices designed to receive or play back video programming transmitted simultaneously with sound, along with any integrated software

• Includes

• Set-top boxes, PCs, smartphones, tablets, and televisions – if IP-enabled• Removable media players (DVD, Blu-Ray)• Recording devices• No exemption based on screen size – unless not “achievable”

• Does not Include

• Display-only monitors• Professional or commercial equipment, including movie projectors

• Interfaces

• All outputs must “convey” captions – open or closed• HDMI complies11 SEL Government Affairs

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IP Closed Captioning – CEA Appeals

• CEA will appeal two elements of the hardware rules• Rules should not apply to every device capable of playing

back video programming

• Still or video camera with removable media

• Rules should not apply to playback-only removable media players

• Playback-only DVD or Blu-Ray players

• Appeal will be submitted by 30 April 2012

• Decision is unlikely before 31 August 2012, perhaps longer

12 SEL Government Affairs

This only includes local playback of content, and does not include BD-Live

downloaded/streamed content.

2012/5/14

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