FCC Filing: Accessibility of Children’s Educational and Informational Television Programming

CLOSED CAPTIONING

MB 17-105 — Modernization of Media Regulation Initiative;
MB 18-202 — Children’s Television Programming Rules;

REPLY COMMENTS

TDI, along with the tagged consumer groups filed a reply comment to the Federal Communications Commission, about its public notice regarding the accessibility of children’s educational and informational television programming.

The organizations stated that the Commission’s 2019 changes on the children’s television rules and its impact on the accessibility of children’s programming remained unclear. The notice only provided a less than satisfactory page containing the National Association of Broadcasters (NAB)’s claims on the state of the children’s accessibility. 

The organizations acknowledged NAB’s declarations that the 2019 changes have little or no impact on the availability of children’s programming accessible to children with disabilities. In addition, NAB remarked that the “vast majority of… children’s programming remains closed captioned.” Regardless of these declarations, the organizations felt these statements are just superficial. NAB admitted their beliefs are based on assumptions that the programming is already captioned or similar to that. 

Still, the parents of children with disabilities will disagree with the claims above. The American Society for Deaf Children conducted a survey with more than 200 parents who have children who watch children’s programming and discovered that only 19% of them saw that children’s programming has closed captions and/or audio descriptions. These gaps raise the concerning possibility that changes to the children’s television rules have resulted in a decline in the accessibility of programming for children who are deaf, hard of hearing, blind, visually impaired, or DeafBlind.

NAB has the authority to gather and present valid data, despite the forewarning of the incoming inquiry on the programming, NAB still offered barely acceptable information. NAB should do better next time in the future in order to provide better analysis to improve the accessibility for children with disabilities in the programming. 

Thus, we urged the NAB to provide a serious and rigorous analysis of the accessibility of its member stations’ children’s programming, and to provide data and documentation of its findings, not just mere conclusions, so that the Commission can verify that children with disabilities are in fact not being left behind by the changes to the children’s programming rules. Not only that, we urged the FCC to require the NAB to present the inquiry in a timely manner. 

[see below, under Tags: for a full list of signatories]

URL below is linked to the actual filing document on FCC’s Electronic Comment Filing System 

https://ecfsapi.fcc.gov/file/110861837124/2021.11.08%20Accessibility%20Advocacy%20and%20Research%20Organizations%20Children’s%20Video%20Data%20Reply%20Comments%20final.pdf

Special Thanks to: SAMUELSON-GLUSHKO TECHNOLOGY LAW & POLICY CLINIC,