TDI FCC Filing: Meeting with FCC Officials (1)
CG 05-231 — Closed Captioning of Video Programming;
CG RM-11848 — Telecommunications for the Deaf and Hard of Hearing, Inc (TDI) Petition for Rulemaking
MB RM-11065 — Telecommunications for the Deaf and Hard of Hearing, Inc (TDI) Petition for Rulemaking
Claude Stout of TDI, along with representatives from the tagged Consumer Groups (Lise Hamlin- HLAA, Zainab Alkebsi- NAD. Christian Vogler- TAP) and and Jake Stephens, Tess Cartin, Kylie Thompson, and Blake E. Reid of the Samuleson-Glushko Technology Law and Policy Clinic at Colorado Law (TLPC), counsel to TDI, met with FCC officials: Diane Burstein, Suzy Rosen Singleton, Eliot Greenwald, and Debra Patkin of the Consumer and Governmental Affairs Bureau to discuss the Petition for Declaratory Ruling and/or Rulemaking on Live Closed Caption Quality Metrics and the use of Automatic Speech Recognition Technologies in the above-referenced proceedings.
We discussed the two main requests in the Petition:
- A short-term request for guidance on whether and how automatic speech recognition (ASR) can comport with the Commission’s existing quality standards and human- and ENT-centric best practices; and
- A long-term request for a rulemaking to improve caption quality by replacing best practices with objective, technology- and methodology neutral quality metrics.
Ms. Burstein recused herself from the discussion of caption quality and left the room for the parts of the discussion on issues other than ASR.
TDI and the Consumer Groups believe ASR will play a role in improving the quality of live captioning programming. However we are concerned that ASR is being implemented by providers without public oversight by the FCC or guidance on how ASR fits within the FCC’s quality standards.We encourage the FCC to publicly express guidance about how it is applying its quality standards and to make clear to TV stations that they must continue to meet the commission’s quality standards when switching to ASR-based captioning. Due to large differences in accuracy across ASR vendors, we request the FCC to issue a declaratory ruling or public statement making clear the FCC’s approach to the deployment of ASR.
URL for Full Filing Document on FCC’s Electronic Comment Filing System
Special Thanks to: SAMUELSON-GLUSHKO TECHNOLOGY LAW & POLICY CLINIC