ACMA 3D TV Discussion Paper Submission
Submission to the Australian Communications and Media Authority in response to the ‘Temporary trials of 3D TV and other emerging technologies’ Discussion Paper
October 2010
Submitted by:
Alex Varley
Chief Executive
Media Access Australia
Suite 4.08
22-36 Mountain St
Ultimo NSW 2007
Tel: 02 9212 6242
Fax: 02 9212 6289
Email:
www.mediaaccess.org.au
I Contents
I Contents ii
II About Media Access Australia iii
II.i Who is MAA? iii
II.ii MAA’s objects (from the MAA Constitution) iii
II.iii How does MAA operate? iii
1 Introduction 1
1.1 Comment on the Discussion Paper 1
2 The context of trials of audio description in Australia 2
2.1 Australia 2
2.1.1 DVDs 2
2.1.2 Cinema 2
2.2 United Kingdom 2
2.3 New Zealand 3
2.4 United States 4
2.5 Canada 4
3 Technical aspects of audio description 6
3.1 Broadcast-mixed versus Receiver-mixed AD 6
3.2 Costs and turnaround times 6
4 Improving audio description in Australia 8
4.1 Impediments 8
4.2 Opportunities 8
4.3 The proposed AD trial on the ABC 8
4.3.1 Commonwealth Government’s position 9
4.3.2 The ABC’s position 10
5 The importance of Channel B for audio description 11
5.1 Before analog switch-off 11
5.2 After analog switch-off 11
5.3 3D television in comparison 12
II About Media Access Australia
II.i Who is MAA?
Media Access Australia (MAA) is a not-for-profit, public benevolent institution and Australia’s primary media access organisation. Our role is to be a catalyst for the provision of access to media for disadvantaged people through the use of technological solutions.
MAA was originally a captioning and audio description supplier known as the Australian Caption Centre, which was founded in 1982. This part of the organisation was divested in 2006. As the ACC, we provided captioning services for all the Australian television networks, as well as the captioning of television commercials, live theatre, videos and DVDs, and pioneered the audio description of DVDs in Australia in 2005. MAA no longer provides commercial access services.
MAA is a national organisation based in Sydney, with a satelite office in Perth, and works in collaboration with consumer organisations, Government and industry across the country and internationally. We also provide a comprehensive free information service (including two websites: www.mediaaccess.org.au and www.audiodescription.com.au), and assist thousands of people with everyday access issues, as well as helping organisations provide more access. We also publish the quarterly Media Access Report, providing factual topical information on media access issues from around the world.
II.ii MAA’s objects (from the MAA Constitution)
The objects for which the Company (Media Access Australia) is established are:
· To establish and maintain an organisation for the provision and promotion of information services principally but not exclusively for the benefit of people who suffer disability for health, education, social, financial or similar reasons; and
· To establish and maintain an organisation for the provision and promotion of media access services for the benefit of individuals with impaired capacity to access such services.
II.iii How does MAA operate?
MAA brings a unique perspective to the world of access and appears to be the only organisation in the world operating in this way. MAA operates as a catalyst for change. We want to see more access to media in Australia and the world. Therefore our starting point is how do you make more access possible? We frame this approach in the context of considering consumer desires, costs, distribution channels, supply techniques, equipment, convergence and regulation.
The question of what the most appropriate level of access should be at a particular time should be answered by the consumers. Our role is to help in getting to that level of access, especially looking at implementation issues, including cost-effective approaches and drawing on successes from other places.
Media Access Australia iii
ACMA 3D TV Discussion Paper Submission
1 Introduction
MAA makes this submission in response to the Australian Communications and Media Authority’s (ACMA) ‘Temporary trials of 3D TV and other emerging technologies’ Discussion Paper. In particular, MAA is responding to the following invitation for comment:
8. The ACMA invites broadcasters and other interested parties to nominate new radio-communications technologies apart from 3D TV for which they might consider conducting trials using temporarily available BSB spectrum.
In particular, MAA is focused on the need for spectrum to be made available for trials of open and closed audio description (AD) on digital television in Australia before analog switch-off.
1.1 Comment on the Discussion Paper
In ‘Other uses of available spectrum’, the Discussion Paper notes the following (p 21):
Audio description technology refers to technical systems which carry additional information broadcast in conjunction with standard television programming for use by viewers who may be visually impaired. To the extent that broadcasters wish to test audio description technologies without impacting on existing services, additional spectrum may be required.
MAA offers that the following issues must be taken into account by the ACMA in determining the allocation of available spectrum—and, in particular, the allocation of Channel B for temporary and extended trials:
a) The international experience of AD and trials thereof;
b) The Commonwealth’s commitment to a trial of AD on the ABC;
c) The likely commitment by the Commonwealth to impose AD targets on broadcasters post analog switch-off;
d) The additional spectrum requirements of AD;
e) The merits and drawbacks of both open and closed AD;
f) The prevalence of AD-enabled equipment which consumers currently possess; and
g) The need to test existing AD technologies.
2 The context of trials of audio description in Australia
2.1 Australia
Audio description in Australia is currently restricted to some theatrical performances (which are described by volunteers coordinated by Vision Australia), DVDs and cinema.
2.1.1 DVDs
Most of the audio description on DVDs released in Australia has been produced overseas. Roadshow is the only Australian distributor to regularly release local titles with AD, which is produced by Red Bee Media Australia and the SubStation.
In 2005, Red Bee Media (then the Australian Caption Centre) was awarded a one-off grant by the then Department of Family and Community Services and Indigenous Affairs (FaCSIA) to investigate audio description, acquire the necessary software and equipment to do it, and produce 10 audio described DVDs.
As of July 2010, 33 percent of DVD titles on new release shelves had audio description. No special equipment is needed to access the AD on DVDs.
2.1.2 Cinema
In June 2008, the Commonwealth Government announced a one-off grant, administered by MAA, which paid for the digital theatre system (DTS) to be installed in 12 independent cinemas around Australia. The DTS allows for the delivery of audio description via disk, and is heard by patrons through headphones.
Earlier this year, Australia’s four major cinema groups, Hoyts, Village, Greater Union Birch Carroll & Coyle, and Reading, agreed with the Federal government to jointly fast-track new audio description and captioning technology as part of a plan to improve cinema access. Audio description will be available in 132 locations, on a minimum of 242 screens, by the end of 2014. In addition, all new cinemas constructed by the four groups will contain accessible technology.
The AD files for these cinema screenings are sourced from overseas.
Currently, Screen Australia’s funding requirements for movies include a provision in their budgets for the production of caption files for cinema screenings and DVD release. There is as yet no requirement to provide AD.
2.2 United Kingdom
Audio description in the UK is governed by the Communications Act 2003 (the Act). The Act outlines a broad framework of how access should be regulated and establishes minimum requirements. It also legislates that Ofcom can create a code for promoting access to television for blind and visually impaired people and the means by which this will occur. This code, ‘The Code on Television Access Services’[1], is the primary means of regulating AD in the UK. Section 304 of the Act ensures that blind people are involved in the consultation process over changes to the regulations.
In 2006, Ofcom noted that, while there was a significant amount of audio description on digital channels, independent research found that only 43 percent of the potential audience knew about the service. To rectify this, Ofcom worked with the Royal National Institute of Blind People (RNIB) and broadcasters to determine the best ways to publicise the service. This resulted in an Audio Description Awareness Campaign, which ran for six weeks and ended on 14 March 2008. This saw AD promoted on more than 70 stations across the UK. It also introduced an Audio Description logo devised by RNIB which is now used in program promotions, and by set-top box manufacturers to identify digital TVs and set-top boxes that are able to access AD. Research after the campaign ended found that awareness among the blind and vision impaired rose from 43 to 72 percent, and from 37 to 60 percent among the overall population. Almost all users of audio description found that it improved their understanding and enjoyment of television.
Section 8 of The Code outlines the relevant targets for audio description. These are fixed against a relevant date which is primarily defined in relation to the the commencement of broadcasting. The targets are 2 percent in the first year, increasing by increments of 2 percent so that after the fifth year, 10 percent of programs need to be audio described.
The Code specifies some exemptions. Section 11 excludes services with an audience share of less than 0.5 percent. Section 18 excludes programs where there are technical difficulties. Two of these are in relation to languages other than English. The other relates to programs where, because of the high content of contextual sound (speech or lyrical music), audio description would be problematic.
A broadcaster only needs to provide access services up to a total cost of 1 percent of their annual turnover. Furthermore, if it cannot afford one third of its target (based on a 1 percent cost analysis) it will be exempt from the provisions altogether.
The Code specifies that it would be expected that Audio Description would be on programs in prime viewing time, but that programming decisions would need to be made in consultation with deaf and blind groups. The code is positive in that it urges broadcasters not to fulfil their quotas through constant repeats of programs.
In 2010, after conducting a review of access provisions, Ofcom announced that it would not be increasing the maximum amount of AD expected of stations from 10 percent. (Some organisations including the RNIB had been lobbying for an increase to 20 percent.) However, some channels are doing more than 10 percent, including BBC channels and Channel 4 and its affiliates (which recently committed to 20 percent). A wide variety of programs are audio described, including Neighbours and Home & Away.[2]
2.3 New Zealand
In August 2010, NZ On Air, the government agency that funds captioning services in New Zealand, announced a NZ $500 000 audio description trial on digital television that will commence in 2011.
This trial will provide a closed, broadcast-mixed audio description service, and new Freeview integrated sets and Freeview digital set-top boxes will incorporate the ability to decode and play the audio description (which will be on a second audio channel). Some older Freeview sets may be able to be upgraded.
According to NZ On Air, the initial service is expected to be on TV One and consist of imported description.Description of local programming has been identified as a future priority.
2.4 United States
Audio description for television is known as ‘video description’ in the US. In July 2000, the Federal Communications Commission (FCC) ordered the four big television networks and the five biggest cable networks to show 50 hours of audio described programs per quarter by April 2002. The FCC’s power to do this was challenged by the Motion Picture Association, and the challenge was eventually upheld. By then, the networks were meeting the quota, and some continue to do so (although Fox is the only one to officially commit to that).
In January 2008, Congressman Ed Markey of Massachusetts released a draft bill, the Twenty-first Century Communications and Video Accessibility Act, which aims to greatly increase the levels of access, and in particular access on Internet-based services, in the United States. One of its provisions is that the FCC’s rules regarding minimum amounts of audio description will be reinstated, and the amounts will be increased. In addition to this, all digital television technologies and equipment will have to accommodate audio description. Onscreen emergency warnings and similar televised information will require non-visual access.
On 5 August the US Senate passed the latest version of the bill, the Twenty-first Century Communications and Video Accessibility Act of 2010, by unanimous consent. On 28 August, the House of Representatives passed the bill with a vast majority.
AD was delivered on analog television via a secondary audio channel (called the Second Audio Program or SAP), and many analog televisions and VCRs were able to receive it. Since analog switch-off took place across America in June 2009, AD has been in a state of limbo. No legislation was introduced to ensure that digital broadcasters transmit AD as a secondary channel, and no standard for receiver manufacturers was developed. Although there is anecdotal evidence that some digital receivers (including some subscription television converter boxes) are capable of receiving AD, the situation remains far from clear.
AD in the US is broadcast-mixed.[3]
2.5 Canada
Since 2001, the CRTC (Canadian Radio-Television and Telecommunications Commission) has required an audio description commitment before it renews broadcasting licenses (usually two hours per week in Year 1, three hours in Years 2 to 4, and four hours to Year 7).
Canada also has The Accessible Channel, which was launched in December 2008, and is the first and only fully audio described television channel in the world. The channel, which is available on all cable and satellite services, broadcasts a mix of programs, including movies, drama, news programs and children’s programs, which are sourced from the main television networks. The AD is ‘open’—anyone who switches to the channel will hear it.