ARCHIVED - Broadcasting Commission Letter addressed to the Distribution List

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Ottawa, 4 April 2019


Distribution List 

Our reference: 1011-NOC2019-0009

Re: Proceeding regarding the English-language closed captioning quality standards relating to the accuracy rate for live programming– Request for Information by 12 April

Madam, Sir,

This letter sets out questions for the Canadian Broadcast Standards Council (CBSC) and Dr. Pablo Romero-Fresco. Answers are requested to the Commission by 12 April 2019.

Commission staff notes that the CBSC and Dr. Romero-Fresco are not parties to this proceeding as they did not file interventions. Nevertheless, given that this proceeding concerns the appropriateness of adopting the NER Footnote1 model developed by Dr. Romero-Fresco and that one of the intervenors has made a proposal that the CBSC should be involved in the certification of NER evaluators, Commission staff is issuing this request to seek their views.


On 16 January 2019, the Commission published Call for comments regarding the English-language closed captioning quality standards relating to the accuracy rate for live programming. The deadline for initial comments was 18 March 2019 and for replies was 2 April 2019.

This letter sets out questions related to the initial and reply comments received at the Commission:

The CBSC and Dr. Romero-Fresco are requested to reply by 12 April 2019. Parties to the proceeding may file reply comments to these responses no later than 18 April 2019. Footnote2

Procedures for filing

Responses to these requests for information must 1) refer to the file number noted above, and 2) be sent to the Secretary General of the Commission via My CRTC Account (at the following link: using GCKey. GCKey allows you to securely access the Government of Canada’s online services and conduct online business.

For further information on how to submit your response, see the CRTC’s web page Submitting applications and other documents to the CRTC using My CRTC Account.

All submissions are to be made in accordance with the Canadian Radio-television and Telecommunications Commission Rules of Practice and Procedure, SOR/2010-277. As set out in Broadcasting and Telecom Information Bulletin 2010-961, Procedures for filing confidential information and requesting its disclosure in Commission proceedings, parties may designate certain information as confidential. Parties must provide an abridged version of the document involved, accompanied by a detailed rationale to explain why the disclosure of the information is not in the public interest.

Should you have any questions, please contact Jennifer Porteous, Senior Analyst, Social and Consumer Policy, at

A copy of this letter and all related correspondence will be added to the public record of the proceeding.

Yours sincerely,

(Original signed by)

Nanao Kachi
Director, Social and Consumer Policy

Distribution list

2016 Working group;;;;;;;;;;;
Canadian Broadcast Standards Council
Dr. Pablo Romero-Fresco;
Wendy Randall
Marc Bonhomme
Henge Design
Canadian Hard of Hearing Association
Keeble Media Inc.
Ai media
Closed Caption Services (
Media Access Canada
Canadian Association of the Deaf / Association des Sourds du Canada /
Northern Alberta Institute of Technology
National Captioning Canada /
The Captioning Group
Sasha Willson
English-Language Local Independent Television Stations Group

Appendix 1 - Questions for the Canadian Broadcast Standards Council

  1. In its initial submission, Keeble Media Inc. (KMI) proposes that the Canadian Broadcast Standards Council (CBSC) be the body that oversees the certification of NER evaluators.  Paragraph 9 (a) to (d) of KMI’s submission specifically says:

    “9. …KMI proposes the following:

    1. The process of certification for evaluators to be used in the regulatory standards process should be overseen by the Canadian Broadcast Standards Council (CBSC) a body that has been trusted for many years by the Commission to administer various broadcast standards.
    2. With the CBSC present, the process does not need a new organization to manage certification, but the CBSC should convene a new advisory panel to guide it in this area. This panel should include representatives of caption consumers, broadcasters, and possibly Dr. Romero-Fresco or a group identified with him, as it will need expert advice from a neutral party, and it is desirable that Canadian NER remain compatible with NER as the model is used around the world.
    3. The CBSC would not itself conduct training and certification, but would approve other parties, on application, to conduct certification. Training might take place anywhere, as it is KMI’s understanding that some Canadian educational institutions may offer NER evaluation training as a part of other courses, but certification for Canadian regulatory purposes could only be undertaken by CBSC approved groups.
    4. The CBSC would also maintain a list of certified Canadian NER evaluators for use by interested parties.”
    • Please comment on the feasibility and appropriateness of KMI’s proposal.

Appendix 2 - Questions for Dr. Pablo Romero-Fresco, developer of NER Model

  1. It is our understanding that you are the developer of the NER Model and that the evaluators used during the trial conducted by the 2016 Working Group were either certified by you or by a Canadian evaluator approved by you. (Please see paragraph 12 of the 2016 Working Group proposal which is linked in paragraph 6 of Broadcasting Notice of Consultation CRTC 2019-9 for the reference)
    • In your experience, please comment on:
    1. what it costs to certify an NER evaluator, including if those costs changed or are they likely to change in the near future;
    2. how long it takes to certify an NER evaluator;
    3. can certification be done remotely or online;
    4. is the certification permanent or for a fixed term, is there a further cost or further training to renew or maintain certification; and 
    5. if you believe that a central certification body is necessary and do you believe that broadcasting and captioning companies are capable of training their staff to become effective and efficient NER evaluators?
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