ARCHIVED - Broadcasting Commission Letter addressed to the Distribution List

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Ottawa, 15 May 2019


Distribution List 

Our reference: Public Notice 2019-9

Public record: 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 23 May 2019

Madam, Sir,

This letter sets out questions for the parties to this proceeding, the Canadian Broadcast Standards Council (CBSC) and Dr. Romero-Fresco. Footnote1 Answers are requested to the Commission by 23 May 2019.


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 (NoC 2019-9). The deadline for initial comments was 18 March 2019 and for replies 2 April 2019.

This letter sets out questions related to the current record for NoC 2019-9:

All parties, the CBSC and Dr. Romero-Fresco are requested to reply by 23 May 2019. Parties to the proceeding may file reply comments to Dr. Romero-Fresco’s response (to the questions set out in Appendix 3) no later than 29 May 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,

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 all parties

On 10 May 2019, the Canadian Broadcast Standards Council (CBSC) responded to a Commission staff Request for Information regarding the possible role of the CBSC in the NER Footnote3 evaluator certification process.  The CBSC response is attached, for ease of reference.

If the CBSC was involved with or responsible for overseeing the certification process for NER evaluators, do you see any issues with what is being proposed in the CBSC response? Please comment on them.

Appendix 2 - Questions for the Canadian Broadcast Standards Council

If the CBSC was involved with or responsible for overseeing the certification process for NER evaluators, do you envision that the Advisory Panel would also adjudicate complaints related to the accuracy of live, English-language closed captioning?

Appendix 3 - Questions for Dr. Pablo-Romero Fresco, developer of NER Model

In paragraph 14 of its reply comments dated 2 April 2019, Canadian Association of Broadcasters/Canadian Broadcasting Corporation (CAB/CBC) submitted that “Broadcasters can ensure the NER model is consistently applied by having their evaluators certified through LiRICS.  We see no need to create a new body or to task the CBSC, which has no expertise in this area, with this role.  There is an established approach that Canadian broadcasters and Canadian captioning companies can benefit from” (emphasis added).

Staff notes that the Commission is currently reviewing the possibility of implementing a slightly modified version of the international NER Model, to be known as the Canadian NER Model, which has been adapted to suit Canadian circumstances.

In light of the above, please comment on feasibility and willingness of LiRICS to:

  1. Take on added inquiries/requests from the Canadian market; and
  2. Train and/or certify evaluators for the Canadian NER model?
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