Broadcasting - Staff Letter adressed to the Distribution List

Ottawa, 18 December 2023

Our reference: CRT 1013-1

BY E-MAIL

Distribution List

Subject: Request for information – Closed captioning of audio-visual programs

On April 27, 2023, the Online Streaming Act^Footnote1 received Royal Assent, marking the first significant amendment to the Broadcasting Act since 1991. The Broadcasting Act outlines Canada’s broadcasting policy and defines the role of the Canadian Radio-Television and Telecommunications Commission (CRTC). The Broadcasting Act is a key instrument in supporting Canada’s creative industries and ensuring that Canadian music and stories are widely available and accessible.

The Online Streaming Act modernizes the Broadcasting Act to bring online undertakings within its scope.^Footnote2 It also amends Canada’s broadcasting and regulatory policies to ensure that programming that is accessible without barriers to persons with disabilities be provided within the Canadian broadcasting system, including closed captioning services to assist persons who are Deaf or hard-of hearing.^Footnote3 

Closed captioning is distinct from subtitles. Closed captioning is intended for viewers who cannot hear the audio. Not only does it display what is being said, but it provides additional contextual information for the viewer by describing who is speaking, what music is playing, and other audible cues.  Subtitles, on the other hand, assume the viewer can hear what is happening on-screen, but the dialogue is difficult to understand (either because it is in a different language, or is obscured in some way). The amended Broadcasting Act is an opportunity to modernize the CRTC regulatory framework on closed captioning.

In light of this, we would like to learn more about your organization's current closed captioning policies and practices. Enclosed within this letter is Appendix 1, containing a set of questions about closed captioning. We kindly request your response to these questions by 31 January 2024.

Procedural information

When submitting your response electronically via the secured service “My CRTC Account” (using Partner Log In or GCKey), please use reference number CRT 1013-1 to ensure efficient processing of your submission. We also ask that you repeat each question in your reply.

This letter and all subsequent correspondences will be made available on the CRTC website and may be included in the public record of future CRTC public proceedings.

Should certain information be deemed confidential under Broadcasting and Telecom Information Bulletin 2010-961, an abridged version of the response must be provided, along with a detailed explanation of why the information's disclosure is not in the public's interest.  It is important to note that the CRTC may disclose or request the disclosure of information deemed confidential, provided that its release is in the public interest. This means that if the potential harm caused by the disclosure is outweighed by the public's interest, the CRTC may disclose confidential information in accordance with its standard practices.

As set out in paragraph 102 of Broadcasting and Telecom Information Bulletin CRTC 2010-959 the Commission's proceedings are intended to allow the public to provide input to help the Commission make better, informed decisions. Therefore, the general rule is that all information submitted to the Commission is placed on the public record and is available for review by all parties and the public. In keeping with this principle, CRTC staff expect parties to disclose information to the fullest extent possible. Additionally, the Accessible Canada Act promotes the removal of barriers for people with disabilities, ensuring full and equitable access. As such, Commission staff encourage parties to disclose information to the fullest extent possible.

Moreover, all documents submitted in response to this request are to be in a file format that can be accessed by those who are blind or partially sighted. This includes formats that allow for text to be enlarged or modified, or that can be read by a screen reader, such as MS Word.  For guidance on creating accessible documents, please refer to the resource "Creating Accessible Documents."

Please use the following naming convention when submitting your document(s):

• For a single document: "Company Name - Brand Name (if applicable) – Closed captioning – Reference #CRT 1013-1 - Response - Language (FR/EN) - Date (YYYY-MM-DD)"
• For multiple documents: "Company Name - Brand Name (if applicable) – Closed captioning – Reference #CRT 1013-1 - Response - Title of Document (e.g., Cover Letter, Appendix, etc.) - Language (FR/EN) - Confidentiality Status (Abridged/Confidential, if applicable) - Date (YYYY-MM-DD)"

If you require any additional information or have further questions, please feel free to contact us at engagement@crtc.gc.ca. We would be happy to assist you in any way possible.

Yours sincerely,

Nanao Kachi (he, him)
Director, Social and Consumer Policy
CRTC

Appendix 1: Closed captioning – Questions for online undertakings and traditional television broadcasters

1. Questions for Canadian and non-Canadian online undertakings

Pre-recorded programs:

1. What percentage of your pre-recorded programs are closed captioned?  English-language programs? French-language programs?
2. Is it standard practice to purchase the rights to or acquire programs with closed captioning included, if available? If not, why not? 
3. Is closed captioning always provided for original programs? If not, why not? 
   1. If yes, what closed captioning method is employed (e.g. stenographers, voice recognition, a combination thereof)?
4. How do you assess the quality of closed captioning for your pre-recorded programs?
   1. Do you have internal reports assessing the accuracy of closed captioning for pre-recorded programs? 
   2. If yes, how often are these assessments completed? 
   3. Submit copies of your two latest closed captioning quality assessment reports for pre-recorded programs.
5. Are there any obstacles that prevent you from providing closed captioning of pre-recorded programs?

Live programs (if applicable):

6. What percentage of your live programs are closed captioned? English-language programs?  French-language programs?
7. What closed captioning method is employed for live programs (e.g. stenographers, voice recognition, a combination thereof)?
8. How do you assess the quality of closed captioning for live programs?
   1. Do you have internal reports assessing the accuracy of live closed captioning? 
   2. If yes, how often are these assessments completed? 
   3. Submit copies of your two latest closed captioning quality assessment reports for live programs.
9. Understanding that there are challenges to closed captioning live programming, if programming originally aired live with closed captioning is re-broadcast at a later time, is the closed captioning corrected? If not, why not?
10. Are there any obstacles that prevent you from providing closed captioning for live programs?

Information and complaints related to captioning:

11. Where can viewers find information related to closed captioning and accessibility features in general? 
12. How can viewers provide feedback or concerns about accessibility features?
13. How many complaints have you received related to the closed captioning over the last three years? 
14. Provide a breakdown, for both English-language and French-language programs, of the percentage of complaints related to:
    1. the availability of closed captioning for pre-recorded programs;
    2. the availability of closed captioning for live programs;
    3. the quality of closed captioning for pre-recorded programs; and
    4. the quality of closed captioning for live programs.

15. How do you address the concerns raised in complaints related to closed captioning

Consultation with the Deaf and hard-of-hearing communities

16. Do you hold regular consultations with Deaf or hard-of-hearing viewers or associations regarding the provision of closed captioning? 

2. Questions for traditional Canadian television broadcasters

17. What percentage of your overnight programming is closed captioned? English-language programs? French-language programs?
18. How many complaints have you received related to the closed captioning of your programming over the last three years? English-language programs? French-language programs?
19. Provide a breakdown, for both English-language and French-language programs, of the percentage of complaints related to:
    1. the availability of closed captioning for pre-recorded programs;
    2. the availability of closed captioning for live programs;
    3. the quality of closed captioning for pre-recorded programs; and
    4. the quality of closed captioning for live programs.

Date modified:

2023-12-18