ACA: Limit IP Closed Captioning Rules to OTT Distributors

The American Cable Association (ACA) again urged the Federal Communications Commission (FCC) to adopt new closed captioning rules that will create a light-touch implementation program for Internet Protocol-delivered programming. ACA’s threshold recommendation is that the FCC apply the new IP captioning requirements only to online video programming providers and distributors that use IP to distribute programming over the Internet. The FCC should exclude from these additional captioning requirements cable operators that use IP to deliver traditional cable subscription services or to add online programming enhancements to their cable services within their cable network footprint, added the ACA.

Under the Twenty-First Century Video Accessibility Act (CVAA), Congress expanded closed captioning mandates to include video programming once published or exhibited on TV and delivered using IP. Consistent with current law and FCC rules in place since 1997, ACA members pass through all closed captioning data that is made available with programming and also ensure that set-top equipment is compatible so that consumers can enjoy captioned programming. Current FCC closed captioning mandates apply to cable services regardless of the distribution technology.

ACA said that limiting the sweep of the IP closed captioning obligations to video programming distributed over the Internet – online – is the most natural and reasonable interpretation of the law; will avoid needless confusion over which captioning rules apply to cable operators using IP to distribute video programming to their subscription TV customers; and will avoid imposing unnecessary burdens on smaller providers.