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Topic: DOJ proposes requiring closed captions and audio description

Harold Hallikainen
Jedi Master Film Handler

Posts: 906
From: Denver, CO, USA
Registered: Aug 2009

posted 07-26-2014 01:42 PM

http://www.ada.gov/regs2014/movie_nprm_index.htm

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Aaron Garman
Phenomenal Film Handler

Posts: 1470
From: Toledo, OH USA
Registered: Mar 2003

posted 07-26-2014 03:04 PM

Here is the text:

quote:
On July 23, 2014, the Attorney General signed the Department's Notice of Proposed Rulemaking (NPRM) proposing to amend the Americans with Disabilities Act title III regulation to provide closed movie captioning and audio description to give persons with hearing and vision disabilities access to movies. Closed movie captioning refers to captions that are delivered to the patron at his or her seat and are visible only to that patron. Audio description enables individuals who are blind or have low vision to enjoy movies by providing a spoken narration of key visual elements of a movie, such as actions, settings, facial expressions, costumes, and scene changes. Audio description is transmitted to a user's wireless headset. The Department is proposing to provide a consistent nationwide standard for movie theaters to exhibit movies with closed movie captioning and audio description for all showings of movies that are available with closed movie captioning or audio description. This proposed rule would impose no independent obligation on movie theaters to add captions or audio description to movies that are not already available with those features.

Title III of the ADA requires movie theaters and other public accommodations to provide effective communication through the use of auxiliary aids and services. This rulemaking specifies requirements that movie theaters will need to meet in order to satisfy their effective communication obligations to persons with hearing and vision disabilities. For a summary of the NPRM and its requirements, see the "Questions and Answers about the Department of Justice's Notice of Proposed Rulemaking Under Title III of the ADA to Require Movie Theaters to Provide Closed Movie Captioning and Audio Description."

The Department anticipates that the proposed regulation will be published in the Federal Register within the next few weeks. At that time, the public will be able to begin to submit public comments either on the regulations.gov website, or by mail. The comment period will be open for sixty days beginning on the date of publication in the Federal Register. The Department encourages the public to review the NPRM and submit comments. This webpage will be updated to contain a link to regulations.gov when the NPRM is published.

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Lyle Romer
Phenomenal Film Handler

Posts: 1400
From: Davie, FL, USA
Registered: May 2002

posted 07-26-2014 04:11 PM

I have never understood why this stuff is part of the ADA. A movie is made of audio and video. If you are blind or hearing impaired, I feel bad for you but you can't possibly experience a movie the way it was intended.

The closed captioning and hearing impaired devices are bad enough in that they force exhibitors (in the case of CC might in the future) to spend money on something for a very small percentage of people but the descriptive audio is taking it WAY too far.

It is a movie, not a radio show. Will stores have to provide employees to give blind people guided tours? What about theme parks?

Even the amount of handicapped seating required is more than what is needed. Back in the early 90's I worked in a GCC location that had a very high percentage elderly audience. This demographic would have a disproportionately high number of people in wheelchairs. Never once (and we sold a lot of weekend shows out) did we ever have more than 2 wheelchair bound patrons in the same showing and even having 2 was VERY rare.

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Harold Hallikainen
Jedi Master Film Handler

Posts: 906
From: Denver, CO, USA
Registered: Aug 2009

posted 07-26-2014 04:25 PM

There's also a 130 page pdf which is the actual notice of proposed rulemaking.

They are inviting comments (after it's published in the Federal Register).

FilmTech users may want to submit comments.

They are proposing a required number of closed caption and descriptive audio receivers. You may want to submit comments on the actual usage of hearing impaired receivers.

Note also that they are proposing equipment be installed in digital auditoriums 6 months after the effective date of the rule. FT users may also want to comment on this.

Harold

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Steve Guttag
We forgot the crackers Gromit!!!

Posts: 12814
From: Annapolis, MD
Registered: Dec 1999

posted 07-26-2014 05:16 PM

Thanks for the info Harold!

I've always held that it was a poorly written law to begin with. A private space with public accommodation should not be forced to take on each and every new technology nor have to contend with each and every form of disability.

A more reasonable law would have only put an obligation on the business to provide transmission of these signals on federally regulated frequencies/carriers.

The receiving part should ALWAYS have been on those that are disabled. If you have hearing loss...that does not mean that you just have a problem that all levels are low...you may have particular frequencies that are deficient. You will have hearing aids to compensate for that. It would be better if the listening device also worked with that. In this manner, even if you are in a shopping mall and a life-safety device (fire alarm) went off...if there is an emergency message your hearing aids would be able to work with that too.

They should set up the frequencies protected for ADA uses and just require theatres (and other equivalent spaces) to broadcast the HI, VI-N and CC on said frequencies and that would be the end of the theatre's obligation. The cost would be minimal.

At that point, you no longer are handing out devices to people, there is no longer a sanitary issue, battery issue, programming issue...etc.

And if you are disabled and have your own device, you could then expect it to work in any theatre (or like space).

I don't think you'll get much blow-back from the theatre to put up an IR panel (could have issues with RF running out of frequencies in a larger plex). Come up with a suitable IR meter to test that you have sufficient level/coverage and you are done.

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Justin Hamaker
Film God

Posts: 2253
From: Lakeport, CA USA
Registered: Jan 2004

posted 08-06-2014 12:34 AM

I haven't seen the full text, but apparently there is an exemption for drive-in theatres because there is not a reliable technology available, and the limited number of theatres limits the financial incentive for R&D - especially with closed captioning. While there are ways to work around the issue, any drive-in that says they have CC or VIN, is setting themselves up for a lawsuit if it can not be reliably delivered to every customer. Which is very likely in a drive-in situation since you have many more variables which are not within the control of the theatre.

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Harold Hallikainen
Jedi Master Film Handler

Posts: 906
From: Denver, CO, USA
Registered: Aug 2009

posted 08-06-2014 11:39 AM

I've read the 130 pages of the NPRM. They do propose an exemption for drive-ins (their definition of a "movie theater" excludes drive-in theaters). I do not believe any of the current closed captioning systems would work reliably in a drive-in. I did see a demo of one system that was an application for a handheld device (phone, etc.). The user downloaded the captions ahead of time. The system synced the captions based on the audio picked up by the microphone on the device. Interesting idea. A similar technique is used by My Lingo to provide the sound track in a different language.

The current NPRM deals only with closed captioning and descriptive audio. Since most drive-ins are using RF transmitters to reach the audience car radio (or a theater supplied broadcast radio), it seems that an additional transmitter could be added to transmit the descriptive audio. But, under the current proposal, drive-ins are exempt.

Harold

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Marcel Birgelen
Film God

Posts: 3357
From: Maastricht, Limburg, Netherlands
Registered: Feb 2012

posted 08-06-2014 01:39 PM

I haven't read that 130 page document, but I was wondering how this "descriptive audio track" is supposed to work with foreign language films with subtitles..?

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Harold Hallikainen
Jedi Master Film Handler

Posts: 906
From: Denver, CO, USA
Registered: Aug 2009

posted 08-06-2014 04:17 PM

Well, that's interesting... I guess that they could tell you the action on the screen AND read the subtitle to you. The DOJ NPRM deals only with exhibition (places up public accommodation) and not with the production side (though there are various settlements between the DOJ and the production side that encourages the inclusion of closed captions and descriptive audio).

Harold

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Carsten Kurz
Film God

Posts: 4340
From: Cologne, NRW, Germany
Registered: Aug 2009

posted 08-06-2014 07:22 PM

Harold,

there is a german smartphone app available for free that plays audio description or subtitles on the device. Same sync mechanism as Lingo. It works pretty good technically, and is of great value IF the audio description is done properly. Some I tested were good, some not so good. As with mylingo, you need to download the neccessary sync/content file before using it, either through WIFI or 3G (goes pretty fast).

http://www.gretaundstarks.de/

The subtitles app of course, is a bit of a problem in it's current implementation, as it needs the smartphone to be held towards your face during the movie (whereas most cinemas have a more or less strict 'no-smartphone-use' policy). They are working on an affordable electronic glasses option to be connected to the smartphone to overcome that.
The VI/audio description app can be put back into your pocket once synced and running, needs no further attention.

I think MyLingo has a real problem in that they need/play localized audio tracks from offline sources while the movie is running in cinemas - I doubt many studios will allow this because it's the perfect way to make localized pirate copies, adding localized audio tracks to existing pirated video copies on the internet.

I know that a smaller high profile cinema chain in germany sometimes offers special versions of some movies remastered with dual language audio tracks. That is, they use a single DCP with added foreign language dialog and play this over the HI/VI system, so the audience may choose which language to listen too, or simply listen into the original language version actors voices from time to time. Not cheap, of course, and not availabe for every feature.

BTW - currently, Germany imposes no legal obligations to install HI/VI equipment in cinemas, but all movies applying for production grants here now need to supply HI/VI tracks in order to receive these grants. There is public founding available to cinemas for the installation of equipment.

A new system just launched is Sennheiser cinema connect, it is similiar to their existing systems, using a local source (e.g. cinema processor) for HI/VI tracks, but transmitting over WIFI in realtime to audience smart phones, like a local streaming service.

http://www.sennheiser-connect.com/index_en.html

Benefit again is that the listening device is brought in by the patrons, no charging, setting up, no sanitizing, patrons will always be familiar with the device/app and can use it in any cinema they want.

- Carsten

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Harold Hallikainen
Jedi Master Film Handler

Posts: 906
From: Denver, CO, USA
Registered: Aug 2009

posted 08-06-2014 10:27 PM

Thanks for the links! I had heard of the Sennheiser system. It seems like it'd be difficult to get lip sync for HI over Wi Fi, but I assume they've done it. For debugging, USL provides a web interface where captions are presented in real time. The interface also shows the current edit unit number, TimeIn and TimeOut of the next caption, playout ID, amount of data in the different buffers, etc. This could also be sent to audience members, though you'd then have lit screens (through we do white text on black) plus a bunch of cameras pointing at the screen. So, Wi Fi captions are doable, if desired. VI, since it does not need lip sync, also seems quite doable. HI seems more difficult.

Again, thanks for all the details on these systems!

Harold

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Marcel Birgelen
Film God

Posts: 3357
From: Maastricht, Limburg, Netherlands
Registered: Feb 2012

posted 08-08-2014 01:48 AM

quote: Harold Hallikainen
Well, that's interesting... I guess that they could tell you the action on the screen AND read the subtitle to you.

Yeah, that sounds like a real "exciting" way of "enjoying" a movie... [Wink]

It reminds me of those horrible dubs on some Russian TV channels, where one or two people (usually a woman and a guy) dub all the voices and you can still hear the original actors voices on the background.

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Randy Stankey
Film God

Posts: 6539
From: Erie, Pennsylvania
Registered: Jun 99

posted 08-08-2014 07:30 AM

You know... This sounds like a perfect application for something like Google Glass.

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Harold Hallikainen
Jedi Master Film Handler

Posts: 906
From: Denver, CO, USA
Registered: Aug 2009

posted 08-08-2014 07:44 AM

Like this ?

Harold

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Randy Stankey
Film God

Posts: 6539
From: Erie, Pennsylvania
Registered: Jun 99

posted 08-08-2014 02:25 PM

Cute!

But, yeah, something like that.

I don't know everything about how Glass works... Just theorizing...

The camera could track the screen or the wearer's movements and keep the subtitles or descriptions superimposed at the right place on the screen.

I assume that the camera will be able to pick up infrared as most solid state cameras can. That would allow Glass to use a series of IR LEDs, placed at strategic points on the borders of the screen to calculate the viewer's position in the theater and distort/transform the text to fit the screen.

Subtitle text could be sent via whatever wireless system Glass uses and and the same IR LEDs used for tracking could be pulsed in order to send codes for synchronizing the text to the picture.

Then, as a bonus, those flickering LEDs would also serve to foil any attempts at recording the movie, either with Glass or any other camera, for that matter.

I don't know if this would actually work but it's an idea.

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