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Author
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Topic: DOJ May Require Closed Captioning
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Jim Cassedy
Phenomenal Film Handler
Posts: 1661
From: San Francisco, CA
Registered: Dec 2006
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posted 07-26-2010 09:12 PM
I got this info from Gary Meyer, co director of the Telluride
Film Festival and operator of The Balboa Theater here in San Francisco.
But it might be of interest to all.
At this time, it is only a "Notice OF Proposed Rule-Making"
but it could have future implications, especially for smaller
theater operators. -JC-
Subject: July 23, 2010 US DoJ ANPRM
Date: Monday, July 26, 2010, 3:33 PM
Dear Member,
As you might have heard or read, this past Friday, July 23, 2010, the US Department of Justice (DOJ) issued an Advanced Notice of Proposed Rulemaking (ANPRM) that contains four components; two of which have general business applications and one of which has direct impact on the exhibition industry – captioning and video description. The Department of Justice (DoJ) has requested comments to be submitted. Below is a recap of the proposal, paraphrasing the federal announcement.
The DoJ is providing advance notice that it is considering whether to propose revising the title III regulations to require movie theatre owners and operators to show movies with closed captions and video description in their theatres at least fifty percent (50%) of the time. The purpose of the notice is to discuss how best to frame such a requirement and to determine the costs and benefits of any such requirement.
The DoJ is asking:
(1) what is the appropriate basis for calculating the number of movies that will be captioned and video described and how should any requirement be phased in;
(2) what is the status of any conversion to digital cinema;
(3) what standards and technologies exist or are in development for captioning and video description;
(4) what are the costs and benefits of movie captioning and video description; and
(5) what impact will such requirements have on small businesses?
The DoJ is also specifically soliciting comments on whether movie theatre owners and operators should be encouraged to screen movies with open captions, even though the DoJ is not considering requiring open captions, as an alternate way to achieve compliance with any regulation, whether certain categories of movie theatre owners and operators should be exempt from any regulation, and whether there should be notification and training requirements included in any regulation. Written comments must be postmarked and electronic comments must be submitted on or before January 24, 2011.
Also, the DoJ is considering rules regarding several areas of concern where individuals with disabilities may face barriers due to inaccessible equipment or furniture. Key areas of concern relative to the exhibition industry include electronic and information technology, including POS devices, kiosks, and ATMs.
Finally, the DoJ is seeking information regarding what standards, if any, it should adopt for website accessibility, whether the Department should adopt coverage limitations for certain entities, like small businesses, and what resources and services are available to make existing websites accessible to individuals with disabilities. The DoJ is also soliciting comments on the costs of making websites accessible, whether there are effective and reasonable alternatives to make websites accessible that the DoJ should consider permitting, and when any Web accessibility requirements adopted by the DoJ should become effective.
The National Association of Theatre Owners (National NATO) in Washington DC is planning to work with the Association’s Captioning Task Force, Committee of Counsel, and the Executive Board to develop a comprehensive response.
If you would like to have any additional information please let me know.
Milt Moritz
NATO of California/Nevada
310-460-2900
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