How to file a captioning complaint with the Federal Communications Commission

The Federal Communications Commission (FCC) encourages feedback from television viewers. According to the FCC, a complaint is a form of feedback, and the Commission wants feedback from viewers. Any television viewer who cares about captioning quality is encouraged to file a complaint whenever they see poor captioning, and you can easily file a complaint from the fcc.gov website.

Many television stations are now using machine captioning as opposed to human captioning or simply the teleprompter. Several companies provide machine captioning to the television stations. These companies and their products are IBM (Watson), ENCO (enCaption3 and 4),  Link (ACE Encoders), and EEG (Lexi).

To file a complaint, we suggest you focus on accuracy, which is one of the four tenets of captioning quality established by the FCC in 2014 (the others are synchronicity, completeness, and placement).

To be accurate, captions must reflect the dialogue and other sounds and music in the audio track to the fullest extent possible based on the type of the programming. Accuracy also requires captions to identify the speakers. We find that automatic captioning violates this standard in many ways:

  • Punctuation: Machine captioning provides limited, or wrong, punctuation.
  • Speaker identification: Machine captioning does not identify speakers with >> or names, often including captions from multiple speakers in the same line.
  • Lyrics and Sound Effects: The FCC Caption Quality best practices clearly state that lyrics and sound effects much be included when measuring accuracy. Engines don’t.
  • Proper Nouns:  Proper nouns are a problem with many engines, especially those not properly trained.

When you watch television programming, keep these criteria in mind, and make notes of any errors in these areas that you see. Try to take photos or record video on your phone to upload with your complaint. In the complaint form provided by the FCC, you will be asked to elucidate the errors and mistakes that you see. You may also attach a screen shot or video showing what you are making a complaint about.

When you open the complaint form provided by the FCC, you need to fill in the following fields.

  • Your email address
  • Subject of the complaint (e.g.: [Station] does not meet FCC quality standards)
  • Description of the complaint (detail the specific instances)
  • Accessibility issues (choose “Closed Captioning on TV” for TV programs)

Once you choose your accessibility issue, additional fields will appear. Those with an asterisk are mandatory.

  • *Preferred method of response: The FCC and the station have to respond to your complaints. This will allow you to choose what medium they use to do so. Your options are email, fax, letter, other, relay service, telephone, and TTY.
  • Name of company complaining about: Enter the name of the specific station.
  • City of Company Complaining About: Enter the city in which the station is located. For national feeds, you may need to look up the station online.
  • State of Company Complaining About
  • Zip Code of Company Complaining About
  • Phone Number of Company Complaining About
  • *Date of Your Issue: you must enter an actual date, even if the problem is continuous.
  • *Time of Your Issue
  • *Your TV Method (cable, satellite, fiber, internet, over the air)
  • *Name of Subscription Service (your cable company)
  • TV Channel
  • Call Sign
  • Network
  • Name of TV Program
  • *City Where Program Was Viewed
  • *State Where Program Was Viewed
  • *Your First Name
  • *Your Last Name
  • *Address 1
  • Address 2
  • *City
  • *State
  • *Zip
  • *Phone
  • *Filing on behalf of someone? (yes/no)
  • Attachments: Include here any photos or video you may have taken of the captioning errors

After you complete and submit the complaint to the FCC, the FCC will evaluate the complaints and contact you if more details are provided. After this, they generally reach out to the programmer or TV station. At that point, the station may also contact you, to compile their response to the FCC. This can take 30-60 days. When you receive these responses, please forward them to NCRA’s Government Relations Manager Matt Barusch at mbarusch@ncra.org, for record keeping.

NCRA believes that machine captioning is not ready for live television programming or any other live events. We know the companies behind this technology will keep working to improve their products. NCRA is committed to providing the best possible access for people who are deaf or hard of hearing.

NPR sued for lacking closed captioning on videos

AllAccess.com reported on Oct. 15 that National Public Radio is being sued by a man who claims the network discriminates against the deaf and hard-of-hearing by not providing closed captioning of videos on its NPR.org website.

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Without captions, warnings about Hurricane Michael failed to reach disabled

Radio station WSAU based in Wausau and Stevens Point, Wis., posted an article on Oct. 13, about Oscar-winning deaf actress Marlee Matlin’s reaction to no captioning being provided on warning videos about Hurricane Michael posted on the internet by the Weather Company.

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Captioner is listed as one of eight amazing jobs for early careerists

A blog posted on Oct. 9 by Glassdoor.com names captioning as one of eight top jobs for early careerists to consider. The blog notes that the profession offers flexible schedules and more.

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Report from the FCC’s Disability Advisory Committee meeting

The Federal Communications Commission’s (FCC) Disability Advisory Committee (DAC) met on Oct. 3 for the last meeting of their second term. This committee comprises organizations in the telecommunications and accessibility realms and provides recommendations on accessibility regulations for the full commission. NCRA has participated for many years in this committee as subcommittee members of the Video Programming subcommittee, which occasionally crafts recommendations on captioning regulations and best practices for the full committee to consider. In attendance at this meeting were NCRA President Sue Terry, FAPR, RDR, CRR, CRC; Board Member Steve Clark, CRC; members Kelly Linkowski, RPR, CRR, CRC, CPE, and Darlene Parker, FAPR, RPR; and NCRA’s Government Relations Manager Matthew Barusch. The meeting was captioned by a live captioner, with captions shown in the room and streamed on the Web, along with StreamText captions.

Much of the agenda for this meeting was dedicated to consideration and approval of recommendations from other subcommittees, as well as a robust discussion on methods to increase consumer engagement. However, a portion of the meeting was dedicated to a review of possible topics of consideration for the DAC’s next term. Included on this list is the issue of automatic speech recognition, including the possible development of technology-neutral captioning quality metrics. As stated by Will Schell, Advising Attorney for the FCC’s Disability Rights Office, the recommendation is for the committee to “explore opportunities and challenges of developing technology-neutral metrics for closed captioning quality, with an eye toward facilitating objective comparisons between different captioning technologies, including automatic speech recognition, in terms of their ability to yield accuracy, completeness, synchronicity, and placement.”

Barusch gave a short speech towards the end of the meeting, reaffirming NCRA’s interest in this topic and commitment to assisting in the development of such metrics.

“Given the rise of ASR usage, especially in the broadcast captioning industry, this topic is particularly important for the DAC to consider,” Barusch said. “We have a number of concerns that this technology is not ready or able to meet the standards set by the FCC in 2014 and feel that it is being implemented to the detriment of consumers.”

Visit the FCC’s Disability Advisory Committee page for more information.

NCRA member recognized by International Association of Women

​​The International Association of Women announced in a press release issued Sept. 25 that the organization has recognized NCRA member Jennifer Schuck, FAPR, RDR, CRR, CRC, as a 2018-2019 Influencer.

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Is court reporting the career for you?

Ms. Career Girl posted an article on Sept. 27 about the benefits of choosing court reporting as a career. The article mentions NCRA and the growing need for people to enter the court reporting and captioning professions.

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FCC’s Disability Advisory Committee meeting announced

The Federal Communications Commission’s Disability Advisory Committee meets on October 3. NCRA’s Government Relations Manager Matthew Barusch; NCRA Board Member Steve Clark, CRC; and NCRA President Sue Terry, FAPR, RPR, CRR, CRC, will attend this meeting and will raise the issue of Sinclair Broadcast Group using IBM Watson Captioning. If you are planning to attend this meeting in Washington, D.C., next week, please contact Matthew Barusch at mbarusch@ncra.org for important information!

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Marco Island to settle lawsuit over closed captioning

The Marco Eagle reported on Sept. 17 that the city of Marco Island, Fla., has agreed to settle a lawsuit alleging violations of the Americans with Disabilities Act for failing to provide closed captioning for videos on the city’s website and cable broadcasts.

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NCRA member shares how teenage intern inspires court employees while chasing her dream

Television station KRQE, Albuquerque, N.M., aired a story on Sept. 17 that features NCRA member Diona Gibson, RPR, an official court reporter for the Bernalillo County District Court, sharing her experience with a summer intern who was born blind and plans to become a court reporter.

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