Movie Captioning – FCC seeking comments now

December 12, 2010 Comments Off on Movie Captioning – FCC seeking comments now

From the HLAA – any questions for the CCAC? CCAC building bridges, bringing in new advocates every day:

DOJ Considering New Rules on Movie Captioning

Twenty years ago, HLAA members came out in force when it was time to comment on rules under the Americans with Disabilities Act (ADA). Our comments helped shape the way the rules were written. We need you to do that again to push for captioned movies.

On July 26, 2010, the Department of Justice (DOJ) published a notice that it is considering changes to its regulations to require movie theater owners and operators to show captioned movies.  DOJ is inviting written comments from members of the public.  Comments sent by U.S. mail must be postmarked and electronic comments must be transmitted on or beforeJanuary 24, 2011.

The DOJ proposes to require movie theater owners and operators to show films with closed captioning.  DOJ proposes to limit this requirement to no more than 50 percent of the films shown, and DOJ is willing to give owners and operators up to 5 years to get to the 50 percent mark.

HLAA believes that “full and equal enjoyment” of services under the Americans with Disabilities Act means that people with hearing loss must be provided the kind of accommodations that would allow us to attend any movie anytime. For people with significant hearing loss, that means 100% captioning. We believe that an across the board industry cap of 50% is arbitrary and inconsistent with the law.

HLAA’s position on movie captioning is:

  • All movies should be made accessible to movie goers with hearing loss though captioning.
  • People with hearing loss should be able to see any movie at any time on any day.
  • There are many ways to caption movies today. HLAA does not specify the method used to caption the movie so long as it provides effective communication.

DOJ is seeking comments in response to 26 questions.  The entire document with all the questions can be accessed at  You can reply to some or all of the questions. We suggest at a minimum, that you respond to DOJ Question #1:

  1. DOJ is proposing that the percentage of movie screens offering closed captioning be set at 10 percent after one year and increased 10 percent a year until 50 percent is reached.  Does this approach provide a proper balance between providing accessibility to consumers, on one hand, and giving owners and operators time to acquire the necessary equipment, on the other hand?

Send your comments today. And tell others to send comments too. We need you to let the DOJ know that 50% in five years is not enough.

end of communication from the HLAA

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