Reply to National Assoc. of Broadcasters, their attorneys and board members

December 21, 2010 Comments Off on Reply to National Assoc. of Broadcasters, their attorneys and board members

Dear National Association for Broadcasters:

Not doing everything cannot be an excuse for doing nothing.

This is a reply to your comments to the FCC, signed by Attorney Bobeck,

Re…FCC: In the Matter of Consumer &  Governmental Affairs Bureau Seeks to Refresh the Record on Notices of  ) CG Docket No. 05-231 , Proposed Rulemaking Regarding  ) ET Docket No. 99-254 Closed Captioning Rules   )

NAB – National Association of Broadcasters, 1771 N Street NW, Washington DC 20036, email to

We in the Collaborative for Communication Access (CCAC) a grass-roots volunteer group, are offended by your arguments before the FCC regarding captioning. We believe you misunderstand the real needs of millions of citizens (and your viewers) worldwide, who require quality real-time speech to text.  Here are some reasons:

Captioning serves millions, not only those with hearing loss. Thousands of others require captions for learning English (or other languages), and due to different learning styles. Those people who do not like captions may turn them off (i.e. captions should be included universally, all the time, on). You would also be surprised perhaps how many use them (even when they say they do not need them).

Why do we need to wait more years for this when modern technology is available for this? Life costs, and the benefits in the long run to all, including your association members, far outweigh the risks of not including captioning.

1.  A TV license is a privileged commercial right that comes with strong
obligations – including access.
2. You have to make  commercial decisions every day based on what the laws
of the land are  and accept that – if you cannot run a business and comply
with the law  then fail, release that license and let somebody else have a
3. The starting point of all discussion on caption quality should be 100%
accuracy – no compromise and certainly no  measure of 98% because all that
happens is that they say “we reached  95% so that’s almost there what’s your
problem?”  What is the TV  standard for picture and sound?
4. Yes quality regulations should be very simple:  only programs that
are truly live should be live captioned.  Captions should be accurate and
synchronous with the soundtrack.

The enemy of the good is the perfect.

Our hundreds of members, and so many more worldwide, understand that equal access is vital – for work, for health, for life! Vital and necessary, soon.

May the light of the season shine upon your further deliberations about this. We invite you to discuss this with the CCAC anytime. Email us on







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