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Media Access Review

Media Access Australia has read and collated the submissions made to the media access review. Over 150 submissions were received primarily from consumers, consumer groups and industry. Media Access has produced summaries of these submissions under five subject headings; blind and vision impaired consumers, deaf and hearing impaired consumers, new media, education and others. The summaries aim to explore the targets proposed by these submissions and the reasons why access is so important to these consumers. In general, consumers wrote of their positive experiences of access and their enthusiasm about the possible expansion of these services.

 Blind and vision impaired consumers

To me TV and movies without audio description is(sic) like shoes without a soul (sic) in them (Lisa Hayes)

An estimated 500,000 Australians are vision-impaired. They include 50,000 who are blind, 4,000 of whom have a form of deaf blindness (National Disability Service)

General

Blind and Vision impaired consumers were less likely than deaf and hearing impaired consumers to respond to this inquiry. This may largely be largely due to the absence of audio description in Australia and a lack of awareness about its possibility. In fact even the Guide Dogs Association made comments about captioning without mentioning audio description.

While several priorities are listed, blind consumers primarily wrote personal testimonies about the importance of audio description rather than proposing definitive plans about the implementation of audio description. The most detailed implementation plan was proposed by Vision Australia.

Priorities

  1. The first priority for blind/vision impaired consumers was to get text (emergency information, sporting scores, ‘more information on our website’ and final comments especially on Australia Story) with audio attached. (Melissa Ryan, Robert Altamore, Matthew Chan, Lynee Davis, Lisa Hayes, Kyrstal Keller, Tom Macmahon, Karen Passmore, Patricia Stillman). A number also wanted this on Advertising (Melissa Ryan, Erik Webb, Vision Australia)
  2. Better promotion and labeling of audio described material where it is available and making this large enough for vision impaired people to read. (National Disability Service, Erik Webb)
  3. Increasing importation of audio described material on DVD (Association of the Blind WA, Scott Nixon). RNIB proposed a reciprocal arrangement for television where Australia and the UK could share files and reduce costs.
  4. A separate audio channel or something analogous to SAP (Marvin Hunkin, Disability Discrimination Legal Centre) or a trial on multichannels (Vision Australia).
  5. A general increase in audio description across media forms and the devices used to display media (Marvin Hunkin, Evelyn Martin, National Disability Service, Steve Richardson, To Tran, Erik Webb) For example the DTS system should be expanded to relay audio discrimination (National Disability Service, RNIB)
  6. Allowing blind consumers to actually access the audio described material through talking remotes or menus like the Dr Who box set (Marvin Hunkin, National Disability Service, Scott Nixon) RNIB proposes that user settings should be preserved.
  7. Text descriptions of graphic material on websites (Tom Macmahon) and a growth in the usability of websites (National Disability Service)
  8. Allowing Audio Description to be affordable for example not only the Sydney Theatre Company (Coral Arnold)
  9. Handheld devices (Royal Society for the Blind SA) and Digital Radio (Vision Australia).

Comments

Consumers submitted that because of their impairment they engaged with media less frequently than they would otherwise or had done previously. (Maria Chapman, Chire Fulford, Sally Jary, Evelyn Martin, Karen Passmore). Those who had experienced audio description understood it to have significantly increased their experience.

Blind and vision impaired citizens felt that their choice was severely limited as very few media were audio described (Dr Lynne Davis, Chire Fulford, Kyrstal Keller). For example Marvin Hunkin requested that older DVDs also have access features.

There was also a particular focus on the need for inclusion in the cultural and social world and to be able to operate independently within it (Dr. Lynne Davis, Mark Enston, Lisa Hayes, Macular Degeneration Foundation and Janet Shaw) The joint submission of People with Disability and the Disability Discrimination Legal Centre commented on the federal government’s platform for social inclusion and the human rights obligations to provide access.

Respondents frequently commented that the lack of audio description meant that they missed out on information or were constantly asking their friends and family for information. (Christine Casey, Maria Chapman, Sally Jary, Kyrstal Keller, Margaret Macarthur, Tom Macmahon, Janet Shaw)

Audio description was perceived as important within the school system. It was submitted that it was vital to allow students to deconstruct texts (Mark Enston, Tom MacMahon) and to generally interact with the curriculum (National Disability Service)

Targets

The main theme was that blind consumers want more audio description.  If a target was set it was usually for audio description to be analogous with captioning (Association of the Blind WA, Sally Jary,  Nadio Mattiazo, Royal Society for the Blind SA, Disability Discrimination Legal Centre, Robert Altamore). Vision Australia provided the most detailed quota regime which is extracted below.  RNIB however noted that it is important to ensure that the quotas is high enough to ensure take up, the UK experience suggests 6-8% with appropriate promotion.

Some respondents highlighted the international implementation of Audio description and proposed that Australia adopt a similar framework (RNIB, Kystal Keller) 

It was also stressed that audio description should be included at the design and implementation stage rather than being an additional feature added retrospectively. (Royal Society of the Blind SA, RNIB and Vision Australia).

Respondents strongly believed that regulation was essential in order to ensure the rollout of audio description.(Association of the Blind WA, Disability Legal Centre, Margaret Macarthur, Tom Macmahon, Macular Degeneration Foundation, Nadia Matiazzo, Disability Discrimination Legal Centre). Royal Society for the Blind SA and Vision Australia saw a role for Disability Discrimination Act and or a related standard. Most other respondents more generally referred to standards or codes of practice. It was also noted that it would be essential to regulate quality with appropriate complaints mechanisms to enforce such (Disability Legal Centre). Finally

People with Disability, Vision Australia and RNIB believe that the AFFC should create an incentive for audio description by only funding films with AD tracks.

The time period for implementation was also important to consumers. It was especially argued that it should not be delayed until the end of the simulcast as FreeTv proposed.  (Royal Society for the Blind SA).  While it was acknowledged that there exist technical hurdles for television description, Access Innovations noted that if you can not transmit audio description on television the files could be made available online. Vision Australia proposes that a trialed implementation on a multichannel would assist broadcasters to overcome some of these technical obstacles.

Vision Australian provided the most comprehensive list of targets

That the Australian government implement the following targets for the delivery of audio description services in Australia:

  1. Television (free-to-air, digital, subscription)
  1. No audio description on analogue television
  2. 2009: Each digital television broadcaster to set aside time on digital multi-channel and/or time-shifted programming for "open" audio description from the time a multi-channel becomes available to them.
  3. December 2011: 5% of programming content with audio description;
  4. December 2013 (digital switchover complete): 10% of programming content with audio description;
  5. 2014: Review of targets, with the expectation that an accelerated increase will be possible with new (MPEG4) technology that will allow the transmission of "closed" audio description.
  1. Audio Description in Cinema
  1. July 2009: Inclusion of a contractual requirement that all movies produced with public funding must be fully accessible (i.e.,captioned and audio-described).
  2. December 2009: all newly-constructed or substantially-refurbished cinemas to have facilities for playing audio-described movies;
  3. December 2010: a minimum of 100 cinemas across Australia to have facilities for playing audio-described movies;
  1. Audio Description on DVD (including Blu-ray):
  1. December 2009: All movies released for cinema with audio description, and television content that has been audio-described here or overseas, to be available with audio description on the DVD version;
  2. December 2009: All DVDs produced by Australian governments to be fully accessible (captioned and audio-described); Vision Australia:
  3. December 2010: 50% of entertainment DVDs released in Australia to have audio description;
  4. December 2015: 100% of entertainment DVDs released in Australia to have audio description.

Deaf and hearing impaired consumers

Deaf consumers and consumer groups made a number of submissions. Regardless the aims of these submissions were largely consistent with minimal variation.

  1. 100% captioning on television (Gillian Ward, Wendy Watson, Jan Wigley, Janie Schacter, Dean Barton Smith, Deaf Australia, Deaf Society of NSW) Special mention was made of daytime programming (Gillian Ward, Elizabeth Wandell, Andrew Stewart, 2x anonymous….) and children’s programs (Kaye Gooch)
  2. Some respondents also commented that the same regulations should govern subscription and community television that do or would govern free to air. (Andrew Stewart, Linda Bruce, Deafness Council WA)
  3. Improved quality of captioning especially when programs are live captioned (Gillian Ward, Dean Barton Smith, Lyn Beaumont, Linda Bruce, Deaf Access Victoria)
  4. Increased number of cinema locations with DTS systems and correspondingly create more variety in times and movies at these locations.
  5. Captioning on all DVDs (Wendy Watson, Alison Spark Jan Wigley, Andrew Stewart) with a particular focus on government funded DVDs.
  6. Captioning in public places eg museums and landmarks (Jan Wigley) waiting rooms (Michael Uniacke) and on flights (Louise Bartheyl).
  7. Standard, consistent and clear labeling of DVDs (Michael Uniacke)
  8. Advertising to be captioned (Janie Schacter, Andrew Stewart, Subtitling and Captioning International) and especially mandated where they are public service announcements.
  9. Internet content should be captioned
  10. Improved access to digital services for those living in remote areas and unable to access captions (Wendy Chapman)
  11. Emergency information to be captioned regardless of whether it is practicable (Deaf Australia)
  12. Increased variety of captioned material (Barbara Hockridge)

Implementation

  1. A speedy, phase in model regulated by the Broadcasting Services Act with increases of 5-10% per year (Deaf Australia, Deafness Council WA). This could include a prohibition of broadcasting the program if captions are not available (Deaf Australia)
  2. Measuring compliance with quotas as minutes over a 24hour period to prevent incomplete captioning.(Deafness Council WA)
  3. A standard under the Disability Discrimination Act (Access Innovations) with the government to fund test cases where conciliation has failed (Deafness Council WA).
  4. Organisations to create disability action plans with the government to lead this process (Andrew Stewart)
  5. Captioning should to be seen as an integral part of production costs (Janie Schacter, Andrew Stewart)
  6. Use captioning as a sponsorship opportunity (Janie Schacter)
  7. Mandatory captioning, quality standards (Wendy Watson, Janie Schacter). These should govern live and offline captioning, require lyrics to be captioned and  captions to be appropriately positioned, coloured etc.
  8. A strong complaints mechanism (Janie Schacter, Peter Mullham) with enforcement mechanisms. This could also include regular reporting on compliance (Deafness Council WA).
  9. Removal or non reinstatement of the FreeTv exemption (Alan Stewart)
  10. All digital tuners to be AS 4933.1—2005 compliant.
  11. Captioned files to be made available online even if this needs to be in open format (Access Innovation, Disability Discrimination Legal Centre)
  12. Improved advertising of captioned movies (Better Hearing Australia Adelaide, Subtitling and Captioning International)
  13. Access should follow though to all media forms it is reproduced in (Angela Brooks)
  14. Impose limits based on cost or market share to reduce unfair burden (Subtitling and Captioning International, Deafness Council WA)
  15. Possible funding for the installation of DTS systems (Subtitling and Captioning International) and Community Television (Deafness Council WA)
  16. Change to MPEG 4 so that the font sizes can be changed for personal preference.
  17. Increase the number of cinemas with captions- targets included 70 (Wendy Watson)-100%, (Janie Schacter) 70-100 cinemas (Jan Wigley, Andrew Stewart, Dean Barton Smith, Deaf Australia, Deafness Council WA) or one cinema per complex (Alison Spark), or one screen per session (Hearing Loss New Jersey). All new or refurbished cinemas should also be accessible (Deafness Forum WA). This could be through a temporary exemption to the Disability Discrimination Act, Disability Discrimination guidelines, a code or changes to the building code.
  18. Trailers for movies should be captioned (Elizabeth Burgess) and tickets should be able to be booked online (Deaf Australia)
  19. Cinema locations accessible to people in regional Australia (Coff’s Coast Community)
  20. Increase the number of sessions for captioned movies (Lise Clews)
  21. Better education of salespeople about caption technology (Tony Colless)
  22. DVD import quotas regulated by an industry code or guidelines (Deaf Australia, Disability Discrimination Legal Centre)
  23. Guidelines for captioning on internet dowloads.
  24. Ten minute delays on live programming to ensure captioning is synchronized and accurate (Helen Goonlag)
  25. Clearly marked, standard CC button on remote controls.

Please note that some suggestions were also made for changes outside the scope of the work done be Media Access Australia; for example, improvements to induction loop systems or Auslan channels.

Rationale

  1. Personal experiences of improved access due to captioning and the disappointment that it was not more widely available was noting by almost all respondents.
  2. Increased market potential (Michael Uniacke, Subtitling and Captioning International)
  3. Failure to caption is discrimination and a violation of human rights including the new Disability Discrimination Convention (Janie Schacter, Angela Brooks, Disability Discrimination Legal Centre). It is no different than audio not being available (Maria Burgess)
  4. The Federal Government’s dedication to social inclusion (Disability Discrimination Legal Centre)
  5. Watching television is important for social and safety reasons (Janie Schacter) It is how most people interact with news and current affairs (Disability Discrimination Legal Centre).
  6. It is important for children to be exposed to the written word (Kaye Gooch)
  7. Weak enforcement currently means media producers have little incentive to caption (Better Hearing Australia Adelaide)
  8. Captioning reduces isolation (Alison Spark, Andrew Stewart)
  9. BBC has managed to reach 100% (RNID) and in general Australian is behind the international market for DVD and cinema (Subtitling and Captioning International)
  10. Ofcom found that people with hearing impairments actually watched more television on average than non hearing impaired people (RNID).
  11. Benefits outweigh the costs and expanding the service would actually reduce costs per file (Access Innovation Media)
  12. Some deaf and hearing impaired people attend the cinema with friends and family but can not follow the movie (Louise Bartheyl)
  13. If internet downloads are not made accessible, hearing impaired people will be left behind again (Tony Clews). Further internet is becoming increasingly mainstream and therefore needs to be regulated (Hearing Loss Association New Jersey)
  14. There is no technical reason for not captioning DVD (Hearing Loss Association New Jersey)

New Media

Consumers did not frequently comment on the accessibility of websites; some exceptions include Tony Clews, Liz Evans, Hearing Loss of New Jersey and the ACT Deafness Resource Centre. A prominent theme of these submissions was that deaf consumers finally have access to video content on television and DVD but with the dominance of internet downloads they are falling behind again. There were also significant concerns within the education sector about the Digital Education Revolution and the strong possibility that the use of downloads and podcasts will discriminate against students with sensory impairments.

There were some positive suggestions about the possibility of the internet improving access. Access Innovation Media expressed that internet downloads provide a unique opportunity to make access files available where they can not be broadcast. This may mean open captioned and open audio described files would be more readily available. Access Innovation believes that these are two important elements of access, firstly making broadband available to all people and second making it accessible to people with disabilities.  It is fundamental to their submission that guidelines be developed under the Disability Discrimination Act.

The National Disability Service argued that universal design principles should be adopted that would allow 100% of all downloaded material to be captioned. They noted the importance of technology being designed with consideration to accessibility and usability simultaneously. CTN endorsed the submission of Media Access Australia and referenced the ‘Accessible Broadband for all Australians’ report.

Industry, where they commented on the issue, were ideologically supportive of making their content accessible but highlighted the costs involved in doing this especially if access features needed to be available in various file formats. Telstra thought this could be somewhat bypassed by producers making suitable caption files for download when they produced captions for other media. Where this was a film funded by the AFFC Telstra believes that funding should be extended to this purpose. Google and Telstra also commented on the masses of user generated content that would be difficult to caption. A final issue raised by Google was the restrictive legislation could stifle experimentation.

Education

Submissions in relation to education were primarily made by teachers of the deaf and hearing impaired. However most other submissions indirectly relate to education as increased captioning and audio description on media more generally would assist students with sensory impairments.

Rationale

  1. Improves world and general knowledge. Religious schools also commented on the importance of access to pastoral care programs (CEO, Parent Council of Deaf Education
  2. Podcasts and digital downloads are increasingly being used to transmit information to students. This will increase as part of the government’s Digital Education Revolution and with many ABC educational programs being available for download. However these resources do not have access features and therefore would limit the experience of students who require them. (CEO, RIDBC, Lynda Beckingham, Gianna Petris)
  3. It is required by the Disability Discrimination Act, Education Disability Standards and World Health Organisation as an environmental factor impacting on disability. (CEO, RIDBC, Lynda Beckingham, Gianna Petris)
  4. Access would increase the independence and inclusion of students with sensory impairments (Santa Sabina, Trinity Grammar)
  5. It would assist students to understand how language creates meaning.
  6. Improved access more generally would allow parents with sensory impairments to assist their children (National Disability Service)
  7. Access also assists ESL students develop English skills and more generally assists students to learn about paraphrasing and synthesizing. (PLC)
  8. Many educational films are merely voiceovers and therefore students do not even have the option of lip reading. (St Alban’s East Primary School).
  9. Access features would significantly improve literacy (Trinity Grammar)
  10. Media education is part of the curriculum for Stage 4-6 (Andre Stewart)

Priorities

  1. To increase the amount of captioned material across all media. Subtitled programs are not sufficient to communicate meaning (CEO, St Alban’s East Primary School, Jan Wigley).  Further, it is not sufficient to provide students with transcripts that take teachers considerable time to prepare, force student to do additional work and do not allow them to develop note taking skills. (PLC, Elizabeth Phipps)
  2. Improved labeling of captioned and audio described material to make it easier for teachers to source (CEO)
  3. Improved quality of captions. This is especially important for students as they will learn spelling and grammar from captions (Parent Council of Deaf Education, Jan Schacter)
  4. Introduction of a multichannel with audio described educational material (RIDBC, St Albans East Primary School)
  5. The introduction of a library of captioned and audio described material (RIDBC, Santa Sabina, Gianna Petris, Elizabeth Phipps)
  6. Legislation to ensure that television programs that have captions are reproduced with captions (Trinity Grammar)
  7. Introduction of captioned or Auslan power points. (Greg O’Grady)

Others

Although the majority of submissions considered the role of captioning for people with sensory impairments other uses of captions were noted. The majority of these considered the importance of captioning for people who were learning English (Ja Song Soon, Elizabeth Burgess and Roberto Castron). This rationale was also considered to be important within the classroom for students learning English and for students proficient in English to learn about language concepts like paraphrasing and syncronising. 

A few submissions also considered the importance of captions in public spaces (Angela Abrahams) or where other people in a room needed silence (Deafness Council WA).