The Motion Picture Association of America has pitched the Federal Communications Commission an alternative timeline and more holistic approach to providing closed captioning for archival Internet-delivered TV shows to avoid what it suggests is the almost-impossible task of tracking down shows re-airing on cable and broadcast individually.
That came in a letter this week to the commission.
The FCC, on Sept. 19, released its proposals for implementing the Twenty-First Century Communications & Video Accessibility Act, which requires the FCC by Jan. 12, 2012, to come up with new regs requiring closed captioning on IP-delivered video that contained captions when it was first aired on TV.
MPAA said its "comprehensive" and "systematic" voluntary approach to captioning was preferable to the scattershot approach proposed by the FCC that would result in random episodes based on the date they were re-aired on television. "Attempting to search for and replace uncaptioned content with captioned content on potentially thousands of Web sites on an episode-by-episode basis is so logistically complex that it would be difficult if not impossible for content owners and their distribution partners to comply."
MPAA also argued that the undertaking was so massive that the FCC's timetables -- six months and twelve months for some categories -- was unrealistic, particularly since it would also be working on captioning all new Internet-delivered TV shows going forward.
MPAA's proposal is that, within 24 months of the effective date of the rules, content owners would caption all full-length content hosted on their wholly-owned and operated Web sites that is licensed for TV -- broadcast of pay -- and aired on or after Jan. 1, 1998, when the TV captioning requirement first kicked in.
Members would pledge within 48 months to provide captions to authorized third-party Web sites of all theatrical films produced on or after Jan. 1, 1998 and licensed for TV.
It would promise that within 72 months it would supply third-party sites with captions for archival, full-length TV shows produced on or after Jan. 1, 2006, and within 96 months would provide captions to third-party sites for archival shows before 2006 and dating back to 1998. The FCC did not require captioning of clips or outtakes.
MPAA picked 2006 because that was when 100% of non-exempt English-language new TV content had to be captioned, so that captioned content is more likely to be available for extraction and reformatting.
MPAA pointed out that the result would be that more content would wind up being aired, since the law only requires captioning of TV shows that re-aired on the 'net after the rules become effective. To try and identify those shows among 2,000 TV stations and 600 national and regional cable nets and coordinate with their distributors would be virtually impossible for archival material. MPAA said such identification and coordination for new programming would be achieved at the front end through contract terms.