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Future of Subtitling Event Report 10 November 2014 Event organisers: Action on Hearing Loss, UKCOD and Sense Event sponsors: GoldEricsson and Deluxe. Silver ITV, Channel 4. Bronze - Cochlear 1 The Future of Subtitling - TV and Broadcasting Conference 10 November 2014 Event report This report draws on the event transcript from The Future of Subtitling conference held on 10 November 2014 to provide summaries and quotes from the presentations and discussions that took place on the day. This report reflects the views of each event speaker, and does not necessarily reflect the organisers’ position on the topics covered. Our sponsors Thank you to our sponsors who allowed us to offer 100 free conference places to people with a personal interest in subtitles: Gold: Silver: Bronze: Background On 10 November 2014 Action on Hearing Loss, Sense and UK Council on Deafness (UKCOD) organised a one day conference to discuss the challenges and solutions for the future of television subtitles. Subtitles were first developed 35 years ago and have proved, at their best, to offer a fully accessible TV experience for deaf people. We have come a long way but many challenges remain, particularly as a result of the changing way in which we watch television. People now access content in a diverse range of ways that encompasses traditional linear 1 broadcasts, catch up TV, TV streamed over the web, internet connected Smart TVs and a variety of Video streaming services. The conference discussed the key challenges around subtitles: how the quality of live subtitling can be improved, the initiatives that will see more subtitles on Video on Demand broadcasts and the innovations in subtitling provision, equipment, software and training. 1 Linear broadcasters are where the viewer has to watch a scheduled TV programme at a particular time and on a particular channel

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Page 1: The Future of Subtitling - TV and Broadcasting Conference ... of subtitling 10 Nov 2014 Even… · encompasses traditional linear1 broadcasts, catch up TV, TV streamed over the web,

Future of Subtitling Event Report 10 November 2014 Event organisers: Action on Hearing Loss, UKCOD and Sense Event sponsors: Gold– Ericsson and Deluxe. Silver – ITV, Channel 4. Bronze - Cochlear

1

The Future of Subtitling - TV and Broadcasting Conference

10 November 2014

Event report

This report draws on the event transcript from The Future of Subtitling conference held on

10 November 2014 to provide summaries and quotes from the presentations and

discussions that took place on the day. This report reflects the views of each event

speaker, and does not necessarily reflect the organisers’ position on the topics covered.

Our sponsors

Thank you to our sponsors who allowed us to offer 100 free conference places to people

with a personal interest in subtitles:

Gold: Silver: Bronze:

Background

On 10 November 2014 Action on Hearing Loss, Sense and UK Council on Deafness

(UKCOD) organised a one day conference to discuss the challenges and solutions for the

future of television subtitles. Subtitles were first developed 35 years ago and have proved,

at their best, to offer a fully accessible TV experience for deaf people. We have come a

long way but many challenges remain, particularly as a result of the changing way in which

we watch television. People now access content in a diverse range of ways that

encompasses traditional linear1 broadcasts, catch up TV, TV streamed over the web,

internet connected Smart TVs and a variety of Video streaming services.

The conference discussed the key challenges around subtitles: how the quality of live

subtitling can be improved, the initiatives that will see more subtitles on Video on Demand

broadcasts and the innovations in subtitling provision, equipment, software and training.

1 Linear broadcasters are where the viewer has to watch a scheduled TV programme at a particular time and

on a particular channel

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The conference was attended by a wide range of stakeholders invested in solutions including Government, Ofcom, ATVOD, broadcasters, access service providers, voluntary organisations and deaf people.

Legislative context

Currently linear broadcasts are subject to quotas for the number of hours of programmes

delivered with access services (subtitles, audio description and signing) if the broadcaster

meets criteria on their audience reach and turnover. The Government has stated it wants

the UK to remain a world leader in terms of the extent and quality of access services and

that it would work with The Authority for Television on Demand (ATVOD) the co-regulator

for Video on Demand services) to increase the provision of access services for Video on

Demand content, monitoring this through ATVOD’s annual survey.

In July 2013 The Department for Culture Media and Sport published a strategy paper

‘Connectivity, Content and Consumers’ which states “we will work with the Authority for

Television on Demand (ATVOD)… to increase the levels of subtitles and audio-description

for on-demand content and we will monitor progress through its annual survey. If it is clear

that progress isn’t being made in three years’ time – a reasonable timeframe in our view –

we will consider legislation” (p22).

Questions submitted in advance to panellists

In order to provide those who could not attend the event with a chance to participate, the

organisers invited questions in advance for our expert panels. Over 100 questions were

submitted, collated into themes, and shared with the panellists in advance of the

conference. Whilst time did not allow us to cover all specific questions at the conference,

many of the themes raised were discussed. The event organisers will be using the

questions to inform their campaigns work moving forward including in representations to

the Department of Culture Media and Sport.

Key issues emerging from questions submitted in advance

Quality of subtitles

Delays between speech and subtitles

Inaccuracies in subtitles

Missing subtitles

Provision of live subtitles on pre-recorded programmes

Subtitles covering important information or peoples’ mouths (essential for

lipreading)

Customisation of subtitles including placement, colours, size, background

Problems with subtitle delays when recording subtitles

Incorrect or different words used in subtitle compared with words actually spoken,

editing of information

Quantity of subtitles

Lack of subtitles on Video On Demand (no regulation)

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Lack of subtitles on linear (traditional) channels, including local channels, and new

channels (due to low quotas, no quotas for low audience channels or new channels)

Lack of subtitles on live streaming online

Paying for a service people with hearing loss cannot access (including licence fee

and purchasing a service)

Lack of subtitles on DVDs

Lack of information about where subtitles are and aren’t available (especially on

Video on Demand)

Lack of subtitles on video clips on websites

Event programme

Event Chair: Jim Edwards, Chair of UKCoD and CEO of Signature

Welcome and Introduction

Paul Breckell, Chief Executive, Action on Hearing Loss

Morning session: Quality of subtitling – where will we see improvements?

The morning session looked at work being done by Ofcom, subtitling companies and

researchers to monitor and improve the quality of live subtitling.

Presentation: Monitoring of the quality of live subtitles

Peter Bourton, Head of TV Content Policy, Ofcom

Presentation: New developments in live subtitling

David Padmore, Head of Access Services, Ericsson Broadcast & Media Services

Presentation: A different approach, a different priority

Dr Pablo Romero Fresco, University of Roehampton

Panel discussion: How can we improve the quality of live subtitles?

Graham Willis, Technical Co-ordinator for Access Services, Deluxe

Ian Cottrell, Controller of Broadcast Operations, ITV

Nathalie Sfakianos, volunteer at Action on Hearing Loss

Peter Bourton, Head of TV Content Policy, Ofcom

Dr Pablo Romero Fresco, University of Roehampton

Simon Pearse, Deaf Access to Communications

Afternoon session: Subtitling on Video on Demand – what does success look like?

The afternoon of the event focused on the provision of subtitles on Video on Demand

(VOD) which includes catch up services such as BBC iplayer and 4oD whereby viewers

are able to watch television content at a time of their choosing.

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Presentation: Your views and how we make them count

Tanvir Ahmed, Senior Campaigner, and Laura Matthews, Senior Research and Policy

Officer, Action on Hearing Loss

Presentation: Technical challenges and success on the BBC iPlayer

Gareth Ford Williams, Head of Accessibility, User Experience & Design, BBC Future

Media

Presentation: Encouraging improvements

Peter Johnson, CEO, Authority for Television on Demand (ATVOD)

Panel discussion: How can we increase the amount of subtitles on video on demand

(VOD) services?

Gareth Ford Williams, Head of Accessibility, User Experience & Design, BBC

Future Media

Peter Johnson, CEO, Authority for Television on Demand (ATVOD)

Alex Varley, CEO Media Access Australia

Lidia Best, Chair of NADP and UKCoD Trustee

Laura Matthews, Senior Research and Policy Officer, Action on Hearing Loss

Summary and next steps

Joff McGill, Head of Information, Advice and Research Sense and UKCoD Trustee

Introduction

Paul Breckell, Chief Executive, Action on Hearing Loss

For the 10 million people in the UK with hearing loss, subtitles are a vital tool to help them

understand and enjoy television. There is real pressure from users to improve access to

TV through more and better quality subtitles. TV is hugely important to all of us and

exclusion can mean a lack of news, information, entertainment and missing out on national

cultural life. Research shows people with hearing loss watch more TV than the average

viewer, and, according to Ofcom, seven and a half million people have used subtitles to

watch TV.

There is much to be proud of in the UK, with an episode of Blue Peter being the first live

programme to be subtitled in 1986. The BBC news has been subtitled since 1990 and in

2008 reached 100% subtitled content on its main channel output. ITV are very close to

achieving the same on ITV 1.

We have seen substantial improvements in the quality of subtitles on national TV. Such

progress is to be applauded but there is still much to do. Viewers continue to experience

errors and delays with live subtitling; there are no legal obligations on Video on Demand

services to include access services and provision is much lower than linear broadcasts.

Digital exclusion can only lead to isolation, and this is not acceptable.

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Monitoring the quality of live subtitling

Peter Bourton, Head of TV Content Policy at Ofcom

“We believe that even the process of monitoring these categories of programmes

has helped to focus the attention of the broadcasters and their access service

contractors to maximise the quality and accuracy of their news products”

Overview

This session outlined the findings to date of Ofcom’s two year project to monitor live

subtitling and the improvements that we are beginning to see. Peter revealed initial

findings of trials where delays to the broadcast of live programming are giving subtitle

providers more time to improve accuracy and latency.

Ofcom’s two year project to monitor live subtitles

After a decade or more of focusing on the quantity of subtitling, Ofcom are pleased that

there are now 70 channels that provide subtitling, most of them delivering 80% or more of

their content with subtitles. The BBC has reached 100% and ITV and Channel 4 are close

to that.

It is has become clear that quality is not yet as good as it could be, hence Ofcom, last

year, launched a two year project to monitor the quality of live subtitling.

Following discussions with users and looking at the research, a number of factors were

identified as being key to quality:

Accuracy – errors in subtitles force viewers to work harder to understand what was intended

Latency – the delay between the speech and subtitles make it difficult for viewers to relate

Speed – if the speed of subtitles is too high more time is spent focussing on the subtitles and less time is available to view the TV pictures

Presentation – research shows that block subtitles are easier to read, but there are times, such as with live programming, when block is not possible and scrolling subtitles are used. Ofcom want to examine the scope for increasing the proportion of block subtitles.

Ofcom decided to look at three genres of programmes: news, entertainment and chat

show. Broadcasters are asked to submit randomly chosen samples of live subtitling after

they were broadcast and these are analysed for quality by Ofcom. The broadcasters do

not know in advance what the samples will be.

Reporting on quality

The first report was published in April 2014 and the second report in November 2014. It

will take more reports and more data before trends can be identified, but the early reports

suggest the process has helped focus attention on the quality and accuracy of news

programmes. There has been more emphasis on getting scripts, running orders, and pre-

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recorded video packages to subtitle providers in advance. The monitoring process is a

potential driver for the broadcasters and their access service contractors.

The early reports suggest that speed of subtitling is not too much of an issue, with very few

samples exceeding the recommended words per minute.

Ofcom’s findings relating to the latency of chat shows

Ofcom recognises that latency is a key issue for users and the early data suggests that it

is not possible to meet the current guidelines of a three – four second delay for live

subtitles. It is a very tough process to get subtitles out in a time span that is comfortable for

the viewer. The median across the samples is six seconds, with a delay of as much as 24

seconds in some cases.

Improving quality - what makes a difference?

There are a number of processes that might deliver better quality live subtitles. Ofcom

would like broadcasters to explore the scope for short delays in live programming to give

subtitle providers more time to improve accuracy and latency. S4C (a Welsh-

language public-service television channel) carried out a trial with some live programming

going out with a 25 second delay. This allowed block subtitles be produced, errors

significantly reduced and latency reduced to two seconds. The trial continues and the

results will be studied with interest.

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Ofcom are also looking at how much original content has to be edited to get subtitles on

the screen. Some people want near verbatim subtitles but some editing makes it more

likely subtitles can appear in a reasonable time scale.

Finally, the work on live subtitling is bringing a greater focus to the processes needed to

produce subtitles and there are signs of greater co-operation between broadcasters and

subtitle providers. The best way of improving quality is to avoid the need for live subtitling,

and Ofcom’s next report will publish more information on the number of pre-recorded

programmes that are delivered late and thus need live subtitling.

New guidance

Once the third and fourth reports are published (Spring and Autumn 2015) Ofcom will

consult on updating the best practice guidance around subtitles as the current version

reflects thinking 10-15 years old.

New developments in live subtitling

David Padmore, Head of Access Services, Ericsson / Red Bee

"When you are watching a news programme, sometimes you can see the same

video package being shown several times within a period of a few hours, so it is

possible to get the subtitles and reuse them”

Overview

This presentation outlined the key issues facing subtitlers and the on-going work to

improve the quality of live subtitling, including better access to newsroom systems and

scripts, increasing production of block subtitles and the combining of live and pre-recorded

subtitles. David also highlighted the importance of promoting the broader value of subtitles,

for example the role that subtitles can play in Search Engine Optimisation (SEO).

Ericsson’s UK subtitling clients

Background

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As a provider of subtitles, Ericsson / Red Bee recognise the massive explosion in volume

of subtitling on TV. Twenty years ago around 20% of BBC content had subtitles, and of

that only a small proportion was live programming.

There is also recognition of the significant degree of frustration viewers feel with the

services – partly down to quality, but also accessibility of the huge amount of Video on

Demand services. Continuing the work on standardisation in the industry will help

improvements spread across multiple platforms.

Ofcom’s activity, the commitment of broadcasters, and the voice of viewers and users of

subtitles all demonstrate the determination to ensure the UK continues to be at the

forefront of subtitling and accessibility.

How is live subtitling done?

Live subtitling is produced from a combination of text which the subtitler can get in

advance (for example the words which the newsreader is reading from the autocue), using

information from repeated content in live programmes (for example, a video package used

across live news bulletins where subtitles can be re-used), and finally live content that you

cannot prepare in advance and so stenography or speech recognition is needed.

Preparation is key as this allows the subtitles to be presented in sync with the audio at

high levels of accuracy. Knowing what is going to be said in advance is very important, so

access to news room systems and scripts is very important, but not always possible,

particularly on live entertainment shows.

Subtitlers do tend to hear the sound before the viewer, so they have a little bit of a head

start, but when the content is very unpredictable subtitlers need to be very resilient and

good under pressure. The mistakes seen on the screen may be down to many issues

going on in the technology and broadcasting environment.

Challenges and Improvements

Accuracy is clearly very important. If the words on the screen do not reflect what people

are saying it is impossible to understand the content. Even compared to a year ago,

subtitlers are receiving more prepared material in advance, allowing production of block

subtitles, a lower latency and increased accuracy. Stenography and speech recognition is

improving and work takes place to make the software work effectively. The subtitling

industry will benefit from the wider interest in speech recognition, which will inevitably

continue to improve.

Latency needs to be kept as low as possible. Again, prepared text means lower delay. A

news programme has a mixture of prepared and live text, so the delay can be variable. It is

difficult to build subtitles for programmes when you are switching between prepared and

live subtitles and to ensure a smooth viewing experience. Continued learning about the

processes involved will result in smoother transitions.

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Delaying live broadcasts for certain types of programmes is an interesting option but

audience trust may be a barrier particularly when you consider the amount of betting on

sports and entertainment programmes. Audience trust is vital to news programmes as

well. Speed is generally less of an issue in the UK as the methods of production used put

an upper limit on the speed that can be achieved. But it can be a problem when subtitles

are presented very fast. Ofcom’s focus on latency is helpful.

Presentation using block subtitles wherever possible is preferred. Some people do like

scrolling subtitles – they like the immediacy – but block enables the text to be in sync with

the audio. The problem with block subtitles and genuinely live content is that it introduces

an additional delay.

The broadcast chain can be key to delivering subtitles effectively and there is now much

greater awareness of what is needed within the industry. Availability of material in advance

is key. Pre-recorded programmes should have pre-recorded subtitles but this is not always

possible when broadcast material is not received in advance or is received very late in the

day.

There are fewer pre-recorded programmes with live subtitles than in the past, but it is

inevitable that specific programmes will be delivered late, for example if they have very

topical, often legally contentious content, such as Have I Got News For You.

The value of subtitling

In the past, the focus has been on the cost of producing subtitles, but perhaps it is more

important to understand the value of subtitling to a broader population.

Subtitles work well for everyone in a noisy environment. Increasingly we see broadcasts in

public spaces and more and more subtitles are used, not only helping all the viewers, but

raising the profile of subtitling.

Subtitles are a great support for non-native speakers of a language, supporting

comprehension and helping with language and literacy development. Interesting work is

taking place in India on using subtitles to help people learn to read – more research is

needed in this area.

Search engine optimisation helps people find and enjoy content and is very important to

broadcasters - subtitles can be very valuable in this respect, helping people search and

navigate their way around a programme. Broadcasters and video content producers are

beginning to see subtitles as a valuable asset file and are finding new ways of using the

data.

So there is cause for optimism. Audiences and social media bring pressure for more

subtitles, content producers see the value of text files that are complete and accurate, the

technology is getting better and research shows the huge benefits of subtitling. But there is

more to do to generate new knowledge about the broad value of subtitles and text.

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The optimism can only be realised if subtitling is of good quality. There is still a lot of

frustration amongst audiences, but we have an active regulator, we have a very engaged

audience in the UK and we have some very committed broadcasters who have done a lot

of work to make their services accessible.

There are some new challenges around, particularly outside of the traditional TV sphere,

so the debates and our horizons need to be broader. There will be a continued focus on

improving accuracy and reducing delay. Regulation has a role, but it is perhaps most

important to ensure the value of subtitling and access services is recognised – this is the

bigger challenge and the bigger picture.

Presentation: A different approach, a different priority

Dr Pablo Romero Fresco, University of Roehampton

Overview

The University of Roehampton trains subtitlers and re-speakers, engages in research

around subtitles and accessible film making and is currently working with Ofcom in the

external review of the quality of live subtitling. This session outlined the University’s current

subtitling research, including research into accuracy and delays of live subtitling and

optimal positioning of subtitles, using eye tracking technology. Pablo also presented the

University’s pioneering Accessible Filmmaking project calling for integration of translation

and accessibility as part of the creative and production process, rather than a post-

production add-on.

Quality – Live Subtitling

Research shows that the accuracy of subtitles in the UK is good when compared to

Switzerland, France and Spain.

The research methodology developed by the University shows that accuracy and the

impact it has is related to the type of errors appearing in the subtitles. Omission errors

occur because of a very fast speech rate, unscripted shows and speakers talking over one

another. Chat shows are a good example, and the result is the subtitlers are forced to edit

or omit words. One in three errors in such programmes are omissions of full sentences

which has a significant impact on comprehension. Without a script it is difficult to find a

solution. Unscripted chat shows remain very challenging to subtitle.

Recognition errors are related to speech recognition software. Research is looking at the

peculiarities of the English language and will be released soon and shared with

broadcasters and access service providers so that it can influence training and practice.

Latency in programmes that are fully live can have good stretches of 4-5 seconds but

realistically six seconds delay is the norm and is as good as we can expect. Indeed this

compares well to other countries. The combination of pre-recorded and live subtitles has

helped to decrease the delay and increased accuracy. It is not without problems. There is

less continuity for re-speakers which in turn impacts on the performance of the speech

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recognition software. With training, this problem can be solved. The pre-recorded element

of the subtitles can be displayed too fast, in an attempt to synchronise it with the audio.

Research shows that subtitles displayed at 200 words a minute gives you around 20% of

the time to look at the images, decreasing accessibility.

Overall, there are problems but with collaboration, there is the potential to find solutions.

The University research group is always looking for collaborative work with deaf

organisations, broadcasters and access service providers, and for topics to research.

Quality – Video on Demand

Initial research shows that two-thirds of viewers surveyed watch Video on Demand

subtitles. 55% often or very often find them satisfactory. Those that find them

unsatisfactory (36%) tend to note issues to do with formatting and the size of subtitles on

different platforms and different devices.

Inconsistent features cause problems. Some platforms and devices don’t identify the

different characters or speakers, others omit information about sound and music.

Accessible film making

The University have been pioneering an approach to integrate accessibility and translation

as part of the creative and production process, rather than see it as an add-on post-

production. Analysis has shown that 57% of the revenue obtained by the top-grossing

Hollywood films from 2000 to 2014 was provided by language translation and subtitles,

through revenue from foreign markets, but at a cost of only 0.1% of the films’ budget.

The task is to persuade producers that translation and accessibility add value, help find

new audiences, provide meta data for search, and help the way films creatively and

accessibly deal with the increasing presence of text on our screens as an integral part of

the programme or film. Evidence is needed to raise awareness about the value of subtitles

and accessibility.

A variety of activity will help with accessible film making. Translators and subtitlers must

learn about production and post-production and if they wish so, they can also learn to

make films. This is the case in the new MA in Accessibility and Filmmaking at the

University of Roehampton, where students learn how to make films and how to translate

them and make them accessible.

Collaboration with film makers, film schools and festivals means that access service

providers work side by side with film makers from the inception of a project. Accessibility

becomes part of the main production budget, not an add-on. A Producer of Accessibility

would work as part of the film production and post-production – they are part of the

creative process.

Persuading commissioners to adopt this approach can result in it being a requirement of

funding.

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Research has been helping film makers find ways of showing text on the screen,

something that is happening more and more – whether it is an SMS exchange, a thought

process or a telephone conversation. Subtitlers have been looking at how to show text on

the screen for a long time, so there is a lot they can contribute to production.

Eye tracking analysis

Dr Pablo Romero Fresco presenting the University of Roehampton’s eye tracking

analysis

Research is also using eye tracking to understand how people view images and text on

the screen. If subtitles are at the bottom of a screen but the image is of two people further

up the screen then their eyes have to track a long way. Experiments are taking place with

different types of subtitles, integrated closer to where the speakers are on the screen. It

might not be for everyone but results show that most viewers do not take any longer to find

the subtitles and they spend less time reading them, so have more time to take in the

images.

Accessible film making also looks to collaborate over the appearance of text. If a film uses

text on the screen, it helps for the subtitles to appear integrated, to look the same, rather

than a completely different appearance.

Finally, progress with regard to accessible filmmaking has already been made with

filmmakers, production companies and film commissions in different European countries.

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The International Telecommunication Union (ITU), a UN group on accessibility, has

supported the initiative and is considering adopting it as part of their standards.

Dr Romero-Fresco has made the first short film involving accessibility from production, a short documentary on audio description entitled “Joining the Dots”, presented at the International Venice Film Festival in 2013.

Panel discussion: How can we improve the quality of live subtitles?

Graham Willis, Technical Co-ordinator for Access Services, Deluxe

Ian Cottrell, Controller of Broadcast Operations, ITV

Dr Pablo Romero Fresco, Reader in Translation, Accessibility and Filmmaking at the

University of Roehampton

Nathalie Sfakianos, volunteer at Action on Hearing Loss and member of Deluxe’s user

panel assessing the quality of live subtitles

Peter Bourton, Head of TV Content Policy, Ofcom

Simon Pearse, Deaf Access to Communications (DAC), a special interest group of the UK

Council on Deafness (UKCoD) established to campaign for equal access to e-

communicaitons for deaf people.

Introduction by Nathalie Sfakianos

Nathalie shared her experiences as a user of subtitles and member of Deluxe’s user panel assessing the quality of live subtitles. She has worn hearing aids for over 20 years. While subtitles enable her to enjoy pre-recorded programmes, and stay ‘in the loop’ with the latest TV series, live television isn’t accessible. “I have learnt an awful lot about the amount of work that is going into live subtitles… however I have to say that despite all this effort… live television does not often feel genuinely accessible to me”. Nathalie’s role assessing quality of live subtitles involves commenting on accuracy, latency and positioning of live subtitles. “If a mistake is made, sometimes it's corrected quickly, and sometimes it is not. Either way, my mind has to work out whether to wait for a correction, or to move straight on. If a correction is made, then I instinctively hesitate to take in the new word. This means that even if the latency has not been compromised much, the work I have had to do to assimilate what has been said, has meant I am lagging further behind.” Where names, quotations or mouths are covered on the screen, this causes further barriers to understanding the content. “This also leaves less or even no time to look at the pictures. The frustration generated by this can be overwhelming”. Nathalie concluded that even when levels of accuracy, latency and positioning are all deemed ‘above average’ in terms of Ofcom’s guidelines, Nathalie’s experience of that programme is often ‘less than average’. “It might be even so frustrating that I stop watching”.

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Question submitted in advance: “Why is it not a legal requirement for all TV channels to

have subtitles on TV?”

Peter Bourton, Ofcom

When Parliament set Ofcom’s remit, there was an expectation that most TV channels

would be subtitled over time, provided that the costs were not disproportionate. Ofcom felt

that it shouldn’t force channels off air because they couldn’t afford the cost of subtitles,

which would reduce consumer choice.

Ofcom selected two criteria for provision of subtitles, to ensure that they offer sufficient

benefit to viewers, and are affordable to broadcasters: size of audience (a UK audience

share of 0.05%), and an income that enables the channel to cover the cost of subtitles by

spending no more than 1% of turnover.

Question submitted in advance: “My husband and I use subtitling all the time. My issue

is with the subtitles obscuring important on-screen information. During factual

programmes, the identity of a speaker is usually flashed up on screen for audiences to see

- for those of us using subtitles, this vital information is obscured by those subtitles. What

plans do you have to address that situation please, to put us on a level playing field with

the rest of the viewing public?”

Graham Willis, Deluxe

Positioning of live subtitles is one of the many things a live subtitler is thinking about when

producing subtitles including colour, accuracy, editing and pace. An effort is always made

to raise or lower the subtitles when an interviewee’s name or a graphic is shown, or to

avoid obstructing the action of a football match for example.

Simon Pearse, Deaf Access to Communications

Sometimes, for example, travel information on the news is covered up by subtitles. There

should be a way of notifying the broadcasters so they can fix problems there and then.

Simon is working with the subtitle providers and the broadcasters to develop a twitter

reporting scheme and is looking for volunteers to trial the scheme.

Dr Pablo Romero Fresco, University of Roehampton

When the University trains their re-speakers for live subtitles the multitasking they have to

do is already complex. Positioning is one more task to be added to this, and the University

of Roehampton really focuses on this element during training. There is unpredictability as

to whether subtitles will need to be re-positioned as a programme progresses, so while

there are things that can be done, this adds to the complexity of subtitling the content.

Suggestion from the audience: The BBC raise their caption graphics for speakers,

leaving space for two lines of subtitles to go beneath. This is something others can do right

away.

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Question from the audience: Can we legislate so that all new TVs have software that

reads what is being said and produces subtitles automatically?

Peter Bourton, Ofcom

A lot of money is being spent on speech recognition to generate subtitles or text, but the

quality is currently low. Research that was recently presented in Berlin shows that results

are not great, and are often better where the speakers are clearer, for example trained

studio presenters, but for people being questioned by the presenters the quality is poor.

Further down the track it might be a possibility.

Dr Pablo Romero Fresco, University of Roehampton

The research that Roehampton has carried out on automatic subtitling normally shows an

average of between 80 and 85% accuracy. This sounds high but is short of the 98% that

we expect. The main issues are introduction of punctuation, identification of different

speakers and accuracy, especially for fast speech.

Simon Pearse, Deaf Access to Communications

Speech recognition software like ‘Dragon’ can be trained to understand individual voices,

which could be an option to enable newsreaders who are on the TV every day to use

speech recognition to convert their speech directly into live subtitling.

Question from Jean Strauss: Who regulates in-flight entertainment? When I go on long

hauls the English films are not subtitled.

Peter Bourton, Ofcom

No one regulates in-flight entertainment.

Input from Robyn Carter, Caption It New Zealand:

If you are flying to the US there has to be 100% captions on those planes.

Question from Giacomo Pirelli: How can we expand the legislation around subtitling

provision to other countries?

Dr Pablo Romero Fresco, University of Roehampton

A project called Digital TV for All did research in 11 countries in Europe looking at the

possibility of standardising guidelines. The conclusion was that it is very difficult because

there are many different national habits.

In the UK, colours are used for character identification, but in other countries they prefer a name tag, for example, and this goes for most of the features in subtitling. So instead, the focus will be on working with associations in every country individually on a national as opposed to an international basis.

Question from audience: Often with subtitling, the first line is perfect but the second line

jumps, disappears, a word appears and it is very jumbled up, which is very confusing.

What is preventing a perfect two lines every time?

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Graham Willis, Deluxe

The subtitler might identify an error while re-speaking and back-space past that error and

then re-speak. Sometimes Freeview boxes and display boxes do present the information

in different ways, and the bottom line can appear to slightly flicker.

Ian Cottrell, ITV

Those who experience individual technical problems can get in touch with ITV through

Viewers Services. It helps to explain what happened, on what channel and what

programme, so ITV can narrow it down.

Questions from Roy Staines: 1. Subtitles on Freeview HD channels are not scaled to

match with the size displayed on corresponding HD channels through Sky and Virgin. This

results in subtitles being shown at half the size on Freeview, which start from the left of the

screen and only go about halfway across. Can the suppliers consider upgrading their

software? 2. Can suppliers and broadcasters develop customisation features via software

which enables viewers to change subtitle size, font, colour and positioning, as with Apple

TV?

Ian Cottrell, ITV

This might be a manufacturer question, as thinking about the broadcast chain, the

customisation described would have to happen in the display equipment or set top box.

Peter Bourton, Ofcom

There is no single answer for customisation but there are promising signs. Samsung

recently demonstrated the ability to change the size of its subtitles, but this is at an early

stage, so no TVs currently on the market will have this facility. External pressure could

help encourage manufacturers to take action on this moving forward.

Dr Pablo Romero Fresco, University of Roehampton

The University of Roehampton is working on a project looking at customisation of subtitles,

among other issues, called Hybrid Television for All, funded by the European Commission.

The project will run for another one and a half years before reporting to the European

Commission.

Question from Susan Daniels, Chief Executive of the National Deaf Children’s

Society (NDCS): Regarding speed of subtitles, can you give us an example of what might

be too fast? Moving forward might speed become a customisable function?

Dr Pablo Romero Fresco, University of Roehampton

The maximum recommended speed is 180 words per minute. Re-speakers don’t normally

produce subtitles faster than that because speech recognition does not work properly at

faster speeds. The University of Roehampton has found that in chat shows speakers

sometimes speak at 220 words per minute, which is 70 words over the limit, and would be

very difficult to read. Chat shows like The One Show can be very difficult with speeds over

200 words per minute and two or three people speaking at once. This is very difficult and

it’s difficult to change.

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Some experiments will be launched in two months in Switzerland to offer the possibility of

slowing down the programmes. This will slow down the audio and the subtitles a bit.

Another way is to delay the subtitles, which means there's going to be more latency. It's a

difficult one to solve, but the University of Roehampton are looking into it.

Simon Pearse, Deaf Access to Communications

This conversation is focusing on re-speaking, but stenographers are able to achieve a

faster speed.

Graham Willis, Deluxe

Deluxe is showing (in the conference side room) a demonstration of Formula 1 racing.

There is a very high word rate, particularly as the commentators get more excited. The re-

speakers condense the speech to bring out the important information. A viewer simply

could not read subtitling for those kinds of high word rates if provided by stenographers.

Question from Marika Rebicsek: Would it be possible to convey emotive information

which is important to speech in subtitles? It is possible to convey this through sign

language interpretation for example.

Graham Willis, Deluxe

Certain styles can be added to subtitles, for example we currently use italics, we can make

all capitals, we emphasise certain words in a different colour just to make it stand out.

Even though it might not convey the exact intention of the speaker it can sometimes make

it clearer that the word was said in a particular way.

Dr Pablo Romero Fresco, University of Roehampton

There are four elements that we teach subtitlers to add to normal subtitles: identification of

characters, information about sound, information about music and information about the

mood or tone of the speaker, which, for example, conveys the loudness of what's being

said or any potential mood information that can be conveyed.

We have also looked at the extent to which viewers prioritise one of those elements

over another. Mood tends to be the one that ranks lowest after character identification,

sound and music, but we still stress it's important to convey it.

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Presentation: Your views and how we make them count

Tanvir Ahmed, Senior Campaigner, and Laura Matthews, Senior Research and

Policy Officer, Action on Hearing Loss

“In 2013, 69 traditional channels were required to provide subtitles, however there

is no similar regulation for VOD services”

Overview

This session outlined the frustrations of people with hearing loss in relation to provision of

subtitles, and the key barriers to providing subtitles on Video on Demand services, before

outlining Action on Hearing Loss’s research and campaigns work on this issue.

Tanvir Ahmed: Frustrations faced by people with hearing loss accessing VOD

services

There has been a dramatic increase in the number of channels and providers and people

have more choice and channels than ever before. Access to TV is a social activity and

brings people together, but when subtitles aren’t available deaf people are excluded from

engaging with others. It is unfair that people with hearing loss pay the same for platforms

like Virgin and Sky and on demand TV but receive a substandard service.

Laura Matthews: Barriers to providing subtitles on Video on Demand services

Technical

Platforms have been built without enabling subtitles to be shown, so now companies are

having to go back to redesign and retrofit those platforms. There are also problems with

subtitle format – if a programme was aired with subtitles on traditional TV you cannot

always transfer subtitles to Video on Demand, which requires a different format.

Regulation

The 2003 Communications Act places a legal obligation on broadcasters to provide

subtitles on their traditional channels. In 2013 69 traditional channels were required to

provide subtitles, however there is no similar regulation for Video on Demand services. In

2009 ATVOD was given the power to encourage Video on Demand services to become

accessible, but has no power to force services to do so. In America there is much stronger

regulation. Here the Government has said they will only consider regulation if they believe

that progress is not being made voluntarily by the broadcasters and service providers

Action on Hearing Loss campaigns work

Action on hearing Loss works with Government and MPs and ATVOD and Ofcom; they

hold meetings with the broadcasters and Video on Demand services, and the subtitling

companies; they work with other charities including SENSE, RNIB and the UK Council on

Deafness; they talk to supporters to gather evidence and undertake research to

understand what people with hearing loss want.

Action on Hearing Loss’s recent Video on Demand research

Recently 655 people with hearing loss responded to Action on Hearing Loss’s Video on

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Demand research. Three-quarters use subtitles all of the time whilst watching Video on

Demand services, when available. 80% said they would prefer to watch Video on Demand

services on their TV, 37% through a computer or a laptop, 29% through tablet device, 7%

through mobile phones.

Amazon instant video campaign

Action on Hearing Loss supported Stephanie McDermid with her call for more subtitles on

Lovefilm; now Amazon Instant Video. This included encouraging people to sign a petition,

and highlighting a stunt by the comedian Mark Thomas. As a result of this campaigning

Action on Hearing Loss secured a meeting with Amazon, to discuss their plans for

subtitles, where Amazon said they are committed to providing subtitles and that work was

already underway in this area and that they are hoping to announce improvements shortly.

The session ended by encouraging delegates to give feedback to broadcasters, who often

tell Action on Hearing Loss that they don’t receive much feedback and so don’t recognise

any problems with the service they provide.

Presentation: Technical challenges and success on the BBC iPlayer

Gareth Ford Williams, Head of Accessibility, User Experience & Design, BBC Future

Media

“Over 500,000 programmes a day are viewed on iPlayer with subtitles”

“With iPlayer, we lead by example, but there is a lot of work still to do”

Overview

This session looked at the challenges that have been overcome to make the iPlayer

accessible on over one thousand devices, revealed the huge audience for subtitled

programmes on iPlayer, and outlined new research into the positioning of subtitles and

plans to provide subtitles on video clips. Gareth also shared the work BBC Future Media

do to support ATVOD in their regulation of Video on Demand providers and urged viewers

to provide feedback to the BBC.

Background to iPlayer

iPlayer is a Video on Demand service and appears on four screens (TV, tablet, PCs and

mobiles) across multiple platforms including YouView, Freesat, Freeview, Virgin TiVo,

Xbox 360, Windows, Sony television and LG Smart TV and thousands of different devices.

Accessibility has always been a fundamental part of iPlayer, from the early stages of

development in 2003 to the launch in 2008.

Overcoming challenges

iPlayer was built on a framework of other people’s technologies and standards, so they

had to engage with a wider industry to ensure the iPlayer was accessible across

thousands of devices and platforms. Since 2010 the technology has been there to provide

subtitles across all platforms. BBC Future Media works with manufacturers of devices

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including games consoles and mobile phones to ensure they are accessible, including

recently with the developers of the Google’s Chromecast second screen media streaming

device

Platforms that BBC Future Media works with

Where other organisations are getting it right, iPlayer uses their technology rather than

‘reinventing the wheel’, e.g. subtitle facilities were already good on the iOS.

Since around 2010 availability of subtitles has been part of the approval process for getting

iPlayer, for example when providers want to launch a TV in the UK with iPlayer pre-

installed on it. BBC Future Media has some quality gates that a dedicated accreditation

team test against. The tests are given to the supplier and who send them the

implementation. If it meets the required standards then they get given the green light.

Demand for subtitles on iPlayer

BBC Future Media recently began monitoring use of subtitles on iPlayer and early findings

indicate that over 500,000 programmes a day are viewed on iPlayer with subtitles switched

on, which is an enormous audience.

Current projects

BBC Future Media is currently carrying out research into the position of subtitles on

iPlayer, to give a better user experience. Prototypes are currently being built and tried out

by research participants, for example positioning subtitles at the top of the screen to avoid

obscuring the picture.

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BBC Future Media’s research into the positioning of subtitles

They are also currently looking at solutions for offering subtitles on clips. The challenges

are wide-ranging, including the issue that clips are obtained from a very large range of

sources, and it may not be possible to reuse previous subtitles.

Regulation

The BBC is exempt from Ofcom and ATVOD regulations, and instead is regulated by the

BBC Trust, which has very strong regulations. BBC Future Media works closely to support

ATVOD, with three members of BBC staff on the ATVOD technical working group. In this

capacity BBC Future Media meets and shares information and learning from their

experience with iPlayer with other broadcasters.

User feedback

Gareth appealed to subtitle users to give more feedback about their experiences of

subtitles, and not to be put off by the automatic reply when they complain. Whilst they

cannot respond to everyone, all feedback goes to their product teams. They identify

patterns, e.g. if 5 people raise a similar problem, this is flagged as something they need to

investigate.

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Presentation: Encouraging improvements

Peter Johnson, CEO, Authority for Television on Demand (ATVOD)

“Sometimes it appears nothing is happening over a long period of time and then a

lot happens, and I think that is what progress is going to look like in the Video on

Demand world over the next few years”

“On the basis of what I have been told in these meetings I think we can expect to

see some quite significant progress over the next 12 to 18 months”

“They are not things that can’t be solved, just things that take effort and changes to

work flow and money to get around”.

Overview

ATVOD outlined their work encouraging Video on Demand (VOD) providers to provide

subtitles, such as bringing together a large number of stakeholders including broadcasters,

manufacturers and platform operators to identify workable solutions to the technical

barriers of providing subtitles on Video on Demand services.

Who are ATVOD?

ATVOD is a co-regulatory body which means they try and work in partnership with

industry. They were designated in 2010 by Ofcom and their duties include encouraging

service providers to make their on demand programme services more accessible to people

with disabilities relating to sight and/or hearing.

ATVOD regulate just over 100 UK-based Video on Demand services including TV catch up

services such as 4oD and ITV player. They also regulate a number of movie on demand

services including Amazon Instant Video and Picturebox and music Video on Demand

services like MTV and specialist niche services, including those offering sports videos or

adult content. They do not regulate platforms such as YouView because they do not

provide Video on Demand content themselves.

ATVOD is a small organisation with the full time equivalent of under four staff members.

How does ATVOD encourage improvements?

ATVOD has a duty to ‘encourage’ but this does not come with any powers to compel. They

cannot set quotas for on demand services, but use soft powers of encouragement.

They encourage through monitoring provision, direct encouragement, publishing

information and guidance, and facilitating industry and stakeholder engagement to find

solutions.

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Key challenges

An illustration of the complexity of delivering accessible Video on Demand content

With many different devices offering Video on Demand content, distribution chains for

Video on Demand are complicated. There are many different platforms and different

aggregators working with a range of content providers. Although a particular piece of

content may have appeared with subtitles when originally broadcast on television, this

does not mean that the problem has been solved for making that content appear with

subtitles on Video on Demand.

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Working with industry to find solutions

Members of ATVOD’s Access Services Working Party

ATVOD established an Access Services Working Party to help identify the priorities and

develop best practice guidelines, which were published in 2012. Following this ATVOD

established a Working Group on Access Services which looks particularly at technical

issues.

The range of stakeholders that ATVOD collaborates with includes advocacy groups like

Action on Hearing Loss and Sense, technical specialists and Video on Demand providers

and platforms. Having everyone in the room together enables content providers,

manufacturers and platforms to identify how they can work together to make subtitles

available. For example, if a set top box operator is in the room with a content provider,

they can have a discussion about the most appropriate format to provide subtitles.

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ATVOD’s current work encouraging providers

ATVOD’s key Video on Demand targets

ATVOD’s Access Services Plan , which takes them through to 2016, identifies the key

priority services to focus on in the next three years, based on those which will have the

most impact on viewers. The regulator also works with Action on Hearing Loss and RNIB

to ensure that these priorities align with the priorities of stakeholders. Moving forward,

focus will be on those 12 or 13 broadcasters who have quota requirements for linear

broadcasting and also provide a Video on Demand service. ATVOD will also focus on

those offering premium movies on demand.

Over a three month period Peter personally had meetings with 23 different key targets to

discuss their plans and the progress we can expect to see over the next 12 to 18 months.

Although ATVOD do not regulate platforms such as YouView, YouTube and the games

consoles, ATVOD include these platforms in their conversations.

Survey of VOD provision

ATVOD have conducted an annual survey of Video on Demand provision since 2011.

Completion of the survey became compulsory in 2014 therefore ATVOD is expecting a

very comprehensive picture of the level of provision this year, as those providers who were

previously reluctant to respond have been obliged to do so. The report is due to be

published before Christmas.

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The survey will highlight areas of best practice and areas where improvement is needed.

Monitoring is a way to create a ‘healthy competitive environment’ for the provision of

access services.

Developing a common format for the provision of subtitles

In the last few months ATVOD has published the first technical report of their working

group on access services .The report concludes that there are no fundamental technical

barriers to the delivery of subtitles with on demand content, and makes an industry

recommendation to adopt a common format for the provision of subtitles in order to make

overcoming some of those technical barriers much easier.

The group has recommended that industry adopt the EBU Timed Text subtitle format2 in

all relevant parts of the delivery chain to significantly simplify workflow issues. The report

also recommends that pre-existing subtitles for acquired programmes be free at the point

of content exchange.

“If everyone is working to the same format you don’t have to keep reinventing the wheel

each time; it will work because somebody else has already made a platform or device

compatible with that particular format. That’s a really important development…”

Regulation

Parliament decided that there should not be quotas around accessibility of Video on

Demand services at this early stage in the development of the Video on Demand industry.

In 2013 a DCMS strategy paper stated that industry would be given three years’ grace in

order to demonstrate progress could be achieved voluntarily with a promise of a review in

2016 with the option of legislation (see page 22). ATVOD hope to demonstrate to DCMS

that a co-regulatory body working in partnership with stakeholders can deliver real results

that improve accessibility of Video on Demand services in that time period.

Commercial providers

To date, Public Service Broadcasters have led the way, but ATVOD hope that commercial

broadcasters will begin to catch up. Once one commercial provider begins to provide

accessible services others could follow. Amazon, for example, have announced that they

expect to begin rolling out subtitles before the end of 2014 and ATVOD have been told by

other commercial providers about imminent developments.

Some commercial services signed contracts for content some years ago which did not

include specifications around access services, meaning they now do not have the rights to

create access services themselves. Some of these services are now going back and

buying the rights, and making sure that new contracts specify subtitling requirements.

2 EBU-STL subtitles files refers to the European Broadcasting Union format for broadcast subtitles files.

Timed-text subtitles files refers to the W3C format for providing standardized timed-text files that synchronise with other elements, such as audio and video files, and software and hardware devices.

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Looking to the future

On the basis of discussions this year, we can expect to see some quite significant

progress over the next 12 to 18 months. When a provider solves a problem, this enables

them to suddenly start a level of provision and then things begin to develop significantly.

We can expect to see public service broadcaster content becoming even more accessible,

and subtitles being made available for the first time on apps for mobile phones and tablets.

Panel discussion: How can we increase the amount of subtitles on Video on

Demand (VOD) services?

Gareth Ford Williams, Head of Accessibility, User Experience & Design,

BBC Future Media

Peter Johnson, CEO, The Authority for Television on Demand (ATVOD)

Alex Varley, CEO Media Access Australia

Lidia Best, Chair of NADP and UKCoD Trustee

Laura Matthews, Senior Research and Policy Officer, Action on Hearing Loss

Question submitted in advance: “As a person who is hard of hearing, why am I charged

the same subscription costs as a hearing person when I cannot enjoy most of the films and

content that are not provided with subtitles. It is discrimination”

Peter Johnson, ATVOD

ATVOD does not have any powers to impose quotas on Video on Demand providers or

powers to impose particular pricing policies, but when more of a competitive environment

begins to emerge this may change. “I think we are now moving into a new position in

which some commercial broadcasters are going to be providing subtitles and I hope some

of the set top box operators will be providing access to subtitle content as well, so people

will then be able to vote with their wallets and sign up to those set top boxes and

subscription services that do offer subtitles”.

Lidia Best, Chair of NADP and UKCoD Trustee

“You buy a service at the same price as everybody else so you expect the level of

service.” “If we do not complain they just do not see it”. It is important for customers to

complain and put more pressure on providers, for example by asking for subtitles before

buying the service.

Laura Matthews, Action on Hearing Loss

“This demonstrates the real need for information about whether subtitles are available so

that people can make an informed decision when they are signing up to a new subscription

service or choosing to download or stream a film. There is some consumer protection

under our consumer laws – if you reasonably expect a product to have subtitles, for

example, if you know it was available with subtitles when shown on traditional television,

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then it might be realistic for you to expect that there are subtitles when it’s shown on Video

on Demand.”

Question submitted in advance: “Why can't subtitles work on the live programmes on any of the BBC, ITV, Channel 4 and Sky channels on the computers?”

Gareth Ford Williams, BBC Future Media There isn’t anything technically that stops subtitles working on live programmes, you just have to understand the work flows and contracts that need to be in place to enable you to do it. BBC Future Media’s first priority has been to focus on making pre-recorded and downloadable content accessible. “It will happen, just give it time and we will get there”.

Question from Susan Daniels, Chief Executive of the National Deaf Children’s

Society (NDCS): How long are we going to have to wait for a voluntary model to work? As

a regulator you don’t have very much power so the only solution is for much tougher

regulation. It seems we could be waiting for another 10 years for all broadcasters to get up

to scratch, by which time technology will have moved on substantially and we’ll be playing

catch-up yet again

Peter Johnson, ATVOD

Under the European directive covering on demand services, member states are required

to have measures in place only to encourage provision. The UK Government chose not to

go further than this requirement and so established ATVOD as a co-regulator with powers

to encourage provision. The Government reviewed its position between 2011 and 2013 as

part of the communications review, and the outcome of that was a strategy document in

which the DCMS gave the industry until 2016 to improve access voluntarily, whereupon it

will conduct another review (see page 22). At this stage a legislative approach will be

considered if sufficient progress has not been made.

We’ve seen the US move to mandatory provision very recently for Video on Demand, so

there’s a precedent there. ATVOD can only encourage as much as it can with the powers

it has.

Gareth Ford Williams, BBC Future Media

The issue of technology evolving is the ‘elephant in the room’, and BBC Future Media are

concerned about this. There is an enormous area that is not being regulated around the

provision of apps. BBC Future Media has an increasing number of interactive children’s

apps: the story time app, the play time app, the Doctor Who app, and a lot of them have

very strong learning outcomes. We need to ensure that deaf children are not left out and

BBC Future Media have started looking at this with NDCS. There need to be guidelines on

delivering access services on these new formats.

Alex Varley, CEO Media Access Australia

The last thing broadcasters want is regulation, which puts barriers in front of them, so this

is an opportunity to negotiate.

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Bear in mind that the context is different in the USA. Taking the Netflix case3 as an

example, there is a culture of suing in the USA which doesn’t exist in the UK. Legislation

covering Video on Demand in the USA4 came through when Barack Obama came to

power and there was a lot of goodwill but “the people in the US tell me now there is no way

on earth that would ever happen again under the current conditions”.

It therefore may not be possible to emulate the US model, so the UK campaigners should

focus on their own model and opportunities “The Government said if they aren’t doing the

job properly by 2016 they probably need to regulate. Why don’t you spell out what it should

be and talk to them about how they can achieve that?”

Question from the audience: “I'm the parent of a deaf teenager, she is 15, doing her

GCSEs at school today so I'm representing her. The question she wants me to put forward

to Gareth is at school her teachers use a resource called Class Clips, which is part of BBC

Bite Size and Florence tells me none of these clips are subtitled. Her support assistant

spends a lot of time transcribing and has to rely on the teacher giving advanced notice of

using a clip. The time that she's transcribing she can't be with Florence supporting her in

class or doing it in her own time. My question is, appreciating the fact you said subtitling

clips is difficult, I wondered if there was a way of pooling the resource. I'm sure there's lots

of support assistants all around the UK are doing the same thing.”

Gareth Ford Williams, BBC Future Media

This is one of the research projects BBC Future Media is currently conducting. With so

many thousands of clips on Knowledge and Learning it is a huge issue. Nearly all clips are

taken from broadcast content originally, and there is a research project at the moment to

try to realign the subtitle work back from the original content. “We think we have come up

with a solution for it. I don’t know how long it’s going to take for it to come out, but it’s

something we are working on.”

Alex Varley, CEO Media Access Australia

Access Australia has started to expand its catalogue of different educational resources

globally that have subtitles on them. See www.mediaaccess.org.au

Question from the audience: Firstly regarding Video on Demand, the issue is we are

paying full price for a contracted service. We’re subscribing to this and it is not an excuse

that it’s on the way. We should be expecting 100% for a 100%. The second thing I would

3 During 2012 the American charity, the National Association of the Deaf (NAD), won a lawsuit against the

online movie provider Netflix. As a result Netflix have to increase the amount of subtitles available on their streamed programming 4 Legislation was passed in October 2010 which requires all subtitled TV programmes to be subtitled when

later delivered over the internet. This is known as the Twenty First Century Communications and Video

Accessibility Act. If a programme is shown on the TV with subtitles, when it is then made available on the

internet, subtitles must also be available. From September 2013, this also includes programmes that are

substantially edited before being made available on the internet.

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like to raise is with the BBC is why are BBC Parliament, BBC news online and other

channels mentioned still inaccessible to people in this country that are deaf?

Gareth Ford Williams, BBC Future Media

Clips are hugely problematic because, for example, if a clip is taken from live news, we

know there is a tendency for the subtitles and the clip to be out of sync. If a clip is used,

you might end up with five seconds of irrelevant content that came before the clip and five

seconds missing off the end. When the news team make the clip they “take a bit from

here, a bit from here and it is turned around very, very fast”. The format on broadcast

cannot be used online, because the two technical formats do not work.

Thousands of clips are published every day, so scale is an issue, and there is a reluctance

to go back into production and produce new subtitles for news which becomes ‘old’ the

same day. Therefore the solution will need to work automatically, as part of the desktop

process. BBC Future Media is putting a lot of investment into this and the Research and

Development team currently have eight people purely working on subtitle projects.

Peter Johnson, ATVOD

Whilst it is frustrating to pay full price for a product that is not accessible, we do not want

the situation where it is acceptable to provide a lesser product at a cheaper price, for

example by encouraging services providers to offer a lesser service and ‘take a hit on

revenue’. The focus should be on getting the level of subtitles on Video on Demand vastly

increased; and we are moving in the right direction. “You do not want to get a situation

where it is acceptable to provide a lesser product at a cheaper price; second rate

services”.

The 2016 deadline should focus our minds, as most service providers would rather not

have a quota imposed on them. The focus should be on getting the major Video on

Demand services to increase their level of subtitling and to keep the pressure up until the

level of subtitling is 100%, and not think about settling for a cheaper product which is not

as good.

Question from Joanna Wootten: I hate rubbish subtitles. What I am interested in

knowing is what is reasonable progress - is it 100%? Is it 80% and is there anything

anybody in this room can do to help to define what reasonable progress is by 2016?

Laura Matthews, Action on Hearing Loss

Part of the reason why we are holding this conference is to try and establish what people

do think will be reasonable progress. So after this conference, we will be pulling together

everyone's views, thoughts and comments, and feeding them back to the Department for

Culture, Media and Sport about what do we want to see by 2016.

Lidia Best, Chair of NADP and UKCoD Trustee

We all need to help define what reasonable progress is. Before services are launched we

need to ensure that accessibly is something that they are budgeting for from the

beginning.

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Simon Pearse, Deaf Access to Communications

1. Some of the BBC content on Netflix has no subtitles despite having subtitles when

broadcast terrestrially. Is there a way that providers can be pushed to ensure their content

has subtitles rather than requiring the VOD provider to pull the subtitles from the providers

of the content?

2. What are your thoughts on people in the UK accessing content from the US through

VOD providers such as Netflix to access subtitled content when it is not available in the

UK?

Alex Varley, CEO Media Access Australia

Piracy is the big word in the industry. 200,000 Australians supposedly watch subtitled

Netflix from other continents. The long term solution is to manage accessibility on an

international basis rather than doing it country by country.

Peter Johnson, ATVOD

Some of the conversations we've had with aggregators who buy content from some

Hollywood studios for example reveal that sometimes the access services are part of the

deal, but sometimes it's not even part of the conversation about whether the access

services that already exist will be included in the deal. Sometimes they ask for significant

extra funds for the access services file even though they don't feel they can pass on that

added cost to the consumer.

There is a conversation about creating a standard operating practice, if a content has had

a subtitle file created for it, should it be possible for the provider to withhold that when that

content is passed on to an aggregator or a platform or should there be a requirement to

make that available free of charge. A lot of this content is being created in one territory

and distributed in another. It's not something we can solve on a national level.

Gareth Ford Williams, BBC Future Media

BBC worldwide would hold the contract with Netflix, not the BBC. BBC worldwide is a

subsidiary part owned by the BBC, and usually they stick with our policies on delivery. The

question will be put forward to them.

Question from the audience: Subtitling on international flights came up earlier. Should

we have a group for lobbying on things internationally from countries around the world?

Lidia Best, Chair of NADP and UKCoD Trustee

The International Federation of Hard of Hearing People (IFHOH) together with the World

Federation of the Deaf are lobbying for captioning worldwide. EFHOH is hoping that

European Accessibility Act will bring stronger laws but it is still work in progress.

Peter Johnson, ATVOD

I think the international dimension is extremely important. Even if quotas were imposed,

they will only apply to companies based in the UK; it wouldn't apply to Netflix for example.

Where services span the borders, the solution ultimately has to be an international

solution.

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Question from the audience: I am able to customise my subtitle experience on the Apple

TV box. As an end user, optimisation and customisation is always going to be an easier

solution. Can iPlayer learn from Apple TV box types of services and in the operating

system itself? I would hope that integrated iOS systems such as that would become the

norm for the end user.

Gareth Ford Williams, BBC Future Media

In 2007/2008 BBC Future Media was looking at developing customisation options, but the

problem was that it didn’t work at scale, and cost became an issue. The broadcaster

started looking at platforms like Virgin etc. who use connectivity via apps on iOS and

android devices, where you can add customisation. iPlayer is taking advantage of these

operating system level customisation frameworks, and supporting them. One of the most

interesting opportunities around customisation coming up is about the ‘Connected Home’.

Next steps

This conference made clear the importance of subtitles and the urgent need to ensure that

all TV content is genuinely accessible to people with hearing loss, regardless of how and

when it is viewed. As outlined at the event, the Government has stated that it believes

voluntary initiatives will see provision of subtitles improve and increase, particularly on

video on demand services, but that without significant progress by 2016 they will consider

legislation.

They have not, however, stipulated what ‘significant progress’ looks like. The outcomes

and discussions at the conference will be used to seize this opportunity to set out the

improvements that people with hearing loss demand so that if necessary we are ready to

fight for the legislative framework needed to ensure that they do not continue to be left

behind by developments in the way that people watch television.

The conference provided a forum for viewers, broadcasters, regulators and providers to

come together, and we look forward to seeing further improvements in the coming months

and years in a range of areas including:

Improvements in technology

Greater co-operation between subtitlers, programme makers, broadcasters and

platforms

Viewer control over customisation of how subtitles appear on the screen, to suit

their specific needs

Up to date, evidence based guidelines on producing subtitles

Recognition of the value of subtitling, beyond simply improved access for people

with hearing loss

The conference organisers look forward to working with all stakeholders across these

themes to build on the fantastic advances that have already been achieved and to deliver

the improvements to subtitling that people with hearing loss are demanding.