Comment (Including rationale for any proposed change):
The purpose of the following LC Comment is to highlight issues that we believe warrant further consideration by the Web Content Accessibility working group before assigning a Level 1 requirement to Guideline 1.2.1: "captions are provided for prerecorded multimedia," particularly as the WAI's Web Content Accessibility guidelines are used as the benchmark for web accessibility by government and other policy-making bodies.
AOL LLC fully understands and supports the need for captioned multimedia, and we do provide the same on several of our highly trafficked areas. AOL was the first commercial Internet Service Provider to offer captioned video. Today, we provide captions for two cartoon series "Princess Natasha" and "SKWOD" on KOL, AOL's online channel for kids ages 6-12, and on video help tutorials developed for the AOL 9.0 software. Additionally, we are currently testing delivery of captioned news and entertainment content through our video portal. We continue to work hard at this area, and plan on announcing further such developments as they take place.
Technologies such as SMIL, Microsoft's SAMI and Apple’s QuickTime all enable display of closed captions on multimedia, and tools like Caption Keeper from the WGBH Media Access Group can be used to repurpose Line 21 television caption data. However, AOL's research to date shows that the acquisition process and production model for the majority of video content distributed by commercial Internet portals such as AOL LLC does not support cost-effective and efficient processes for delivery of closed captions in a timely manner. A collaborative effort between the Internet industry, content producers and web accessibility experts is required to develop solutions before commercial web portals can fully conform to this Level 1 requirement to caption prerecorded multimedia. Guideline 1.2.1 assumes that the web site displaying the multimedia content is the producer of the content. What is not considered is the barriers created by the process of acquiring repurposed third party content, or who is responsible for captioning content produced by a third party and distributed via multiple web sites/services. While AOL LLC has made substantial progress towards captioning of our video content, there are three barriers inhibiting AOL LLC's goal of complete conformance to a Level 1 success criteria:
i. Internet production units of broadcast networks prepare the content for streaming before the content is captioned, usually in real time. For example, field packages produced for TV networks' nightly newscasts are often streamed before they air. As a result, Internet portals receive the video asset too far up stream in the content production workflow. This presents two possible scenarios:
- A content aggregator (Internet portal such as AOL's) needs to manually caption a video stream produced and owned by a separate content provider. Neither is this scalable, nor are vendor solutions robust enough at this point (e.g leveraging a programmed transcript which only provides the text of the audio, and excludes ambient sounds and time stamp data).
- Captions are added to the streaming video long after it has been published to the web site assuming the portal and partner repurpose the captions originally created during the TV broadcast. This is problematic as some videos have a very short shelf life.
ii. Lack of information on the whereabouts of existing caption files when broadcast content is repurposed for the Internet. There is an increasing amount of "video on demand" products online that allow people to view archives of current or old TV series, movies, music videos, short films, etc. It is very likely that most of the content has been captioned. Unfortunately there isn't a central database that Internet portals or content partners can search to locate the caption agency who captioned a particular season of a show. It is important to note that the content provider to the portal may not always be the content producer or the entity responsible for captioning the content for television.
iii. Need for a common delivery protocol. Commercial Internet portals receive video from many of the same content providers (broadcast networks, etc.). Internet production units are generally very small in terms of staff so delivering multiple text formats to multiple portals is not feasible. Solutions are required to ensure content providers can deliver caption data in an efficient, cost-effective manner. This is a solvable problem, but identifying solutions will require cooperation from many players.
AOL LLC proposes changing the Level 1 Success Criteria for Guideline 1.2, namely 1.2.1 and 1.2.2, to Level 2 Success Criteria. This change reflects the ground realities of being a content aggregator on the Web. This proposal is necessitated by the current reality that content aggregators on the Web partner with multiple content providers. Issues such as who is responsible for producing captions, delivery of caption text files and other barriers described above must be addressed before policy-making bodies can effectively leverage this guideline. Alternatively, we recommend adding language which recognizes the current barriers to wide scale availability of captions for prerecorded multimedia, and encourages development of solutions to resolve them.
The working group considered carefully the levels assigned to all the GL 1.2 success criteria. SC 1.2.1 and 1.2.2 are level A success criteria because vision and hearing impaired users will not be able to access multimedia without this information. SC 1.2.2 can be satisfied by a full transcript. But captioning is a much better augmentation for the deaf than a separate transcript, since much can be communicated non-verbally, even when there is no action.
The working group acknowledges that current acquisition process and production model for the much of the video content distributed by commercial Internet portals creates a problem in creating captions for time-sensitive material in a timely manner, and that this may present a near term barrier for multimedia that is time-sensitive.
However, without captions individuals who are deaf or hard-of-hearing cannot access multimedia, and AT cannot compensate for lack of captions. There are other alternatives, like full text alternatives, but they face similar issues and are less useful to people who are deaf. WCAG conformance is also based on the state of the content, not the process by which it is produced. Captioning therefore belongs at Level A.
We have added the following language to How To Meet SC 1.2.1 that recognizes the current barriers to captions.
"It is acknowledged that at the present time there may be difficulty in creating captions for time sensitive material and this may result in the author being faced with the choice of delaying the information until captions are available, or publishing time-sensitive content that is inaccessible to the deaf, at least for the interval until captions are available. Over time, the tools for captioning as well as building the captioning into the delivery process can shorten or eliminate such delays."