On June 4, 2012, the National Association of the Deaf (NAD) led a number of organizations and consumer groups in submitting comments in response to a Public Notice issued by the Federal Communications Commission (FCC) on the accessibility of closed captioning controls on devices and equipment.
The Twenty-First Century Communications and Video Accessibility Act (CVAA) directs the FCC to mandate access to closed captioning features on both video programming equipment and navigation devices through mechanism that is “reasonably comparable to a button, key, or icon” designed specifically for activating closed captioning features.
Closed captioning controls must be easily accessible, in order to prevent navigation through unfolding maze of menus, or prevent users from having to turn on/off a device in order to access closed captioning controls.
The closed captioning control is a mechanism that is used to turn on/off closed captions and/or customize size, color and positioning, among many other features. The NAD, along with other consumer interest groups, believes that closed captioning controls need to be treated with a role that is equivalent to that assigned to current volume controls.
If a physical button on the device or remote raises or lowers volume, then there should also be a physical button to access the closed captioning control. If users control the volume inside a program, then the closed captioning control needs to be placed adjacent to the volume control.
Hearing people rely on the ability to quickly adjust the volume of programs, particularly if someone is speaking softly, or if there is background noise in the surrounding environment. Deaf and hard of hearing people have similar experiences and often face situations where the closed captions cover important on-screen text such as an important news headline or sports box score and need to quickly turn off the closed captions to read the text, and then quickly turn the closed captions back on. Consumers also need information about which programs are captioned prior to viewing video content. Oftentimes, deaf and hard of hearing people simply do not know if the content is accessible until after they’ve watched 30 seconds to a minute of non-captioned advertisements.
In comments submitted to the FCC by the NAD and other consumer groups, it was recommended that the closed captioning control be accessible at all times. Additionally, it is important that users do not have to turn on / set up the closed captioning every time they use a device, but that their closed captioning settings remain the same even when the unit is powered on and/or off.
Please feel free to read the comments we submitted in response to the FCC Public Notice here and here.