DeafHear Submission to the Broadcasting Authority of Ireland. Access Rules Review Public Consultation July 2014

Transcription

1 DeafHear Submission to the Broadcasting Authority of Ireland Access Rules Review Public Consultation July Introduction DeafHear is a national organisation that provides a range of services to Deaf and Hard of Hearing people and advocates for better access to services in the wider community. 's Vision is of an inclusive society where Deaf and Hard of Hearing people are fully integrated, with equality of opportunity and participation. DeafHear s role is to make this Vision a reality by promoting the equal rights of Deaf and Hard of Hearing people and enhancing their life opportunities. Broadcasting services are a vital aspect of modern life in terms of access to information, recreation and education. Television broadcasting services are particularly important to Deaf and Hard of Hearing people. Television programmes need accessibility features such as subtitling and sign language presentation to enable Deaf and Hard of Hearing people to understand and enjoy them. There are over a quarter of a million people in Ireland with a significant disabling hearing loss and approximately 5,000 people whose first language is Irish Sign Language (ISL), and these people require subtitles or Irish Sign Language interpretation to access and enjoy television programmes. DeafHear, in its Access Rules Review submission to the BAI in January 2012 described how typically 3% of any television audience require subtitles to access and enjoy the programme content. 2. Question 1: Proposed changes to the Subtitling Rules In our 2012 submission we argued that the Public Service Broadcaster should be mandated to provide 100% of programmes with subtitles, as this could be done with a small increase in resources (less than 1% of programme production costs) relative to the number of beneficiaries (3-15% of television

2 viewers). The BAI have never responded to our rationale, nor have they addressed the additional points we made. For example, DeafHear argued that it was important to move from a perception of subtitles as an addon access feature of programmes to one where subtitles were are as an integral feature of television programme production (at least for Public Service Broadcasters). This could help in overcoming resistance and scepticism that may exist among certain broadcasters (OCS 2009 report on Access Provision A Human Resource Analysis, commissioned by the BAI). But the situation remains unchanged due to a combination of a lack of leadership, vision and/or understanding on the part of the BAI. In effect the BAI are proposing that the day when the Public Service Broadcaster will be obliged to provide 100% subtitling is at least five years away. If the BAI have their way, it probably won t be achieved until sometime in the 2020s! The critical issue at stake is that this approach sustains a culture among broadcasters and programme makers of viewing access features as a burden on programme production, rather than a core feature which will contribute to audience satisfaction and enjoyment, (and provide more equitable access to television programmes for Deaf and Hard of Hearing people as prescribed in the UN Charter for Persons with Disabilities). Evidence supporting this view that subtitles and other access features are an add on burden to programme makers comes from the operation of the BAI Sound and Vision Scheme. While it is mandated that projects funded under this scheme must be broadcast with subtitles, on at least three occassions in the last 18 months DeafHear has informed the BAI of breaches in this regard, (and we have only been able to monitor a small number of such programmes). Furthermore, while the BAI encourages applicants to the Sound and Vision programme to include access features such as audio description and Irish Sign Language, not one such example has been forthcoming. DeafHear urges the BAI to show leadership in regard to access to broadcasting services for people with disabilities. We urge the BAI to move to a point where Public Service Broadcasters must provide 100% subtitling services, at least on major channels. At the very least we urge the BAI to mandate this for RTE 1 within the lifetime of these proposed rules i.e. by We do not believe that this would require an unreasonable additional cost to RTE. DeafHear believes that if the BAI were to adopt this proposal for RTE 1, this would demonstrate real leadership and commitment to the development of Access Features on television. It would help convey to broadcasters, programme makers, and the wider public that on at least one television channel, subtitling is a core programme production and broadcast element. It would send a message to policy makers and the wider public that the BAI is serious in endeavouring to provide equal access to television services for people with disabilities. It would help to create a more enlightened culture towards access services both within broadcasting and in the wider community.

3 Question 2: Proposed targets for audio description. DeafHear notes the failure to date to meet the targets prescribed for audio description. We accept the views and comments of our colleagues in the TV Access Coalition who represent people who are blind and visually impaired in relation to the provision of audio description. Question 3: Proposed targets for Irish Sign Language. Firstly, DeafHear welcomes the progress made by RTE in 2013 in increasing the volume of programmes available with Irish Sign Language presentation, and notes that for the first time in 2013 RTE surpassed its target in this area. We also welcome the BAI proposal for Irish Sign Language presented programmes on RTE Junior for the first time, and for the increase in the target percentage of Irish Sign Language presented programmes on RTE 1 and RTE 2. However, we are concerned and surprised that there is no guidance or commentary in the consultation document or in the BAI proposal on targets for Irish Sign Language provision on the balance between mainstream programmes with Irish Sign Language presentation and programmes produced and aimed primarily for the interest of members of the Deaf Community and presented in Irish Sign Language. Also, there is no guidance on the balance and nature of mainstream programmes to be presented in Irish Sign Language. DeafHear is aware that many members of the Deaf Community are concerned at the dumbing down nature of the News for the Deaf, which is an extremely abbreviated form of the news of the day. This can also convey a message to others that a basic news service is sufficient for Deaf people, with obvious associated outcomes. These range from impacting on the esteem of individual members of the Deaf Community, to a lack of respect and understanding of Deaf Culture and Irish Sign Language. Is it any wonder that many hearing people think that Irish Sign Lanaguage is not a real language? Also, the News for the Deaf service incorporates no reporting, simply a newscaster reading a script and a person signing the content. DeafHear urges the BAI to insist that within the extended proposed targets for Irish Sign Language, RTE extend the present News for the Deaf programme to at least double its present length, incorporating at least one external news report within the bulletin. DeafHear believes that this is important not just to Deaf people, but also for wider public awareness, perception and expectation of what constitutes fair and reasonable public service to Deaf people. DeafHear would accept a proposal to introduce this in 2015 to give RTE time to prepare accordingly. We believe there would be minimal additional costs involved. In recent years there have been some omplaints to RTE in relation to the standard of some Irish Sign Language presentation on RTE. It is important that presenters have the necessary competencies and skills, which at a minimum should include a Level 4 Irish Sign Language qualification and a high level of

4 accomplishment in translating from English into Irish Sign Language. We also suggest that Irish Sign language presenters on television would be assessed and accredited on a regular basis by a panel which included a number of Deaf people. Finally, there is no guidance on the balance of mainstream programmes to be presented in Irish Sign Language. To date, while the increase in Irish Sign Language presented programmes in 2013 was most welcome, all of the programmes were in the light entertainment category. A proportion of the proposed target should include an element of Irish drama. DeafHear believes that many members of the Deaf Community would be thrilled if Fair City was broadcast with Irish Sign Language presentation. Question 4: Proposed changes to compliance. DeafHear welcomes the comments within the BAI consultation document regarding the quality of subtitle provision, and also welcomes the proposed change to compliance to include quality and reliability. This is particularly pertinent in the context of live subtitling, and it is appropriate that substandard access services should be discounted in terms of broadcasters meeting their prescribed targets. In recent times DeafHear and other organisations and viewers have actually assisted RTE in improving the live subtitling service by providing feedback directly to RTE. In many cases problems were not due to a lack of resource provision on the part of RTE, but rather poor performance on the part of the subtitling service provider. This has been difficult to monitor for all parties concerned on an ongoing basis, due to the resources involved in doing so. After four years of ongoing lobbying, campaigning and complaining, RTE have indicated that the RTE Player will have subtitles available on iphones and on computer and laptop devices by August DeafHear believes that not only will this enhance access to RTE TV programmes for Deaf and Hard of Hearing people, but it will enhance the capacity of users to highlight any problems with the quality of subtitles on RTE, and assist the BAI with the proposal to discount programmes for meeting target requirements where the subtitling service is below the required standard. Question 5: Proposed change to time at which targets are set for new services. DeafHear accepts the BAI proposal in the consultation document on this issue as fair and reasonable. It expects the BAI to actively encourage applicants for new services to include reasonable access provision on such services from the outset.

5 Question 6: Proposed change to the lenght of the broadcast day for certain television services. DeafHear accepts the proposal to extend the period by which access services would be measured over the length of the broadcast day of the channel in question. However, we believe that it is important that a balanced approach is taken in this regard to ensure that programmes with access features are not consigned to off peak viewing hours. Such an outcome would only encourage negative perceptions and values in relation to the provision of access services, and have a corresponding negative impact on the esteem of citizens who rely on such services. Therefore we propose a balanced approach which measures the access provision over the broadcast day of the channel, but segments the broadcast day into 3-4 slots into which a proportionate percentage of programmes with access features must be broadcast. For further information on this submission contact: Brendan Lennon Head of Information and Policy DeafHear 35 North Frederick Street Dublin 1 brendan.lennon@deafhear.ie