2900 abc at the movies - acma/media/broadcasting investig… · web viewon 28 september 2012, the...

Investigation Report No. 2900File no. ACMA2012/1342

Broadcaster Australian Broadcasting Corporation

Station ABC1 (ABN New South Wales)

Type of service National television broadcasting service

Name of program At the Movies

Date of broadcast 22 August 2012

Relevant legislation Section 130ZR(1) of Part 9D of the Broadcasting Services Act 1992

Date Finalised 23 May 2013

Decision Breach section 130ZR(1)(a) of Part 9D of the Broadcasting Services Act 1992 [captioning]

ACMA Investigation Report – At the Movies broadcast by ABC on 22 August 2012 1

The complaintOn 28 September 2012, the Australian Communications and Media Authority (the ACMA) received a complaint regarding the broadcast of At the Movies on 22 August 2012 at 10.15pm, by the Australian Broadcasting Corporation (ABC) on ABC1 (the program). The complainant alleged that the ABC provided a “sub-par” captioning service for a prime-time program, continuing:

The substance of my complaint is that the captioning service provided was not in sync with the

audio track.

Section 13 of the Broadcasting Services Act 1992 (BSA) provides that a national broadcasting service includes the ABC.

This complaint relates to a provision of the BSA that is applicable to a national broadcaster. As such, the complainant complained first to the national broadcaster, and finding the national broadcaster’s response inadequate, subsequently referred the complaint to the ACMA for consideration.

The ACMA has investigated the ABC’s compliance with paragraph 130ZR (1)(a) of Part 9D of the BSA.

The programAt the Movies is described on the ABC website as:

Film critics Margaret Pomeranz and David Stratton plunge into the world of cinema every week on At the Movies on ABC TV every Wednesday night at 10.00pm and repeated on Saturdays at 8.00pm.

With their sophisticated and heartfelt critique to what's new on the big screen, David and Margaret combine years of experience immersed in the world of filmmaking with an encyclopaedic understanding of cinema history.

Their renowned skill and expertise give Margaret and David wide access to the international stars featured in the big new releases. At the Movies presents interviews with the big names, and profiles the contributions of cinema greats.

Margaret and David's dedicated fans enjoy the infectious enthusiasm and knowledge they bring to each review - whether it's of a small budget indie film or a blockbusting extravaganza.

Look forward with anticipation to your next night out At the Movies armed with David and Margaret's famous star ratings.1

At the Movies typically runs for half an hour. In regard to the particular broadcast on 22 August 2012, the program was scheduled to be broadcast from 10.15pm to 10.45pm2.

AssessmentThis investigation is based on submissions from the complainant and the ABC, as well as copies of the broadcast of the program, from 22 and 23 August 2012, provided to the ACMA

1 http://www.abc.net.au/atthemovies/about/2 TV Week, ‘August 18-24 2012’, p86; and, The Sydney Morning Herald, ‘The Guide’, August 20-26,

2012, p10.


http://www.abc.net.au/atthemovies/about/

by the ABC. Both copies were viewed due to technical problems with the copy of the broadcast from 22 August 2012.3

Issue 1: Was the ABC required to provide a captioning service for the broadcast of At the Movies on ABC1 on 22 August 2012?

Relevant provisionsSubsection 130ZR (1) of Part 9D of the BSA provides, inter alia:

(1) Each national broadcaster must provide a captioning service for:(a) television programs transmitted during designated viewing hours; and

(b) television news or current affairs programs transmitted outside designated viewing hours.

Section 130ZL defines designated viewing hours as:

Programs transmitted before 1 July 2014

(1) For the purposes of the application of this Part to programs transmitted before 1 July 2014, designated viewing hours are the hours:

(a) beginning at 6 pm each day or, if another time is prescribed, beginning at that prescribed time each day; and

(b) ending at 10.30 pm on the same day or, if another time is prescribed, ending at that prescribed time on the same day.

Finding

The ABC was required to provide a captioning service in accordance with paragraph 130ZR(1)(a) of Part 9D of the BSA.

ReasonsOn 22 August 2012, At the Movies was scheduled to be broadcast from 10.15pm to 10.45pm. According to the time-code for the copy of the broadcast provided to the ACMA for 22 August 2012, the program commenced transmission at 10.17pm. The ABC is required to provide a captioning service for programs transmitted during designated viewing hours, and news and current affairs programs transmitted outside of designated viewing hours, on its primary television broadcasting service (the Basic Rule). As defined in the BSA, the ‘designated viewing hours’ are the hours beginning at 6pm each day, and ending at 10.30pm the same day4. Section 130ZR of the BSA also provides a range of exceptions where broadcasters are not required to comply with the Basic Rule. None of these exceptions apply in this case.

In assessing the quality of a captioning service the ACMA takes the approach that the captioning service must be considered in the context of the program as a whole. The ACMA considers that where a program has commenced within the designated viewing hours,

3 In the copy of the 22 August 2012 broadcast provided to the ACMA, the program’s audio/visual components and captions deteriorate at 10.42pm. An exact program finish time cannot be determined from the recording. The ABC submitted that due to technical difficulties the last few minutes of the broadcast were not captured by the off air recording, however ‘the repeat [on 23 August 2012] [provides] an accurate version of what went to air’. The ACMA estimates the program finished at approximately 10.45pm, however the exact finish time is not material in this investigation.

4 For programs transmitted before 1 July 2014.


notwithstanding that part of the program has been broadcast outside designated viewing hours, there is an expectation to provide a captioning service for the entire program.

Issue 2: Did the ABC provide a captioning service for the broadcast of At the Movies on ABC1 on 22 August 2012?

ABC’s submissions The ABC’s response to the complainant on 27 September 2012 stated:

[...]

two episodes of At the Movies are recorded consecutively each second Wednesday. As such, the first episode is finalised shortly before broadcast that evening, while the second episode is held over for broadcast until the following week. Due to the tight broadcast deadlines it is necessary for the first episode to be delivered with live captions, while captions are pre-prepared for the second episode.

In the case of the episode broadcast on 22 August, as it was the first program in that cycle and was completed just prior to broadcast, it was delivered with live captions

[...]

While pre-prepared captioning is desirable, I have been advised by ABC Television that as the production schedule for At the Movies is unlikely to change, this mode of captioning will continue.

In the ABC’s response to the ACMA of 1 November 2012, it stated:

[...]

the ABC has provided the ACMA with a copy of the off air captions for the 22 August edition of the program, together with the repeat of 23 August. Unfortunately, due to a technical difficulty the last minutes of the 22 August program were not captured by the off air recording; however, the repeat will give you an accurate version of what went to air [...].

Additionally the ABC provided further comment to the ACMA on 25 January 2013, noting:

[...]

[T]he ‘interim approach’ meta-principles states the ACMA will have regard to the extent that during live closed captioning:

a) captions coincide as closely as possible with the relevant soundtrack, so that the relationship between the visuals and the sound is preserved for the viewer;

b) the priority is always to transcribe as much of the spoken content of the program as possible is transcribed.

As the ACMA would be aware, the ABC's live online captions are transcribed in real time using the "live-stenographer" model. The captions are produced by skilled stenographers using shorthand machines to type captions as the words are spoken live-to-air. In the live captioning environment there will always be a time lag between the audio and the caption. The ABC and


its captioning provider aim for a delay of no more than a few seconds, and the ABC is satisfied that the captions during the 22 August edition of At the Movies were consistent with the requirements of the meta-principles. Further, taking into account the live captioning environment and challenging content of the program, as much of the spoken content of the program as possible was transcribed.

The ABC provided submissions to the ACMA, dated 4 March 2013, in response to the ACMA’s Preliminary Investigation Report, which included the following:

[...]

The ABC does not dispute that the captions and the soundtrack differed. As we have previously explained, the ABC uses ‘steno-captioning for live and late delivered programs. This ensures that the ABC can deliver captioned programs to viewers, while managing the kind of complex and finely balanced production schedules that is typical of television broadcasting.

Live ‘steno-captioning’ will never achieve the same quality as pre-prepared captions: the method is imperfect....while the ABC’s captioning provider seeks to minimise these problems, it is not only unrealistic to expect a precise and immediate presentation of each spoken word in captioned form, but the Quality Captioning Considerations impose no such requirement.

…

Furthermore, the Quality Indicators explicitly state that for live closed captioning, ‘the priority is always to transcribe as much of the spoken content of the program as possible’ ....the ACMA’s preliminary investigation reports have not addressed the impact of effect of this qualification...similar qualifications have previously been interpreted by the ACMA in respect of superseded paragraphs 38(4)(a) and (b) of the BSA as taking precedence over any mandatory obligation to fully comply with applicable captioning quality standards in the context of live news broadcasts (ACMA Investigation Report No. 1507 and 1520).

The ABC notes that the ACMA has previously accepted intermittent delays of up to 4 seconds between visuals and sound in passages of fast paced dialogue contained in programs using pre-prepared captions.

On 28 March 2013, the ACMA sent its revised Preliminary report to the ABC. In its 30 April 2013 response to the revised preliminary finding, the ABC noted the following:

[...]

It is not reasonable to expect that live captions will provide a flawless transcript of the soundtrack. The captions will appear after the words have been spoken. They will not always include all of the spoken words, particularly if the stenographer is working to minimise delay. Viewers allow for this and adjust their expectations, knowing that they might have to bring more of their own common sense and general knowledge to bear to maximise comprehensibility. Importantly, viewers using captions will try to understand what is being communicated.

[...]


[W]e do disagree with the approach taken by the ACMA in determining whether captions have been presented ‘as close as possible’ to the soundtrack. For broadcasters, an assessment of what is possible will include consideration of the complexity and novelty of the language used, the pace of the program, any interactions between speakers and particularly the extent to which speakers interject or speak simultaneously. The ACMA has given no consideration to these practical realities. The ACMA appears to have based its assessment on what constitutes ‘as close as possible’ by considering the genre of the program...

[...]

The effect of the ACMA’s approach is to demand a higher quality of captioning for those programs which are inherently more difficult to caption. This is not achievable in the live captioning environment.

[...]

Turning to the program itself, for the most part At the Movies consists of two hosts sitting in the studio discussing films. A delay of five seconds in this context does not seriously compromise the comprehensibility of the program for a viewer using captions.

[...]

[that coloured captions were used inconsistently and in a confusing manner ]The ABC disagrees. While there were some isolated incidents which may have caused a moment of confusion, a consistent approach was employed throughout the program.

[...]

As for the ACMA’s Example C [Attachment B], we agree that captioning of this aspect of the program was difficult to follow for a short period. However, we do not agree that overall this leads to a conclusion that the program itself was effectively uncaptioned. It is relevant to note that, at this stage in the program, the captions were running several seconds behind the soundtrack. On the soundtrack, the presenter’s commentary continued over the footage of the film for several seconds before the soundtrack switched to the film itself. When the speaker changed to the actor in the film, the colour of the captions did not immediately change. Taking the time to make this change would have further delayed the captions as the film was leading into a dramatic moment.

[...]

[that some blocks of dialogue appeared on screen for a second or less] The pacing of the captions reflected the speed of the dialogue at this point in the program... In relation to Example B [Attachment B], we do not agree that the speed of the captions here would have prevented viewers from comprehending the dialogue.

[...]

Overall, the ABC’s view is that few words were missing, and the absence of the omitted words did not detract from readability to such an extent as to justify a finding that the program was effectively not captioned.

[...]


There were grammar and presentation errors, but not to such an extent as to render the captions incomprehensible. The errors that did occur were largely phonetic in character.

FindingThe ABC breached paragraph 130ZR(1)(a) of Part 9D of the BSA.

Reasons The term ‘captioning service’ is not defined in the BSA although implicit in the obligation to provide a captioning service is the requirement that the captioning service satisfy certain standards relating to quality. Section 130ZZA of the BSA provides that the ACMA may determine a standard relating to the quality of captions provided for television programs by national broadcasting services, along with other television service providers. Such a standard has not yet been determined. In the interim, the ACMA has developed, in consultation with industry and community groups, a set of ‘Quality Indicators’ (Attachment A), to which it has regard in assessing what is an acceptable quality for a captioning service.

In the present investigation, the episode was broadcast with ‘live’ captions, as opposed to pre-prepared or ‘block’ captions. The Captioning Quality Indicators apply to both ‘live’ and pre-prepared captions and they are the key indicators that the ACMA will have regard to when assessing whether a level of quality has been reached that ensures the captions provided are meaningful to the viewers who rely on them.

In its most recent submission of 28 April 2013, the ABC noted

The effect of the ACMA’s approach is to demand a higher quality of captioning for those programs which are inherently more difficult to caption. This is not achievable in the live captioning environment.

The ACMA does not accept this submission. Its approach requires captions to be meaningful to the viewer regardless of the method of captioning used. Accordingly, any assessment of the quality of captioning must focus, not on the method of captioning, but on the outcome for the viewer, with the principle objective being that captions provide deaf and hearing impaired viewers with meaningful access to television programs.

In fact the ACMA acknowledges that specific quality indicators may be more or less achievable depending on the method of captioning used and accordingly assesses the combined cumulative effect of the presence or absence of relevant quality indicators on the overall readability and comprehensibility of captions, which ultimately will determine whether the captions provided meaningful access to the television program for the deaf and hearing impaired viewer.

The ACMA assessed the captioning in the broadcast against all relevant quality indicators. In particular, the ACMA assessed the relevant Quality Indicator in the ‘Timing and Editing’ category, which is 2(vii) (a) and (b) as the program was captioned ‘live’, along with the other relevant Quality Indicators, and considered their cumulative effect on the overall readability and comprehensibility of the captions. Contrary to the ABC’s submission that the ACMA failed to take into account the complexity of the language used in the program, the pace of the program and the interactions between the speakers, the ACMA did consider the nature and characteristics of the particular program in its assessment. The program was comprised of critiques of current and classic films partly in conversation and partly in in-depth review. The


hosts, known for their repartee, interactions and interjections, informed the audience of storylines, characters and background information, and rated each film. The program consisted of five reviews and each review lasted between 4 and 8 minutes in which snippets of the film being reviewed would be played, at times with the film’s own accompanying audio and at other times with the hosts’ commentary.

The assessment was undertaken by viewing the program with captions and without volume. The ACMA then compared the captions to the soundtrack. In its assessment, the ACMA relied on the ABC’s submission that its offline recording on the broadcast on 22 August 2012 was not an accurate reflection of the broadcast due to technical difficulties leading to the deterioration of picture and sound towards the conclusion of the recording. The ACMA has assessed both recordings and is satisfied that the second recording, from 23 August 2012, would have utilised the 22 August 2012 caption file and, the offline recording of the latter program, without technical faults, provides an accurate record of the program.

The ABC submitted to the ACMA that it “does not dispute that the captions and the soundtrack differed”, however in its 30 April 2013 letter the ABC argued that those differences identified by the ACMA, did not affect the overall comprehensibility of the program.

Grammar and presentation – Quality Indicator 1

Errors occurred in spelling and presentation throughout the program (Examples D and E at Attachment B). The ACMA notes that whilst a viewer reliant on captions may, on occasions, be able to work out the meaning of a word from phonetically spelt captioning, given the number and frequency of the spelling errors that occurred throughout the program (on average, a spelling error occurred once a minute), when combined with the other captioning issues, these spelling errors did affect the overall readability and comprehensibility of the program.

Timing and Editing – Quality Indicator 2

Quality Indicator 2(vii)(a) takes into account circumstances where programs are ‘live captioned’ and provides that the captions coincide as closely as possible with the soundtrack, so the relationship between the visuals and the sound is preserved.

The ACMA assessed whether the captioning service preserved the relationship between the visuals and the sound by having the captions coincide as closely as possible with the relevant soundtrack. Importantly, this assessment considered the cumulative effect of the measures on the whole program, having regard to the overarching principle that the captions are required to provide deaf and hearing impaired viewers with meaningful access to the television program. The ACMA considers achieving this principle requires overall readability and comprehensibility of captions.

The ACMA found that in the context of this type of program, the delay (generally of five seconds throughout), meant that the captions were not ‘as close as possible’ to the soundtrack and that accordingly the relationship between the visuals and the sound was not preserved for the viewer. The program content in this instance relied on the panellists discussing movies, while excerpts of the movies, sometimes with fast action and changing imagery, were being played. A delay of five seconds meant that the captions could not have been considered to be ‘as close as possible’ to the relevant soundtrack to enable meaningful access by a viewer, reliant on the captions, when so much was happening visually in the program. A consistent delay of five seconds in a reasonably fast paced program in which


speakers interact, interject or speak simultaneously, prevents a viewer dependent upon captions from being able to comprehend the discussion by the panellists and how they relate to the associated movie segments that are played.

In its 30 April 2013 letter, the ABC referred to the ACMA’s previous interpretation of qualifying terms including ‘as far as practicable’ in ACMA investigations No. 1507 and 1520, in relation to superseded legislative provisions of the BSA and in relation to similar phrases used in the Quality Indicators. The ACMA notes that the approach to interpretation of superseded provisions of the BSA in the investigation reports referred to is irrelevant to the current investigation and to the application of the Quality Indicators by the ACMA. Having said that, the ACMA notes that the phrase ‘as far as practicable’ is used in a completely different context in the Quality Indicators. In the previous legislation the phrase relates to the provision of the captioning service, whereas in the Quality Indicators it relates to the presentation of the captions themselves. In the earlier legislation, the phrase was used to qualify the objective that broadcasters provide captioning services. In other words, broadcasters should provide captioning services for television programs, only as far as practicable. In the Quality Indicators, the phrase is used to qualify the extent to which particular captions should satisfy the quality indicator relating to presentation. That is, when complying with the mandatory obligation to provide a captioning service a broadcaster must, as far as practicable, ensure the captions do not overlap or impede any text based information already on screen. With respect, the ACMA is of the view that the statutory principle to which the ABC refers does not apply where a phrase is used in a different context. That is, how a phrase is to be interpreted will depend on the context in which it is used. So the same phrase used in provisions where the subject matter is the same, but the obligation is different, will have a different effect depending on what the provision requires. Similarly, whilst other phrases to which the ABC refers may have similar meanings, they are also used in different contexts and therefore analogies cannot always be drawn between the application of one provision to the application of another provision, even though both provisions contain the same or similar phrases and cover the same subject matter.

The ABC submitted in its 4 March 2013 letter, that the ACMA in investigation 2737 previously accepted intermittent delays of up to four seconds between the visuals and sound, in passages of fast paced dialogue contained in programs using pre-prepared captions. The ACMA considers that any delay in the timing of captioning, and the impact of that delay on the comprehensibility for the viewer will depend on the particular program and needs to be assessed on a case by case basis.

The ABC also submitted in its 30 April 2013 letter, that comprehensibility of captions is not only concerned with accuracy, but how readily the reader can understand the message being conveyed. It is the ACMA’s view that a lack of accuracy, combined with other captioning issues, will affect the overall readability and comprehensibility of the program, such that the viewer will not be able to readily understand the message being conveyed

The ABC further submitted that if the delay is a consequence of the stenographer attending to what is specified in Quality Indicator 2(vii)(b) as the priority to always “transcribe as much of the spoken content of the program as possible” then the delay should not amount to a breach. The ACMA does not accept this submission. The priority referred to in 2(vii)(b) must not be at the expense of providing the deaf and hearing impaired community with meaningful access to television programs. Accordingly if the delay between the captions and the soundtrack,


combined with other captioning issues, affects the overall readability and comprehensibility of the program, such that the viewer cannot readily understand the message being conveyed, the delay will, amongst other factors, contribute to a finding that the broadcaster has breached its obligation to provide a captioning service.

This is one of several considerations to gauge overall readability and comprehensibility of captions in this program and ultimately whether the captions provided meaningful access to the television program.

Colour – Quality Indicators 3 and 4 iii.

The impact of the delay in captions was further compounded when considering the instances of inconsistent and confusing use of coloured captions to identify speakers (as evident in example A at Attachment B). The ABC submitted that a pattern of identification of speakers had been set in the program which had been broadcast beforehand, whereby the colour of all of the top line remained the same, even if there were two different speakers being captioned in that one line. The ABC noted that to make colour changes would have consumed more time, just one of the many challenges faced by the steno-captioner. The ABC believed that viewers reliant on captions would have maintained an understanding of the dialogue being conveyed.

This is not the view of the ACMA. Colour coding is just one of several aspects impacting overall readability and comprehensibility of captions in the program and combined with the other issues with the captioning service that have been identified in this report, the ACMA considers that the overall readability and comprehensibility of the captions in this program would have been seriously compromised.

Missing captions

Missed captioning for the host’s review and film sound was noted in particular at Example C at Attachment B.

The ABC submitted that the dialogue that the ACMA has identified as uncaptioned in Example C was indeed captioned and that just one word was found to have been missed: “Recall”. The ACMA agrees with the ABC on this point. The ABC referred to the ACMA’s acceptance of the offline recording of the 23 August 2012 repeat of the program utilising the 22 August caption file to provide an accurate record of the program without technical faults. In both preliminary reports, the ACMA has quoted from the captioning of the 22 August 2012 broadcast.

Overall cumulative effect

The 30 minute information based program covered five films with frequent and rapidly changing visual content as well as a continual change of pace in sound with monologue reviews (normal pace), discussion (fast paced) and sound from those films being reviewed. In this context, a delay of five seconds in captions, coupled with a range of captioning issues including spelling errors, inconsistent colour coding, timing and missing captions, would have made it extremely difficult for viewers dependent on the captions, however sound and prudent their common sense to follow the program. The ACMA does not accept that it is fair to expect the viewer, to rely on what the ABC describes as ‘familiar tools’, to bridge the gap of comprehensibility for a program, when


there are so many errors across various Quality Indicators which when combined, diminish the accessibility of a program to a viewer.

The ACMA found that the relationship between the visuals and sound was continually broken due to the overall readability and comprehensibility of the captions not meeting standards in the Quality Indicators. Being an information-based program, a crucial component for a viewer reliant on captions is the readability and comprehensibility of captions in the context of each film review.

It is the conclusion of the ACMA that there were numerous problems with the captioning service provided with the program and that the cumulative effect of the broad range and frequency of these captioning issues identified in this report, would not have resulted in the captioning service providing meaningful access to the program to the deaf and hearing impaired viewer.

In these circumstances, the broadcaster cannot be regarded as having provided a captioning service as required. Accordingly, the ACMA has formed the view that the national broadcaster breached paragraph 130ZR(1)(a) of Part 9D of the BSA.


ATTACHMENT A

Considerations – the quality of captioning

IntroductionThe ACMA is committed to ensuring that the captioning services provided by television broadcasters give the deaf and hearing-impaired community meaningful access to television.

As part of this commitment the ACMA uses the quality indicators set out below to assess the overall readability and comprehensibility of closed captioning.

In considering whether a particular broadcaster has satisfied the captioning obligations, the ACMA has regard to all of the relevant quality indicators and, most importantly, the cumulative effect of their application rather than assessing a broadcast against each individual criterion.

Quality IndicatorsGrammar and Presentation

1. In assessing closed captions during programs, the ACMA will have regard to the extent that:

i. punctuation is used to make captions as easy as possible for viewers to read;

ii. punctuation conveys, as much as possible, the way speech is delivered;

iii. sentence case is used where practical;

iv. spelling is, as far as practicable, accurate;

v. repetition of information that is already on the screen (such as the name of a presenter or temperatures in a weather report) is avoided;

vi. as far as practicable, closed captions do not overlap or impede any text based information already on the screen.

Timing and Editing


i. closed captions coincide with the relevant soundtrack, so that the relationship between sound and visuals is preserved for the viewer;

ii. closed captions stay as close as possible to the original wording while allowing the viewer enough time to read the captions and still watch the action of the program;

iii. where time allows, and where practical, closed captions are verbatim (word for word);


iv. having regard to the intended audience, text reduction remains faithful to the script, and vocabulary and sentence structure is preserved as much as possible;

v. line breaks reflect the natural flow of a sentence and its punctuation;

vi. closed captions are not consistently more than three lines in length (the preference is for one-line or two-line captions to be used);

vii. during live closed captioning:

a) captions coincide as closely as possible with the relevant soundtrack, so that the relationship between the visuals and the sound is preserved for the viewer;

b) the priority is always to transcribe as much of the spoken content of the program as possible is transcribed.

Identification of Different Speakers

3. In assessing closed captions during programs, where there are different speakers, the ACMA will have regard to the extent that broadcasters have ensured that, as far as possible, the captions clearly identify and distinguish each speaker. This should be done through varying the colouring of the closed captioning, and as far as possible, varying the positioning of the closed captions (see 4 and 5 below).

Colour and Font


i. white closed captions are used as much as possible as they are the easiest to read;

ii. sound effects are identified using a different colour and the same colour is used for all sound effects throughout the program;

iii. if using colour to denote different speakers, as far as possible, a different colour is used for each speaker.

Positioning


i. as far as possible, positioning of closed captions avoids obscuring important information on the screen, such as action, superimposed text, graphic text descriptors or activities, or the speaker’s lips;

ii. as far as possible, positioning is varied to identify who is speaking.

Sound Effects


i. any noise or music that enhances the visual, contributes to characterisation or adds atmosphere, is captioned;

ii. a viewer does not receive any more information than a hearing viewer would get.


ATTACHMENT B

Screen Shots 1 – Timing and speaker identification

Example A

The below screen shots provides examples of captions which appeared for minimal duration on screen.

Example B

Screen Shots 2 – Timing and Editing (and speaker identification)

Example C


David: ‘...Federation of Britain. He works in [a menial job]. [While visiting the head quarters of Recall], where exciting memories are supposed to be [implanted], [Doug finds himself facing armed men] and discovers he’s not really who he thinks he [is, is actually part of the resistance] against the Government or is he a Government agent?’

Character 1: ‘None of the secret [life] elements you chose [can actually be] true. [It will cause irreparable conflict and] confusion, that is how brains get blown.’

Character 2: ‘Don’t worry...’

Screen Shots 3 – Grammar and presentation

Example D

David: ‘music is boringly [repetitive]’

Example E

Margaret: ‘... I think she plays [coy to] a [nauseating] extent.’


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