Canadian Association of Broadcasters

October 6, 2008

Via Epass

Mr. Robert A. Morin
Secretary General
Canadian Radio-television and
Telecommunications Commission
Ottawa, Ontario
K1A 0N2

Dear Mr. Morin:

Re: Broadcasting Notice of Public Hearing/Telecom Public Notice CRTC 2008-8: Unresolved issues related to the accessibility of telecommunications and broadcasting services to persons with disabilities - Reply Comments

  1. These are the Reply comments of the Canadian Association of Broadcasters (CAB) in the above-noted proceeding. The CAB is the national voice of Canada's private broadcasters, representing the vast majority of Canadian programming services, including private radio and television stations, networks, specialty, pay and pay-per-view services. The goal of the CAB is to represent and advance the interests of Canada's private broadcasters in the social, cultural and economic fabric of the country.


  1. In the first phase of this proceeding, the CAB provided initial comments with respect to the three areas related to improving access and inclusion for persons with disabilities which are of particular relevance to Canada's private broadcasters - captioning, Described Video and the portrayal and employment of persons with disabilities. We note that most other parties focused on telecommunications service providers and terminal equipment issues in their first round submissions; to the limited extent some of them addressed broadcasting matters, they too concentrated for the most part on these same three areas.

  2. In our July 24 first phase submission, we described the various initiatives relating to captioning, Described Video and the portrayal and employment of persons with disabilities which private broadcasters have initiated and participated in over the years. It is clear from these activities that Canada's private broadcasters have taken these matters seriously, and continue to do so. It is for this reason, we submit, that the focus of comments in this proceeding has properly been directed elsewhere. Moreover, where concerns have been raised about broadcasting matters, we submit that many of these matters are already being addressed in projects already underway.

Closed Captioning

  1. As the Commission is aware, and as detailed in our July 24 first phase submission, the CAB has established English- and French-language Closed Captioning Working Groups which are currently developing proposed solutions for a number of closed captioning issues. The two Working Groups, which have been meeting over the last several months, will file their reports with the Commission at the end of November, consistent with the CAB's December 7, 2007 Action Plan which the Commission approved on February 28, 2008.

  2. The CAB anticipates that the reports of the Working Groups will address the issues that members of the Deaf and hearing impaired communities have raised in the recent past and which some of them have raised again in the current proceeding.

  3. That being said, both Working Groups have identified that many complaints from the public concerning the quality of closed captioning deal with problems arising outside the broadcaster's control. Accordingly, the CAB is of the view that not only broadcasters but broadcasting distribution undertakings (BDUs) must get involved in ensuring the quality of closed captioning received by end users. To this end, the CAB recommends that, in the context of this proceeding, the Commission examine issues relating to the pass-through of closed captioning by BDUs.

Described Video

  1. In our July 24 first phase submission, the CAB indicated that it was undertaking research to provide an update regarding described video, including the challenges relating to availability and costs (which, amongst other things, differentiate described video from closed captioning). We are pleased to attach to this submission a report entitled "Described Video in Canadian Private Television", undertaken on behalf of the CAB by CONNECTUS Consulting Inc. The CAB understands that this is the first comprehensive study of Described Video ever undertaken in this country (and perhaps in the world). The Report addresses the various matters regarding described video which were raised by other parties in their first phase submissions.

  2. As described therein, the study was designed and conducted on the basis of three methodological approaches:
  1. The following is a summary of the Report's key findings:
  1. The CAB looks forward to discussing with the Commission the observations and conclusions of this important Report during our appearance at the November 17 Public Hearing.

Portrayal and Employment of Persons with Disabilities

  1. As described in our July 24 first phase submission, Canada's private broadcasters have undertaken a number of initiatives in recent years regarding the portrayal and employment of persons with disabilities.

  2. Most recently, as highlighted in our first phase submission, the CAB has developed a new Equitable Portrayal Code, the first of its kind in the world, to ensure fair, accurate and non-
    stereotypical portrayal of all persons in television and radio programming. The new Code is being launched across Canada in 42 languages and is being made available in alternative, accessible formats. We are confident that, going forward, this new Code will contribute in a meaningful and positive manner to help overcome negative portrayal in broadcast programming based on physical or mental disability.

  3. As also described in our July 24 submission, the CAB is currently planning Diversity Webinars to be offered to both our English- and French-language broadcaster members. As currently contemplated, these Webinars will focus on strategic planning for human resources, including hiring and employee retention strategies as they relate to persons with disabilities. We also look forward to providing the Commission with more information about these new diversity initiatives during our appearance at the upcoming Accessibility Hearing.

All of which is respectfully submitted.


Original signed by:

Jay Thomson
Vice-President, Regulatory and Policy


CONNECTUS Consulting Inc. Logo

Described Video in Canadian Private Television



Final Report

Submitted to the Canadian Association of Broadcasters

October 6, 2008

Table of Contents


  1. Summary of Key Findings

  2. What is Described Video and How is it Produced?
  1. Regulatory Background - Described Video
  1. The Impact of The Accessible Channel on Described Video Availability

  2. The Challenge of Described Video
  1. Approaching Solutions

Appendix A - Note on Methodology

Appendix B - Regulatory Obligations and Expectations for Described Video

Appendix C - The Research Team

Described Video in Canadian Private Television

Final Report


CONNECTUS Consulting Inc. (CONNECTUS) is pleased to present the Canadian Association of Broadcasters (CAB) with its Final Report on Described Video in Canadian Private Television (the Study).

Following a brief summary of the methodologies applied to the Study, our Report is organized as follows:

First, we present a Summary of Key Findings from the Study.

Second, we present What is Described Video and How is it Produced? This discussion on 'Described Video (DV) basics' provides context and background for the Study's findings.

Third, we present Regulatory Background - Described Video, which summarizes (i) regulatory obligations and expectations applied to broadcasters and distributors in Canada and (ii) regulatory requirements for DV in two other jurisdictions: the U.S. and the U.K.

Fourth, we identify the impact that The Accessible Channel, a new digital basic service to be launched later in 2008, will have on the availability of English-language DV.

Fifth, we identify The Challenges of Described Video.

This part of our Report is largely based on a series of one-on-one interviews undertaken with representatives of the Canadian broadcasting industry, including conventional OTA broadcasters, specialty services, and program distributors.

In the final section of our Report, we present a discussion on Approaching Solutions, largely addressing those challenges and concerns identified by Study participants.

We note for purposes of our Report that our discussion on solutions is not intended as a series of recommendations, but rather as a range of ideas raised by Study participants that may warrant further discussion within the broadcasting industry.

Our Report is accompanied by three Appendices. Appendix A details the methodology applied to the Study and presents a list of participating companies. Appendix B presents a summary of CRTC regulatory obligations and expectations pertaining to DV. Appendix C presents our Research Team biographies.

As a final introductory note on a point of style, our Report occasionally uses direct quotes from individuals participating in the Study. These are identified with single quotation marks ('...').


The Study was designed and conducted on the basis of three methodological approaches.

First, we reviewed a wide range of information that is available on DV from industry service providers, television broadcasters, the accessibility research community, the Canadian Radio-television and Telecommunications Commission (CRTC) and other resources. This information included a review of conditions of licence that oblige broadcasters to air DV content.

Second, we examined the quantity of DV content available from conventional and specialty broadcasters by using a number of sources, including conditions of licence, programming guides and resources such as the Audio Description International Website

Third, we conducted a series of one-on-one telephone interviews with a total of 16 individuals representing broadcasters, broadcasting distribution undertakings (BDUs) and DV service providers:


DTH service providers did not participate in the Study.

DV Service Providers

Additional details on the Study's methodology can be found at Appendix A.

  1. Summary of Key Findings

  1. What is Described Video and How is it Produced?

What is Described Video?

Described Video is a method of programming enhancement that is used by broadcasters to create a more accessible television experience for consumers of content who are blind or living with vision loss, i.e. the vision disability community.1

Also known as video description, audio description and described video service, Described Video involves adding a voiceover soundtrack to a program during pauses in dialogue, in order to provide audiences with an explanation of what is happening on screen. Thus at those moments when there is silence, or when only background noise, sound effects or music can be heard, an additional soundtrack of audible narration can explain what the on-screen characters are doing and/or what type of action is taking place.

For example, during the opening sequence of a program with Described Video, the voiceover narrative will identify the program's performers by name and describe their physical appearance, and read on-screen production credits such as 'Created by' and 'Produced by'.

DV is often cited as 'closed captioning' for those with a vision disability, in that it is intended to augment programming for members of this community in much the same way as closed captioning functions for the Deaf and hard of hearing community.

Like closed captioning, Described Video needs to be 'accessed' by end users through their television receivers, by turning on the Secondary Audio Program (SAP) channel that contains the program description. In other words, the DV is 'closed' and needs to be 'opened' or turned on by users.

We note that, in the case of The Accessible Channel, all programming will include described versions - and the description will be open, i.e. just turn to the channel and the audio description will be there, thereby avoiding the need for users to turn on the SAP channel.

Described Video was pioneered in the 1980s by the U.S.-based Public Broadcasting System (PBS) and more specifically through the Media Access Group at WGBH. DV has been available to the vision disability community in varying degrees within specific genres of Canadian programming - primarily drama, long form documentaries and children's programming as directed by the CRTC - for approximately nine years.

How is Described Video Produced?

The process of producing a Described Video version of a program requires the participation of a number of players in the broadcasting system - and is at once fairly straightforward to create but much more complex to move from production to air in a timely fashion.

A program is commissioned, acquired or produced by a broadcaster. The completed program is sent (sometimes by an independent producer but most often by the broadcaster) to a company that specializes in producing Described Video.

The process of description is highly detailed and requires significant expertise to achieve the level of quality expected by both broadcasters and users.

Unlike closed captioning, DV requires the production of scripted narrative; screenwriters are typically employed or contracted by DV production houses to write the description for a program.

An individual is then hired by the DV house to perform the voiceover for the program; the narrative drafted by the screenwriter is essentially 'acted out' by the performer - who may be male or female depending on what is most suitable for the program. Tone, inflection, cadence and other vocal factors are carefully monitored by the in-house producer, and must be appropriately tailored to the program - whether drama, documentary, comedy, children's, etc.

Once the voiceover process is complete, the program audio must then be remixed with the descriptive narrative added to the SAP channel, and sent back to the broadcaster with the DV intact.

Broadcasters have very little lead time between acquiring a finished program, outsourcing for DV and then airing the program with the DV narrative in place. The actual time required for turning around a DV version of a program is three to five days for English-language programs depending on how 'tricky the script and voice over are to complete' and as long as two weeks for French-language programs. It is generally acknowledged that documentaries are much more challenging to describe than either drama or children's programming, and thus take longer to complete.

(Several broadcasters participating in the Study indicated that faster turnaround times are possible for English-language content through the use of technology to move programs back and forth, and by relying on highly qualified service providers who can hire screenwriters to create narrative overnight (as in the case of providing a described version of W5 in less than 24 hours). However, these instances appear more rare and potentially involve a cost premium.)

Once the DV versioned program is returned to the broadcaster, the broadcaster will alert the BDUs (i.e. cable or DTH services) that the program is available in Described Video - allowing the BDU to make the necessary technical adjustments that will enable the pass through of the program to subscribers.

For their part, users of DV need to (i) find out about the programs' availability, through available program guides, websites, program announcements or other means and (ii) turn on their television receiver's SAP function to access the description.

A simplified diagram below illustrates the various stages required to bring Described Video to the vision disability community.

The Process of Producing Described Video

The Process of Producing Described Video - See above explanation How is Described Video Produced?

  1. Regulatory Background - Described Video

In its 2001and 2002 licence renewals for the major television groups, the CRTC established the first rules for the minimum weekly provision of Described Video programming: stations owned by the major television groups CTV, Canwest, CHUM and TVA were required to provide Described Video programming, beginning at two hours per week and rising to four hours per week by September 2006.2

Along with conditions of licence requiring broadcaster provision of DV programming, the Commission initiated a set of rules governing how broadcasters must meet these obligations. In order to count towards their DV requirements, the DV content provided by broadcasters must meet the following conditions:

(Additional perspectives on genre restrictions and related regulatory conditions applying to Described Video are presented later in our Report.)

Apart from the above noted obligations of conventional OTA broadcasters, 13 specialty services licensed or renewed since 2001 have also received conditions of licence requiring the provision of minimum levels of Described Video content. These vary according to individual service, but typically require the provision of three hours of Described Video per week by the end of the licence term.

Given the need for specialty services to develop their programming plans, and the need for BDUs to upgrade their systems in order to pass through DV programming to subscribers, the Commission determined that specialty services required to broadcast DV programming would begin at two hours per week commencing September 1, 2005, rising to three hours per week by September 1, 2008.

We note at this point that the vast majority of DV programming that is available to the vision disability community is Canadian in origin. While this is in part due to the regulatory framework for the provision of DV set out above, there is very little foreign programming available to Canadian broadcasters in a DV-ready format - i.e. as explained below, the vast majority of programming acquired from the U.S. comes without description on the SAP channel.

Broadcasters participating in the Study indicated that, even if desired, it is 'inordinately difficult' to provide a described version of a U.S. show in time for that program to be simulcast in the designated slot in the broadcast schedule. For example, dramatic programs acquired from the U.S. 'can arrive at the last minute' - and there is simply no opportunity to create an SAP soundtrack in time for broadcast.

Given the regulatory restrictions on Canadian DV content, the cost of producing DV versioning and incessant timing and scheduling pressures, Canadian broadcasters focus their DV resources on the programming they produce or fund domestically, rather than on programming acquired from other jurisdictions.

DV Regulatory Framework and BDUs

The Commission has also established a series of regulations for BDUs - i.e. cable and satellite distributors of programming from television licensees - to ensure that DV programming is passed through to subscribers.

In 2005, the Commission indicated that cable distributors with more than 6,000 subscribers must pass through Described Video programming to subscribers, noting that Class 1 cable and DTH BDUs must upgrade their systems to permit this pass through to take place.3

However, given the economic inefficiency of passing through DV on an analog basis, the Commission elected to provide BDUs with flexibility in terms of how they meet their obligations:

All Class 1 broadcasting distribution undertakings (BDUs), direct-to-home BDUs, and satellite relay distribution undertakings must pass through video description of all programming services distributed on a digital basis, by not later than 1 September 2009.

All Class 1 BDUs must pass through video description of all local, over-the-air signals distributed on a digital basis as well as all video description signals provided to those BDUs by Shaw Broadcast Services and distributed on a digital basis, by not later than 1 January 2008.

The Commission will consider applications by Class 1 cable BDUs to be relieved, by condition of licence, of the requirement to pass through video description programming on an analog basis subject to providing complimentary set-top boxes to subscribers who are blind or who have a visual impairment, in order to enable those subscribers to access video description programming on a digital basis.4

In addition, Class 2, Class 3 and exempt BDUs are required to pass through video description of all programming services on a digital basis.5

The above noted decisions essentially comprise the Canadian regulatory framework for the provision of Described Video content by television licensees, and for the distribution of DV programming by broadcasting distribution undertakings.

And as detailed later in our Report, the recent licensing approval for the new mandatory-to-basic service, The Accessible Channel, will significantly increase the amount of DV programming available within the Canadian broadcasting system.

Described Video in the U.S. and U.K

With respect to the U.S., very little DV programming is actually available, and U.S.-based broadcasters no longer invest in technologies required to support this service.

This is primarily because of a 2002 United States Court of Appeals ruling that struck down the Federal Communications Commission (FCC) regulations requiring OTA television broadcasters to provide minimum levels of described video content. The court's decision was based on the grounds that the FCC had acted beyond its authority in adopting and implementing such rules.6

As noted by a number of Study participants, this legal decision directly impacts the quantity of DV content that can be made available in Canada for the Canadian vision disability community. Only PBS continues to actively engage in programming description, primarily in the children's genre. At the present time, this limits the amount of American DV programming to:

But according to broadcasters participating in the Study, Described Video versions of U.S. (and other foreign) programming are generally not passed along to Canadian broadcasters, as rights to the DV version may not always be available, or the U.S. distributor from which the program is acquired may not have access to the described version.

Contrasted with the U.S., the United Kingdom has the most developed and most regulated of all European markets for Described Video (referred to in the U.K. as audio description). Ofcom - the U.K. communications regulator - introduced graduated quotas for both OTA and subscription television services in 2003; as of 2008, virtually all programming undertakings in the U.K. are required to provide audio description for no less than 10 percent of programming each year.8

These requirements are part of a comprehensive Code on Television Access Services developed by Ofcom and updated on an annual basis. The Code exempts advertising, electronic program guides and programs targeting overseas audiences from its access provisions. However, broadcasters are required to provide Ofcom with details on audio description training provided to producers, editors and presenters.9

Although difficult to quantify, one estimate suggests that the Ofcom regulations have resulted in a range of 30 to 60 hours per day of Described Video programming being made available to those with a digital receiver, across all services that provide audio description programming, and not including repeat programming.10

Ofcom monitors broadcaster compliance with audio description requirements, and publishes a quarterly summary report on access services.

As a final note, although DV presentation standards have not yet been developed in the U.K., the Independent Television Commission (predecessor to Ofcom) developed a series of Guidelines for Television Access Services that function as service protocols for audio description, captioning and signing (cumulatively, access services).11

  1. The Impact of The Accessible Channel on Described Video Availability

Beyond the conditions of licence obliging conventional and some specialty broadcasters to provide minimum hours of DV content on a weekly or monthly basis, the Commission has also applied a regulatory encouragement approach to other broadcasting services.

These variable regulatory requirements applying to Described Video programming make it difficult to calculate that actual volume of DV available to users.12

However, based on existing regulatory obligations, the combined English-language OTA services of CTV, Canwest, E!, A-Channel, Citytv and Omni 2 provide approximately 21 hours of Described Video programming per week in most major markets. When the regulatory obligations of widely available specialty services such as Vision, Access, APTN, Discovery, Comedy, Treehouse and Teletoon are included, the amount of available DV programming totals about 54 hours per week.

On the French-language side, OTA services from TVA provide four hours of DV content per week (beginning in the fall of 2008). The DV programming hours made available by specialty services such as Télétoon, Séries +, Canal D, VRAK and APTN bring total weekly DV availability to 22 hours.

Beyond these total hours, Pelmorex provides Described Video on an hourly basis by providing audio regional forecasts on both The Weather Network and Météomédia.

But while current totals for available DV programming may be difficult to estimate, the impact of The Accessible Channel on DV availability is not at all difficult to predict.

It will be dramatic, on several levels.

In terms of quantity, The Accessible Channel (TAC) intends to provide open DV content on a 24/7 basis as soon as possible once the service launches later in 2008. This plan will increase total DV availability by 168 hours per week or 8,700 hours annually. Based on the open provision of DV programming on TAC, users will not need to turn on the SAP channel to enjoy the DV version of the content they wish to access.

But TAC represents far more than a 'volume solution' for available DV content.
This is because TAC is designed to air quality, 'top shelf, Greatest Hits' programming available from multiple broadcasters - and as such will serve as a destination site for the vision disability community. TAC also intends to develop hundreds of hours of original programming as it moves forward during its licence term.

In addition, TAC will be distributed in a manner rarely seen in the broadcasting system: it will be a digital basic service, available in millions of Canadian homes. Moreover, TAC has a guaranteed business case, with a set wholesale subscriber rate of $0.20 per month in Anglophone markets - plus whatever advertising sales the service can generate. With this type of distribution, TAC is assured guaranteed revenue as it rolls out its service across Canada.

Furthermore, it is just as important to realize that TAC is seeking innovative ways to contribute to the broadcasting system as an accessibility leader.

To this end, TAC will make a major contribution to what our Study has noted is one of the single biggest DV challenges: building awareness of programming availability within the vision disability community.

At regular intervals throughout the broadcast day - 'every four hours or so' - TAC will promote the availability of DV from its own service and from the services of other broadcasters through a 10-minute announcement. This means that users will be able to tune to TAC and determine which programming will be available in DV - and where it can be found - over the next four-hour period.

TAC also intends to work with service organizations representing the interests of Canadians who are blind or are living with vision loss, in order to acquire feedback and advice on a regular basis. Such groups may also serve as a resource for the promotion of DV programming schedules on their websites and through other types of communication with their constituents.

On the issue of audience measurement - broadcasters indicate there is little information on DV use among audiences - TAC has also indicated that it will work with BBM Neilsen to identify viewers for TAC programming, but will add those viewers to the audience inventory of the broadcaster from which the programming was acquired.

Like any new broadcasting service, TAC is faced with a number of challenges, the most pressing of which is to acquire programming content from Canadian rights holders (who themselves must work through any outstanding program rights issues with foreign studios or other rights holders). For programming acquired that is not available in a DV version - including High Definition programming - TAC intends to outsource the addition of description to a DV production house.

TAC also acknowledges a major hurdle not generally discussed within the broadcasting industry: described advertising, which the disability community has previously identified as desirable. To this end, TAC intends to discuss potential opportunities for advertising description going forward.

But overall, our research strongly suggests that TAC will provide a much greater volume of high quality DV content, based on a business model that all but ensures broad accessibility by the vision disability community - a combination of elements not seen anywhere else in the world.

  1. The Challenges of Described Video

Broadcasters and BDUs participating in this Study clearly voiced their commitment to the provision and distribution of Described Video programming, and recognize the importance of Described Video content to the vision disability community.

Participants also raised a number of challenges, issues and concerns underpinning the production and distribution of DV. In order of most often mentioned, comments from participants focused on:

The Cost of Producing DV

Throughout one-on-one interviews undertaken for the Study, broadcasters uniformly noted the high cost of producing Described Video programming as the most significant challenge they encounter.

In general, participants indicated that producing English-language DV through a versioning house such as DV Works costs approximately $1,600 per hour of programming - and slightly more for French-language content at $1,750 per hour. A number of participants contrasted this expenditure with the cost of closed captioning, which typically averages about $300 per hour of programming - and takes far less time to produce (a few hours for closed captioning compared with several days for Described Video).

The much higher cost of DV is directly attributable to the resources required for creating a DV version of a program (screenwriters, performers, technicians) as outlined earlier in our Report.

As noted above, current regulations require Described Video to be produced in the programming genres of drama, documentary and (to a lesser degree) children's programming. This means that the bulk of DV versioning is produced for episodic television series, 'to take advantage of the repeat factor and potentially recoup some of the costs involved'.

As noted by a number of participants, providing description for series (as opposed to one-off programs) can also enable the vision disability community to determine which programming is available in Described Video (i.e. 'word gets around that a particular program is going to be available with description').

But producing DV versions of a television series adds significant costs to post-production budgets. For example, adding description to the children's program Franklin in both English and French increases the cost of post-production significantly - approximately $42,000 for 26 half-hour episodes in English and 26 half-hour episodes in French at a cost of $800 for each half-hour produced. Applying this formula to, for example, three different television series would add in excess of $125,000 to the annual post-production expenditures of a private broadcaster.

There are also additional distribution costs involved, estimated at approximately $30,000 per year for the average broadcaster.

As noted by several participants in the Study, the process of producing and distributing DV also trigger a number of 'below the line' costs beyond the actual cost of versioning the program, including salaries, feeds, the creation and distribution of digital copies, the remixing of sound, etc. Broadcasters point out that there is 'much more than meets the eye in terms of how much an hour of DV can cost you. It goes beyond what we pay (the DV production house)'.

On the BDU side, participants in the Study noted that although digital pass through is far less expensive than analog pass through, extra bandwidth is required in order to distribute DV programming to subscribers. The more DV programming distributed, the more bandwidth required, resulting in 'significant cost increases'.
As noted by Bell TV,

Each described audio track requires approximately 300 MHz of bandwidth. Consequently, the more programs with described video that are offered simultaneously, the greater the challenge for (the company) to accommodate.13

In addition, BDUs note that in order to pass through DV programming to subscribers, that programming must be supported on a per channel and per head end basis, with each requiring a separate encoder. Although digital pass through is 'far more straightforward than analog' pass through, centralization and maintenance bring additional costs to the distribution of DV.

Lack of DV in Acquired Programming

As stated earlier in our Report, the bulk of programming that is acquired by broadcasters from the U.S. does not include descriptive narrative on the SAP channel. Moreover, a number of broadcasters indicated that programming acquired from other jurisdictions such as the U.K. will generally 'not include rights for the described version'.

It should be noted that none of the Study participants suggested that acquiring additional DV programming from other jurisdictions would relieve them of their regulatory obligations and expectations in terms of producing Canadian DV content.

The frustration thus stems from the inability of broadcasters to provide described versions of foreign programming to the vision disability community. As noted by one broadcaster, 'I have no problem with a focus (for DV) on Cancon. But I'm sure the audience would like to have description for their favourite U.S. show, too.'

Regulatory Restrictions on DV Programming Genres

Given the lack of available DV foreign content, Study participants expressed considerable frustration at the current genre restrictions that confine the bulk of DV programming to categories drama and long-form documentary that must be broadcast during 7:00 p.m. to 11:00 p.m. viewing hours in order to qualify for a broadcaster's obligations.

Based on the findings of this Study and from previous research conducted in the area of disability issues and broadcasting, we conclude that existing restrictions on DV programming genres do a disservice to broadcasters and - subsequently - to the users of DV content.

While participants in this Study acknowledged that some programming genres - live productions, extremely fast-paced action, play by play sports, and news - do not readily lend themselves to description, removing genre restrictions would enable broadcasters to better meet their obligations while providing described programming diversity for those with vision disabilities. Reality programming clearly stands out as but one genre of content that would readily lend itself to DV versioning.

We note that this was previously identified by the National Broadcast Reading Service (NBRS) during licence renewal hearings for the major television groups in 2001, when NBRS recommended the removal of genre restrictions for Described Video.

Lack of DV Awareness and Difficulties in Promoting DV Availability

Apart from cost and a lack of DV for acquired programming, Study participants commonly discussed issues concerning awareness about available Described Video programming within the vision disability community, and efforts by broadcasters and BDUs alike at DV promotion.

This issue represents another factor that distinguishes closed captioning from Described Video.14

Since closed captioning is available through much of the broadcast schedule on most services, a user can simply turn on the closed captioning function of their television receiver - and captioning shows up for most programming viewed. Closed captioned programming is also identified through use of a "CC" logo and through a variety of resources such as programming guides, both print and online, and sponsorship announcements

However, this is not the case with Described Video programming. An on-screen logo ("DV") is generally not used to signify Described Video content since it is only in a visual format, and there is very limited use of pre-program and commercial break announcements such as, "The following program is available in described video".

Cable distributors in particular expressed frustration at the challenge of finding solutions to promote the awareness of DV programming for subscribers with vision disabilities. While Bell TV (a DTH service) provides an audio channel identifying DV program listings for a given day, it is generally acknowledged that users with vision disabilities can have a very difficult time determining which programs are available in Described Video, and when they are scheduled for broadcast.

This issue would also appear to extend beyond the availability of Described Video programming.

As noted above, BDUs have recently been relieved of pass through of DV on an analog basis, so long as they provide complimentary set top boxes to subscribers with a vision disability. Lack of awareness about DV programming is evident in this situation as well: BDUs participating in the Study report that there is very little uptake of the newly-available free set top boxes by subscribers with vision disabilities to date, despite the increasing efforts of BDUs to promote their availability.

Technical Challenges for End Users

Beyond a lack of awareness of DV programming on the part of users, BDUs noted that 'accessing DV programming through one's television set' can be very challenging for someone who is blind or living with vision loss.

As noted above, the process of DV versioning involves the insertion of a descriptive narrative into the Secondary Audio Program channel and the distribution of the program by BDUs to their subscribers.

However - as is the case with closed captioning - a user must 'turn on' a television receiver's SAP function in order to access the description. This requires a number of steps that, as noted by one BDU, 'can be challenging for someone with a vision disability to perform independently'. As indicated by one Study participant, in attempting to turn on the SAP function, 'there are five places where something can go wrong'. BDUs participating in the Study stated that they are stepping up efforts in training customer service representatives to deal with this concern - but noted that the issue is compounded by another factor.

If a user turns on the SAP function on their television receiver, and a program does not have a descriptive narrative included, then the program may have the regular program soundtrack inserted on the SAP. However, the program may have no audio at all, depending on how the audio was mixed at the broadcaster site. This can result in obvious confusion for users.

Additional technical challenges faced by users involve the use of set top boxes (STBs) to access DV programming. As noted by Rogers Communications in an interrogatory response to the Commission's Accessibility proceeding, and echoed by other BDUs participating in the Study,

Current digital set-top box (STB) technology provides programming information on the television screen within an interactive program guide (IPG)...While the STBs deployed by Rogers do support the pass-through of descriptive video service (DVS) programming and closed captioning, they do not include other features that would enhance accessibility (e.g. on-screen text in an audible format; audible key selections when completing certain actions; the ability to increase the font size of text in the IPG; adaptive remote controls).15

Rogers notes that this poses 'a significant challenge' to those with vision disabilities, although the issue lies with source manufacturers such as Scientific Atlanta that produce STBs in the U.S. for the North American marketplace. BDUs noted during the course of the Study that while their ability to influence STB features is limited - especially given the absence of DV regulation in the U.S. - they are continuing to work with manufacturers to advance accessibility features.

Too Few Service Providers for DV Versioning

A number of broadcasters participating in the Study indicated that there are very few service providers that can provide high quality Descriptive Video in a 'reasonable turnaround time' of less than five days. This means that service providers themselves can 'get backed up - while the quality is generally good, there is always a timing issue to get the show to air with DV in place'.

This in turn raises the issue of whether the existing service provider industry could handle increased volumes of DV while meeting the highly sensitive scheduling and simulcasting needs of broadcasters.

It is generally believed that this is a more short-term issue, in that that more DV services will enter the marketplace as more programming becomes described. Some post-production houses with the technical capacity to remix program audio 'are looking at getting in to the business, or are starting slowly' - and as the field becomes more competitive, the costs of DV versioning may be reduced.

It was also acknowledged by broadcasters participating in the Study that the quality of descriptive narrative provided by DV services is very high, 'especially from the experienced firms'. But broadcasters are also aware that quality must be carefully monitored from newer players in the market, which 'adds time and cost to turnaround'.

Very Tight Turnaround Times

As noted earlier in our Report, the turnaround times for Described Video - from sending the program to a DV house, back to the broadcaster, to the BDU, to air - are extremely tight. It is important to note that broadcasters rarely receive a program well in advance of its air date; in fact, a program which the broadcaster wants to outsource for description likely arrives with little lead time prior to airing. This sharply reduces the amount of time for the versioning process, and places pressure on both the broadcaster and the DV house to deliver a quality product within a relatively short span of time.

DV and High Definition Broadcasts

At the present time, the transition of the Canadian television industry to the High Definition (HD) standard poses a considerable challenge to the provision of Described Video content. As noted by broadcasters participating in the Study, 'no Secondary Audio Programming channel exists yet for the delivery of Described Video over HD'.

This is posing particular challenges for broadcasters that are best illustrated with an example.

As noted earlier in our Report, CSI is one of only a handful of foreign programs that is available in a described version. CTV, which broadcasts CSI in the Canadian market, pays an additional fee in order to acquire the DV version of the program.

CSI is also available in both a Standard Definition (SD) feed and a High Definition (HD) feed - but the described version of the program is only available via the SD feed, so this is the feed used by the broadcaster. In other words, the broadcaster pays a premium for a version of the program that is more inferior in terms of its technical quality in order to deliver the DV version of the program to audiences.

Lack of Audience Measurement

As pointed out by several participants in the Study, the provision of DV is a matter that is at once 'part of our regulatory obligation and part of our commitment to our community'. However, there is virtually no audience data available to broadcasters that measure the uptake of DV content by the vision disability community. Access to some form of audience measurement from BBM Neilsen is viewed as a vehicle that would assist broadcasters with their DV planning and expenditures; as noted earlier in our Report, The Accessible Channel is looking at the viability of measuring audiences for DV within the context of its business plan.

Lack of Feedback from the Disability Community

Similarly, virtually all participants in the Study indicated that they rarely, if ever, receive feedback from the disability community about Described Video content - whether negative or positive, whether about the quantity of DV programming available to them, its quality, scheduling or other factors.

There are two potential reasons for this lack of feedback from the disability community.

First, individuals who are blind or who otherwise live with vision loss tend to be on the older end of the demographic: approximately 65 percent of this group is over the age of 65, and viewed by advocacy groups as not likely to complain.16

Second, companies engaged in the production of Described Video appear to be the central point of contact for the disability community with respect to evaluating or commenting on program descriptions. DV production houses often hold focus groups comprised of people with vision disabilities in order to test DV quality in terms of tone, inflection, interruption of dialogue, accuracy and other factors. The fact that broadcasters are rarely contacted by the vision disability community about DV may simply be a function of successful product testing and its perceived quality with the target audience.

  1. Approaching Solutions

Representatives from the broadcasting industry that participated in the Study identified a number of approaches to resolving the challenges, issues and concerns set out above. These include, but may not be limited to:

We note for purposes of our Report that the following discussion is not intended as a series of recommendations, but rather as a range of ideas raised by Study participants that may warrant further discussion within the broadcasting industry.

The Accessible Channel

We will not at this point restate our findings concerning TAC as set out earlier in our Report.

However, it is worth noting once more that, from a solutions perspective, TAC is an extremely bold and innovative initiative - in effect, a solution from the Commission - that is already attracting worldwide attention for its programming and business models, and for its groundbreaking approach to accessibility.

Clearly, The Accessible Channel will make a dramatic difference so far as the availability of English-language DV content is concerned. But far from becoming a 'programming wasteland', TAC will also provide destination viewing for the vision disability community by providing high quality content and additional accessibility leadership within the broadcasting industry by taking measures to promote DV programming provided by other broadcasters.

In our view, the role of TAC in resolving issues related to DV - in terms of quality, quantity and building awareness - has enormous potential, especially given the commitment of licensed broadcasters to work with the service on a going forward basis.

Described Video Standards

Discussions on the potential value of developing content, technical and/or operational standards for Described Video generated a somewhat mixed reaction from Study participants.

A number of Study participants pointed to the potential value of establishing standards or guidelines as a means of (i) monitoring the quality of DV services provided and (ii) addressing a number of the above noted technical and operational issues.

With respect to DV quality guidelines, these have actually been developed within the operations of some individual DV production houses (and by The Accessible Channel). While there is no 'national' set of guidelines per se, those drafted in the professional practice of audio description may prove to be a valuable resource should the industry wish to explore a centralized set of standards.

Similarly, technical guidelines for the production and distribution of Described Video have been developed at various points within the broadcasting industry. For example, the Digital Technology Working Group organized by Industry Canada with the participation of the broadcasting industry continues to look at developing standards to ensure the inclusion of audio on the SAP channel whether a program is described or not.

As a third resource for identifying existing standards, manuals and guidelines have previously been developed in the U.K. and Ireland.

But overall, there is no single, comprehensive point of reference on technical or quality standards for Canadian private broadcasters.

As noted above however, one of the barriers to establishing guidelines for DV is the absence of feedback from the disability community on existing Described Video produced and distributed by the broadcasting industry. Given this, and given the existence of standards at various points in the industry, several Study participants suggested that establishing standards may be an exercise that is not, in the end, 'really required, since we know what the technical issues are, and no one out there is pointing to problems with (DV) quality'.

As a general observation, there may be some value to further dialogue on standards within the broadcasting industry, to the extent that they may be useful in addressing some of the unresolved technical issues noted in our Report. However, more feedback from the disability community would be required to point out any issues with the quality of DV content.

Once again, our sense from having undertaken previous research on disability issues is that there is more likely a concern from the vision disability community over the quantity of DV programming available, the lack of U.S. programming available in DV and barriers to accessing DV content, than over the quality of the product itself.

Pooling the Resources of Broadcasters

While Study participants readily note that TAC will play 'an extremely important role' in providing DV programming and industry leadership on accessibility, they also note that programmers and distributors will need to come up with innovative ideas about DV content as well.

Several participants suggested that, given the high cost of producing Described Video, the pooling of funds for DV production and/or the sharing of DV programming content may be a viable strategy.

In this way, broadcasters could have access to both funding for DV versioning and to a bank of programming for broadcast. The availability of this programming could in turn be promoted cooperatively through the listings and websites of individual programmers and BDUs, as well as through The Accessible Channel.

It should be noted that Study participants indicated on several occasions that industry cooperation would potentially facilitate approaches to other DV challenges. For example, the above noted Digital Technology Working Group and individual companies within the broadcasting industry are continuing to explore options for making DV programming more accessible to end users - such as working with STB manufacturers and Electronic Program Guide developers to find solutions for more clearly identifying the 'what, when and where' of Described Video.

But we also note that a number of Study participants identified some concern with the idea of pooling resources and creating a programming bank, in the absence of more user awareness about DV programming.

A Role for the Disability Community

Building awareness about Described Video programming clearly emerged as a central issue that was identified by all participants in the Study. The absence of DV feedback from the disability community seems to exacerbate this concern.

While broadcasters and BDUs continue to work at promoting DV through various means such as advanced Electronic Program Guides, posting information on websites, customer service orientation for staff and working with The Accessible Channel, a number of participants suggested that the disability community itself might be able to play a role in the promotion of Described Video.

For example, service organizations representing the interests of people with vision disabilities could serve as a conduit of information about DV programming and scheduling for their constituents, while providing a source of feedback about quality, accessible DV content.

Once again, this suggestion would seem to be best integrated as a component of on-going industry dialogue about Described Video.


  1. Terms that reference persons with disabilities tend to vary depending on the purpose of that use. For purposes of our Report, we refer to the 'vision disability' community although the terms 'blind', 'vision impairment' and 'living with vision loss' are equally acceptable to the disability community.

  2. See for example, Broadcasting Decision CRTC 2001-458 - Licence renewals for the television stations controlled by Global; Broadcasting Decision CRTC 2001-385 - Licence renewals for the TVA television network and CFTM, Montréal; Broadcasting Decision 2002-323 - Licence renewals for seven CHUM Limited Television Stations.

  3. See Broadcasting Public Notice CRTC 2005-18

  4. Broadcasting Public Notice CRTC 2007-101 - Distribution of video description by Class 1 cable broadcasting distribution undertakings (BDU), direct-to-home BDUS and satellite relay distribution undertakings
    See also CRTC 2008, 'Broadcasting Services for the Visually Impaired' Weblink:

  5. U.S. Court of Appeals, Decision No. 01-1149, November 8, 2002 Weblink:

  6. U.S. Court of Appeals, Decision No. 01-1149, November 8, 2002 Weblink:

  7. WGBH Media Access Group; Weblink:
    It should be noted that DV programming lists for U.S. broadcasting services differ depending on the source. The Media Access Group at WGBH and the Audio Description International website are believed to have the most up to date information for U.S. DV programming.

  8. Ofcom Code on Television Access Services April 18, 2008; see Annex 1. Weblink:

  9. Ibid at paragraph 18, page 4.

  10. Media Access Australia - Audio Description: U.K. Weblink:

  11. Ofcom, Guidelines on the Provision of Television Access Services Weblink:

  12. These regulatory categories are explained in more detail at Appendix B of our Report.

  13. Bell ExpressVu, Interrogatory Responses, Public Notice CRTC 2008-8 Unresolved issues related to the accessibility of broadcasting and telecommunications services for persons with disabilities, June 2008

  14. See Broadcasting Decision CRTC 2001-458 at paragraph 71.

  15. Rogers Communications Inc., Interrogatory Responses, Public Notice CRTC 2008-8 Unresolved issues related to the accessibility of broadcasting and telecommunications services for persons with disabilities, June 2008

  16. This was a finding from a study conducted by CONNECTUS for the CRTC in early 2008, Stakeholder Consultations on Accessibility Issues for Persons with Disabilities, Weblink:


Appendix A

Note on Methodology

Described Video in Canadian Private Television (the Study) was undertaken by CONNECTUS Consulting Inc. (CONNECTUS) for the Canadian Association of Broadcasters (CAB) from July to September 2008.

The following methodologies were applied in undertaking the Study.

First, we reviewed a wide range of information that is available on Described Video from industry service providers, television broadcasters, the accessibility research community, the Canadian Radio-television and Telecommunications Commission and other resources. This information was adapted to our Report's discussion on the regulatory underpinnings of Described Video in Canada.

Online resources from other jurisdictions - notably the U.S. and the U.K. - were also reviewed.

Second, we compiled information about the quantum of DV programming available on Canadian English- and French-language broadcasting services from a number of sources, including:

Third, we developed an instrument and scheduled a series of discussions with broadcasters, BDUs and DV service providers on the current status and key challenges associated with Described Video. We approached a total of 20 companies and/or individuals requesting their participation in the Study; 16 agreed to an interview. All interviews were conducted by telephone, and email exchanges provided additional information after interview completion.



Service Providers


Appendix B

Regulatory Obligations and Expectations for Described Video

The Canadian Radio-television and Telecommunications Commission (CRTC, the Commission) has established three categories of regulation pertaining to the provision of Described Video by licensed broadcasters.

The first of these involves the use of Conditions of Licence, which obliges broadcasters to provide a minimum level of DV programming on either a weekly or monthly basis. The major television groups such as CTVglobemedia, Canwest Media and Rogers, fall into this category; each station owned by a major group must typically broadcast a minimum of four hours of Described Video programming each week (as noted earlier in our Report, 100 percent of which must be original programming, with at least 75 percent from the drama and long-form documentary categories).

A number of other analog and digital specialty services also fall within this category of regulation, including Vision TV, Access Television, Space, Teletoon/Télétoon and History.

The second category is based on regulatory encouragement rather than obligation. In this case, a licensee may still be developing its programming strategy, or may require technical upgrades in order to produce DV content. The Commission has in the past applied this type of regulatory approach to a range of television services such as TVA, The Weather Network/Météomédia, Discovery Channel, TMN, Super Ecran and The Family Channel.

Often - but not always - this type of encouragement would potentially result in approximately six hours per month of DV content from these services; in the case of The Weather Network/Météomédia, this would result in the provision of DV on a regular, hourly basis through the provision of audio regional forecasts. We would anticipate that the fulfillment of such regulatory encouragement would be a matter examined by the Commission when a licensee comes up for licence renewal.

The third regulatory category concerning DV neither obliges nor encourages a licensee to provide Described Video content, but instead requires a licensee to 'provide audio description wherever appropriate'. This means that a licensee will be more self-directed in the provision of Described Video programming; the requirement is that licensees build awareness about DV, acquire programming with DV versioning when possible and/or upgrade technical capacity in order to accommodate DV.

This category of 'as appropriate' applies to a wide range of specialty and pay services, including Mystery, Biography, Canal Vie, Canadian Learning Television, Telelatino, OLN, TSN, Superchannel, CPAC and others.


Appendix C

The Research Team

Richard Cavanagh served as Senior Consultant to the Study and authored the Report. Mr. Cavanagh has over 20 years experience in the field of communications research, and 15 years experience in studying issues concerning persons with disabilities and the communications sectors. Mr. Cavanagh led a 2005 study on The Presence, Portrayal and Participation of Persons with Disabilities in Television Programming and conducted a 2008 consultation with the Canadian disability community on behalf of the CRTC.

Mr. Cavanagh has conducted additional research for the private broadcasting industry on the use of respectful language when referencing persons with disabilities.

Mr. Cavanagh holds an M.A. in sociology from Queen's University, and a Ph.D in Social Sciences from Carleton University.

Sylvie Croteau served as Project Interviewer for the Study. Ms. Croteau is Vice-president with Ad Hoc Récherche in Montréal, and has considerable expertise in researching communications issues. An expert in qualitative research design and analysis, Ms. Croteau most recently worked with CONNECTUS on a number of major research initiatives, and is currently working on a project concerning telecommunications and the Québec-based disability community.

Ms. Croteau holds an M.Sc. in Communications from and a B.Sc. in Liberal Arts, both from the Université de Montréal.