Source document: https://docs-lawep.s3.us-east-2.amazonaws.com/1697634379905.pdf (Australia)
The Centre for Culture and Technology GPO Box U1987 Perth Western Australia 6845 Web ccat.curtin.edu.au 28 May 2020 Senator Katy Gallagher Senate Select Committee on COVID-19 By email: covid.sen@aph.gov.au PO Box 6100 Parliament House Canberra ACT 2600 Dear Senator Gallagher, Live captioning on Australian television The Digital Inclusion and Media Access program in The Centre for Culture and Technology brings together researchers working on understanding the potential of digital media in the context of redesigning and reimagining a more inclusive world.
We promote the redesigning of our digital systems so that they work for all potential users, including users with disabilities, varying language needs and diverse cultural preferences.

We write to you in relation to the Australian Communications and Media Authority’s (ACMA) Television Caption Quality Standard.

The Standard came into effect in 2013 and determines quality based on three factors – readability, accuracy and comprehensibility.
Communications has been integral to gaining public acceptance for an understanding of the government’s response to the COVID-19 pandemic.

In general communications have been excellent – clear, flexible and available in a variety of formats.

However, the live captioning has continued the standard of incomprehensibility observed prior to the pandemic.
Emergency communications during the COVID-19 pandemic and before that, the Australian bushfires, has intensified our concerns that live captioning on Australian television is inadequate and must be reviewed.

1 of 3 CRICOS Provider Code 00301J COVID-19Submission 329 Throughout 2019 and well before either of these emergencies, we reviewed the quality of live captioning on Australian free to air television and called for a review of live captioning during emergency communications.
Together with the Australian Communications Consumer Action Network, we presented these concerns to ACMA.1 We understand that in an emergency our recommendation to review a standard that has been in place for years may not be a priority; however, our observations of the error riddled live captioning of COVID update press conferences, particularly at the national level reinforce the urgency of our recommendation.
Our assessment of the quality of live captioning on Australian broadcast television followed ACMA’s Caption Quality Standard and assessed readability, accuracy and comprehensibility based on a qualitative and quantitative analysis of errors related to legibility, speech, non-speech and whether captions were verbatim.
Full findings are outlined in our report published by ACCAN Specifically, we discovered • repeated and significant errors such as missing words, spelling errors, unclear distinction between speakers, and issues with sync.

• A persistent lag of up to 10 seconds • Significant nuance was lost when watching programs exclusively with captions • Captions were not always verbatim.

• Up to 34 errors per half an hour was recorded in some programs.
The combined impact of these errors made it difficult or impossible to follow programs via captions alone.

At that time, we called for a dedicated analysis of caption quality of live emergency broadcasts including audience responses.

We also observed promising advancements in artificial intelligence and machine learning as a tool to assist in the creation of accurate captions and address the issue of delays often experienced in live captioning.
With delays of between 2 and 10 seconds consistently identified throughout the review, we recommended the broadcasters investigate the potentials of artificial intelligence while bearing in mind community concerns about the use of Automatic Speech Recognition.2 Despite technological change, broadcast television remains the most watched medium for Australian audiences with disability.

It is particularly important in an emergency.


During the COVID19 pandemic, governments’ ability and willingness to communicate regularly with citizens has had a direct correlation with those citizens’ willingness to follow directives related to social distancing, hygiene, and quarantining.
2 of 3 1 http://accan.org.au/our-work/research/1691-live-caption-research 2 http://wfdeaf.org/news/resources/27-march-2019-wfd-ifhoh-joint-statement-automatic-speech-recognition-telephone-relay- services-captioning-services/ CRICOS Provider Code 00301J (WA), 02637B (NSW) COVID-19Submission 329 Our observations of live caption quality during the pandemic is that is was inaccurate and would not be possible to follow.
This is a problem for the 1 in 6 Australians who are deaf or hard of hearing, not to mention the significant ageing population.

In addition, the pandemic has well and truly established another audience for captions – those without hearing loss who either can not or do not want to have the sound on their television on.

We urge the government to take this opportunity to recognise that quality, accurate captions are a human right.
We make the following suggestions • • • • review the caption quality standard incorporate a quantitative component to the standard conduct a specific and dedicated analysis of the errors broadcast during pandemic invite submissions from the Deaf and hard of hearing communities regarding their experiences of live captions during the pandemic In conclusion, accurate captions provide a better television experience and by extension stronger feelings of social inclusion.
In a pandemic we cannot afford to exclude anyone and especially not vulnerable populations who rely on captions for access to information.

Yours sincerely Professor Katie Ellis Director Centre for Culture and Technology 3 of 3 CRICOS Provider Code 00301J (WA), 02637B (NSW) COVID-19Submission 329