Film-Tech Forum ARCHIVE: New Closed Captioning and Audio Description Rules

This is topic New Closed Captioning and Audio Description Rules in forum Digital Cinema Forum at Film-Tech Forum ARCHIVE.

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Posted by Harold Hallikainen (Member # 5405) on 11-22-2016, 11:34 AM:

Thanks to Esther Baruh at NATO for letting me know. New rules at : https://www.ada.gov/regs2016/movie_captioning_rule_page.html

Harold

Posted by Frank Cox (Member # 6258) on 11-22-2016, 02:34 PM:

I'm in Canada so this doesn't apply to me, but this stuff does have a habit of sneaking across the border so I won't be surprised to see similar regulations here before too long.

I was curious as to whether the regulations are intended to apply only to chains and such or if it also applies to mom-and-pop operations.

From Questions and Answers

quote:

2) Are all movie theaters required to comply with the specific requirements of this rule?

No. This rule applies only to certain movie theaters as defined by the rule. The rule defines a movie theater as a “facility, other than a drive-in theater, that is owned, leased by, leased to, or operated by a public accommodation and that contains one or more auditoriums that are used primarily for the purpose of showing movies to the public for a fee.” The specific requirements of this rule, however, do not apply to any movie theater that shows only analog movies in all of its auditoriums. Additionally, drive-in theaters are excluded in the definition of movie theater because the technology to provide closed movie captioning and audio description in such venues does not yet exist.

I still don't know. What does "owned or leased by a public accommodation" even mean? How can a public accommodation own or lease anything?

I get the impression that any theatre covered by these regulations (all theatres in the US?) must have the equipment ready to go upon demand so it looks like there's going to be a short-term boom in sales of these gadgets.

Posted by Justin Hamaker (Member # 2165) on 11-22-2016, 04:03 PM:

Frank, my impression is it applies to ALL digitally equipped movie theatres - and digitally equipped auditoriums.

One of the immediate impacts is the need to advertise the availability in newspapers, web sites and apps, all ticketing locations, and phone recordings. Sounds like we need to ensure third party ticketing sites are providing this information, in addition to our own web sites.

Posted by Frank Cox (Member # 6258) on 11-22-2016, 04:44 PM:

I don't know... it says that theatres are required to "notify the public" but I don't see where it say how that must be done. Perhaps you could just put up a sign in the lobby and be compliant?

Of course, "notice" is a tiny consideration compared to the cost of obtaining, installing and maintaining the equipment. How much does that stuff actually get used, anyway? I have two wheelchair parking spots in my auditorium and one of them might get used maybe two or three times a year, both of them at the same time maybe once in five years. Assuming that this gadget needs to be charged, what are the chances that it will actually work after sitting on the charger for the past 36 months without being moved.

Posted by Mark Gulbrandsen (Member # 72) on 11-22-2016, 05:07 PM:

Frank,

Are Canadian laws different regarding this, or do you use the same ADA laws on this stuff up there?

Posted by Frank Cox (Member # 6258) on 11-22-2016, 05:32 PM:

The laws are different here, but it seems that after stuff like that is passed in the US it tends to leak across the border, as I said earlier. Some Canadian politician thinks, "Hey, there's a good idea" and the next thing you know a similar regulation is being put into place here.

Most of the disabled access stuff like wheelchair parking and ramps and the like is part of the building regulations, as far as I know.

Posted by Mike Blakesley (Member # 26) on 11-22-2016, 08:42 PM:

quote: Frank Cox
I get the impression that any theatre covered by these regulations (all theatres in the US?) must have the equipment ready to go upon demand so it looks like there's going to be a short-term boom in sales of these gadgets.

Well a lot of places already have them -- we got a used system many years ago which crapped out a couple of years ago. It was probably requested about four or five times, max, in the 20 or so years we had it. I knew the gov't was working on new "regs" so I've held out in replacing it. So I'm in the market, but certainly not everyone is.

Posted by Justin Hamaker (Member # 2165) on 11-23-2016, 05:27 AM:

Frank, I get the impression your community's population is not representative of the population at large.

This is my general experience with ADA issues.
1. Our handicap parking spaces are usually different frequently for. For any given show,even slow weekdays, at least 2-3 of our handicap parking spots are used.

2.Assisted listening devices we have 10 headsets, 4 of which we keep ready to use. We probably check out 5-10 times per week for amplified sound. We have had 4 units out at one time just once or twice, but we have had 3 out at once.

3. We have 3 closed captioning boxes, and we usually get 2-3 checkouts per week. Generally our CC users are the same 4-5 people. We have had We have had 2 checked out at once, but this was 2 ladies who frequently come together and both use CC. I don't believe we have ever had more than 2 out at a time.

4.The visually impaired narration normally only gets used 1-2 times per week, and most of the time it's for the same woman. Over the years we have only had maybe 2-3 other people use the system.

5. Each of our auditoriums has 4 designated wheelchair spots with corresponding companion seats. We probably average 10 wheelchairs per week. Although not common, we have had to move people to free up the handicap seating.

As far as the equipment goes, we have the USL system. The headsets handle ALD and narration, and the CC boxes use the same transmitter. When checking out the headsets, our cashier's actually turn then on to ensure they are functioning, as well as explaining how they are used. All employees are trained for this, and I would assume my staff does it right 90-95% of the time.

When the units are returned, we actually remove the batteries and test them to see if they need to be changed. When the devices are put away, they are ready for the next checkout.

Since our system was installed we have logged every checkout, and the data generated was sent to the Justice Department to use in determining the number of units required for each theatre. The initial proposal was enough units for 5-10% of seats, which would have been about 50-100 for my theatre. Our data proved these numbers were roughly 10 times more than what was actually needed.

Posted by Scott Norwood (Member # 30) on 11-23-2016, 06:55 AM:

As one who is not familiar with the current state of closed-captioned and audio-described movies: how many movies actually have the tracks for this encoded on the DCP? Do all major releases have it now? Or is it rare? Or somewhere in between?

Does every auditorium in a multiplex need these systems, or is it sufficient to have enough equipped auditoria to support movies that have the data encoded? (Obviously, this is a moot point for a mainstream cinema if every major release has the tracks.)

Posted by Chris Daigle (Member # 7347) on 11-23-2016, 10:13 AM:

I understand that with the USL unit you can use either the cup holder display or the glasses for viewing the closed captions.. any feedback from someone currently using the system on which is the better option from a durability standpoint? Is the cup holder unit annoying to those sitting close by?

Posted by Mike Blakesley (Member # 26) on 11-23-2016, 10:40 AM:

I don't know why we didn't get more usage on our old system than we did... we do get quite a few senior citizens to the movies. I have always assumed it's because we have pretty good sound, or the ones who can't hear well just don't come. But we've never really promoted the hearing-impaired feature either. I'll probably promote it more when we get a new / better system than the one we had.

Posted by Harold Hallikainen (Member # 5405) on 11-23-2016, 11:05 AM:

I've done a quick read of the new rules. I have to do a more detailed read. As I recall, you will need to include the availability of HI, VI, and CC in schedules and ads. There are standard symbols for each (VI is called AD for Audio Description).

On the USL glasses and cup holder receiver, I believe the cup holder is more durable but have not seen many returns on the glasses. Returns on the cup holder receivers are mostly due to people trying to recharge non-rechargeable batteries. The batteries can leak all over the inside of the unit pretty much destroying it. The CCR-100 includes an internal charger for NiCd and NiMH batteries, but the system ships with alkaline batteries. A "charger kit" is available as an option. That includes the rechargeable batteries, a USB power supply, and USB cable. A while back, we started putting a "do not charge" label over the USB connector on the CCR-100 to discourage people from buying their own USB power supply and charging the alkalines.

The CCR-100 is more sensitive than the CCH-100 (glasses). I'm trying to improve the sensitivity of the CCH-100.

I like the idea of logging actual usage of the system. In addition, on a movie change, it'd be nice to walk the auditoriums and make sure everything is working before your customers find out differently.

Harold

Posted by Scott Norwood (Member # 30) on 11-23-2016, 12:56 PM:

Isn't the advertising requirement kind of pointless if everyone is required to have the systems installed? Or is the idea to advertise which titles, specifically, have the tracks available for use?

Posted by Leo Enticknap (Member # 534) on 11-23-2016, 01:02 PM:

Yes - out of closed captions, HI audio descriptions, and/or VI audio descriptions, some DCPs have some of these tracks, some all and some none. So anyone needing this facility will need to know if the movie they are going to see has the supplementary track on it. So there are essentially two parts to the regulation: 1 - you have to have the equipment up and running for your patrons to use these tracks if they want to, and 2 - you have to tell them which movies have the tracks and which ones don't.

Posted by Harold Hallikainen (Member # 5405) on 11-23-2016, 01:03 PM:

It appears to be a notice as to which movies have which feature (HI, VI, CC). It SEEMS that HI would be required whether the movie has an HI track or not (using an LCR mix), but I can't say for sure. The notice requirement is worded as below:

Notice. On or after [INSERT DATE 45 DAYS AFTER DATE OF PUBLICATION IN THE FEDERAL REGISTER], whenever a public accommodation provides captioning and audio description in a movie theater auditorium exhibiting digital movies, it shall ensure that all notices of movie showings and times at the box office and other ticketing locations, on Web sites and mobile apps, in newspapers, and over the telephone, inform potential patrons of the movies or showings that are available with captioning and audio description. This paragraph does not impose any obligation on third parties that provide information about movie theater showings and times, so long as the third party is not part of or subject to the control of the public accommodation.

Harold

Posted by Justin Hamaker (Member # 2165) on 11-23-2016, 02:11 PM:

I can confirm that HI and CC are nearly universal from the major studios and art houses. The narration track seems to be universal from the major studios, but can be hit and miss from the minors. Wienstein seems to be the biggest culprit from the common art houses to not include the VIN track.

Posted by Leslie Hartmier (Member # 7053) on 11-23-2016, 02:54 PM:

Frank,

in Canada, it is the responsibility of the province to determine such things, it seems.

In Ontario, it is necessary to maintain HI/VI for all possible shows at all possible times, and has been for years.

In Alberta, it is not strictly necessary, although I suspect it will be one day reasonably soon, in part because of the ADA thing.

One 'funny' anecdote about that is that one of our locations in Alberta had the entire HI/VI system removed for installation at a location in Ontario because in years, not one person requested it at the Alberta location. NOT. ONE.

The day after I shipped the hardware out to Ontario, I get this (WARNING: SARCASM) gentle, respectful call from the Alberta location, mentioning how fine it would be were I to reinstall said devices for finally, one person had requested HI/VI. The mutually kind dialogue I had with my location-based co-worker was, sadly, not to end with the system being re-installed.

My co-worker is, shall we say, a fairly forthright individual, and felt no restraint to informing me of her considerations of what I might do with myself as regards self-intimacy for quite some time.

Ahh, the good times.

Leslie

Posted by Bob Ezra (Member # 841) on 11-23-2016, 06:35 PM:

Harold

Would the IRC-28C IR emitter work from inside the booth, through 1/4" plate glass, into a room 25'x 70' with 125 seats?

Thanks

Posted by Justin Hamaker (Member # 2165) on 11-23-2016, 06:52 PM:

Bob, I can tell you that you would likely lose coverage to the back couple rows. You might also have issues with reaching the full width of the auditorium. We have our transmitters in the auditorium, and we still have a a few seats that have trouble getting a signal. You have to remember the IR is line of sight.

Posted by Leslie Hartmier (Member # 7053) on 11-23-2016, 07:24 PM:

Same with us. Line of sight is very important it seems, and we did try messing with the IRC-28C from inside a booth, and even in a direct line, the glass really did a number on the signal.

Posted by Harold Hallikainen (Member # 5405) on 11-23-2016, 10:49 PM:

Sending the IR through a booth window works in smaller auditoriums. It does make installation simpler. But, just as you see a lot of reflected projector light in the booth, a lot of the IR is reflected by the glass instead of being transmitted through it. For best coverage (and relative ease of installation), we suggest the panel go on the rear wall of the auditorium near the port window. The IR panel should be "aimed" at the screen. The IR reflects off the screen and covers the entire auditorium. My initial tests were at the Fremont Theater ( https://www.kcet.org/shows/artbound/the-many-lives-of-the-fremont-theater ). The theater has about 800 seats and is about 125 feet from the rear wall to the screen. Every seat receives HI/VI audio plus closed captions. I have had challenges working with theaters with balconies. With the emitter near the port window, it's really hard to get coverage under the balcony. I ended up having the panel installed at the side of the screen and aiming it for the opposite (diagonal) corner of the auditorium.

Harold

Posted by Leslie Hartmier (Member # 7053) on 11-24-2016, 05:03 PM:

Addendum to my statement of who has to do what - all new builds must have complete HI/VI availability. That is a federal requirement. However, all provinces have the option to be more aggressive with their requirements.

The federal government simply set the minimum acceptable requirements.

Additionally, if there is cause, and a consistent request for it, all provinces require the location to comply with HI/VI support.

So, if you build a new theatre? Gotta have it.
Someone needs it, asks for it, and you don't have it? Gotta put it in.
No one asks, and you've not built the theatre since the law came into being? Depends on the province. Ontario requires that HI/VI be available and working at all times, for example.

Now I know.

Posted by Bob Ezra (Member # 841) on 11-26-2016, 11:47 AM:

Harold

What are the weight and dimensions of the IRC 28?

Are there any diagrams showing mounting bracket?

I looked but could not find...

Thanks

Posted by Harold Hallikainen (Member # 5405) on 11-26-2016, 11:53 AM:

I'll have to go into the office to check the weight of the IRC-28C. There are some drawings of the mounting brackets at http://ftp.uslinc.com/ftp/Products/IRC-28/Documents/UPC-28C%20%26%20CD%20pkg.pdf .

Thanks!

Harold

Posted by Sam D. Chavez (Member # 1841) on 11-26-2016, 01:29 PM:

IRC 28 weighs about 3 pounds. I have one in the shop I just checked. There are a couple of ways to mount it. Very easy. Running the wires is the hardest part and even that is reasonable depending on local conditions.

Posted by Bob Ezra (Member # 841) on 11-26-2016, 03:26 PM:

thanks Sam

Posted by Jason Metcalfe (Member # 5739) on 11-27-2016, 11:13 PM:

Is there a previous ruling on the number of amplified HI headsets required, separate from the descriptive audio headsets?

Posted by Steve Guttag (Member # 268) on 11-28-2016, 06:57 AM:

Yes, HI headsets are supposed to be 4% of seat count. Because that missed the mark so horrendously (way over estimated the needed amount), this time around theatres showed that seat-count isn't such a good guide to actual usage. So they went with screen count. However, from what I can tell, this new DOJ ruling has zero effect on the previous requirements.

Posted by Harold Hallikainen (Member # 5405) on 11-28-2016, 08:10 AM:

I agree. No change in the assistive listening requirement. The actual number of receivers is listed at https://www.ada.gov/regs2010/2010ADAStandards/2010ADAStandards_prt.pdf#page=81 . ALS requirements are at https://www.ada.gov/regs2010/2010ADAStandards/2010ADAStandards_prt.pdf#page=201 .

Harold

Posted by Steve Guttag (Member # 268) on 11-28-2016, 09:21 AM:

Thanks for that Harold. I see that over 500 seats (within a complex) the requirement drops some but still absurdly high.

Posted by Justin Hamaker (Member # 2165) on 11-28-2016, 03:44 PM:

Those numbers MIGHT be appropriate for a live performance facility which is regularly at near capacity. My theatre has a seating capacity of about 1000, which would require 35 headsets. As I said earlier in the thread, we have never needed more than 4 at one time, but we have 6 additional units we keep in the office just in case they are needed.

Posted by Jason Metcalfe (Member # 5739) on 11-28-2016, 04:01 PM:

Thanks Steve and Harold

I'm wondering if the HI requirement is going to be re-checked along with this new ruling...

Posted by Harold Hallikainen (Member # 5405) on 11-28-2016, 08:06 PM:

I have not seen anything about revisiting the assistive listening requirements. Someone could petition for a rulemaking to revise the requirements.

Harold

Posted by David J Hilsgen (Member # 2614) on 11-28-2016, 10:54 PM:

How about drive ins

Posted by Harold Hallikainen (Member # 5405) on 11-28-2016, 11:03 PM:

Drive-ins are exempt. The new rules apply to "movie theaters" which they define as:

(vii) Movie theater means a facility, other than a drive-in theater, that is owned, leased by, leased to, or operated by a public accommodation and that contains one or more auditoriums that are used primarily for the purpose of showing movies to the public for a fee.

Harold

Posted by Justin Hamaker (Member # 2165) on 12-02-2016, 05:21 PM:

This rule/law has now been recorded, so theatres which currently have closed captioning and descriptive narration need to be in compliance by January 17. This primarily pertains to making sure the information is displayed at the box office and ticketing locations, on show times recordings, in newspaper ads, and on web sites and mobile apps.

Posted by Julian Antos (Member # 5497) on 08-02-2017, 04:45 PM:

Perhaps a dumb question, but does the installation of a HI/VI system cancel out the requirement for Assistive Listening Devices? Our theater has neither and we'll be putting in HI/VI later this year, but do we still need to install Assistive Listening Devices. If so, can anyone reccomend a manufacturer of these things that actually sell a good product? All the ones I've seen seem to break constantly. We only have one patron who has asked about them, but he's very vocal about it.

Posted by Harold Hallikainen (Member # 5405) on 08-02-2017, 04:55 PM:

I believe HI IS "assistive listenting." Here are a couple papers I wrote.

1. Best Practices describes the different technologies.

2. New Technology Requirements summarizes the rules and provides a link to the actual rules.

Harold

Posted by Julian Antos (Member # 5497) on 08-02-2017, 05:00 PM:

Very helpful, thank you!