Film-Tech Forum ARCHIVE: DOJ proposes requiring closed captions and audio description

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Posted by Harold Hallikainen (Member # 5405) on 07-26-2014, 01:42 PM:

http://www.ada.gov/regs2014/movie_nprm_index.htm

Posted by Aaron Garman (Member # 1653) on 07-26-2014, 03:04 PM:

Here is the text:

quote:
On July 23, 2014, the Attorney General signed the Department's Notice of Proposed Rulemaking (NPRM) proposing to amend the Americans with Disabilities Act title III regulation to provide closed movie captioning and audio description to give persons with hearing and vision disabilities access to movies. Closed movie captioning refers to captions that are delivered to the patron at his or her seat and are visible only to that patron. Audio description enables individuals who are blind or have low vision to enjoy movies by providing a spoken narration of key visual elements of a movie, such as actions, settings, facial expressions, costumes, and scene changes. Audio description is transmitted to a user's wireless headset. The Department is proposing to provide a consistent nationwide standard for movie theaters to exhibit movies with closed movie captioning and audio description for all showings of movies that are available with closed movie captioning or audio description. This proposed rule would impose no independent obligation on movie theaters to add captions or audio description to movies that are not already available with those features.

Title III of the ADA requires movie theaters and other public accommodations to provide effective communication through the use of auxiliary aids and services. This rulemaking specifies requirements that movie theaters will need to meet in order to satisfy their effective communication obligations to persons with hearing and vision disabilities. For a summary of the NPRM and its requirements, see the "Questions and Answers about the Department of Justice's Notice of Proposed Rulemaking Under Title III of the ADA to Require Movie Theaters to Provide Closed Movie Captioning and Audio Description."

The Department anticipates that the proposed regulation will be published in the Federal Register within the next few weeks. At that time, the public will be able to begin to submit public comments either on the regulations.gov website, or by mail. The comment period will be open for sixty days beginning on the date of publication in the Federal Register. The Department encourages the public to review the NPRM and submit comments. This webpage will be updated to contain a link to regulations.gov when the NPRM is published.

Posted by Lyle Romer (Member # 1266) on 07-26-2014, 04:11 PM:

I have never understood why this stuff is part of the ADA. A movie is made of audio and video. If you are blind or hearing impaired, I feel bad for you but you can't possibly experience a movie the way it was intended.

The closed captioning and hearing impaired devices are bad enough in that they force exhibitors (in the case of CC might in the future) to spend money on something for a very small percentage of people but the descriptive audio is taking it WAY too far.

It is a movie, not a radio show. Will stores have to provide employees to give blind people guided tours? What about theme parks?

Even the amount of handicapped seating required is more than what is needed. Back in the early 90's I worked in a GCC location that had a very high percentage elderly audience. This demographic would have a disproportionately high number of people in wheelchairs. Never once (and we sold a lot of weekend shows out) did we ever have more than 2 wheelchair bound patrons in the same showing and even having 2 was VERY rare.

Posted by Harold Hallikainen (Member # 5405) on 07-26-2014, 04:25 PM:

There's also a 130 page pdf which is the actual notice of proposed rulemaking.

They are inviting comments (after it's published in the Federal Register).

FilmTech users may want to submit comments.

They are proposing a required number of closed caption and descriptive audio receivers. You may want to submit comments on the actual usage of hearing impaired receivers.

Note also that they are proposing equipment be installed in digital auditoriums 6 months after the effective date of the rule. FT users may also want to comment on this.

Harold

Posted by Steve Guttag (Member # 268) on 07-26-2014, 05:16 PM:

Thanks for the info Harold!

I've always held that it was a poorly written law to begin with. A private space with public accommodation should not be forced to take on each and every new technology nor have to contend with each and every form of disability.

A more reasonable law would have only put an obligation on the business to provide transmission of these signals on federally regulated frequencies/carriers.

The receiving part should ALWAYS have been on those that are disabled. If you have hearing loss...that does not mean that you just have a problem that all levels are low...you may have particular frequencies that are deficient. You will have hearing aids to compensate for that. It would be better if the listening device also worked with that. In this manner, even if you are in a shopping mall and a life-safety device (fire alarm) went off...if there is an emergency message your hearing aids would be able to work with that too.

They should set up the frequencies protected for ADA uses and just require theatres (and other equivalent spaces) to broadcast the HI, VI-N and CC on said frequencies and that would be the end of the theatre's obligation. The cost would be minimal.

At that point, you no longer are handing out devices to people, there is no longer a sanitary issue, battery issue, programming issue...etc.

And if you are disabled and have your own device, you could then expect it to work in any theatre (or like space).

I don't think you'll get much blow-back from the theatre to put up an IR panel (could have issues with RF running out of frequencies in a larger plex). Come up with a suitable IR meter to test that you have sufficient level/coverage and you are done.

Posted by Justin Hamaker (Member # 2165) on 08-06-2014, 12:34 AM:

I haven't seen the full text, but apparently there is an exemption for drive-in theatres because there is not a reliable technology available, and the limited number of theatres limits the financial incentive for R&D - especially with closed captioning. While there are ways to work around the issue, any drive-in that says they have CC or VIN, is setting themselves up for a lawsuit if it can not be reliably delivered to every customer. Which is very likely in a drive-in situation since you have many more variables which are not within the control of the theatre.

Posted by Harold Hallikainen (Member # 5405) on 08-06-2014, 11:39 AM:

I've read the 130 pages of the NPRM. They do propose an exemption for drive-ins (their definition of a "movie theater" excludes drive-in theaters). I do not believe any of the current closed captioning systems would work reliably in a drive-in. I did see a demo of one system that was an application for a handheld device (phone, etc.). The user downloaded the captions ahead of time. The system synced the captions based on the audio picked up by the microphone on the device. Interesting idea. A similar technique is used by My Lingo to provide the sound track in a different language.

The current NPRM deals only with closed captioning and descriptive audio. Since most drive-ins are using RF transmitters to reach the audience car radio (or a theater supplied broadcast radio), it seems that an additional transmitter could be added to transmit the descriptive audio. But, under the current proposal, drive-ins are exempt.

Harold

Posted by Marcel Birgelen (Member # 6801) on 08-06-2014, 01:39 PM:

I haven't read that 130 page document, but I was wondering how this "descriptive audio track" is supposed to work with foreign language films with subtitles..?

Posted by Harold Hallikainen (Member # 5405) on 08-06-2014, 04:17 PM:

Well, that's interesting... I guess that they could tell you the action on the screen AND read the subtitle to you. The DOJ NPRM deals only with exhibition (places up public accommodation) and not with the production side (though there are various settlements between the DOJ and the production side that encourages the inclusion of closed captions and descriptive audio).

Harold

Posted by Carsten Kurz (Member # 5396) on 08-06-2014, 07:22 PM:

Harold,

there is a german smartphone app available for free that plays audio description or subtitles on the device. Same sync mechanism as Lingo. It works pretty good technically, and is of great value IF the audio description is done properly. Some I tested were good, some not so good. As with mylingo, you need to download the neccessary sync/content file before using it, either through WIFI or 3G (goes pretty fast).

http://www.gretaundstarks.de/

The subtitles app of course, is a bit of a problem in it's current implementation, as it needs the smartphone to be held towards your face during the movie (whereas most cinemas have a more or less strict 'no-smartphone-use' policy). They are working on an affordable electronic glasses option to be connected to the smartphone to overcome that.
The VI/audio description app can be put back into your pocket once synced and running, needs no further attention.

I think MyLingo has a real problem in that they need/play localized audio tracks from offline sources while the movie is running in cinemas - I doubt many studios will allow this because it's the perfect way to make localized pirate copies, adding localized audio tracks to existing pirated video copies on the internet.

I know that a smaller high profile cinema chain in germany sometimes offers special versions of some movies remastered with dual language audio tracks. That is, they use a single DCP with added foreign language dialog and play this over the HI/VI system, so the audience may choose which language to listen too, or simply listen into the original language version actors voices from time to time. Not cheap, of course, and not availabe for every feature.

BTW - currently, Germany imposes no legal obligations to install HI/VI equipment in cinemas, but all movies applying for production grants here now need to supply HI/VI tracks in order to receive these grants. There is public founding available to cinemas for the installation of equipment.

A new system just launched is Sennheiser cinema connect, it is similiar to their existing systems, using a local source (e.g. cinema processor) for HI/VI tracks, but transmitting over WIFI in realtime to audience smart phones, like a local streaming service.

http://www.sennheiser-connect.com/index_en.html

Benefit again is that the listening device is brought in by the patrons, no charging, setting up, no sanitizing, patrons will always be familiar with the device/app and can use it in any cinema they want.

- Carsten

Posted by Harold Hallikainen (Member # 5405) on 08-06-2014, 10:27 PM:

Thanks for the links! I had heard of the Sennheiser system. It seems like it'd be difficult to get lip sync for HI over Wi Fi, but I assume they've done it. For debugging, USL provides a web interface where captions are presented in real time. The interface also shows the current edit unit number, TimeIn and TimeOut of the next caption, playout ID, amount of data in the different buffers, etc. This could also be sent to audience members, though you'd then have lit screens (through we do white text on black) plus a bunch of cameras pointing at the screen. So, Wi Fi captions are doable, if desired. VI, since it does not need lip sync, also seems quite doable. HI seems more difficult.

Again, thanks for all the details on these systems!

Harold

Posted by Marcel Birgelen (Member # 6801) on 08-08-2014, 01:48 AM:

quote: Harold Hallikainen
Well, that's interesting... I guess that they could tell you the action on the screen AND read the subtitle to you.

Yeah, that sounds like a real "exciting" way of "enjoying" a movie... [Wink]

It reminds me of those horrible dubs on some Russian TV channels, where one or two people (usually a woman and a guy) dub all the voices and you can still hear the original actors voices on the background.

Posted by Randy Stankey (Member # 64) on 08-08-2014, 07:30 AM:

You know... This sounds like a perfect application for something like Google Glass.

Posted by Harold Hallikainen (Member # 5405) on 08-08-2014, 07:44 AM:

Like this ?

Harold

Posted by Randy Stankey (Member # 64) on 08-08-2014, 02:25 PM:

Cute! [Big Grin]

But, yeah, something like that.

I don't know everything about how Glass works... Just theorizing...

The camera could track the screen or the wearer's movements and keep the subtitles or descriptions superimposed at the right place on the screen.

I assume that the camera will be able to pick up infrared as most solid state cameras can. That would allow Glass to use a series of IR LEDs, placed at strategic points on the borders of the screen to calculate the viewer's position in the theater and distort/transform the text to fit the screen.

Subtitle text could be sent via whatever wireless system Glass uses and and the same IR LEDs used for tracking could be pulsed in order to send codes for synchronizing the text to the picture.

Then, as a bonus, those flickering LEDs would also serve to foil any attempts at recording the movie, either with Glass or any other camera, for that matter.

I don't know if this would actually work but it's an idea.

Posted by Harold Hallikainen (Member # 5405) on 08-08-2014, 03:03 PM:

I've played with Google Glass a little bit (30 minutes or so). I believe it uses a Bluetooth RF link to the user's phone. It has a full motion color image in one eye. The image is high in the field of view, so we'd have "super titles" instead of "sub titles." It's quite possible to send captions or subtitles over Ethernet (we do that for debug in the USL equipment) or Wi Fi. But, we think the ease of use of IR linked captions and HI/VI makes IR a better choice (no programming required).

Thus far, I don't know of anyone trying to keep the caption or subtitle stationary over the screen. The USL glasses and Sony glasses have the caption follow your head. If you WERE to want to hold it in a certain position on the screen, I think just detecting the lit rectangle of the screen would be enough to determine where the screen is. In most cases, though, the caption or subtitle takes up the entire display, so there is not room to scroll the image around following the screen as the user turns her/his head.

Interesting ideas, though!

Harold

Posted by Randy Stankey (Member # 64) on 08-08-2014, 04:34 PM:

Do you think it is possible for Glass to receive captions via IR?
You could put an IR emitter in the front of the auditorium.

You wouldn't necessarily have to perform a full image superimposition. I think it would be enough to just use the IR for image stabilization.

The reason I suggested using IR to track the screen is because, if the image is dark, the computer might not be able to detect the edges of the screen. I was also guessing that it would be easier for the computer to detect four discrete points instead of calculating all four edges.

Again, all just conjecture.

Posted by Harold Hallikainen (Member # 5405) on 08-09-2014, 03:04 PM:

I've just finished reading the comments filed thus far in this proceeding (how are YOU spending your weekend?). Summaries and links to the individual comments are now available at http://ming.hallikainen.org/DojNprm/ . I'll update the page when new comments are filed.

Harold

Posted by Frank Angel (Member # 248) on 08-09-2014, 06:10 PM:

Didn't the MPAA get the local police and FBI come into a theatre and confiscate the Google Glass right off the patron's head who was using them and then throw that hapless individual to the ground and beat him with billy clubs for copyright infringment? The wife was also dragged out of the theatre and confinded in a separate room, strip-searched and interogated -- I think she may have been waterboarded as well to get her to give up the bootlegging network king-pins.

Posted by Harold Hallikainen (Member # 5405) on 09-04-2014, 07:51 PM:

Yesterday, the DOJ extended the comment period until December 1, in response to a request from NATO. My summary of comments filed so far is athttp://ming.hallikainen.org/DojNprm/ .

Harold

Posted by Harold Hallikainen (Member # 5405) on 11-25-2014, 10:49 PM:

The DOJ comment deadline is approaching! Comments on the proposed rulemaking are due December 1 at 11:59 PM ET. A summary of all comments filed thus far is available at http://www.hallikainen.org/DojNprm/ . There is also a link there to the DOJ page where you can file your comments.

Harold

Posted by Harold Hallikainen (Member # 5405) on 01-02-2015, 07:48 PM:

I have FINALLY finished summarizing the comments filed with the US Department Of Justice on closed captioning and audio description for movie theaters. The summaries are available at http://www.hallikainen.org/DojNprm/ .

Good bedtime reading?

Harold

Posted by Justin Hamaker (Member # 2165) on 01-02-2015, 09:35 PM:

A couple very common misconceptions I see in the comments:

1. Closed caption and descriptive audio systems would significantly add to profits.
>Because we log every use of ALD, VIN, and CC equipment, I can say without doubt that the use is minimal. Primary use is for ALD, and this is most common for films skewing to a senior citizen audience.

We normally have 4 headsets available and ready to use at any given time (plus more in the office if needed). In the nearly 2 years since installing the system, we have had maybe 2 instances where all 4 units were used at once. And in no case have we ever had more than 4 out at one time. In most cases we never have more than one unit in use at any given time.

2. Open captions would not distract the general public.
>I think this comment is colored by the individual's desire for open captions. I have not seen any objective evidence either way on this issue. However, I believe it would detract from the enjoyment of the average moviegoer.

3. Accessibility devices are inexpensive.
>The reality is the cost of equipping a multiplex to transmit and having an adequate supply of devices is rather expensive. If you look at the payoff for each device as a portion of the ticket price from each use, it's likely the payoff period will exceed the useful life of the units.

Posted by Brad Miller (Member # 2) on 01-02-2015, 11:47 PM:

quote: Justin Hamaker
2. Open captions would not distract the general public.
>I think this comment is colored by the individual's desire for open captions. I have not seen any objective evidence either way on this issue. However, I believe it would detract from the enjoyment of the average moviegoer.

I couldn't watch it. I would walk out as a moviegoer. Open captions are only good when you CAN'T hear the sound, such as sitting in a restaurant or a doctor's office, because that's similar to watching a silent movie. When the sound is available to hear though, it's an immense distraction. (At least to me)

Posted by Buck Wilson (Member # 5885) on 01-03-2015, 12:05 AM:

I strongly agree with the last two posts

Posted by Frank Angel (Member # 248) on 01-03-2015, 09:26 AM:

I firmly believe that the intention of the ADA requirements are laudable, but the ADA implementation has always been wrong-headed in how it has calculataed the arbitrary numbers needed for ADA compliance. At least in large venues like ours, the number of required devices (seats, headsets, etc) is totally out of sync with the real-time need. Here are the numbers: installed as per ADA requirement vs. MAXIMUN number of times these have actually been used during any one month of the year:

Wheelchair seating with adjacent companion seats 25/2
Assisted listening devices, available from the concessions counter in the Grand Lobby 35/3
ADA-compliant parking spaces 40/8
Accessible restrooms on the Grand Lobby level 2/EVERYONE uses them because we cannot enforce compliance, i.e., we can't keep non-handicapped individuals from using these restrooms; like, have an usher standing at the door forbidding older patrons from using the very near-by ADA restrooms and forcing them to go down or up flights of stairs when there are no handicapped individuals in sight? Sure, if you want a riot and LOTS of ill-will.
Large-print programs, available by request with 72 hours notice, So far, only once.

It seems clear to anyone who can do math that the requirements are serious over-kill and present a unnecessary burden on a business.

These new regs will be the exactly the same. They will require us to install expensive equipment in numbers well beyond the actual demand/need.

Seems it would be quite easy for a theatre to track the actual real-time need for ADA required equipment and technologies over, say a year's time, the number of actual requests made by handicap persons and allow that number vs, a small percentage higher for a buffer, to be used as the requirement. The theatre could be required by ADA regs to dutifully record those yearly numbers and the requirements would be based on that data. The theatre would also have to report any time a request was made for said devices but none were available.

Alternatively, the ADA equipment and technology requirements could be determined by the actual known number of handicapped persons in any given locality within a calculated distance from a theatre, this based on Census data from the Current Population Survey Annual Social and Economic Supplement (CPS ASEC) of the Census Bureau. Other Federal agencies also collect and report disability statistics. Why require a theatre to purchase and maintain 35 hearing assisted headsets if there are only 10 known persons with hearing disability within a 100 mile radius of the theatre? It seems there are legitimate and much better ways of determining how many devices a theatre needs to install that to just set an arbiturary percentage of number of seats as is done now.

I'm just saying, the laws should take into account known densities of handicap individuals within a reasonable proximity of the establishment required to supply such devices.

BTW, the idea that someone could possibly enjoy a movie if they had to watch the subtitles on a smartphone....what? looking up and down at the device and the screen?...is ludicrous.

Posted by Harold Hallikainen (Member # 5405) on 01-03-2015, 10:10 AM:

The NATO and others Joint Recommendations call for much lower minimums with usage tracking. Every six months, the theater would adjust the quantity of devices on hand to be at least 150% of the average weekend demand for the devices. This was submitted by NATO and several disability rights groups. Various other groups also endorsed this concept. This proposal also requires theaters to file reports every six months with the DOJ. I really don't think the DOJ wants to get into all that paperwork. But, I think they may require theaters to make the reports and have them available for the DOJ to review (which would probably be complaint driven). If a theater has reports showing they meet the 150% requirement, that could be an adequate defense.

A few commenters suggested basing the requirement on census data on the number of hard of hearing individuals within a certain radius. One comment figured out that a theater needed something like 18,000 devices based on this. I think the demand-based method is more reasonable.

LOTS of commenters want open captions. The Wisconsin Association of the Deaf pointed to a product from Invisivision ( http://www.invisivision.com/ ) that uses polarized filters to make onscreen captions visible. This, of course, would not work with white screens and would probably interfere with polarization-based 3D.

USL demonstrated a system based on polarization and patent 4859994. A silver screen was placed below the main screen. An LCD projector without a polarizer projected captions onto the silver screen. Those with polarized glasses saw the captions. Those without the glasses saw a green box. Exhibitors did not like the green box. I suspect users would not like having to look below the screen for the captions (there are several comments in the DOJ filing about this with both caption boxes and glasses).

Another method of invisible on-screen captions is covered by patent 7414698. It puts the text on the image as a positive and negative superimposing on alternate projector flashes. The eye averages these out so they are not visible to those who see all the flashes. Those wishing to see the captions would wear shutter glasses to pick up only one of the flashes.

Harold

Posted by Mike Blakesley (Member # 26) on 01-03-2015, 10:14 AM:

Since we have maybe one request for a hearing device every 2 plus years, our "average weekend demand" would be zero, so 150% of zero is still zero, so....I'm good! [Wink]

Posted by Justin Hamaker (Member # 2165) on 01-03-2015, 11:56 AM:

There is a theatre very close to a deaf school in Washington DC, and my understanding is that even that theatre sees minimal demand for CC and VIN.

Posted by Steve Guttag (Member # 268) on 01-03-2015, 12:00 PM:

So clearly one law professor gave an assignment or the folks in Tennessee just like reading DOJ postings for kicks!

If you NEED captions of some sort, they you want Open Captions...and I can understand that. Glasses are a bust as the captions would be flying about where ever you point your head. Closed caption devices suck because it requires you to not only move your eyes off the screen for the time it takes you to read, it also requires you to refocus your eyes between near and far fields. Rear Window would work to some extent because the text would continue to be far field though placing the reflector such that it superimposed the text where desirable would likely be distracting to those behind you.

I would think a viable alternative would be all-time closed captions with select days/show times to have open captions based on consumer demand.

I think Justin so squarely nails the factors at play here. Furthermore, this industry does not need yet one more excuse for potential movie patrons to stay home so they don't have to "put up" with the distracting open captions. Like it or not, the overwhelming majority of the movie business is not seeking open captions and those should not be given yet another reason to stay away. Make no mistake...open captions all the time would lead to attendance decline. One need not put up with THAT at home.

With the audio tracks...it would nice if the DOJ could standardize the source of the VI-N track such that all devices, consumer or pro have access to it as a discrete feed. In the home, it can be an alternate audio feed that normally means losing the Super-Duper sound track in favor of a mono/stereo track with the descriptions.

I still strongly feel that it is not discrimination to not provide the actual listening/captioning devices but merely the transmitters. If I needed a hearing aid or like device, I would want to use my own rather than the nasty thing you hand me.

Also on the audio side of things, the loop systems are the "favored" systems as they work with the "T-Coil" position of hearing aids. They are mostly impractical for cinemas (and most businesses) and are quite expensive. However, with a conventional receiver one can use a Neckloop to broadcast the equivalent of a loop for a LOT less money. http://www.williamssound.com/catalog/nkl-001. Instead of plugging in headphones, plug the neckloop in and away you go.

Another problem with some of the systems out there is that they completely cover the ear. If you want the VI-N channel, you are also typically blocking out the regular sound of the theatre with the headset. This is another reason I think people should supply their OWN listening devices that cater to their particular needs. One shoe does not fit all feet.

Posted by Leo Enticknap (Member # 534) on 01-03-2015, 12:08 PM:

Firstly, many thanks to Harold for compiling this page.

Another gotcha I didn't see mentioned in any of the submissions (though I was only skimming and may have missed it) is that theaters that show archive, rerelease, foreign and other "obscure" content are potentially screwed. Admittedly that is only a tiny fraction of the country's theaters, but this would be a big deal for us.

If you're playing an obscure Hollywood 'B' movie from 1935 one evening and an archive print of a BBC documentary from the 1970s the next, there is no subtitle or audio description content available for it - none has ever been created, it's as simple as that. So if this became law, either we'd have to hire a post house to do that, costing thousands of dollars per hour of content, or break the law, or stick to a small range of well-known classics and new releases.

Posted by Harold Hallikainen (Member # 5405) on 01-03-2015, 12:37 PM:

The proposed rules specifically say that you do not have to create captions. You only have to play them if the content has it. This, however, raises the question (brought up by some commenters) as to whether you need to play closed captions or audio description if you are playing from DVD or BD. These may have captions or audio description, but cinema equipment is unlikely to be able to deal with them unless you put them on screen.

By the way, we have captions enabled on our Roku so we can watch Lillihammer. We watched a fireplace video. A minute in, the text "Crackle, pop" showed up.

Harold

Posted by Marcel Birgelen (Member # 6801) on 01-13-2015, 03:01 AM:

There are many arguments against it, like the availability of those meta-tracks for legacy and independently produced content, the extra costs involved, etc.

This whole government mandated regulation regarding accessibility for disabled is slightly getting out of hand, not just in the U.S., but it's a general western issue.

I guess the primary argument here is simple: You're most likely not running a Public Service institution. And while it may be graceful for you to provide adequate infrastructure for disabled guest, experiencing movies, unfortunately, requires some basic "bodily functions" to be present and in a somewhat working condition and while the requirements are not as intense as e.g. for skiing, they're still required for the experience. And while we would laugh at the notion of making all ski trails compatible for blind people, if somebody would suggest the same for theaters tomorrow, many people would call it a GREAT IDEA...

quote: Brad Miller
I couldn't watch it. I would walk out as a moviegoer. Open captions are only good when you CAN'T hear the sound, such as sitting in a restaurant or a doctor's office, because that's similar to watching a silent movie. When the sound is available to hear though, it's an immense distraction. (At least to me)

As I stated before, I'm totally against mandating this by law. Personally, I find those audio descriptions also rather annoying and also more often than not missing the point entirely. Even if you're hearing impaired and you see a big explosion, do you really need to be told: [Series of loud booms]* ?

But I grew up with subtitles... About 85% or more of the content hitting the theaters around here is foreign in some way and usually comes with subtitles. All foreign movies on TV com with subtitles and they were "burned in" on every VHS release. And although I prefer to watch movies of which I can comprehend the language being spoken without any subtitles, you will, eventually, get used to them and they will cease to distract you.

Subtitles are, by the way, also a great way to get to know a foreign language. I think, watching movies with subtitles in foreign languages works way better than many language courses around.

* If you're also required to play the Visually Impaired soundtrack, you will see a series of big explosions on screen, hear an ear-shattering series of explosions in surround all around you, will read it on screen to confirm it really happened and a gentle voice will also remind you: A series of big booms.

Posted by Steve Guttag (Member # 268) on 01-13-2015, 06:51 AM:

quote: Marcel Birgelen
Even if you're hearing impaired and you see a big explosion, do you really need to be told: [Series of loud booms]* ?

You miss the point. There is a difference between subtitles (language translation) and captions (sound replacement). If you are deaf, you will likely miss audio cues that hearing people will take for granted. If the theatre does not have nor turns up their LFE track, you may not "feel" the boom that was evident to others. Think of a scene where you see someone press their remote control bomb detonator and the audience merely hears the explosion from "far off."

The idea with the current legislation is a group of friends where one is blind, one is deaf, one is in a wheel chair, one is merely hard of hearing and one is "not handicapped" any of those manners can all go out, sit together and "enjoy" a movie together like "regular people." The blind person gets the audio description channel to augment the normal sound track...they can hear the dialog but have no perspective as to where people are on screen, particularly those not speaking. The deaf person gets the captions so they get not only the spoken word but a sense of the music/effects. After all, if the music and effects are not important to the movie, why are they in there? The person in the wheelchair gets to sit in one of the designated areas that represent typical seating for the theatre with his/her friends sitting next to him/her. The one that is merely hard of hearing can use the Hearing Assistance to raise the volume for just him/her without bothering other patrons. It also accommodates those with multiple handicaps too.

I maintain, it shouldn't be the theatre's responsibility to provide ANY listening devices or even caption devices. The theatre shouldn't be handing out anything...that should be the handicapped person's responsibility...just like getting one's own glasses or wheelchair or whatever. The regulation should stop at the transmission of the signal.

As an able-bodied person, I prefer rear-window for captions because it is completely unobtrusive to those that don't need them. I'm curious if society could get used to having captions BELOW the screen. That is use LED boards to create a caption display below the screen such that the captions are not in the picture to distract. It would be a learning experience thing though since it would be a distraction at first until people who don't want them learn to just not look below the picture. Theatres would have to be designed to ensure that they would be visible from every seat too.

I also like "Open Caption Sunday" or some such concept where open captions are run on ALL movies in a particular time slot EVERY week such that those that desire them can count on them being there and those that just can't live with them will know when to avoid going to the theatre. This is probably the most workable and least costly solution. It may require some fine tuning as to the number of time slots that are dedicated to it based on actual need/demand.

What the DOJ should also consider is the harmful business impact of requiring something that the prime movie going patron finds distracting and a reason to NOT go to the theatre. It is wrong to discourage 90% of the people to accommodate less than 1% of the people that may buy a ticket that day. (Made up numbers but the idea is that time-after-time theatre owners have shown that actual use of the ADA devices are WAY-WAY below what legislation has required).

Posted by Mike Blakesley (Member # 26) on 01-13-2015, 12:04 PM:

quote: Steve Guttag
I'm curious if society could get used to having captions BELOW the screen. That is use LED boards to create a caption display below the screen such that the captions are not in the picture to distract.

I think there are a lot of people who would not even want to try to get used to them and would just think they were a distraction and it could even discourage some of those people from coming to the movies -- they'd say "I'll stay home where I can turn the damn captions off."

And some people who like captions might object to them being below the screen because now they have to keep shifting their gaze up and down (especially if it's a particularly large screen).

I don't mind captions during a movie - in fact with some movies, especially action movies and those with characters speaking with accents, I wish they were there so I could understand the dialogue better. But I think the notion of adding a distraction to 100% of the shows for the benefit of the less than 1% of people who want/need it doesn't make much sense.

Posted by Marcel Birgelen (Member # 6801) on 01-13-2015, 12:29 PM:

quote: Steve Guttag
You miss the point. There is a difference between subtitles (language translation) and captions (sound replacement). If you are deaf, you will likely miss audio cues that hearing people will take for granted. If the theatre does not have nor turns up their LFE track, you may not "feel" the boom that was evident to others. Think of a scene where you see someone press their remote control bomb detonator and the audience merely hears the explosion from "far off."

No, I didn't miss the point and you can safely assume I know the difference between subtitles and "captions" as in, the audio replacement captions (although those terms are often mixed/confused) for hearing impaired people. My point was, how stupid it would be if you would be required to play both the HI track as open captions and VI audio track per default.

Now for the usefulness of those HI and VI tracks altogether. I do get the (limited) usability of those tracks for private use, but for cinemas, the use really is extremely limited.

I happen to know some hearing impaired people, and both of whom I spoke about those captions do think those "descriptive audio captions" are mostly just stupid. Although the subtitles are important for them to correctly understand the dialog, their hearing aids are usually more than sufficient to get the idea of almost all sounds. And in regards to people who where deaf right from their birth, they usually don't have any sense what most of those sounds actually sound like, so those cues will probably just get lost on them.

I also happen to know a blind person who was born blind. He never even considered to go to the movies, because... what's the point actually? He even doesn't own a TV, because, you might guess it already, it's rather pointless for him to "watch" TV.

quote: Steve Guttag
a group of friends where one is blind, one is deaf, one is in a wheel chair, one is merely hard of hearing and one is "not handicapped" any of those manners can all go out

This almost sounds like the start of a great joke [Razz]

quote: Steve Guttag
As an able-bodied person, I prefer rear-window for captions because it is completely unobtrusive to those that don't need them.

My experience with them is very limited, but I've witnessed them twice if I remember correctly. I do remember them casting an eery yellow, flickering glow on the screen... If I would go for a system with closed captions, I would certainly opt for a wireless system with individual receivers, not a big LED screen at the end of the room and a bunch of mirrors.

quote: Steve Guttag
I'm curious if society could get used to having captions BELOW the screen. That is use LED boards to create a caption display below the screen such that the captions are not in the picture to distract. It would be a learning experience thing though since it would be a distraction at first until people who don't want them learn to just not look below the picture. Theatres would have to be designed to ensure that they would be visible from every seat too.

Some multiplexes with floor to ceiling and wall-to-wall screens will have a hard time fitting those. Besides that, I think this will be a hell of a distraction. I think I would always rather want them IN the picture than below, above or even besides the picture. I remember something just slightly similar... About 15 years back, a cinema over here experimented with a LED sign in the right corner below the screen, showing the number of minutes until the start of the show, the number of minutes until the intermission, the remainder of the intermission and finally the time until the end of the show. The thing needed to be programmed per show. The idea was apparently to keep people in their seats until the intermission or end of the show and also getting them back on-time for the re-start of the show. The thing wasn't only a failure because nobody understood the actual meaning of those numbers, it was also a major and rather pointless distraction.

Posted by System Notices (Member # 2357) on 07-08-2017, 07:47 PM:

It has been 907 days since the last post.

Posted by Melanie Loggins (Member # 6454) on 07-08-2017, 07:47 PM:

I've looked for discussion of this in other threads, so if I've missed it, I apologize. So... the DOJ has ruled that all digital cinemas have to be in compliance by June 2018. I have found four possibilities: Willaims Sound, QSC, Sony, and Dolby. Maybe there are other products I've missed? And.... thoughts? What have you used and liked? Or not liked? I did read through all the comments here, but I figured they were old enough that it warranted asking again.

Posted by Clint Koch (Member # 1179) on 07-08-2017, 11:52 PM:

There is a new player to the game, Sennheiser with it's CinemaConnect product. You can find it at https://en-us.sennheiser.com/hearing-visual-aid-app-cinemaconnect or contact me for more info if you like.

Posted by Leo Enticknap (Member # 534) on 07-09-2017, 12:58 AM:

If I'm reading this right, the Sennheiser system requires theater customers to have a smartphone (and to be willing and able to install an app on it, though that's a secondary issue) in order to be able to use the closed caption and/or audio description.

Would that be compatible with DOJ accessibility rules? Could a customer who does not own a smartphone claim that (s)he was being discriminated against if a theater tells customers that they have to have one in order to use the assistance tracks, or would the argument hold water that the ownership of these devices is now so widespread that there is effectively no longer any economic barrier to anybody having one?

Posted by Frank Cox (Member # 6258) on 07-09-2017, 01:07 AM:

After working so hard to stamp out cell phones in the auditorium, now we're going to encourage, even require, them?

Posted by Steve Guttag (Member # 268) on 07-09-2017, 06:36 AM:

I don't think Williams has a complete solution either. They can handle the two audio tracks but not the captions. One could augment a Williams system with a Captilink system and if QSC has kept the CCE-100, though expensive, it could also supplement a Williams system.

I have a love/hate relationship with the Sennheiser system. I REALLY like the idea that the end-user supplies their own receiving device. Forcing businesses to supply those is wrong on so many levels. The ADA is supposed to prevent business from putting up barriers to the disabled, not participate in whatever the disability is. The business provides the wheelchair ramps, not the wheelchair. Requiring businesses to provide listening/viewing devices is as dumb as requiring them to provide corrective glasses if you are nearsighted.

From an audio standpoint, Sennheiser using one's phone/pad/pod like device shouldn't be an issue (doesn't need to light up or be visible). From a caption standpoint, using the phone's display could be disturbing to others and encourages everyone to use their phone while a movie is playing (you can't enforce a rule for some but not others. Once phones are lit up, they are lit up). I believe they are working a "Google Glass" like viewing device.

Clint would know more on its status.

From what little research I've done on it, it seems pricey, for what it is, and I think one has to use THEIR WiFi access point, for some reason. That is a non-starter for me. Again, Clint would know more specifics.

I believe they BYOD approach is the correct one (in general). It solves so many failings of the present model of how many devices to have, sanitation, actually providing the proper audio correction for one's particular impairment...etc.

Posted by Carsten Kurz (Member # 5396) on 07-09-2017, 08:12 AM:

We use a completely open and free HI/VI/CCAP system in germany, with apps available for iOS and Android (Greta & Starks). Basically it's an offline system, the user downloads the aux tracks at home, through WIFI, or 3G/4G, if necessary, right ahead of exhibition time. You are free to offer them free WiFi at your cinema to speed it up a bit, but it is doable over 3G/4G easily.

That means, you have to supply nothing, except pointing patrons towards that possibility.

Once people use this app, they get notifications of new titles with HI/VI/captions available. So they choose the title, but not the cinema or equipment. The system works by syncing the VI-N/captions to the audio track in the auditorium. So, if they buy the Bluray or DVD later, they can use the same app to have VI-N or captions at home.

I also like the idea that people bring their own device. Aside from hygienic issues/battery charging/setup/provisioning, it gives these people back their autonomy to choose and act. Also, they do not have to out themselves as being handicapped in order to receive a device. They just enter the auditorium as everyone else.

Yes, you have no way to promote your business against others based on your offering of assistive equipment, but as in the US, every cinema is forced to supply HI/VI devices, there will soon be no promotional incentive anyway, as everyone offers it.

The VI-N listening part using this app on iOS or Android is very unobtrusive - you select the movie before the show starts, hit 'run', then you can put your phone into your pocket and go on only with your headset (including volume control if your headset supports it. Bluetooth also supported.
You don't need a WiFi or 3G connection during the movie, so you can set it to flight mode or silent mode.

The captions part, yes, that COULD be obtrusive, but so far, it hasn't happened in our auditorium. You can also tell patrons using it that they should prefer the last row of seats. The company supporting this system we are using are also working on wireless connected glasses for the captions.

In germany, cinemas are not forced to supply assistive devices. Movie productions are forced to supply assistive content, and cinemas receive funding if they buy and supply assistive devices.

So far, no clear winner can be seen between the smartphone solution and established dedicated devices. In germany, it is still in the beginning with these solutions.

Leo - the way I understand it, even if smartphones are an option, you would probably have to supply smartphones to people if they demand it.

- Carsten

Posted by Dennis Benjamin (Member # 1137) on 07-09-2017, 09:09 AM:

quote: Melanie Loggins
So... the DOJ has ruled that all digital cinemas have to be in compliance by June 2018. I have found four possibilities: Willaims Sound, QSC, Sony, and Dolby

We are using the QSC (formerly USL) brand and so far, they are working great.

Posted by Leo Enticknap (Member # 534) on 07-09-2017, 10:01 AM:

quote: Carsten Kurz
Once people use this app, they get notifications of new titles with HI/VI/captions available. So they choose the title, but not the cinema or equipment. The system works by syncing the VI-N/captions to the audio track in the auditorium. So, if they buy the Bluray or DVD later, they can use the same app to have VI-N or captions at home.

That's really clever. The phone's mic simply listens to the same audio that the customer does (or could, if his or her hearing allowed) and uses that to sync the captions or commentary. Furthermore, as you're not including the movie audio itself in the data pacakage that the app uses, only information as to what it should listen for as a cue to display each line, there is no copyright infringement issue.

I hadn't thought about Steve's BYOD angle - that people with disabilities in other contexts are required to provide their own assistive equipment (the theater only provides the ramp, not the wheelchair) - but it makes a lot of sense. Reminds me of a court case shortly before I left Britain: someone sued a council for charging to use disabled parking spots, claiming discrimination. The council's response was that they are only required to help level the playing field for disabled people, not skew it. So, because they can't walk as far and/or as easily, they do need a spot closer to their destination. But that does not in itself mean that they are unable to pay to park, so the charge still applies.

So, as applied to our business, we wouldn't be able to claim that because we forgot to put our glasses or contact lenses on, the picture looking fuzzy is the fault of the theater; so by the same token, asking customers to provide their own device (especially a common one, that almost every adult citizen of every developed country owns) to receive assistive audio and subtitles is not unreasonable or discriminatory.

Posted by Harold Hallikainen (Member # 5405) on 07-09-2017, 10:44 AM:

Nice to hear the QSC/USL system is working well for you. I try to keep it that way!

Though dated, some info on various technologies is at http://ftp.uslinc.com/ftp/Products/IRC-28/Documents/AccessibilityBestPractices130425a.pdf .

Also, a summary of the US DOJ requirements is at http://ftp.uslinc.com/ftp/Products/IRC-28/Documents/NewAccessibilityRequirements_170119.pdf .

The system Carsten mentioned is interesting. It's a bit similar to MyLingo. The content is downloaded ahead of time and synced based on auditorium audio. I suspect that only the feature ends up getting captions since the user has to select the content to be captioned (and would have to select each trailer). These systems require the studios to deliver the soundtrack ahead of time so an audio signature can be developed (though it's possible for the vendor to supply the studio with software to generate the signature from the soundtrack). If the system is handling HI, the studio also has to either permit remix of the soundtrack to generate the HI audio or deliver the HI audio. There may be hesitation by studios to deliver this content outside a DCP. Further, the HI delivered by these systems does not get the auditorium specific forensic mark possibly allowing the audio to be used for pirated copies of movies.

On Bring Your Own Device, it seems that as long as a theater has the US DOJ required equipment ("auxiliary aids") available, patrons are free to use their own devices. Some people have bought QSC/USL headphones for their own use. Also, there are also consumer devices (such as http://www.tvears.com/ ) that use the same 2.3 MHz FM over IR, so consumers can purchase their own HI receiver.

For captioning, it would certainly be possible for a consumer to purchase their own receiver. However, use of a phone or similar is more practical than a specialized receiver. As mentioned above, I think a BYOD approach could be used in the US as long as the theater meets the minimum equipment requirement (having receivers that no one may ever use). Use of cellphones in theaters can be distracting due to the lit screen (cellphones thus far seem to use backlit LCD which emit a fair amount of light, even with a black screen, when compared with OLED displays used in dedicated caption receivers). Cellphone use in an auditorium makes it difficult to determine if the device is being used for captions, HI, VI, or movie piracy. It would be possible to make a "cup holder" mount that the phone would be mounted in that would block the camera lens.

Closed captioning has thus far relied on text delivery to the user. Brazil will soon require use of sign language. It appears three methods of delivery are available, all using consumer devices like cell phones.

1. Download sign language video and sync based on auditorium sound.

2. Use SMPTE 430-10 interface to servers to get closed caption text, machine translate to sign language animation commands, send commands over wifi to phones in auditorium that run an application with an animated avitar that does the sign language.

3. Delivery of sign language video in the DCP. Eventually this would be an AuxData track, but to get started, it is proposed to encode the video as VP9 and put it on audio track 15. It can be delivered by existing servers out the AES/EBU outputs (with forensic marking disabled on that channel). The video would be transmitted (probably by wifi) to devices in the auditorium (probably cellphones).

Somewhat related, there is also discussion of delivery of alternate language audio tracks. I suspect these will be stereo tracks to carry, for example, Spanish in US theaters. Currently, it is possible to devote a couple audio tracks in the DCP for this with no changes to the server. The audio would be forensically marked and transmitted (somehow) into the auditorium. This could also be done using AuxData tracks in the DCP. This could be handled within the IMB if enough audio outputs are available and if the IMB can forensically mark these audio outputs. The AuxData can also be delivered to an outboard media block (OMB) using SMPTE 430-14. However, OMBs are indeed media blocks with heavy security requirements, forensic marking requirements, etc. The other approach to handling these additional language tracks is "sidecar" delivery and use of auditorium sound to sync (which is what MyLingo does).

So, there's a lot going on! I'm keeping an eye on it for QSC.

Harold

Posted by Carsten Kurz (Member # 5396) on 07-09-2017, 01:59 PM:

quote: Harold Hallikainen
These systems require the studios to deliver the soundtrack ahead of time so an audio signature can be developed (though it's possible for the vendor to supply the studio with software to generate the signature from the soundtrack). If the system is handling HI, the studio also has to either permit remix of the soundtrack to generate the HI audio or deliver the HI audio. There may be hesitation by studios to deliver this content outside a DCP. Further, the HI delivered by these systems does not get the auditorium specific forensic mark possibly allowing the audio to be used for pirated copies of movies.

Hi Harold,

no, they don't do HI, they would rely on HI options in the theatre/CP to create HI via other means. It could be possible that they upgrade their app to receive HI realtime from the CP the way Sennheiser does it. Of course, once HI hit's a personal device, no matter wether through WiFi, or IR RF, it can always be tapped, so, yes, the small benefit would be that in the one case it could theoretically be tapped before the release, and in the case of established realtime HI, not before it is actually screened (which may be enough of a difference for the studios).

The benefit of the audio fingerprint VI-N for the studio is that they don't have to include this with the DCP distribution early on. They can package the DCP without VI-N and while the distribution is prepped, the service company can do the VI-N on a side track, and it all comes together in the cinema later. It is also relatively easy to support many different languages inside the same auditorium, as the language can be chosen per device and is not limited to one or two RF channels. That may be beneficial for festivals.

The audio fingerprint TC can not be used to create a pirate copy, as it is a very low frequency volume envelope. It is also fault tolerant against editing/jumps introduced late in distribution, as it will simply resync without user intervention.

The best thing, though, is that it actually works very solid. When I tried it with one of the first movies they released with it, I was quite skeptical, giving a smartphone to a person with visual impairment in a cinema auditorium and expecting him to handle the device. But it went exceptionally well, not just techwise, also the VI-N itself was of exceptional quality, tonal aspects, intelligibility, loudness, timing, etc. The latter, of course, can't be credited to the app, but the skillful people who created the VI-N track.

Regarding alternative audio tracks - I have heard of two cinemas in germany which offer german and english dialog simultaneously.

In the one case, a smaller chain orders a special DCP with the english dialog on the HI or VI-N tracks, and they transmit it with their existing HI/VI installation.

The other cinema has a spare Doremi, and runs an english CPL synced to the one playing the german version.
The special DCP is quite expensive, while the synced Doremi is (nearly free), but will probably not always work due to sync/version issues, and if no english DCP/KDM is available.

But having an alternative language track on a regular basis would certainly make the investment into a HI/VI-N system more attractive, as it could serve both needs.

- Carsten