rachaelbradley
commented
2 years ago Thank you for your comment. We have assigned it to the milestone where we will address captions. You may see discussion in the comment thread and we may ask for additional information as we work on it. We will mark the official response when we are finished and close the issue.
Since open captioning appears burnt in a video, this kind of captioning can be more challenging than closed captioning for some groups of people. These challenges do for example apply to people with a restricted language, such as immigrants and people with cognitive disabilities. For these groups, closed captioning will be better, as it makes it possible to easily translate. Adding new languages is also easier.
Moreover, as the automatic translation technology becomes better, closed captioning will possibly make texting available in more languages. This technology is not applicable to open captions, as these are burned in. It is also worth mentioning that the quality of open captioning on streamed videos is dependent on bandwidth unlike closed captions.
Based on this, we support the suggestion on scoring closed captions differently compared to open captions. Despite open caption’s restrictions, and that it can cause challenges in combination with new captioning, we find it important to emphasise that open captioning is better than no captioning. Open captions must therefore be rated higher than no captioning. To encourage closed captioning, it is however important to not score the two types of captioning equally. We do therefore support a change towards reserving the highest rating to closed captioning.
When it comes to the suggested reservation on which videos etc. that must be captioned, we are afraid the opening for exceptions based on whether the media is “essential to accomplishing the task” can lead to many providers wrongfully allowing themselves exceptions. What is published on an ICT solution should by default be “essential to accomplishing the task” based on a presumption that irrelevant content is not published.
The draft mentions “advertising and promotional videos” as examples of media not essential to accomplishing the task. It is however important to remember that advertisement is as important for disabled people to become aware of products and campaigns, as it is for others. Such videos can therefore be essential for the users, although they are not essential for the visit per se.
Moreover, it is a fine line between advertisement, instructions, necessary information etc. One example is political advertisements videos. This can make it difficult to draw a line when the exceptions are too flexible. An exception should therefore, if needed, be mirrored: All videos must have captions, unless that clearly is not necessary for the users or the content or captioning of the video is out of the website’s control. Moreover, it should be emphasised that this exception is meant as a safety valve.
To reflect the difference between videos essential to accomplish the ICT-solutions’ tasks, and other videos, you may consider different ranking.