The American Cable Association is urging the FCC not to apply its new IP closed captioning rules to IP delivery of traditional cable programming, but rather confine it to IP delivery of online video programming over the Internet.
"To get this right, the FCC must avoid imposing conflicting, unnecessary and burdensome obligations, or create a patchwork of requirements that will unfairly burden smaller cable operators with more limited access to capital and smaller subscriber bases over which to spread regulatory compliance costs," said ACA President and CEO Matthew M. Polka.
ACA filed reply comments Nov. 1 in the FCC's implementation of the Twenty-First Century Communications and Video Accessibility Act of 2010 (CVAA).
The act, which passed a year ago next week, required the FCC to come up with rules requiring any online video that is closed captioned on TV to be closed captioned online and look into requiring captioning of web-originated video.
The FCC says it only plans to require captioning of full-length programming, not outtakes or clips.
Congress gave the commission until Jan. 12, 2012, to come up with the new rules.
ACA also advises the FCC to "incorporate elements of the definition of an OVD from the Comcast-NBCU Order to cleanly distinguish MVPDs subject to existing captioning requirements from online video distributors subject to the new IP closed captioning requirements.
"Hew closely to the statutory mandate of the CVAA and impose no more than a rendering or pass through" obligation on video programming distributors.
"Clarify that the IP closed captioning obligation does not apply to broadband Internet access service providers."
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