PhoneAbility
Ofcom Consultation on Television Access Services
June 2006
Response from PhoneAbility
PhoneAbility is an organization whose objective is to promote accessible Information Communication Technology (ICT) to support the needs of older and disabled people. It was formerly called the COST 219 UK Reference Group but now has a wider remit. PhoneAbility became a registered charity in 2004.
PhoneAbility's mission is for its members to be active advocates for accessible ICT, and, in particular,
- to support inclusivity
- to encourage appropriate implementation for the benefit of older people and those with disabilities of all ages
- to be alert to global developments and their implications
PhoneAbility is glad of the chance to respond to the Ofcom consultation and in this document makes several comments that are not strictly tied to the questions suggested in the consultation, but which we believe to be important, and, in addition, we have responded to the specific questions in the consultation document where these are felt to be relevant to our work.
USABILITY:
The take-up and use of Television Access Services, which have involved broadcasters in considerable investment, is very much dependent on the ability of potential users to operate the equipment - it is useless for broadcasters to provide services if viewers find them too difficult to make use of. The current generation of digital TV receiving equipment is frequently difficult to use, with complex set-up arrangements and confusing operational requirements. These ‘usability’ issues are creating a real digital divide between those who can use the current digital TV services and those who can’t.
It is easy to suggest that this is an issue mainly affecting people who have disabilities or who are elderly, but PhoneAbility members are aware that the complications of using digital television are affecting vast numbers of people of all abilities, physical and mental. Setting up a TV used to be such a simple task - plug it in, connect the aerial, tune it manually or automatically to the four or five analogue channels, and that was it, for ever. In addition to the TV display, today’s viewer is likely to have to install and cope with a set top box, a VHS recorder, a DVD player, all connected by a web of thick SCART cables that are usually intertwined with numerous mains cables plus coax cables connected to the UHF TV and VHF radio aerials.
Having to deal with complex remote controls having buttons with names such as ‘mode’, ‘Scart’, ‘zoom’ and ‘AV’ which are less than self-explanatory, is a further complication and it is no surprise that some users decide that this is all too complex and decide to stay with the five analogue channels.
We are not asking for any vast technological development, but for Ofcom to try to find ways of ensuring that more thought and consideration be given to the design of digital TV equipment. As just one example, some TV remote handsets have a button clearly marked ‘subtitles’ which is simply used to toggle between making the subtitles visible. Other TVs require the user to go into several stages of a menu to select or deselect the subtitles. It is not anywhere obvious how to display the appropriate menu and then select the required option.
More than anything, USABILITY needs to be improved in several areas:
- Clear, simple remote controls with larger, well spaced and well labelled buttons.
- On-screen menu systems need to be intelligently designed, with displays that can be easily read.
- Digital TVs shouldn’t ‘crash’ - ever - and if they must, they should quickly put themselves right without the viewer having to intervene. At the very minimum, boxes need to be fitted with readily accessible switches that really do disconnect the box from the mains supply, allowing for a ‘hard’ reset. Most current boxes require unplugging from the mains in the event of a crash, which can be difficult in many homes. It is also important to tell users that this is the action they need to take if a box crashes, and that switching off at the mains will do no harm.
- Usability is strongly influenced by the quality of the information supplied with the product. Information manuals need to be clearly and simply written, with clear explanations of technical terms and concepts used in digital television.
In a world where, technologically, anything seems possible, can this be too much to ask?
PhoneAbility wishes to point out that these simple suggestions wouldn’t benefit just a limited market of people who are elderly or disabled, but that digital television needs to be made usable by EVERYBODY. If this can be made to happen, so that we can all use digital television simply and without complication, we will be well on the road to ensuring that those with special needs can use it too.
PhoneAbility requests Ofcom to do everything possible to persuade TV manufacturers to simplify the operation of their receiving equipment and to provide simple instruction and information manuals.
AUDIO DESCRIPTION:
After a huge investment by UK broadcasters in the audio description pilot project, and the availability of well over 100 hours per week of audio described programmes that are regularly transmitted over the digital channels, there is still very little take-up of the service. The plug-in module solution which worked so well was rapidly superseded - effectively replaced - as set top box manufacturers Netgem realised that they could achieve the same end by purely software means. Using currently available higher specification chips and clever software, set top boxes can now provide Audio Description at little extra cost, a great example of a broadcaster-driven research project leading to a practical commercial solution that can benefit millions of visually impaired people. Unfortunately, only one TV manufacturer has so far adopted this approach, which means that the chances of a visually impaired user having access to the AD services are slim.
PhoneAbility requests Ofcom to do everything possible to persuade TV manufacturers to make Audio Description facilities available on all receivers.
SIGNING:
Signing for people who have hearing difficulties is another area in which digital television shows great promise. Signed broadcasts are currently shown with the signer visible to all - Open signing - but the signer needs to be of a reasonable size so that her actions can be clearly seen, and this can be distracting for viewers who don’t need the service. The BBC and others are working on a ‘closed’ service which can display the signer or not, at the touch of a button, just as happens with subtitles. Motion capture and animation techniques are used to achieve this, with digital signals driving a cartoon representation of the signer - an ‘avatar’. The system is not yet capable of adequate signing for television; there are problems with finger bends and positions and in getting adequate detail in facial expressions, but work continues, and ‘avatar’ signing may one day provide a satisfactory solution. There is considerable resistance from some users to the idea of using avatars, and an ideal solution could be to have a full-resolution video picture of the signer, whose size could be varied by the user, inset into the main TV picture. This is not technically impossible, but would require large amounts of bit-rate, which is likely to remain a scarce commodity in digital terrestrial television.
PhoneAbility requests Ofcom to do everything possible to encourage further research into various practical and economic methods of providing closed signing.
SUBTITLING:
In addition to providing answers to the subtitling-related questions in the survey (later in this response) PhoneAbility would like to submit the following related comments.
- PhoneAbility understands the importance of using colour in television subtitles to distinguish between different speakers, but notes a recent tendency towards the use of paler, less saturated colours, presumably for ‘artistic’ reasons. Unfortunately, this can reduce the contrast between the subtitles and the TV picture, making the subtitles more difficult to read. The characteristics of the colours, including their luminance, can be defined by the broadcaster, but it is not usually possible for the viewer to make changes to optimise his display.
PhoneAbility requests Ofcom to consider research into this area, so that broadcasters and receiver manufacturers may be informed about the optimum colours to use and whether it would be possible or desirable for viewers to be able to alter the luminance and chrominance of the displayed subtitles.
- Phoneability has not received comments about the size of the Tiresias subtitles being less than the ‘standard’ 24 pixels high, but believes that since the 24 pixel standard was arrived at only after a long period of discussion and consultation it is in principle wrong to accept smaller subtitles, even though their readability may be considered adequate, thanks to the excellent readability characteristics of Tiresias.
- PhoneAbility suggests that the effects of the use of subtitling when High Definition displays are being used should be properly researched before the widescreen HD services come into widespread use. It may, for example, no longer be appropriate for the ’24 pixel’ standard to be applied when the HD screen displays either 720 or 1080 lines rather than the 576 lines of the current standard definition service.
PhoneAbility requests Ofcom to consider research into this area, so that broadcasters and receiver manufacturers may be informed about the optimum size of subtitle characters to be used on high definition services.
- PhoneAbility notes problems caused with live subtitling on programmes such as football matches, where the subtitle box area can obscure what is from time to time the most vital area of the picture - where the ball is! It would be helpful to learn whether some method could be found to continuously position the subtitles away from the currently ‘active’ screen area, and whether some degree of transparency or ‘veiling’ of the subtitle box could make the ball more visible, without the loss of contrast making the subtitles difficult to read.
PhoneAbility requests Ofcom to consider research into this area, so that broadcasters and receiver manufacturers may be informed about the optimum positioning and possible transparency of subtitles for sports programmes.
- PhoneAbility notes that subtitling can occasionally disappear from TV programmes, with this sometimes being confined to certain transmitter regions. It appears that the broadcasters are not aware of such problems until they are raised by viewers. There are also sometimes problems with the quality of the transmitted subtitles. Monitoring of the presence and quality of subtitles should be a regular and constant duty of the broadcasters.
PhoneAbility requests Ofcom to require broadcasters to put in place procedures for the constant monitoring of the presence and technical quality of subtitles.
CLEAN AUDIO:
For many years the possibility of broadcasters providing a 'clean audio' channel which provides the speech without any background music or other sounds alongside the standard TV sound channel has been discussed and debated. With digital television, the cost (financially and terms of the digital bitrate usage) of providing an extra audio channel is modest, and it is believed that the extra production costs are likely to be small compared to the large number of people who would be helped by such a facility.
PhoneAbility requests Ofcom to consider promoting research into the practical possibility of introducing a ‘clean audio’ channel for TV programme transmissions.
Responses to Ofcom questions:
Q1. Do respondents consider that the audience share-based method of selecting which channels should provide access services is reasonable, or do they consider that there are alternative methods that would be better?
Q2. Do respondents consider that the audience share threshold of 0.05% remains appropriate having regard to the objectives of the Communications Act, or do they consider a different threshold to be appropriate, and if so, why?
PhoneAbility has no objection to continuing to use this measure and has no alternative suggestions to offer, but considers that it is important that greater flexibility in both the audio description, signing, and subtitled programme targets should be achieved over the longer term.
Q3. Do consultees agree that the Code should be amended to deal with channels in common ownership on the lines proposed?
PhoneAbility sees no disadvantages with the suggested amendments.
Q4. Do respondents agree that the current arrangements for providing signing on television should be reviewed, to see if there are better ways of meeting the needs of people who use signing? If so, what alternatives would you favour, and why?
PhoneAbility believes that it is necessary to encourage further research into practical and economic methods of providing closed signing, since the current open-signing system can irritate some users, and the fact that many signed programmes are transmitted at unsuitable hours means that the services are not being used as intended.
The Ofcom view that sign presented programmes are more valued than sign interpreted programmes should not be allowed to affect the amounts of audio described and subtitled programmes, as the review perhaps suggests that it might.
Q5. Should the guidance recommend that, for programmes that have not already been signed, broadcasters should display a larger image of the signer on the right hand side of the screen?
PhoneAbility believes that using larger images would cause problems for normally sighted viewers. Ideally, the user of the in vison signer would be able to adjust the size of the signer’s image, but research into how this might best be achieved will be required.
Q6. Should the guidance recommend that signers wear clothing that is appropriate to the type of programme they are interpreting?
Q7. Should the guidance recommend the provision of subtitling for all signed programmes?
PhoneAbility foresees no difficulties if these proposals were adopted.
Q8. Do respondents agree that a suggested maximum speed of 160-180 wpm would be appropriate for subtitles in pre-recorded programmes, or do they have an alternative view, and if so, why?
PhoneAbility notes that this proposal appears to be formalising what is happening in practice. The acceptability of various subtitle speeds depends so much on the needs and abilities of the individual user.
Q9. Do respondents agree that, on grounds of practicability, there should be no guidance on the maximum speed for subtitling of live programmes? If not, why, and what alternatives would they suggest?
Q10. Do respondents agree that the guidance should not specify a lower maximum speed for children’s programmes, but should advise broadcasters to exercise common sense?
PhoneAbility considers that the acceptability of subtitle speeds depends on the needs and abilities of the individual user.
Q11. Do respondents agree that the guidance should continue to specify different colours of subtitling for different speakers?
PhoneAbility supports this proposal and believes that the use of different colours is useful in aiding understanding by helping to distinguish between different speakers, but notes a recent tendency towards the use of paler, less saturated colours, presumably for ‘artistic’ reasons. Unfortunately, this can reduce the contrast between the subtitles and the TV picture, making the subtitles more difficult to read. The characteristics of the colours, including their luminance, can be defined by the broadcaster, but it is not usually possible for the viewer to make changes to optimise his display. PhoneAbility believes that further research into this area is needed, so that broadcasters and receiver manufacturers may be informed about the optimum colours to use and whether it would be possible or desirable for viewers to be able to alter the luminance and chrominance of the displayed subtitles.
Q12. Do respondents agree that the guidance should specify a minimum height of 20 full brightness pixels (excluding pixels used for anti-aliasing), as well as encouraging broadcasters to adopt anti-aliasing techniques when renewing or upgrading equipment?
Phoneability believes that since the 24 pixel standard was arrived at only after a long period of discussion and consultation it is in principle wrong to accept smaller subtitles, even though their readability may be considered adequate, thanks to the excellent readability characteristics of Tiresias.
PhoneAbility suggests that the effects of the use of subtitling when High Definition displays are being used should be properly researched before the widescreen HD services come into widespread use. It may, for example, no longer be appropriate for the ’24 pixel’ standard to be applied when the HD screen displays either 720 or 1080 lines rather than the 575 lines of the current standard definition service
PRESUMABLY AN ERROR IN QUESTION NUMBERING
Q10. Do respondents agree that it is reasonable to apply the rules on the selection of channels to provide access services on a uniform basis, even though this means that no channels aimed at people from ethnic minority backgrounds are required to provide access services? If not, please explain any alternative proposals you may have.
PhoneAbility has no considered view on this topic.
PRESUMABLY AN ERROR IN QUESTION NUMBERING
Q11. Do you agree with Ofcom’s assessment of the risks identified above, and the actions taken to address them? If not, please explain your answer.
PhoneAbility has no considered view on this topic.
Q12. Do you agree that the approach taken to determining the average costs of broadcasters is reasonable? If not, please what alternative approaches that you consider would be appropriate?
PhoneAbility has no considered view on this topic.
Q13. Do you have any comments on the assessment of average costs? If you disagree with the assessment, please provide data to support any arguments you make.
PhoneAbility has no considered view on this topic.
Q14. Do you have any comments on Ofcom’s approach to assessing the benefits?
PhoneAbility has no considered view on this topic.
Q15. Do you have any other comments on the impact assessment?
PhoneAbility has no considered view on this topic.
Last updated: 14.11.2007 © Copyright reserved
