The Irish Deaf Society has submitted their comments in reaction to new proposals by the Broadcasting Authority of Ireland for its new access rules.
BAI Proposal for new Access Rules 2012
The Irish Deaf Society sends its contribution to the BAI. The emphasis with this document is that it contains a wide range of views from various members of the Irish Deaf community. The Irish Deaf Society is the largest Deaf-led organisation in Ireland working with both the Deaf and hard of hearing community. Our work focuses on issues such as achieving equality and access for Deaf people.
The Irish Deaf Society organised a forum discussing the new proposed access rules by the BAI. The group forum was held Tuesday 10th January 2012. The group included:
- Caroline McGrotty, Chairperson Irish Deaf Youth Association and TV presenter
- Bernadette Walsh, Chairperson of the Irish Deaf Women’s Group
- Dominic McGreal, Board member of Greenbow
- Kevin G Mulqueen, Chairperson Irish Deaf Society
- Elaine Grehan, Manager of Deaforward
- Eddie Redmond, IDS Office Manager and TV presenter
- Brian Crean, Manager of the Deaf Adult Literacy Service
- Donal Desmond, Board member, Irish Deaf Sports Association
- Tracey Treanor, Staff, Irish Deaf Society
- Susan Whelan, Staff, Irish Deaf Society
All were informed of background of BAI and rules that were set up in 2005. All have read the new proposed rules.
Before the discussion was opened, the group agreed unanimously that without doubt, they wanted to see all TV channels broadcast in Ireland achieve 100% subtitles and ISL availability on screen.
Question: What are your views on the change from ten years to a five year timeframe?
The general consensus was that it whilst it acceptable for targets to be set at 5 years, but more consistency was needed for the review. All the group bar one opted that the review take place every 6 months. 2 years is too long a time to wait and ensure that targets are being met. By a more consistent monitoring structure, it would ensure targets are being met.
The group also felt with the new dawn of digital and how technology is improving year on, year out that digital technology should increase the capacity of all broadcasters and how targets should be easier to meet unlike the old rules.
Question: What are your views on the move from a single target to a target range?
The group took the reasons why the BAI propose this measure and whilst they comment on the low numbers proposed as being disappointing. They agreed that a target range could only apply once a certain criteria was met:
- sub-standard subtitles not to be included (i.e. broken subtitles, subtitles disappearing after break, wrong subtitles inserted)
- Repeat programmes not be included within target. Once a programme has been aired and included in target – its repeat figures should not included in target
- A proper monitoring system be put in place to actively monitor subtitle standards
- Broadcasters to be actively encouraged to aim for the higher target.
Question: What are your views on the proposed targets, as detailed above?
The group were without question disappointed to see such low targets considering the 2005 access rules encouraged by 2014 100% subtitles on RTE. With technology in TV/Digital so advanced, the group wondered why the targets were so low and would actively encourage the BAI to increase the proposed targets by a further 10-15%
The group wondered why for RTE there was an increment of 2% each year but by 2016, there is only 1% proposed from 2015 (89%) to 2016 (90%). The group would like consistency for each of the broadcasters each year.
The group were disappointed with the figures for 3e and considered them far too low considering how many years they have been in production.
Question: Are you satisfied that the level of subtitling provided would continue to be measured over an 18-hour day?
The group accepted the notion of an 18 hour day however would encourage broadcasters that if they have availability of subtitle files for programmes aired after 1am – they should be aired.
There was discussion over the targets being measured on a 24 hour basis and if this was to become a possibility, the targets would have to rise to match the ratio of an 18 hour target.
The majority of the group favoured the 18 hour option.
Question: What are your views on the approach to Existing digital channels?
The group would encourage broadcasters to ensure that subtitles will not be affected after the switchover and would encourage active testing between now and October 24th 2012. Any problems must be actively dealt with.
Question: What are your views on the approach to New digital channels?
The group were not happy with no targets being considered for the new digital channels considering they are currently available.
A minimum target range should be in place. One focus group member proposed they match the target range of RTE2. Another group member proposed a target range based around 50%.
Irish Sign Language
No question was asked specifically on Irish Sign Language (bar the time frame) and the group had comments regarding the ISL proposed target range.
The group were not happy with the lack of ISL being proposed. Irish Sign Language is a completely different language to English and for ISL users in the country, they are all losing out on their enjoyment of TV.
The BAI proposal in its introduction included: The Access Rules were set up in 2005 and showed the amount of subtitling, ISL and audio description which TV broadcasters like TV3, RTE, etc should provide in order to increase the understanding and enjoyment of TV for people who are Deaf, hard of hearing, partially sighted or blind.
80% of Deaf adults have a reading level of an 8-9 year old. (National Rehabilitation Board Report, 1991)
Whilst subtitles are without doubt the favourite medium of most Deaf people watching TV, we cannot disregard those who use Irish Sign Language as their main language and English their 2nd Language (and often sub-standard 2nd language)
Programmes that the group would like to see more of:
- RTE production, Hands On
- RTE production, News for the Deaf – but to be aired longer than its current state of 2 minutes
- RTE production, ISL weather. An extra ISL weather to be considered mid-week.
The majority of the group did express that they were not in favour of an ISL signer on screen (in a bubble in the corner of the screen) however the group would like to see this become an option. i.e. if a Deaf person would like to see a programme with ISL – they could have the option of ‘switching it on’ like they do the subtitles option. They would not like to see the ISL signer embedded onto screen for everyone to see but for it to become an optional choice.
The group definitely want to see more ISL on children programming as ISL is important to the language acquisition of a child’s language developmental skills.
The Irish Deaf Sports association would like to see a trial run of sport commentary being translated into Irish Sign Language. Whilst sports tend to be a visual sport, voice-over comments are not translated into ISL (or English subtitles)
For the target % for RTE and ISL (and AD) – the group would like to ensure that repeated programmes not be included in the final %
The group would like to ask the BAI to consider an ISL target for all channels to be considered at its 1st review after the 2012 access rules are finalised.
Question: What are your views on: the retention of the 24-hour measuring period for Irish Sign Language?
The group would like to see the measuring period be shortened to 18 hours in fear of all ISL programmes being aired during the night.
Question: What are your views on this approach to other broadcast services?
The group were adamant that they did not want ISL targets to be included within the subtitle targets. Both English and ISL are drastically different that it was unfair to both ISL users and Deaf and Hard of Hearing people who do not use ISL. For non-ISL users, they could ultimately lose out on the subtitle targets.
The group as previously mentioned would like the BAI to consider a target for ISL for all broadcasters within the new review of the access rules.
Question: What are your views on this approach to compliance?
The group are in favour of this approach.
Question: What are your views on the setting up of a User Consultative Panel?
The group agrees to this. One of the group suggests that the Irish Deaf Society always be contacted as they are their main representatives for Deaf people and ISL users in Ireland
The Irish Deaf Sports Association would like for them to be the main representatives for sporting broadcasting. They are the best advisors when it comes to subtitles (colour, type, size, etc)
It was suggested if this was the appropriate place to mention it that the BAI be willing to consider the option of receiving complaints from the Deaf community regarding broadcasters failure to provide subtitles when they are promised on a more regular basis. i.e. if RTE news was not subtitled today – could a viewer at home complain on individual programmes.
Questions: What are your views on the retention of the current approach in respect of captioning, the prioritisation of programmes and the promotion of Access Services?
Regarding: Use of captioning
The group was aghast to find that previous research showed that the Deaf community did not mind when broadcasters used captioning or subtitles. This is simply not the case. The group were without doubt in favour of subtitles as they reflected the Deaf group more in terms of providing more information, i.e. when a gun-shot went off in background or a sound was emitted off-screen.
The group accepted that some programmes may be captioned and not subtitled but would always favour subtitles more.
It was suggested more research be done on this element.
Regarding: Prioritisation of programming
The group would like to see more programmes being considered for subtitling that were included before.
During 2011 which included a variety of news events such as the Queens visit, the Obama visit, The Referendum and elections – none of these programmes or discussion programmes such as the Vincent Browne show on TV3 were subtitled. The group applaud the efforts of RTE1 for ensuring that unexpected programming in 2011 was subtitled. However it was extremely disappointing to see that TV3 did not comply.
TV3 are not showing any Irish produced programming with subtitles.
The group would like the BAI to investigate programmes which were funded by the BAI sound and Vision funding for subtitles. Were programmes on other channels such as TV3 subtitled?
One person suggests that in the next review – that prioritisation of programmes be looked into rigidly to see if a compromise could be made to expand the type of programming that are subtitled.
The group want more children programming to be subtitled and include ISL.
The Irish Deaf Sports Association would like to see Irish broadcasters showing the Deaflympics (The 2nd oldest sporting event in the world after the Olympics). Broadcasters have previously aired the Special Olympics but not the Deaflympics. The Irish Deaf Sports Association are often involved in major sporting events and they would like coverage of these events too.
The Irish Deaf Sports Association also suggest that the interval commentary be subtitled. Quite often, the sport being shown is subtitled but the commentary is not. This applies to all sports such as Football, Golf and Tennis.
Regarding: Promotion of Access Rules The group would like to ensure that all printed material, TV menus and TV broadcasters web-pages all continue to use the (S) symbol to denote subtitles are present on a programme and would encourage the symbol (ISL) to be used when a programme is denoted as included Irish Sign Language.
Additional Comments by the Irish Deaf Society
The IDS would advise the BAI that for any future proposals and reviews that will be made available in booklet form to be also made available in Irish Sign Language. 80% of Deaf adults have a reading level of an 8-9 year old as previously discussed in this document. It should be made priority for the Deaf community and not as an afterthought.
The last proposal of 2005 were never actively monitored or followed up on. We seek assurances that within the review period (proposed every two years) and what will happen if broadcasters fail to comply with the rules.
The IDS has been informed that the iPlayer is not under the remit of the BAI. We would seek that it should be considering the output of programming via iPlayers (that have been previously aired) fall under the remit. Technology has changed so dramatically over the last few years that TV enjoyment is now in the hands of the viewer on when they want to watch TV yet this does not apply to Deaf and hard of hearing people.
Comments from Deaf and Hard of Hearing people around the country.
We have included comments from every day users of TVs in Ireland. These comments were emailed in directly to IDS, texted to staff and left on our Facebook page.
Cathy: I don’t like it when swear words aren’t subtitled – they are often integral to the tone of a production. It also feels like censorship.
Wendy: I don’t like when the subtitles are delayed on screen. This is evident in live subtitling such as on ‘Primetime’. Pat Kenny will be talking on screen for a period of time but it takes a good while before the subtitles come up.
Wendy: I would like a standardised symbol on subtitles indicating music. At the moment I have seen the letter “I” used to denote subtitles I I will always love you I — it is not clear on screen that music is being subtitled.
Wendy: It really annoys me when subtitles censor language. We read, sign, talk, know about the world and use bad language ourselves everyday. Its insulting when they censor subtitles.
Wendy: Subtitles often freeze – and this means I miss out on what’s being said as subtitles when they freeze, then jump to what is currently being said on screen.
Wendy: I have noticed when watching TV late at night – say around 10pm-12am. Subtitles will stop around the 11pm mark. This is unacceptable.
Wendy: Some advertisements are not subtitled but important ones like information on road safety, smoking, etc should be subtitled. This information should be accessible.
Wendy: I appreciate that the 6pm and 9pm news on RTE are subtitled – but other news bulletins and news at 1 are not subtitled.
Wendy: A fluent ISL user and Child of a Deaf adult (CODA) Declan Buckley, also known as ‘Shirley Temple Bar’ presents a bingo show during the week with no subtitles. This is insulting as Declan Buckley would be considered a member of the Deaf community yet he is not subtitled.
Sarah: I’m not sure if this is an issue as well for other Sky customers, but if I watch any recorded RTE programmes in my planner, there are always problems with the subtitles. However if I watch a live programme on RTE (not recorded on my sky box) the subtitles are grand.
Thomas: Sky UPC and Soarview are working fine but subtitles on different channels such as RTE are having problems.
Karen: Sometimes when I visit my boyfriend’s apartment in Dublin, The UPC subtitles don’t work on RTE, TV3 or on any other stations.
Elizabeth: I notice that its in the evening times when I record “home and away” at six thirty and “neighbours” at five thirty on RTE that the subtitles are crap.
Lorna: I live in Balbriggan and I have UPC. There are never any subtitles on TV3. I wanted to watch a programme about Tesco in Ireland but it was not subtitles. There seems to be only a few subtitles on my TV. BBC, UTV and Channel 4 have brilliant subtitles.
Bernadette: There is a film called ‘Mad about Dogs’ on TV3 at 9pm tonight but it has no subtitles. I’m really disappointed.
Maurice: There are only 4 programmes subtitled today on TV3. This is not enough (Nov 23rd 2011)
Patricia: Why are TV3 putting subtitles on at 1.55am – I’m in bed like everyone else! TV3 never have subtitles so why are they putting them on at that time!
Steven: All subtitles should be on all the time. TV3 are so selfish and has no respect for Deaf people. They only show Emmerdale and Coronation street and even then the subtitles don’t be working properly. I couldn’t be bothered with TV3 anymore, its just a waste of time.
Bernadette: The snapper was on last night – It had no subtitles.
Lynn: Very few programmes have subtitles and those that do, are not reliable, as it stops / start, or showing subtitles of previous show on a wrong programme, or just don’t work at all, and that’s for all of the ‘subtitled’ programmes – not reliable at all… More subtitled programmes and reliable subtitling would do.
Michelle: I do not even bother watch tv3 as I don’t want to be let down once again. It’s such a shame as I’m Irish and want to watch Irish TV.
Mary: ’The Morning Show’ should have subtitles. They had a Deaf girl on it talking about being deaf with her mother for over 20 minutes and they had no subtitles. Where are our Irish Deaf citizenship rights?
Aiden: TV3 can afford expensive US imports and yet can’t even provide basic services like subtitles
Bernice: I was so disappointed last night, I was running around the house to get everything done, put the kids to bed and sat down in time to watch the Snapper only to see it wasn’t subtitled. It was very disappointing as the rest of the family wanted to see it. My family are hearing and they were looking forward to watching it too but they won’t watch TV with me without subtitles so we watched something else. I want to watch Irish TV with my family.
Jen: TV3 is a huge let down and has let me down many times. I’ve gone to watch a movie on TV3 with my partner and we can’t because there are no subtitles. I always go “what’s new…”. I was on TV3 myself a few years ago on their morning AM show and I even mentioned it there why they don’t have subtitles on this programme and all they said was we’ll look into it. I wished TV3 would listen to its Deaf audience – we just want to be treated equally like our hearing peers.
Kenneth: I have made several complaints to TV3 myself and their excuse back to me was “We will look into it for u and get back to u ASAP” to this day Not a single reply has come back to me yet. I’m a proud Irish man and TV3 is sh*te and have not watched TV3 now for a good few years.
Aiden: ….and the Vincent Browne show is not subtitled. Not cool
Jacinta: We need more subtitles and not just all soaps. I want 100% subtitles on TV
Cathy: I never watch TV3, as I know the subtitles won’t work.
Joanne: I have never really bothered watching TV3 as their subtitles are so bad. They had a programme about puppy farming and I was looking forward to it being subtitles but it wasnt. RTE have subtitles on a lot of their programmes. Its a shame for us Deaf people.
Edward: There are no subtitles on Judge Judy (TV3). In America its shown with subtitles so why can’t TV3 show it with the same subtitles?
Michelle: I want subtitles on TG4 “switched at birth” as its a Deaf themed programme. I only found out recently they are showing it but with no subtitles. This is crazy. Did TG4 do no research before importing the series?
Michelle: I think the BAI need to meet the Deaf community more and do more surveys.
Sarah: Another thing I have noticed recently is that some of the words are being omitted from the sentences in subtitles which isn’t fair on Deaf people. It’s our right to have access to every single word uttered! in the cases where swear words are heard by the hearing audience but censored in the subtitles is also unfair.”
Sarah: Whatever hearing people can access, provisions should always be put in place to allow Deaf people to access it.”
Report compiled by The Irish Deaf Society, January 2012.