APPENDIX 14
Memorandum submitted by the Royal National
Institute for Deaf People.
1. INTRODUCTION
1.1 RNID welcomes the opportunity to submit
evidence to the Culture, Media and Sport Committee's inquiry into
the Funding of the BBC. Television offers a vital link to the
outside world for the 8.7 million deaf and hard of hearing people
in the UK.[68]
The BBC, as a public service provider, plays a particularly crucial
role in maintaining and developing this link in light of technological
and social change. The introduction of digital services and the
impending switch-off of analogue transmissions render the role
of the BBC even more important.
2. BACKGROUND
2.1 The Royal National Institute for Deaf
People (RNID) is the largest charity representing the 8.7 million
deaf and hard of hearing people in the UK. As a membership charity,
we aim to achieve a radically better quality of life for deaf
and hard of hearing people. We do this by campaigning, providing
services, and through social, medical and technical research.
2.2 RNID's vision is "a world where
deafness and hearing loss are not barriers to opportunity and
fulfilment".
2.3 Five million people use subtitles regularly
whilst watching television,[69]
and one million use subtitles wherever possible. This number is
due to increase as the population ages and technological advances
such as digital broadcasting perfect subtitling. By 2001, there
will be more than 20 million Britons over the age of [70]
and currently over 43 per cent of the population aged 50 and over
have a hearing loss. At least 20 per cent of television licence
fee paying households are deaf or hard of hearing.
3. RNID'S RESPONSE
TO THE
INDEPENDENT REVIEW
PANEL'S
REPORT ON
THE FUTURE
FUNDING OF
THE BBC.
3.1 RNID wholly welcomes the Panel's recommendation
that the BBC should aim to subtitle 50 per cent of their new digital
services by year five rather than year 10 and that this target
should rise to 100 per cent by year 10. The fact that the BBC
has accepted these recommendations and, "committed itself
formally to adopt targets along these lines" is a very positive
step towards ensuring that the digital revolution is inclusive
for the millions of deaf and hard of hearing viewers in the UK.
3.2 RNID strongly considers that increased
accessibility for deaf and hard of hearing viewers should not
be limited to the BBC's public service role. The BBC should lead
on its commercial services as well, ensuring that its programmes
and videos are subtitled and made as fully accessible to deaf
and hard of hearing viewers as possible. For example, joint commercial
ventures such as with Flextech on UKTV, should involve the BBC
ensuring that existing subtitles are broadcast with its programmes
rather than merely supplied and not used due to "prohibitive
costs of re-editing for Flextech".
3.3 In consideration of the costs in providing
reasonable levels of subtitling, RNID supports the Independent
Review Panels' decision that there should be no changes to the
current concessionary licence scheme for deaf and hard of hearing
people.
3.4 RNID agrees with the Review Panel's
opinion that the BBC should be permitted to retain additional
efficiency savings however, RNID considers that any efficiency
savings gained through improved subtitling practices should be
dedicated towards providing additional subtitles. Re-use of existing
subtitles, purchasing existing subtitles from outside sources
rather than re-doing them in-house and streamlining production
of subtitles for both broadcast and home video would not only
improve efficiency but deliver considerable savings as well. The
BBC's unit costs appear to be above the industry average.
3.5 Other than in the area of digital television
the BBC meets, but does not exceed the targets set by the ITC.
ITV and Channel 4 also meet these targets despite being commercial
broadcasters. Granada TV is subtitling 72 per cent of its output
against a target of 56 per cent. The BBC, despite its public service
funding, does not lead the industry in provision of subtitles.
3.6 The BBC does not promote its subtitles.
While ITV has recently shown a trailer promoting subtitles across
the ITV network, the BBC has refused to do this saying its airtime
is too precious for this purpose. RNID's NOP survey shown that
significant proportions (over 40 per cent) of the over 55 age
group, who are likely to find subtitles of most use, are unaware
of their existence or how to access them. Older viewers are disproportionately
high users of analogue TV.
4. RECOMMENDATIONS
FOR ACTION
BY THE
GOVERNMENT
4.1 Digital television has the potential
to dramatically improve subtitling delivery and quality. Using
improved fonts and symbols, there are significant benefits for
deaf and hard of hearing viewers. RNID considers that the introduction
of a digital licence fee is untenable for deaf and hard of hearing
viewers until there is parity of subtitling provision across the
new BBC digital channels. Without such parity, there can be scant
justification for deaf and hard of hearing people to subscribe
to digital services and pay the additional licence fee. This would
further exclude deaf and hard of hearing people from the new technologies
and improved subtitling capabilities.
The impending switch-off of analogue television
requires the BBC to ensure that its digital broadcasts are and
remain highly accessible to deaf and hard of hearing viewers.
The new digital services (BBC Choice, BBC Knowledge, BBC Parliament)
should reach parity levels of subtitling provision with BBC 1
and BBC 2 before analogue is switched off to ensure that deaf
and hard of hearing people are not excluded from the digital revolution.
Recommendation: All BBC channels should have parity of subtitling
volume before analogue switch-off is implemented.
4.2 As a leading global brand as well as
a public service broadcaster funded by a licence fee, the BBC
must not be complacent in delivering accessible commercial services.
Approximately 20 per cent of licence fee paying households are
deaf or hard of hearing, and a considerable amount of the BBC's
commercial activities rely on previous licence fee funding—such
as archive programming broadcasts on UKTV and home videos of successful
BBC programming. Recommendation: any BBC video or DVD, where the
original programme is shown with subtitles, should be marketed
with closed caption subtitles.
4.3 RNID considers, as recommended by the
Independent Review Panel's Report, that there should be no changes
to the current concessionary licence scheme. However, if the Government
deems a supplementary digital licence is warranted, RNID would
argue for dramatic and immediate increases in subtitling provision
across all new DTT programme providers. Without such an increase,
deaf and hard of hearing viewers should be exempted from paying
the digital licence fee, as their access to new digital services
would be severely limited. This was not and is not comparable
to the higher rate charged for a colour licence as accessibility
was never herein an issue. Recommendation: levels of subtitling
on DTT, set by regulation, should be increased in order to bring
forward the date at which parity exists between analogue and digital
services.
4.4 RNID considers that the BBC should ensure
that its subtitling provision and details of how to access this
provision is consistently and thoroughly promoted. This would
ensure not only value for money but would also ensure that BBC
subtitled programmes were reaching as wide an audience as possible.
Recommendation: A promotional trailer for subtitles should be
created and shown regularly (minimum of once a month in prime
time and once a week overall). There should be a section in the
Radio Times indicating how to access subtitles and outlining their
benefits.
4.5 There is urgent need for independent
monitoring of subtitling provision across all media. At present
consumers have no choice but to accept the broadcasters' figures
which often contradict those from other independent sources. Recommendation:
that the Government, the ITC and Hearing Concern, (who have developed
monitoring technology), work to establish a practice of consistent,
independent monitoring of subtitling provision.
The RNID would be delighted to supplement this
information with oral evidence.
October 1999
68 RNID compiled data using OPCS population estimates.
116: A Davis: Hearing in Adults. 1995; A Davies et al; "Risk
factors for hearing disorders: epidemiological evidence of change
over time in the UK" in The Journal of the American Academy
of Audiology vol. 6 no 5 (1995). Back
69
Broadcasters' Audience Research Board (BARB): Panel Classification
Survey (1996). Back
70
Millennium Direct: (1998). Back
| 
