Small Entity Compliance Guide for Closed Captioning

03.15.12 – In compliance with Section 212 of the Small Business Regulatory Fairness Act of 1996, the FCC has issued a Small Entity Compliance Guide “intended to help small entities comply with new rules adopted” in the Report and Order concerning the implementation of Closed Captioning on Internet Protocol-Delivered Video Programming as related to the Twenty-First Century Communications and Video Accessibility Act of 2010 (CVAA) [MB Docket No. 11-154]. The guide outlines the requirements of video programming owners, distributors and providers and also highlights how small entities are affected by the R&O especially in terms of exemptions. Currently, the FCC allows small entity video programming distributors (VPD) and owners (VPO) to petition for a full or partial exemption from the requirements of Section 202(b) of the CVAA, which requires VPD and VPOs to implement internet protocol closed captioning, if the requirements are economically burdensome. In addition, small entities can petition for an exemption from Section 203, which delineates which devices must include capabilities for IP-delivered closed captioning, “if compliance is not achievable or technically feasible.” The guide states that the “exemption process will allow the Commission to address the impact of the rules on individual entities, including smaller entities, and to modify the application of the rules to accommodate individual circumstances.” [Source: FCC]

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