March 22 deadline passes with less than total compliance

We told you so. Back in March, we reminded all video programming distributors (VPDs) that they were supposed to file their contact information with the Commission as required under the newly-effective rules relative to the closed captioning complaint process. The contact information was due on March 22. But did everybody do what they were supposed to? Apparently not, because on April 27, the Commission issued a public notice reminding VPDs of the filing requirement, noting that “many VPDs” have yet to provide the required information. Demonstrating the seriousness of all this, the public notice warns ominously, if somewhat vaguely, that “[f]ailure to provide such information could result in enforcement action.” That’s tellin’ ‘em.

Anyway, since the Commission seems to feel so strongly about this, we figure that the least we can do is try to give it a hand – so this is a CommLawBlog public service message, reminding VPDs that they’re supposed to submit to the Commission contact information to be used in the event of a closed captioning complaint.

As the public notice indicates, the closed captioning complaint rules provide three ways to get that information to the Commission. Two of those ways are addressed only in passing in the notice, probably because the Commission would prefer that they not be used. (Those two ways are: (1) filing it in hard copy with the Chief of the Disability Rights Office, Consumer and Governmental Affairs Bureau; and (2) sending it in an email to CLOSED CAPTIONING_POC@fcc.gov.) The public notice does go on at some length about the third, preferred, way – submitting the info through the hand webform at https://esupport.fcc.gov/vpd-data/login!input.action.

The Commission is right to push VPDs in the direction of the webform, which has a lot going for it. In fact, it makes you wonder why the Commission offers the other two alternatives at all. Be that as it may, here’s the scoop on the webform.

All you need is your FRN, FRN password, and the contact information. The first page you access asks for your FRN and password. After you login with those, you’re at a screen with three tabs in the upper left corner. If you haven’t entered any contact information for any station (or system, if you’re a cable person), you click on the middle tab labeled “New VPD”, which will then take you through a series of screens. each soliciting aspects of your contact information. It’s all pretty simple (although the Commission provides a “support” tab in each screen, just in case).

The primary advantage of the webform is that the VPD gets to enter the information itself. The other alternatives require FCC staff themselves to enter the data into the system – which obviously introduces the possibility of inadvertent error.

So all you VPDs, let’s get to it. We don’t want to have to warn you again.