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Audio Description requirements 9.1.2.3, 9.1.2.5, 10.1.2.3, 10.1.2.5, 11.1.2.3 and 11.1.2.5 miss a fundamental point

Audio Description requirements 9.1.2.3, 9.1.2.5, 10.1.2.3, 10.1.2.5, 11.1.2.3 and 11.1.2.5 miss a fundamental point and appear to require that all video must have associated audio description. This is a strong misunderstanding of the needs of users and is not acceptable as-is.

Problem

The end goal is that audio-visual content is accessible to users even if they cannot see the video image. In some cases audio description is the best current technique to fulfil that goal. However there are huge amounts of video content in existence that neither need nor benefit from additional audio description because their non-audio-described soundtrack is already accessible. For example programmes that are made to be consumed either as radio shows or as video programmes, or live programmes in which there is a commentary explaining what is happening.

This is to some extent made clear in the Intent section of Understanding SC 1.2.3 however that is not clearly a normative requirement.

Proposed alternatives:

Either:

  1. Reword these sections to focus on the needs of users, i.e. that the video component of the audiovisual content needs to be perceivable to users who cannot see it, either by the inclusion in the audio track of enough information for the user to understand the contents of the image, or as an alternative technique, by the provision of audio description.

Or:

  1. Add a Note that this requirement only applies to ICT where the audio content does not already include enough information to allow the user to understand the contents of the video image.

Similarly, the applicable/relevant conformance sections in C need to be amended to include an assessment of whether or not the audio content allows users to perceive the content of the video image adequately - that they cannot needs to be a prerequisite for requirement for audio description, otherwise they should pass directly.

Context for this comment:

The BBC provides one of the highest proportions of audio description of all public service broadcasters, and exceeds the regulator (Ofcom) defined minimal volumes and internal targets (see 2023-24 Annual Report page 134), but a 100% target would neither be practicable nor helpful, especially since around 40% of broadcast output is live, and editorial guidance already exists to allow that content to be perceivable by audience members who cannot fully see the video image.

Edited by Nigel Megitt