First United Methodist Church 20 I Monroe Street • Jefferson City, MO 65/0 I • 573-635-6886 • Fax 573-635-9745

r N9~Ned &Inspected

Office of the Secretary \.,J' JAN 17 'Z.01'z. Federal Communications Commission Attention: Disability Rights Office, Room 3-B431 FCC Mail Room 9300 East Hampton Drive Capitol Heights, MD 20743

Case Identifier: CGB-CC-O 13 5

Petition for Exemption from Closed Captioning Requirements

Introduction

The First United Methodist Church was built in 1901 and located at 201 Monroe

Street in Jefferson City, Missouri. Although the address has remained the same, it has

continued to grow and expand. The Carson Annex was added in the 1950s and in 1984

the Christian Life Center was added, a multi-purpose, activity room with a full court

basketball and volleyball area.

First United Methodist Church is located three blocks east of the State Capitol

building in Jefferson City. The city has a population of approximately 40,000. The

location of the church in the Capitol City gives it a unique blend of visitors and members

from across the political spectrum.

The mission of First United Methodist Church is to be "a Welcoming community,

Growing in God's grace, Seeking to be active followers of Jesus Christ."

The television ministry program of First United Methodist Church is called

"Celebration of Worship." This quality program airs the previous week's sermon,

musical selections and occasional promotional pieces about various church ministry

programs. "Celebration of Worship" works to achieve the church's mission by reaching

1

Case Identifier: CGB-CC-0135

out and spreading the word of God to those in the Jefferson City and surrounding areas

who cannot physically attend worship services for varying reasons.

Each "Celebration of Worship" program is 28 minutes and 57 seconds long and

airs each Sunday at 10:00 a.m. on the local CBS affiliate, KRCG-TV 13. The program is

produced and edited by a dedicated group ofvolunteers with input from a part-time

church staff member. Volunteers work as a team on Sunday mornings to video the 8:30

a.m. and 10:50 a.m. worship services each week. Certain, skilled individual volunteers

then take time from their personal schedules during the week to edit and produce the 30­

minute program to air the following Sunday. KRCG-TV is the top rated television

station in the market and has a strong viewership ofmen and women, ages 18 to 49. The

church is also aware, through numerous and various forms of correspondence, that the

"Celebration of Worship" program is watched by nursing home residents as well as

hospital patients, homebound and elderly populations and offenders incarcerated through

the Department of Corrections.

For the reasons set forth below, First United Methodist Church of Jefferson City,

Missouri, hereby requests an undue burden exemption from the closed captioning rules

for its "Celebration of Worship" program, pursuant to the recent Amendment of Section

79.1(f) ofthe Commission's rules.

Nature and Cost of Closed Captions

Estimates to determine the cost of closed captioning for the "Celebration of

Worship" program were sought from numerous companies including: CaptionLabs

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Case Identifier: CGB-CC-0135

(Columbus, OH), ClosedCaption Maker (Harrisburg, PA), CPC - Computer Prompting &

Captioning Co. (Rockville, MD), VITAC, a Merrill Communications Company (offices

in Canonsburg, PA, North Hollywood, CA, and Arlington, VA). [See Exhibits A-D for

various pricing amounts and service options.]

Through research, we have discovered there are basically three ways in which you

can obtain closed captioning for programs such as "Celebration of Worship": purchase

captioning software and encoding equipment, or contract with a company to caption the

program each week - sending it back and forth each week by mail, or contract with a

captioning company to provide tum-key captioning, which provides a captioning file

each week sent over the internet. All of these options require a text transcript file created

each week of the sermon. Providing a transcript on a weekly basis would add an

additional 4 to 6 hours ofwork for a volunteer or the cost of $75 to $100 a week to pay a

typist.

Research shows purchasing captioning software and encoding equipment could

cost between $4,000 and $10,000. However, this does not include the cost ofupgrading

our current editing system (VT 4.5 - which is approximately 7 years old) so that it is

compatible with today's captioning software options. Factor in new editing software,

updates, maintenance, on-going technical support and other unknown expenses; it could

cost an additional $2,500 to $5,000 a year.

Contracting with a company to do the captioning and time coding by mailing an

edited program back and forth each week is not a viable option due to the quick tum

around time required each week. Volunteers who edit have approximately four days to

put the program together (Sunday through Wednesday). The final version is picked up

3

Case Identifier: CGB-CC-0135

by a KRCG sales representative on Thursdays. If a company were able to provide this

service it would run approximately $200 a week, which does not include the expense of

postal services.

The captioning files sent over the internet option would require the purchase of

new editing software and a system to be able to do roll-up or pop-on captioning. This can

be accomplished for approximately $150 a week after the initial software investments of

approximately $2,500 to $5,000.

The above options for providing closed captioning fOf the "Celebration of

Worship" program at First United Methodist Church would make it difficult to maintain

the group of already busy and hard-working volunteers, and would put an economical

burden on the budget. Other equally viable programs at the church would have to be

eliminated or suffer tremendous cuts.

Impact on the Operation of the Program Provider

The total cost to produce the "Celebration ofWofship" program each year is

approximately $30,000. Each week KRCG-TV charges $595.00 to air the program. [See

Exhibit E] The church has conservatively estimated that it would cost at least an

additional $248.00 a week to add closed captioning to the program. Increasing the cost

of the program by a minimum of $12,896.00 a year would jeopardize the continuation of

the entire television ministry at First United Methodist Church in Jefferson City,

Missouri.

4

Case Identifier: CGB-CC-0135

Financial Resources of the Program Provider

First United Methodist Church, Jefferson City, Missouri, is a tax-exempt

organization according to the Internal Revenue Service. [See Exhibit F] The

"Celebration of Worship" program is funded mainly by contributions. [See Exhibits o­

M] When the television ministry first began in 1983, a promise was made to the largest

contributor that the program would never solicit television viewers for money for the

church and/or specifically the television ministry.

In order to fund any increase of this magnitude, other vital First United Methodist

Church programs would necessarily suffer. These programs are funded almost entirely

by donations which are voluntary and difficult to predict, especially in today's economy.

There is no extra money in the church budget to cover this type of unforeseen cost.

Types of Operations of the Program Provider

First United Methodist Church is a non-profit religious institution providing

Christian education for all ages, worship, music, mission opportunities (local, state,

national and international), and a television ministry to reach those who are unable to

worship a the church location.

Other factors

As a petitioner, First United Methodist Church believes that it would be

economically burdensome to provide closed captioning for the "Celebration of Worship"

program for which an exemption is sought. Furthermore, as noted above, the program is

produced and distributed locally, and the messages of First United Methodist Church are

of primarily local public interest. The episodes are not news, and do not have repeat

5

Case Identifier: CGB-CC-0135

value. Notwithstanding the applicability of the exemption, we have filed this petition in

abundance of caution and for the purpose ofestablishing certainty.

Conclusion

As shown by this petition and its attachments, we request the Commission grant a

waiver of the closed captioning requirements in this case, because requiring closed

captioning would be economically burdensome. The costs of captioning would be

excessively high and would have a significant impact on First United Methodist Church's

operations. First United Methodist Church's type of operations and financial resources

are different in kind and magnitude to other larger churches and mainstream

programming providers. We respectfully ask that due to the difficulty and expense of

providing closed captioning, a exemption to the Amendment to Section 79.1(f) is

warranted.

If more information is needed, please contact me at the address provided below.

Respectfully submitted

~tJ1 First United Methodist Church By: Debra M. Walker Media Ministry Coordinator 201 Monroe Street Jefferson City, MO 65101 (573) 635-6886 debbeewalker@aol.com

Dated: January 13,2012

6

First United Methodist Church 20 I Monroe Street • Jefferson City, MO 65 101 • 573-635-6886 • Fax 573-635-9745

GENERAL AFFIDAVIT

State of Missouri County of Cole

BEFORE ME, the undersigned Notary,

on this, l~ ra Walker, known to me to be a credible

person and a of lawful age, who being by me first duly sworn, on her oath, attests to and affirms the above facts.

A,JVI iti2~£'-~LA=".....-----­uebra M. Walker~ First United Methodist Church 201 Momoe Street Jefferson City, MO 65101

on this, )~

~_~~.JI:..£iL.l':~_=--.L_~~~~~~~=----day of January, 2012, persona yappeared

BEFORE ME, the undersigned Notary,

c-rYl day of January, 2012 personally appeare errold Kelly, known to me to be a credible person and of lawful age, who being by me first duly sworn, on his oath, attests to and affirms the bove facts.

old Kelly First United Metho 201 Momoe Street Jefferson City, MO 65101

Subscribed and sworn to before me, this __'l'~....c... day of January, 2012.

~JiQ./V'CA Jr\ ~~ [signature ofNotam t t -V

Terena M. Schaefer

[typed name of Notary]

NOTARY PUBLIC l My commission expires: . ~ q ,20_)L-S _

First United Methodist Church 20 I Monroe Street • Jefferson City. MO 6510 I • 573-635-6886 • Fax 573-635-9745

January 13,2012

Office of the Secretary Federal Communications Commission Attention: Disability Rights Office, Room 3-8431 9300 East Hampton Drive Capitol Heights, MD 20743

Declaration

I, Jerrold Kelly, am Church Administrator of First United Methodist Church, Jefferson City, Missouri, and I have reviewed the Petition for Exemption for Closed Captioning filed on behalf of First United Methodist Church, Jefferson City, Missouri, in this matter, and, upon information and belief, believe the statements regarding our organization and the "Celebration of Worship" television program to be true and accurate.

Crt uRQ.f;/

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First United Methodist Church 20 I Monroe Street • Jefferson City, MO 65101 • 573-635-6886 • Fax 573-635-9745

January 13,2012

Office of the Secretary Federal Communications Commission Attention: Disability Rights Office, Room 3-B43 1 9300 East Hampton Drive Capitol Heights, MD 20743

Schedule of Programming

Title of Program "Celebration of Worship"

Produced by First United Methodist Church, Jefferson City, MO

Length of Program 28 minutes, 57 seconds

Air Time Sundays, 10:00 a.m.

Station KRCG-TV 13, a local CBS Affiliate

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\.,., S~.e~~o~,"~,~~~~ 877·258·7800 • www.Captionlabs.com

IMPORTANT CLOSED CAPTIONING INFORMATION

November 2, 2011

Dear Media Director,

The FCC's recent decision to overturn your closed captioning exemption certainly creates new factors to consider. Production costs and air time purchases are already difficult mountains to climb. Now, you're facing another giant peak in figuring out what to do about closed captioning.

By losing the exemption from the FCC, there are many financial hurdles to consider. Purchasing captioning software and encoding equipment alone can be insurmountable. Of course, you'll also have to spend time figuring out the captioning process itself as well as FCC regulations. Then, creating the captions will eat up your time and constantly push you up against tight deadlines. Wrestling with these costs and issues will leave you feeling like your only option is to go off the air.

As a producer of religious television content myself, I have firsthand experience dealing with the financial burden and questions facing you right now. I also understand and believe in the purpose and significance of your television program. That's why I want to help you move forward.

The FCC's decision can be intimidating, but my company can help you eliminate that stress. We've helped many producers save weeks of production time and thousands of dollars with our unique eCaptioning process. Simply put, I know that we can save you time and money. Plus, we do all the extra work to keep you compliant with the FCC.

I'd love to discuss how my company can help you. We are committed to finding the most cost-effective solution for you. In fact, I will personally give you a special ministry discount. Simply mention this letter when you call and you'll receive discounted pricing as low as $167 per half-hour program! Be sure to contact me soon, because I can only extend this offer to a limited number of clients.

Providing captions can be very beneficial to the mission of your organization. I believe this is truly a great opportunity for us to help you strengthen the message of your ministry:fv1ilHons of Americans are hard of hearing. Closed captioning will make your program more accessible to both the deaf and elderly communities and is available to you at a fraction of the cost of air time and other production expenses.

Remember to mention the special ministry discount when you call. I look forward to talking to you soon!

Si~Cely, II

-- ()L .t/--. Adam R. Grover

CaptionLabs Phone: 877-258-7800 ext. 104 Email: agrover@captionlabs.com

P.S. Please don't hesitate to contact me. The special ministry discount of $167 can only be offered to a limited number of clients, so call and lock in the special pricing today.

.... r.... ... .. ,-,.'

Walker, Debra

From: debbeewalker@aol.com Sent: Sunday, January 08, 2012 9:04 PM To: Walker, Debra Subject: Fwd: Closed Captioning Follow-Up Attachments: Software_vs_Outsourcing.pdf

-----Original Message----­From: Ben Kalb <bkalb@mediaimages.com> To: debbeewalker <debbeewalker@aol.com> Sent: Thu, Jan 5, 2012 9:08 am SUbject: Re: Closed Captioning Follow-Up

Hi Debra!

I'm glad you checked out our site! We are a Christian company, so we love helping out ministries. In fact, many of our clients are ministry television shows (both local and national distribution).

We do not sell software, but rather a turn-key captioning service. We have found that for most ministries, the upfront cost of captioning software combined with the ongoing support of that software and systems is not a good financial investment -- especially when you combine the labor involved to create the captions.

I have attached a whitepaper that compares and contrasts Software vs. Outsourcing. Hopefully it will help you make a good decision for your ministry.

Now, about our service... Like I mentioned earlier, we provide turn-key captioning. We do everything: human transcription, caption line formatting, and synchronization. We then are able to send you a file that you can import into your edit system, so the captions are played out to your tape master for the TV station. It is really that simple. Plus, we guarantee all of our work and we offer a turn-around time that is super quick. I also have additional information I can send you about the process, just let me know if you would like me to send it your way.

As for cost, a majority of our clients are paying less than $175 per episode. Compare that with the cost of software (around $8,000), and hiring a professional service like ours usually makes good sense.

If you would like me to work on a quote, I would be more than happy to do that. And if you would like recommendations for software companies, I can also refer you to some good ones. Just let me know how I can help.

God Bless!

Ben Kalb bkalb@mediaimages.com phone: 614.410.3000 ext. 105 www.mediaimages.com

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From: debbeewalker@aol.com To: bkalb@mediaimages.com Sent: Thursday, January 5,20129:47:13 AM Subject: Re: Closed Captioning Follow-Up

Ben,

Thanks for your follow-up. First United Methodist Church is a small to medium church located in Jefferson City the Capitol of Missouri. We have had a television ministry since the early 80s and it has been basically run from the beginning with volunteers. We are really looking into what it would take to purchase a closed captioning software that would work with our current editing system. Do you have software programs? If not,do you know of a company that sells such software that you would recommend? Our turn around time is usually about four days - between recording the sermon and having it ready for broadcast. Our volunteers come in to edit at their convenience. So we are limited on turn-around time.

Any information you can give would be much appreciated.

Thanks, Debra Walker -----Original Message----­From: Ben Kalb <bkalb@mediaimages.com> To: debbeewalker <debbeewalker@aol.com> Sent: Wed, Jan 4, 2012 9:37 am SUbject: Closed Captioning Follow-Up

Hello Debra, Let me introduce myself. My name is Ben and I am in charge of the closed captioning department here at CaptionLabs. noticed you viewed our pricing page yesterday, and I wanted to follow up with you to make sure I could answer any questions that you may have. With new digital technology, there are many different methods of getting closed captioning onto your video master and out to stations and networks. We've successfully helped all our clients find the best tools and methods for their unique situation, and I can do the same for you. Please tell me more about what you need, and we will put something together to work for you! Thanks for checking us out! Have a great day! Sincerely, Ben Ben Kalb - VP Operations bkalb@mediaimages.com phone: 614.410.3000 ext. 105 CaptionLabs a division of Media Images Inc.

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0' ~ C!J)sed Captioning Services by CaptionLabs IOur Pricing Page 1 of2

• Who We Are

o Our Story o Quick Facts o ClosedCaptioning Blog

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o Get In Touch

OUf Pricing

We believe knowing how much you're going to pay should be hassle free. Our most common pricing packages are shown below. Look them over and see which fits your needs best. And of course, if your project requires some special details, we will be glad to help with those too! Just click on the Project Quote button to the right.

Package:

PROJECT

Turnaround (Business Days)

Same Day Service Available

Setup Fee

Quicktime & AVI Master File Accepted

Minimum Episode Commitment

TRANSCRIPTION

Verbatim Transcript Included

Finished Transcript Word Document No

CAPTION DISPLAY Economy Standard Premier

Roll Up Captioning

Pop-On Captioning No +$75

1/5/2012http://www.captionlabs.com/how-we-do-it/pricing_table/

• ' ~ .Ciosed Captioning Services by CaptionLabs IOur Pricing Page 2 of2

Screen Position Fixed Movable Movable

Languages English English & Spanish Any

ENCODING

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HD Vide Encoding No No

BILLING & SUPPORT

Net 30 Billing (Upon Credit Approval) No

Technical Support Basic Advanced Advanced

Aner Hours Support No

100% Salisfaction Guarantee

Price Pel' Episode* ,I $157 $237 Ii Call For Pl"ice i fl

*Prices are for closed captioning, up to 30 minutes in length. Extra services like tape duplication and shipping are not included Project Quote Let's talk. ..

• The Lab Blog

o 5 Tips for Stress-Free Delivery of Holiday Programs Posted December 12, 2011 o FCC Revokes Nearly 300 Captioning Exemptions Posted November 14,2011 o Adding Captions in DVD Studio Pro Posted November 1,2011 o Video Description Services Posted October 25,2011 o Proposed Rules for Internet Captions Posted September 28, 2011

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I r) w ti purchasing

optioning software: [) () {1? f/ y~W h C1 t You , ,I f\ I I \11/ on 5 ! You

Increasing Consider the True Cost of Ownership requir~m~

closed After graduating from college and finding his dream job, Rickmeanalo decided he needed to purchase a new car. He wanted

producers something that made a strong first impression, and he fell in marketJg love with a sharp, black European import. Although the cost software~' was high, he could afford the payments, and he loved the On thesurf~ power and prestige he felt when he drove it. software pa solve aUdfa problems,bijt Rick was happy with his purchase until he realized that he hidden issues hadn't counted all the costs. Instead of using the regular before making a unleaded he was used to, this car wouldn't run well without purchasE! - an

premium in the tank. His insurance rates went through thecostIYrni~~~ thingst(j . roof and the repair bills for his classy import were triple that sear-chin of his old domestic car. In fact, he couldn't even perform captionin routine maintenance without going to the dealer. Rick was

stuck with an expensive purchase with even more expensive maintenance. Worse yet, over the three years that followed, his killer car got older and less appealing, and it dropped significantly in value. In the long run, it wasn't a good investment at all.

In many ways, buying closed captioning software is a lot like making a decision while on the car lot. There are more things to consider than just the initial cost ofthe software. The additional starting costs of a computer workstation, video encoders and duplication tape machines also come into play, and drive the price up immediately.

And costs don't necessarily stop with the initial purchase. Technology is always changing, and as new software is developed, upgrades will be necessary. Factor in the software and hardware updates, ongoing maintenance, tech support and other hidden costs, and the price tag ends up being much more than that of the initial software purchase.

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The Transcription Hurdle

The first overwhelming hurdle many producers encounter with their new software is getting the spoken work converted into text. The software salesman may breeze right by this step and simply tell you to import your transcript into their software. But how you get that transcript isn't as easy as it sounds.

In this age of technology, many new users of captioning software assume that voice recognition technology will do the whole job for them. Computers have come a long way, but unfortunately, technology hasn't progressed to the point where voice recognition is accurate enough for captioning. With countless dialects, accents, tonal qualities and an ever-changing slang vernacular, computer software just isn't highly refined enough to do the job that a thinking, reasoning human can do.

When they find out that voice recognition leaves a lot to be desired, producers are left with two options- typing up the transcript themselves or hiring someone to do it. Doing it themselves is an option a lot of busy producers abandon after the first try. The average half-hour program contains 7,000 words, and oftentimes programs have a consistent speaking rate of 230-250 words per minute (wpm). For the average typist, a half-hour program can turn into five or six hours of sheer agony and frustration.

Other producers utilize the services of a Certified Court Reporter (CCR), who uses shorthand and a stenograph machine to transcribe the program's audio track. Although this process is much easier than the other options listed above, it is expensive. Prices usually range between $65 and $125 per half-hour for this service.

This results in a tough decision for the producer - whether to spend hours of his own time, pay for hours of a professional court reporter's time, or an enticing third option, which is to use an office assistant who can type rapidly and doesn't realize how much that skill is worth. This can be a temporary solution to the problem, until that person goes on vacation or leaves for another job. Finding the perfect office assistant also adds to the bottom line,

when salary and benefits come into play.

In any case, the transcription hurdle is another factor to consider when counting the whole cost of purchasing software.

o CaptionLabs www.CaptionLabs.com - 877-258-7800

cap·~ioning

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software: Dont KfiowCan Cost You

The Learning Curve

All new software has a learning curve, and producers realize going in that it will take a little time to gain proficiency. But many professionals, although they are so used to dealing with technology, fail to consider one crucial skill they will have to develop: caption formatting. The rules for formatting captions could fill volumes. Things like capitalization, how lines break, read rates, when to use italics, use of onomatopoeia and speaker identification are just a few examples of the rules the caption transcriber must master in order to turn out a readable product.

Producing closed captions takes much more than a transcript. It also requires a proficient knowledge of language arts and style guides. In order to remain profitable, the captionist needs to know these rules inside and out, and be able to apply them quickly and correctly. In addition, the captionist needs to understand how to format captions on the screen for easy readability, employing an understanding of how the human eye takes in information.

This learning curve leads to increased cost, in terms of both time and mOney. Most producers are juggling too many responsibilities already to dedicate dozens of hours to reading and deciphering software manuals and style guides. Putting those lessons into practice requires even more time, and in the long run, the result just isn't worth it.

It takes an enormous amount of time and education to learn to properly format captions. This leaves many producers wondering if those hours wouldn't be better spent creating phenomenal video, rather than dealing with the learning curve.

fCC Complaints and Non-Compliancf;

There are more than 40 million Americans who are deaf and hard of hearing. For this segment ofthe population, closed captioning is vital. Without it, these cannot receive information or entertainment from television, and they are shut off from a large part of our culture. Closed captioning advocates are very vocal about problems with captioning, and the FCC has implemented processes to make these complaints heard. This is good in that producers will know when something is wrong with their product. On the other hand, it means a lot more work. And although there was a paycheck associated with the production of the video, there's

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captioning software: ~'~/hC1t You Dont Knovv CO!) Cost You

no extra money tied to the time it takes to fix viewer complaints. It is becoming more essential every day to get it right the first time.

Program producers need to be prepared to deal with viewer complaints. It's likely that a coding error or a simple oversight will lead to a mistake every once in a while. But releasing captions that do not conform to standard practices will increase the chances of receiving complaints every time. The captionist must possess all of the parts of the puzzle - technological ability, language proficiency and a methodical dedication to excellence. Finding the right person to do the job will save huge amounts of time, money and frustration in the long run.

SoftlftJare

One of the big selling points of captioning software is that it's tangible. You aren't buying a service, but something you can actually put your hands on. And if your business changes drastically in the next year or two, someone will surely buy it for a reasonable price, right?

Unfortunately, that's probably not true. Just like any technology, the value of software drops rapidly and almost immediately, because new and better technology is constantly coming into the marketplace.

Before making a major purchase, it makes sense to consider whether the purchase price will be able to be recouped, even in part. It might not be worth a fraction of what it originally cost. For instance, what would you give for a used computer running DOS 6.0? Would you even ta ke it for free?

Sornetimes Outsourcing Makes Sense

Each year, hundreds of millions cars are taken to an auto shop for an oil change. Sure, the owners could do the work themselves, but the payoff just isn't worth the effort. The oil change pros make it so qUick, easy and cost effective that there doesn't seem to be any benefit in doing the work at home. It may cost a little more in the short term, but the indirect

savings are well worth the upfront cost.

.....'\."~'" L'J Caption abs

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By outsourcing the oil change, the driver doesn't have to lie beneath the car, endure extreme temperatures and scraped knuckles, or ruin a perfectly good shirt, He doesn't have to find an environmentally approved place to dispose of the used oil, or clean up the oil spill on the garage floor that somehow made it's way inside the house to the new carpet.

The same can be said of captioning software. There are some great products out there, but the cost of using them outweighs the benefits in many cases.

When getting the oil changed or captioning a video, our time is much more valuable than the few extra bucks that

may be left in our pockets when we do it ourselves. In addition, we can't compete with the professionals because we don't have the numbers on our side.

No matter what the business, professionals have economy of scale working in their favor. A well-established captioning company handles captions for dozens or even hundreds of programs on a regular basis. These companies already have a team of transcribers and caption writers who are very efficient and highly experienced. Because of the volume of work these companies do, the high expense of the equipment has only a minimal effect on the final price ofthe product.

Outsourcing closed captioning can also save significant amounts of time. Because the operation is honed to perfect efficiency, the average project can be completed much more quickly than it could be by even the most well intentioned producer trying to complete an entire project alone.

In most cases, the benefits of outsourcing closed-captioning outweigh every reason to do it in­house, The high upfront cost of software, difficulty creating a transcript and the high learning curve are all substantial things to consider. But the most important factor is time. Time is valuable, and that comes into sharp focus when we think about how much time is lost in learning a new skill. When we stick to what we do best and delegate the rest, productiVity goes up and so does profit.

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The government is treating captioning as the important function it is, and those who are providing accessibility to disabled individuals are being rewarded with tax credits. The "Disabled Access Credit" allows businesses to receive a tax credit of up to half of their expenses related to providing access to the disabled. For qualifying companies, the credit is 50% of expenditures over $250, not to exceed $10,250, for a maximum benefit of $5,000.

Closed captioning qualifies for this credit, meaning that $5,000 could be applied to your company's tax liability. For companies that purchase captioning software and the related equipment, the payoff can be big, but only for one year. Because the maximum expenditure is $lD,2S0, companies that purchase software can usually write off the maximum amount the first year, but will have very little or no credit in following years.

On the other hand, companies that choose to outsource can usually claim the maximum credit every year. A programmer who produces a weekly show could save half by outsourcing and claiming the Disabled Access Credit.

Here's a Comparison:

·Please consult your CPA. These statements are used as examples and may not apply to your situation.

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Estimate the Cost of Captioning on Yom

Most people - especially those who have been on the receiving end of an especially good software sales pitch - believe that they will be able to do captioning themselves and save money. The numbers, however, tell a different story. Here are some costs to consider.

~ The initial cost of investment is high. Even if the cost is divided over several years, it still adds considerable overhead to the bottom line. HD captioning and encoding equipment is very expensive, so depending on specific system requirements, a producer should plan to spend between $8,000 and $20,000 to get an in-house captioning operation rolling.

~ Technical support and software updates aren't free. In order to get the most from a system, the user will have to purchase support and software updates. Prices vary, but the average annual investment is about $600.

~ The cost of transcription. Most producers will end up outsourcing the transcription portion of the project anyway. Whether the transcription is done in-house by a staff member or outsourced to a court reporter, the cost will run about $70 per 30-minute program for a verbatim transcript.

~ Time is money. There are both direct and indirect costs of employees' time when using captioning software. Everyone has heard that time is money, but that phrase has a special meaning to people in the video production business. Deadlines are tight and even a small delay can cause costs to skyrocket. The value of time is too complex to calculate by looking at a simple hourly wage. The only way companies can be successful in today's economy is to make the most of every minute. That means directing employees to the things they do best, and finding someone else to do the rest. The result is efficiency that can make (or save) the company money and time.

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Page 8

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Hiring a closed captioning service can help a company to save money, reduce hassles, improve quality and stay focused on their core business. Consider the costs of purchasing software vs.

outsourcing for a program producer who produces 100 programs over a three-year period.

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No matter how many bells and whistles a software package may have, outsourcing closed captioning turns out to be a good fit for producers in almost all situations. It results in a high quality product that doesn't break the bank, and doesn't leave the producer with a tension migraine. Just like clients should leave the creativity to the creative experts, producers should find a quality captioning agency and let them work their magic.

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