CAPTIONING OF VIDEO AND AUDIO MATERIALS
Binding City Policy
ARC-BTS-3.04
Purpose
The purpose of this administrative rule to define the City’s captioning policy. The intent of the policy is to increase the accessibility for individuals who are deaf or have hearing loss to City of Portland video and audio content produced for external use. The City Council adopted resolution #36940 on June 28, 2012 directing the development of an implementation plan and cost information for captioning media. On September 12, 2012 Council accepted a report conveying the implementation plan for captioning media produced by the City of Portland, which directed the development of this administrative rule.
Scope
This administrative rule covers the video and audio content produced, distributed and posted by City of Portland bureaus for external use. This rule applies regardless of whether the materials are produced directly by a City bureau or by a third-party on behalf of the City bureau. This rule also applies to these materials regardless of whether they are hosted on the City’s website or another host server, excluding material posted directly to TRIM/Efiles. For purposes of this rule, any reference to City bureaus’ websites is intended to include any third-party website hosting City bureau-produced materials.
Policy
New Video and Audio Content
1. Video content produced by or for City bureaus for external use after the effective date of this administrative rule must be captioned.
2. Under normal business operations, such video content must be captioned at the time it is posted on the website.
3. In some circumstances, City bureaus can post uncaptioned video content and provide a captioned version later, ideally within five working days.
4. In some circumstances, City bureaus can provide a written transcript instead of captioning the video content. However, it is the intent of the City’s captioning policy that most of video content posted by City bureaus is captioned rather than transcribed, because captioning provides a better viewing experience for individuals with hearing loss.
5. Audio content produced by or for City bureaus for external use after the effective date of this administrative rule must be captioned or accompanied by a written transcript.
6. City bureaus will provide captioning or transcription of their video and audio content that accurately reflects the substance of those materials.
Existing Video and Audio Content
1. City bureaus are encouraged, but not required, to produce and post captioned or transcribed versions of their existing video and audio content that is significant and/or which is frequently accessed by the public.
2. Nothing in this administrative rule alters the City bureaus’ responsibilities to respond to requests from the public for reasonable accommodation to provide materials in an alternate format.
Exceptions
The following types of City of Portland video and audio content are exempt from the requirements of this administrative rule
1. External sources – Content produced by an agency other than the City of Portland.
2. Internal use – Content produced by or for the City of Portland for internal use (e.g., training or workplace information) by City employees.
3. Archival material – Media produced by or for the City of Portland that is posted directly to TRIM/Efiles and not a City website.
4. User-generated content on social media.
Administrative Rule Review
The Office of Management and Finance is directed to conduct a review of this administrative rule no less than one year from the effective date of the rule. The scope of the review will consider:
1. The impact of the administrative rule on improving the accessibility of video and audio materials to individuals with hearing loss.
2. The impact on the volume and nature of video and audio content produced by City bureaus.
3. An analysis of the methods used (captioning or transcripts) that City bureaus used to comply with this administrative rule.
4. Financial and other impacts on City bureaus resulting from compliance with this administrative rule.
The goal of the review is to determine what changes, if any, should be made to the scope and provisions of the administrative rule to best achieve the intent of the City’s captioning policy.
Responsibility
The Chief Administrative Officer of the City of Portland is authorized to approve, amend and/or delete this administrative rule under BTS Admin Rule 1.02.
City Bureaus will be responsible for complying with this administrative rule to ensure applicable content is captioned appropriately per the rule.
The Bureau of Technology Services will identify a standard set of software tools to be used for manually captioning content. These standards will be published in the BTS Technology Standards documents at https://www.portlandoregon.gov/bts/46940
Citywide Disclaimer
Language similar to the information below shall serve as a disclaimer and will to be posted on the City’s website; all bureau websites should link to this central policy disclaimer.
City of Portland
Captioning Practices
The City of Portland welcomes the public to view its websites, including video and audio content. In August 2013, the City implemented a captioning policy in order to increase the accessibility of video and audio materials to individuals with hearing loss. The details of the captioning policy are outlined in BTS Admin Rule 3.04.
In compliance with the captioning policy, City of Portland bureaus will provide captioning or transcription for video and audio content developed for public use after September 1, 2013.
Please note there may be video and audio content or links on City websites that are not captioned or transcribed, e.g. content produced by community groups or another third-party for their own purpose which have been included by the City to provide additional useful information to viewers.
The City of Portland’s captioning policy does not extend to other organizations’ video and audio content. The City does encourage all organizations developing video and audio content for public use to consider captioning as a means of increasing access to individuals with hearing loss.
History
Authorized by Resolution No. 37027, adopted by City Council August 14, 2013 and effective as of September 1, 2013.