Considerations on Broadcasting Choices for Slovenia Regarding Accessibility

Radio Television Slovenia (hereinafter “RTVS”) submitted a response, received on 4 November 2016, to the letter sent by Ms Andrea J Saks entitled The Broadcasting Choices for Slovenia Regarding Accessibility to Dr Dušan Caf, Executive Director of Digitas Institute. With her permission, the letter was published in a blog post and thus publicly available. The response submitted by RTVS was prepared by Ms Mateja Vodeb, Accessibility Coordinator, and cosigned by Mr Marko Filli, Director General.

General remarks

Digitas Institute (hereinafter “Digitas”) is not a registered media organisation and is not obliged to publish any response from third parties on its web pages, especially not in the case of inappropriate and/or offensive remarks or comments that may insult or offend other individuals or their work.

In this particular case, we have decided to publish a part of the RTVS’ letter and provide our immediate reply. RTVS demonstrated, in our opinion, a lack of understanding of the issues addressed and failed to provide facts and evidence for its claims. Following the RTVS’ biased or even false claims, we felt obliged to defend Ms Saks’ reputation and ours as well. Besides, we also felt responsible to provide our free advice to RTVS, which is a public service television broadcaster, especially to its Programme Council and Supervisory Council, and contribute our experience and insight to the debate in order to help them understand decisions they have made regarding the new RTVS’ 2017–2020 strategy as well as its business and programming plan for 2017.

It is seen from the response that RTVS, instead of concentrating on the creation of access services and improving the accessibility of its programmes, primarily focuses on technology issues. RTVS has thus shifted the focus of the discussion from accessibility requirements to advocating for a specific technology. It even puts, without any justification, technology considerations ahead of legal and regulatory requirements. In fact, the opposite should be the case.

We would like to emphasise that accessibility services for persons with disabilities must not be considered as a luxury but provided as a right, in accordance with the Constitution of the Republic of Slovenia, United Nations’ Convention on the Rights of Persons with Disabilities (UNCRPD) and Equalisation of Opportunities for Persons with Disabilities Act.

For RTVS, the provision of accessibility services should be of the utmost importance, not only in words but in conduct. RTVS should ensure that its programmes as well as digital products and services, broadly speaking, are accessible to the widest audience possible. It should accordingly put more focus on the creation of accessibility services. Conformity of its products and services, including the underlying technology, to accessibility requirements should be carefully assessed.

There is no technology barrier for creating, exchanging and delivering access services. There are of course certain considerations, but RTVS should primarily rely on technology standards already implemented in existing transmission systems. It should choose solutions that are cost-effective and reliable. RTVS should provide accessibility services at a reasonable cost and refrain from imposing any new discrimination or barriers for persons with disabilities.

Our response is structured as follows: we first present the original text submitted by RTVS (obtained from a scanned image by a third party software), provide unofficial rough translation of main issues, and then give our reply in English. The decision regarding the language of the reply was based on the following considerations: the original post was published in English and the response could contribute to a broader debate on the broadcasting choices regarding accessibility.


In Digitas, we conduct our activities in accordance with principles of transparency and accountability. We promote public discussion on accessibility of digital products and services in line with our core values and ethical principles. We are technology agnostic and refrain from promoting any particular technology platform. Yet, we are in favour of the application of open international standards.

Our response is for information purposes only. We expressly disclaim all liability to any person in respect of anything and in respect of the consequences of anything done or omitted to be done wholly or partly in reliance upon the whole or any part of the contents of this response, published on this web site. We are also not responsible for any third party content, which can be accessed through this web site.

Response of RTVS and reply of Digitas

RTVS’ response (1)

Original text

»Izražate zaskrbljenost, da tehnološke rešitve, ki jih uvaja RTV Slovenija niso ustrezne, izpostavljate celo njihovo domnevno diskriminatornost. Čutimo se dolžne, da vašo skrb pomirimo z zagotovilom, da so naše tehnološke rešitve ustrezne, visoko strokovne in uveljavljene tako v tujini kot doma, tako pri stroki kot pri uporabnikih. RTV Slovenija ima dovolj izobraženega strokovnega kadra, ki zelo dobro pozna položaj in stanje storitev RTV Slovenija ter ima jasne načrte, kje je in tudi v katero smer je potrebno nadaljevati. Imamo točno določene cilje in tudi jasno postavljeno časovnico vpeljevanja tehnoloških rešitev za dostopnost naših programov. V nadaljevanju našega odgovora tudi navajamo razloge za naše odločitve in ovržemo trditve, ki jih v blogu navaja ga. Andrea J Saks, zlasti tiste, s katerimi J Saksova poudarja, da bodo naše odločitve pripeljale k dodatni diskriminaciji gledalcev z oviranostmi […] .«

Rough translation

Based on the claims that its technology solutions are not appropriate and may be discriminatory, RTVS felt obliged to ensure us that its technology solutions are appropriate, highly professional and renowned in Slovenia and internationally, both within the profession and among the users. RTVS further claims to have qualified personnel that well understand the RTVS’ services and have clear plans on how to proceed. They have clear objectives and timeline for the implementation of technology solutions to provide accessibility of their programmes. RTVS explains its decisions in more details hereinafter and rejects the claims of Ms Saks, especially those related to additional discrimination of persons with disabilities […].

DIGITAS’ reply

We don’t want to argue with RTVS. However, it is seen from the RTVS’ response and the Digitas’ reply that RTVS has failed to provide facts and evidence for its claims. It is also seen that RTVS has a rather narrow and sometimes even false understanding of the issues it has raised in its letter.

RTVS’ response (2)

Original text

»Če se želite dodatne informacije o ustreznosti tehnologij vam svetujemo, da se obrnete na pooblaščene osebe za posredovanje uradnih stališč s področja tehnologij za dostopnost v organizaciji TU, ki so strokovnjaki s področja tehnike in tehnologije.«

Rough translation

RTVS advises us to consult the International Telecommunication Union (ITU) in order to get an official position on suitability of accessibility technologies for broadcasting.

DIGITAS’ reply

The RTVS’ advice regarding consulting the ITU is not only unnecessary but also highly inappropriate. In Digitas, we have a deep understanding of the telecommunications and broadcasting industry as well as of the regulatory environment. We are fully aware of the standardisation work carried out by the ITU Telecommunication Standardisation Sector (ITU-T) and ITU Radiocommunication Sector (ITU-R). Activities of ITU, including conferences, workshops and studies, generate treaties, decisions, guidelines and standards. These publications are all available through the ITU library. We are also familiar with the work of the European Telecommunications Standards Institute (ETSI), including its digital video broadcasting standards.

Digitas has published a letter of Ms Andrea J Saks, in which she expressed her personal views. In our opinion, her views could contribute to current accessibility policy and implementation considerations in Slovenia.

Ms Saks wrote the letter as someone who had been working in the area of accessibility with persons with disabilities for many years. She expressed her personal ideas and views about accessibility for broadcasting in Slovenia and not about the whole of Europe. She has been a renowned international telecommunications specialist for the deaf, who has served as chairman of the ITU JCA-AHF (Joint Coordinating Activity on Accessibility and Human Factors) and Coordinator of the IGF DCAD (Dynamic Coalition on Accessibility and Disability).

In our opinion, it is clearly seen from her affiliations that she is not an ITU employee. However, Ms Saks’ association with the ITU extends over more than 25 years. She has been active in accessibility for more than 50 years. She is known for guiding the ITU in making itself accessible in taking into consideration accessibility features from the beginning and not relying on doing expensive refits later. She has been responsible for promoting the Accessibility Check List for Standards Writers and other service providers, so that they think about accessibility as mandatory (cf. FSTP-TACL Telecommunications Accessibility Checklist, 2006).

Ms Saks personally works closely with the ITU Deputy Secretary General as well as keeps the Secretary General informed. She has worked with these gentlemen since the 1990’s in their various positions. Her position as an advisor on accessibility to the ITU is therefore not in question.

RTVS’ response (3)

Original text

»Naši načrti namreč temeljijo na skladnosti z mednarodnimi standardi za področje TV dostopnosti, prav tako zasledujemo dobre prakse in smernice na tem področju, ki jih priporoča EBU (European Broadcast Union) in so tudi potrjene s strani pristojnih organizacij za standarde.«

Rough translation

RTVS explains that its plans are aligned with international TV accessibility standards and that it follows best practices and accessibility guidelines, recommended by the European Broadcast Union (EBU) and endorsed by standards organisations.

DIGITAS’ reply

We know that RTVS completed the digital broadcasting switch over in June 2011, by implementing the European Digital Video Broadcasting (DVB) standard for digital terrestrial television (DVB-T). This is a widely used standard that includes accessibility specifications for closed captioning and audio description. Despite this fact, RTVS in five years has not provided access services for live broadcasting using these DVB accessibility functionalities .

Ms Saks hasn’t questioned the RTVS’ technology considerations, but has only expressed concerns about the accessibility of its programmes. Admittedly, we share her concerns. In our opinion, accessibility services for persons with disabilities must not be considered as a luxury but provided as a right, in accordance with the Constitution of the Republic of Slovenia, UNCRPD and Equalisation of Opportunities for Persons with Disabilities Act.

RTVS has implemented the DVB standard that allows for providing accessibility functionalities but has failed to provide accessibility of live broadcasting. If the existing broadcasting DVB-T services are capable of providing accessibility functionalities and RTVS does not already provide basic access services, why would this be different, if there was Hybrid broadcast broadband TV (HbbTV) implemented?

RTVS should provide TV accessibility services (for live broadcasting) regardless of distribution technology used. There are of course some considerations, especially regarding signing for the deaf, which may require a dedicated TV channel or IP video stream. Waiting for the implementation of HbbTV may unfortunately be considered as an excuse for not providing accessibility services or even means to prolong their provisioning and not a viable strategy of a socially responsible organisation that conducts its operations in accordance with legal and regulatory requirements.

This certainly does not build any confidence that RTVS actually has the best solution, when other techniques and technologies available would in fact make accessibility possible, if implemented instead of HbbTV. We therefore share Ms Saks’ concerns and, unfortunately, the new RTVS’ 2017–2020 strategy as well as its annual business and programming plan for 2017 only confirm our concerns.

RTVS’ response (4)

Original text

»Ravno ta teden bo potekal Access Services Experts meeting v organizaciji EBU, kjer bo predstavljen tudi potek evropskega projekta Hbb4al, za katere tehniko vaša referenca trdi, da ni primerna.«

Rough translation

RTVS refers to the Access Service Experts meeting, organised by the EBU in the beginning of November 2016, where the European HbbTV4all project is to be presented.

DIGITAS’ reply

We could not comment on the EBU meeting as we did not participate, nor we have received any material from RTVS related to the meeting (held last week).

We appreciate the research work regarding HbbTV. It should be noted, however, that a fact the HbbTV4all project was presented at the meeting might suggest that its results have not been widely deployed yet and the research work might still be ongoing. There is nothing at this juncture that will assure persons with disabilities that HbbTV4all will not have some difficulty in providing all the accessibility features. HbbTV4all was presented in a workshop at the ITU on 4 April 2016. The presenter actually made a statement that sign language was very difficult to deploy and expressed doubts about its future prospects. There is a captioning record of the presentation, where the speaker’s words have been captured and are on the record.

There are also webpages on the ITU portal dealing with accessibility. They include the work of ITU-T and ITU-R. We advise RTVS to do further research instead of just relying on a single research project, whose results are yet to be deployed in “real life”.

RTVS’ response (5)

Original text

»Ga. J. Saksova v pismu poziva dr. Cafa, naj bo pozoren na TU – T standarde, medtem ko ITU – R standardov niti ne omenja. TU – R standardi se nanašajo na radiodifuzijo, njihove funkcionalnosti omogočajo prenos in signalizacijo komponent ter podatkov interaktivnih storitev. Med njimi je za storitve dostopnosti programov RTV Slovenija pomembna prav hibridna radiodifuzno širokopasovna televizija HbbTV. Za združitev obeh standardov (TU – T in TU – R) je bila zato ustanovljena RG-AVA Group (Intersector Rapporteur Group Audiovisual Media Accessibility).// Več o standardih in tej tematiki lahko preberete v naslednjih povezavah:

  • HbbTV je eden od IBB sistemov, ki je uradno priporočen s strani TU – R z oznako ITU-R BT.2075
  • HbbTV je tudi del uradnega poročila Report TU-R BT.2267

O primernosti HbbTV za dostopnost lahko najdete tudi tukaj:«

Rough translation

RTVS reflects on the ITU-T standards and notes that Ms Saks has not mentioned any ITU-R standards, which cover broadcasting and provide functionalities for transport (broadcasting/distribution) and signalisation of components and data of interactive services. RTVS claims, that among these standards, HbbTV is important for accessibility of the RTVS’ programmes. It further states that in order to combine both the ITU-T and ITU-R standards, the Intersector Rapporteur Group on Audiovisual Media Accessibility (IRG-AVA) was established ( It points to additional sources with more details on standards and the topic:

  • HbbTV is one of the IBB systems officially recommended by the ITU (c.f. Recommendation ITU-R BT.2075);
  • HbbTV is part of the official Report ITU-R BT.2267.

More information on suitability of HbbTV for accessibility can also be found on the following link:

DIGITAS’ reply

We feel we must remind RTVS that standards are voluntary regarding implementation. While the ITU defines (or, in certain cases, recognises) technical standards in many areas, their adoption is voluntary and left for the marketplace to choose which ones are applicable for a particular context or use case. Technology of course changes rapidly and some international standards no longer are as up to date as some of the newer ones coming to the fore. So, RTVS has been either misinformed or does not understand the rules and regulations that bind the ITU as a UN organisation to standardise technology.

Digitas does not understand why RTVS mentions the IRG-AVA in this context. The IRG-AVA is an Intersector Rapporteur Group meeting across the ITU-T and ITU-R, to economise on the number of meetings so that issues of common interest can be discussed at the same time. But the final decision on what to be made into a Recommendation is made by the parent Study Groups that the Questions of IRG-AVA belong to. As the chair of the ITU JCA-AHF, which coordinates all the accessibility-related work in the ITU, Ms Saks is fully aware of the IRG-AVA’s activities, and not mentioning their name does not mean she is missing something.

There are many ITU-R standards and even old DVB-T standards, that already have captioning. By mentioning DVB, Ms Saks in fact referred to the ITU-R standards. Perhaps, RTVS should study those ITU-R and DVB standards first, before duplicating efforts or creating new inaccessibility barriers. By doing so, it could avoid the exclusion and discrimination against persons with disabilities, when it wasn’t technically necessary, especially if better choices of technology existed.

RTVS’ response (6)

Original text

»Gospa J. Saks med standardi TU – T izpostavlja le tiste, ki se nanašajo na uporabo IPTV za dostopnost. RTV Slovenija kot nacionalni operater digitalnega televizijskega omrežja DVB – T ter oddajanja na satelitu ne razpolaga z omrežjem, znotraj katerega bi lahko uporabila tehniko IPTV. Ta deluje le v zaprtih in strogo nadzorovanih in upravljanih omrežjih posameznih IPTV operaterjev. Pri tem je potrebno poudariti, da signala IPTV ni možno razširjati čez javna IP omrežja. HbbTV tehnika teh omejitev nima. Zato deluje povsod preko IP omrežij, tudi javnih. Namen RTV je namreč, da so vsebine dostopne najširšemu krogu gledalcev znotraj različnih omrežij in ne samo IPTV. HbbTV standard sicer vključuje tudi IPTV sprejemnike kot primerne za sprejem HbbTV storitve, pri tem pa morajo biti skladni s HbbTV standardom (V 1.5, V 2.0,…).«

Rough translation

RTVS claims that Ms Saks emphasises only those ITU-T standards that use IPTV for accessibility. It claims that RTVS as a national operator of the digital terrestrial television network (DVB-T) and satellite television network (DVB-S) does not have a network, where IPTV can be implemented. RTVS further claims that IPTV operates only within closed, highly controlled and managed (private) networks of individual IPTV operators. According to RTVS, the IPTV signals cannot be distributed over an open (public) IP network. On the other hand, it claims, HbbTV is not bound by these limitations. It can be implemented in all IP networks, including public ones. The aim of RTVS is to provide its programmes to as wide an audience as possible across different networks, not only (private) IPTV networks. The HbbTV standard also includes IPTV receivers as appropriate for receiving HbbTV services, but they need to be compliant with the HbbTV standard (V 1.5, 2.0, …).

DIGITAS’ reply

Ms Saks has emphasised the importance of observance of the UNCRPD. She has given (older) DVB-T and IPTV as examples of ways to provide accessibility services.

She is an accessibility expert and as such she has never promoted any particular standard, even the IPTV one, which is indeed an international standard that provides for both access services and interactivity. However, she has said if one could use more accessible and inclusive standards such as IPTV, without the need to marginalise or use special channels or times to have accessible programmes, then it was worth considering.

She hasn’t questioned HbbTV as such but the concept that accessibility services can be viably provided complementary to digital terrestrial broadcasting. Such a solution is questionable both from the technological and legal/regulatory points of view.

The RTVS’ understanding of IPTV seems rather narrow. Whether an IPTV service is provided over a closed private network or over an open public network is totally up to the nature of an operator and its business decisions. IPTV is a way to deliver content, just like broadcasting over RF. Just as there are both private and public broadcasters, there can be public and private IPTV services.

RTVS’ response (7)

Original text

»IPTV signal ne deluje znotraj omrežij kabelskih operaterjev, saj le-ti uporabljajo DVB- C tehniko, za prenos vsebin in ne IP prenosa, kot je v primeru IPTV. IPTV signal tudi ne deluje na pametnih napravah (tablice, telefoni), temveč mora biti signal IPTV pretvorjen v drugačno obliko (obliko za streaming), ki se šele po pretvorbi lahko prenese preko IP omrežjih, tudi javnih.«

Rough translation

RTVS claims that the IPTV signal does not operate within cable networks, which use DVB-C for the broadcast transmission of digital television and not IP, used in the case of IPTV. According to RTVS, the IPTV signal does also not work on smart devices like tablets or smart phones, where the IPTV signal needs to be transformed into another form (suitable for streaming), that can be — only after the transformation — transmitted over IP networks, including public.

DIGITAS’ reply

It seems that RTVS does not understand the IPTV standards. Whether IPTV is used in a closed or open network is a business matter, as mentioned above. ITU-T’s Y.1910 is an IPTV architecture recommendation, which describes an open network based model as well as closed ones (and IMS-based one). This recommendation was adopted by the UK’s DTV group as their reference.

RTVS’ claims that IPTV cannot be transmitted over DVB are false. There are standards that support such transmission and if a (network) operator chooses to use a technology such as WDM, DVB-C and DVB-S signals can be sent along with IP. That means that IPTV can be used in DVB-C/S networks as well. On the other hand, we wonder how HbbTV can be used in DVB-C or DVB-S networks without an IP connection.

RTVS can provide TV content for various transmission networks, being that DVB (T,C, or S) or IP. Access services can be offered for all these platforms. The basic approach should be to provide access services for DVB (T,C, or S). On the other hand, HbbTV is yet another platform, which is primarily meant to provide interactivity, controlled by broadcast signals. But in order to provide interactivity, RTVS needs interactive services based on IP.

It also seems that RTVS does not clearly understand and/or separate individual processes in a value chain of creating accessible TV services, when it speaks of transformation of streams.

RTVS’ claims that IPTV signal does not work on smart devices like tablets or smart phones are simply misplaced. There is lots of IPTV content available for smart phones and tablets. Since IPTV is based on IP, it seems obvious that any device that can handle IP can receive IPTV content and services. Unless RTVS has in mind an old type of proprietary IPTV, which used to be popular among European telcos. ITU-T’s IPTV is standard-based and flexible.

RTVS’ response (8)

Original text

»Video vsebina, ki se preko HbbTV dostavlja v formatu MPEG – DASH se lahko tudi sprejema na pametnih napravah brez predhodne pretvorbe, kot je to potrebno pri IPTV.«

Rough translation

RTVS explains that in HbbTV, video content is transmitted in the MPEG-DASH format and can be received also on smart devices, without any prior transformation as required in the case of IPTV.

DIGITAS’ reply

IPTV services have already adopted MPEG-DASH, where necessary. ITU-T Recommendation H.721 is one of the first international standards that has adopted MPEG-DASH. In fact, the ITU-T Study Group 16 has been closely working with MPEG and they have jointly produced recommendations H.264 and H.262. On the other hand, Digitas wonders how HbbTV video content is transmitted in MPEG-DASH over RF (DVB-C/S).

RTVS’ response (9)

Original text

»HbbTV tudi omogoča spremljanje dostopnih vsebin na istem programskem kanalu (SLO1, SLO2, SLO3), vendar prenos vsebine poteka preko internetnega protokola le v času dostopnosti storitve v tehniki za osebe z oviranostmi in ne ves čas. Evropska skupnost financira evropske projekte, kot je na primer Hbb – Next in Hbb4all, znotraj katerih razvijajo tehnike prav za dostopnost z uporabo HbbTV standarda. Skupnost EU si tako prizadeva preučiti in izkoristiti lastnosti HbbTV sistema, ki zagotavljajo konvergenco storitev za dostopnost z dodatno nadgradnjo linearne vsebine – interaktivnostjo ter z dodatkom osebnih izbirnih nastavitev posameznika, kar do sedaj ni bilo nikoli še možno na tak način. Na klasični IPTV se dostopne vsebine lahko predvajajo vedno le na ločenih kanalih, kar pomeni, da osebe s senzornimi oviranostmi lahko vsebine spremljajo ločeno od ostalih, kar je diskriminatorno. To pa ne velja v primeru IPTV sprejemnikov (ki odgovarjajao HbbTV standardu), ki jih pa slovenski operaterji žal ne uporabljajo.

Več o prednostih HbbTV, kot OTT storitvi lahko najdete tudi na povezavi:«

Rough translation

RTVS explains that HbbTV enables watching accessible content on the same channel (SLO 1, SLO 2, SLO 3), where accessible content is transmitted over an IP network only when the service is available (and not all the time). The European Union is financing projects, like Hbb-Next and HbbTV4all, aimed at developing accessibility services and functionalities based on the HbbTV standard. In this way, the European Union is trying to research and exploit HbbTV features, which provide for the convergence of broadcasting and broadband services in order to provide accessibility — by complementing the linear content with interactivity and personal settings, which have not been available so far in such a manner. In classical IPTV, accessible content can only be transmitted on separate channels, which is discriminatory for persons with disabilities. This does not apply in the case of IPTV receivers (compliant with the HbbTV standard) that were unfortunately not used by Slovenian IPTV operators. 

RTVS provides a link to a site, describing more advantages of HbbTV as an Over the Top (OTT) service:

DIGITAS’ reply

By claiming that the European Union is trying to “research” HbbTV features, RTVS seems to suggest that accessibility features in HbbTV are still in a research stage and one cannot help wondering, when they are mature enough to be deployed. This means that one can still wait and assess, what the results are from research projects such as HbbTV4all. There have been several EU funded projects that experimented and researched on advanced features of innovative broadcasting, but have never been widely deployed. MHP was one such example and DVB-H was another.

It is clear that the IPTV that RTVS has in mind is not based on the ITU-T IPTV standard.

As mentioned above, the ITU-T IPTV standard can be used in various ways. It is indeed based on IP, so it can be used for OTT services as well. (OTT is a term applied to IP based services done by someone other than a telco, but recently some telcos, also in Slovenia, have begun providing their own “OTT” services).

RTVS’ response (10)

Original text

»Gospa J Saks razume HbbTV kot trend v EU, ki promovira HbbTV. HbbTV je zaradi uspešnosti in potenciala že zdavnaj prešla evropske meje. Več informacij lahko najdete na primer tukaj: http://www.eurofinsdigitaltesting. Com/media/28676/hbbtw-flier-2015.pdf ali«

Rough translation

RTVS provides evidence that HbbTV has spread beyond Europe, which is contrary to Ms Saks’ claims that it is solely a European trend:

DIGITAS’ reply

Since Ms Saks was more concerned about accessibility, not HbbTV per se, she was referring to the fact that HbbTV based accessibility services had not been widely deployed. Digitas would like to know how many of these countries were actually using and deploying HbbTV to provide accessibility services.

It would also be worthwhile to note that officially “adopting” is not necessarily the same as “deploying”. Many countries that announced that they adopted DVB-T in the past are now deploying something entirely different. And it might be a bit too naïve to believe what was stated in a flier.

RTVS’ response (11)

Original text

»Gospa J. Saks tudi omenja, da HbbTV do sedaj ni bila na voljo nikjer, razen v Veliki Britaniji in Italiji, kar je ravno nasprotno od resnice. Do sedaj ravno omenjeni državi nista bili zainteresirani za HbbTV, saj sta imeli dobro uveljavljeni lastni tehnologiji (MHRG, MHP). Z razširitvijo standarda za HbbTV verzije 2, bosta tudi prešli na HbbTV. Več o tem:«

Rough translation

RTVS claims that according to Ms Saks, HbbTV has so far not been available anywhere else but in the UK and Italy, which is not true. These two countries have not been interested in HbbTV as they both deployed their own technologies (i.e. MHRG and MHP). With the new version of the HbbTV standard (HbbTV 2.0) both countries will migrate to HbbTV:

DIGITAS’ reply

It is obvious that RTVS misinterpreted the following sentence: “I understand that there is a trend in Europe to promote HbbTV as a way to provide interactivity, which has not been available for public broadcasting in Europe except for a few countries like the UK and Italy.”

Ms Saks spoke about interactivity and the sentence was meant to convey the idea/fact that there were only two countries in the EU that provided interactivity on their digital TV (DTV) channels; one was the UK with MHEG and the other was Italy with MHP. Many people in Europe seem to forget or ignore the fact that the EU has had interactivity but not much accessibility. MHP was introduced as a way to provide interactivity, but not widely adopted. In other words, the EU has had recourses to provide interactivity and accessibility other than HbbTV before, but accessibility has actually not been provided, due to economics and business considerations. This suggests that even with HbbTV there may not be enough accessibility services anyway.

RTVS’ response (12)

Original text

»Gospa J. Saks je skeptična glede uspešnosti HbbTV za gluhe in naglušne. Ravno na tem področju je RBB zaradi zavzemanja za dostopnost in inovativnih projektov 31.10. 2015 prejel posebno nagrado “Golden Crown”, več informacij je na povezavi:–2014-2017-.html«

Rough translation

RTVS claims that Ms Saks is sceptical regarding the effectiveness of HbbTV for deaf and blind. It provides evidence that HbbTV is rather successful in this respect, as German broadcaster RBB received a special award — Golden Crown — on 31. 10. 2015:

* Note: An additional source: 

DIGITAS’ reply

We certainly appreciate this RBB’s achievement. It should be noted, however, that the prize was awarded for the RBB’s long time involvement in barrier-free accessibility and special acknowledgement was given to its achievements regarding personalised subtitles for “catch-up TV” within the HbbTV4all project. In fact, perhaps it should also be noted that HbbTV4all has been using the HbbTV platform, because its receivers have been conveniently available in certain countries in Europe, to experiment and research into advanced ways of providing access services. Their results and achievements are independent of and orthogonal to HbbTV itself. The same result can be achieved with IPTV, as has been proven since 2010 in the JCA-AHF of ITU-T (without any external funding).

RTVS’ response (13)

Original text

»Veseli nas tudi, da ste opazili pomemben napredek in prizadevanja RTV Slovenija na področju dostopnosti. Intenzivno se ukvarjamo z možnostmi za še večjo dostopnost, ki so trenutno na voljo in preučujemo dobre prakse iz tujine, ki bi jih bilo možno prenesti v naše sisteme. Kot korektno ugotavljate, je Slovenija zaradi svoje specifičnosti (maloštevilni uporabniki jezika v primerjavi s velikimi državami, država podnaslavljanja, večji delež tujejezičnih vsebin, ni komercialnega interesa za razvoj govornih in drugih tehnologij, …) v slabšem položaju kot velike zahodne države in je zato pot do primerljivega deleža prilagojenih vsebin bistveno zahtevnejša. Trenutno se nahajamo pred velikimi tehnološkimi, organizacijskimi, kadrovskimi in finančnimi izzivi, ki bodo v prihodnje nadomestili obstoječe rešitve z bolj optimalnimi. Rešitve, ki so trenutno na voljo, smo v povezavi z uporabniki vpeljali z namenom omogočanja največje možne stopnje dostopnosti, ki je v tem trenutku še izvedljiva. Enako prakso uvajajo tudi druge, s Slovenijo primerljive države.«

Rough translation

RTVS is pleased that Digitas has recognised its efforts and progress in the area of accessibility. It is intensively considering the possibilities to provide more accessible content. It is also considering good practices in other countries, suitable for the implementation in the RTVS’ systems. RTVS claims that Slovenia as a small country is at disadvantage (small population, subtitling country, more content in foreign languages, no commercial interest for developing language and other technologies). It is more difficult to provide the same level of service accessibility as in larger Western European countries. RTVS faces technological, organisational, human resources and financial challenges in order to replace current technologies with more optimal*. Current solutions have been implemented in co-operation with users in order to provide maximum accessibility possible. The same approach is applied in other countries comparable to Slovenia.

* Note: We wonder what an optimal technology may be?

DIGITAS’ reply

This exactly is the reason why Digitas is careful about adoption of HbbTV for accessibility. RTVS should consider more carefully, if what is acceptable in larger Western European countries like Germany or Spain is also a viable option for a small country like Slovenia.

It is somehow strange that RTVS does not provide accessibility services of live broadcasting, although it could already do so in a cost effective manner with the existing technology. Instead, it has bound the provision of accessibility services to a new technology, HbbTV, intended for implementation.

It should be emphasised again that HbbTV is aimed at providing interactive services and certainly does not guarantee the creation of more accessibility services per se. Moreover, financial challenges due to hefty investments, planned by RTVS, may even further delay the creation of more accessibility services and even slow down the deployment of HbbTV itself.

There are also other considerations that may further delay the provision of new accessibility services. Synchronisation of live broadcasting with additional content being delivered over IP will always be an issue as Internet may not be always available or may not work as expected, as it is a “best-effort” network. HbbTV cannot yet provide real time and effective interworking of different streams. There are no mechanisms implemented yet, able to synchronise content delivered over networks using different transport protocols with different end-to-end delays. Even in an ideal case, synchronisation will always be an issue that may affect the quality of access services.

RTVS should also consider the cost of making accessible content, such as closed captioning and audio description. HbbTV itself is a delivery system and does not help in the creation of content.

With this regard it may be worth mentioning that some of the results in HbbTV4all assume the existence of a good Automatic Speech Recognition (ASR) engine and a Text-To-Speech (TTS) system. Digitas is aware of the RTVS’ plans to implement the TTS, but is doubtful if any viable ASR system exists for Slovenian. With the size of Slovenian speakers, it is unlikely that high quality systems, especially for live broadcasting, will be developed very soon. This may even further delay the provisioning of accessibility services.

Legal and regulatory issues may pose additional challenges to access services provided over HbbTV, especially with regard to potential undue discrimination of persons with disabilities, who do not have access to fixed broadband Internet. Such discrimination is not only unacceptable but may also be illegal. Therefore, we call upon the RTVS leadership, its Programme Council and Supervisory Council, to reconsider their plans in order to avoid potential litigations in the future. In our opinion, RTVS should try to get approval of the government and regulatory authorities as it is bound by media sector laws as well as other laws to provide accessibility services.

RTVS’ response (14)

Original text

»Aktivno se udeležujemo mednarodnih strokovnih posvetovanj na najvišjem nivoju na temo tehnologij dostopnosti, kjer so naše predstavljene rešitve dobro ocenjene. V EBU TV Committee, najvišjem organu organizacije EBU, je prav naša sodelavka, ga. Natalija Gorščak, koordinira področje dostopnosti.«

Rough translation

RTVS claims that their employees actively participate at high level international expert events in the field of accessibility technology, where its solutions are well accepted. The RTVS’ representative Ms Natalija Gorščak is a coordinator for accessibility in the EBU TV Committee.

DIGITAS’ reply

We would welcome more concrete information regarding “these solutions” in factual and scientifically defined terms and not just as general concepts. Perhaps Ms Gorščak would care to comment and indicate, where these solutions have actually been technically deployed and how successful they have been in terms of meeting the requirements of the UNCRPD. We would also appreciate detailed data on accessibility to programming (as a share of total programming) over time and the RTVS’ future plans in this regard.