STATEMENT OF
COMMISSIONER ROBERT M. McDOWELL
Re. Closed Captioning of Video Programming; Closed Captioning Requirements for 
Digital Television Receivers, CG Docket No. 05-231 and ET Docket No. 99-254.
I am delighted that the Commission has moved to streamline and simplify the complaint 
process for consumers experiencing problems with closed captioning.  It also is appropriate for 
us to clarify, to the extent anyone seriously needs such guidance, that the mere transition of a 
programming channel or network from analog to digital format does not alter the existing 
obligations of a “video programming distributor” – meaning a broadcaster, cable operator, 
satellite television operator, or other multichannel video provider – to provide closed captioning 
to serve people with hearing disabilities.
Today’s revisions to the consumer complaint process for closed captioning should not be 
an end point for reform of the Commission’s complaint processes generally.  I have not forgotten 
the February 2008 findings of the U.S. Government Accountability Office (“GAO”), which 
reviewed the FCC’s enforcement procedures generally and found them wanting in several 
respects.1 Among other issues, GAO noted that the Commission has received an annually 
increasing number of complaints of all types in recent years, but that the agency has not set 
measurable enforcement goals in many instances and lacks reliable data-collection and analysis 
processes that would help us better analyze trends, allocate Commission resources, and 
accurately track and monitor complaints and their disposition.  Going forward, I will look for us 
to re-double our efforts to make the consumer complaint process easier and accurately assess 
how well we handle our enforcement responsibilities.  
  
1 See U.S. Government Accountability Office, Report to the Chairman, Subcommittee on Telecommunications and 
the Internet, Committee on Energy and Commerce House of Representatives, Telecommunications:  FCC Has Made 
Some Progress in the Management of Its Enforcement Program but Faces Limitations, and Additional Actions Are 
Needed, GAO-08-125 (February 2008).