by Dave Garb, Legislative Committee Chair
Closed Captioning and Web Accessibility Requirements for Local Governments
Where it Currently Stands for PEG
The Americans with Disability Act has compliance obligations for local government accessibility for websites, video streaming, and even cable broadcasting.
While the FCC has long excluded community television from captioning requirements, the Department of Justice, state governments, and private citizens have renewed a push to require captioning for all types of video content, and particularly those found on the internet.
Last month, JAG held a special webinar that explored where the requirements currently stand for access television, along with thoughts on where it might be heading, when the DOJ might make a decision, and what should be done now to prepare for the immediate future.
Our guest speaker for this informative event was Brandon M. Dittman, a founder and partner of Wilson Williams Fellman and Dittman*, an expert on the ADA and Rehabilitation Act Captioning Requirements and FCC Regulations for Closed Captioning, as well as the DOJ and their rule-makings.
Brandon relayed the following facts to the participants:
• Since 1998 the FCC has stated under its regulations that local government content is categorically exempted from captioning on television. Other government agencies such as the DOJ who are responsible for enforcing the Americans with Disabilities Act, will say otherwise. And even the FCC takes the position that video programming may be subject to captioning requirements even if they don’t require it.
• The American with Disabilities Act – Title 2 regulates public entities and regulates governments. If you’re a government entity of any kind, you fall under Title 2
• DOJ Requires Web Content Accessibility Guidelines (WCAG) 2.1 https://www.w3.org/WAI/standards-guidelines/wcag/docs/ or https://www.w3.org/WAI/WCAG22/quickref/?versions=2.1 for all web content, and captioning for video content, whether live or prerecorded is required.
• Different parts of the Rehabilitation Act which needs to also be considered include:
- Section 504 states that “No otherwise qualified individual with a disability in the United States … shall, solely by reason of his or her disability, be excluded from the participation in, be denied the benefits of, or be subjected to discrimination under any program or activity receiving Federal financial assistance or under any program or activity conducted by any Executive agency”.
• Section 508 – “Electronic information and information technology must be accessible for
people with disabilities”.
(You could potentially become subject to this if you receive federal funding. Such funding could come with a requirement that you comply with the Rehabilitation Act.)
One of the most eye-opening moments of the webinar was when Brandon stated that “Any person can bring what’s called a citizen suit where they can act as their own private attorney general. Especially on the website side. A private citizen can ask for an injunction and can demand that you change your practice or stop doing the discriminatory practice.” They can recover all their attorney’s fees, and in most cases, they can get monetary damages of some kind.
So what should a PEG Channel do to prepare when the DOJ comes down with more changes about Closed Captioning?
Brandon offers the following suggestions:
• Basically you should just start budgeting for it now. And I would start with the things that are used most by the public, whatever those may be. So your websites, your public meetings, those sorts of things.
• Most of you have Video-On-Demand Channels, so whatever goes on there should have the ability to be captioned somehow. If for whatever reason you have an exception or whatever else you still may be under, you actually are still under the ADA’s broader requirement for effective communication. And just so you know, that’s always kind of lurking in the background. There still is the effective communication piece to this.
• Look towards the future to ensure that your servers have the ability to create automatic closed captioning. It’s a lot harder to prove the case that captioning is not good enough versus you didn’t have anything. It is going to deter all but the most determined from filing a lawsuit against you because again, it’s a lot easier to prove that you have nothing.
JAG works exclusively with vendors that can help you prepare for the possible future of adding closed captioning into your programs.
There have been no final rulings at this time by the DOJ. But what is being considered when the effective date is decided, is to implement a delayed implementation based on population size. For example, if you’re a government below 50,000 people, you may get three years to comply, with larger municipalities having perhaps two years.
Don’t panic about it just yet, but start to budget! We cannot ignore it forever! This seems like something we might have to face whether we want to or not.
If you would like to view this special webinar in its entirety with our guest Brandon M. Dittman. please go to:
JAG: ADA and Closed Captioning Webinar 12-21-23
Still in Play: HR 3557
The American Broadband Deployment Act
Reminder everyone: This bill imposes new restrictions on local authorities regarding their ability to regulate a variety of state and local land use and zoning issues that pertain to the deployment of telecommunications infrastructure, including wireless and wireline deployment, as well as new limits on requirements and renewals of cable franchise agreements.
Please watch our informative video on HR 3557 and hear what might happen if it is passed at: https://www.youtube.com/watch?v=fzP_t_SPzGk . And please pass this link around to all of those who can stop this harmful bill. JAG constantly advocates, analyzes and addresses emerging issues in areas such as: Local Government Communications and Internet Policy, New Technology Initiatives and Advancements, Cable Franchising and, the Operation of Public, Education and Government Media Facilities.
News & Events
Posted: January 22, 2024 by Doug Seidel
Spotlight: Middletown Township Builds TV Studio in New Town Hall
by Tara Berson and Raven Rentas, Township of Middletown
Home to 68,000 residents, Middletown Township is one of the largest municipalities in New Jersey. Due to the size of our community and diverse age ranges, interests, and neighborhoods, it is important for the Township to offer various ways for residents to access information. One of those communications tools has been our municipal TV channel which has changed over the years, particularly with the addition of our brand new TV studio this year. We had the opportunity to work with experts in the industry who helped guide the project from beginning to end.
How It Started
In November 2021, my colleague Tara Berson and I traveled to Atlantic City for the annual New Jersey League of Municipalities conference and attended the Jersey Access Group’s (JAG) seminar about cable television consumption post-pandemic. Feeling inspired after the session ended, we introduced ourselves to some of the presenters: JAG President Bob Duthaler and External Relations Chair Geoff Belinfante. We exchanged contact information, expressed our interest in becoming JAG members, and discussed our plans for a TV studio in Middletown’s new Town Hall that was being built.
In May 2022, we moved into our new Town Hall. With the new building came new opportunities so we used this transition to emphasize the importance of having an in-house TV studio to help promote key Township initiatives and programming, as well as provide a potential revenue stream through shared service agreements with other communities. We already had our mayor and administrator’s approval and funds secured through a Comcast grant, so we were given a space to help fulfill our aspirations of airing interesting and informative content.
Bringing the TV Studio to Life
We knew that creating a TV studio from scratch was a large task for us to take on in addition to our regular responsibilities. With that in mind, we reached out to Bob Duthaler to see if he (DNS Media) would be interested in supporting our Communications and IT Departments by joining our team as a consultant. Thankfully Bob was up for the challenge, so we hired him. Bob took the reins and introduced us to vendors, received quotes, and figured out next steps. With his help, we were able to determine the equipment specs for when this project went out to bid. By the end of 2022, we were feeling more organized and had finally become JAG members!
In February 2023, we joined our Purchasing Department at a pre-bid for our TV studio project, which was divided into two categories: lighting and control room equipment. We briefly met vendors and showed them the studio space and the office that was going to be utilized as a control room, as well as answered their questions. A month later, our Purchasing Director advised us that RDM Rigging would be handling lighting and G&G Technologies would be the equipment vendor. Both companies also offered training, which was much needed since we are not experts in TV production.
Our equipment arrived in April. Due to the studio’s small size, we needed to use an empty office near the Communications Department for the control room. Our IT and Public Works & Engineering Departments ran cables and installed electrical outlets wherever needed to ensure that our TV studio and control room could work together efficiently since they are not in the same vicinity.
In May, Rich DiMinno of RDM Rigging and his crew installed the pipe grid in the studio over the course of several days. While our lighting infrastructure was being taken care of, Marvin Charyn of G&G Technologies assigned John Micewicz to set up the control room (see photo). John trekked to Middletown from Westchester County, New York over the course of a few months to help set up our control room, work with our IT Department to connect our new TriCaster system to TelVue, and trained us on how to properly use the equipment.
In July, the lights for our TV studio arrived and Rich DiMinno and RGM Rigging were back to install them, along with the help of Paul Distefano of DeSisti Lighting. In August, they returned to Town Hall to teach us how to use the lighting console, which is situated in our TV studio but can also be used from our control room. In between that time, we ordered a small table and two comfy chairs, making our TV studio finally complete in August 2023 (see photo).
Lights, Camera, Action!
After almost 18 months full of vendors, doubts, training, and dedication, our TV studio was born! Building our TV studio wouldn’t have been possible without the help of our colleagues, the expertise and knowledge of our amazing vendors, and advice from our JAG family. We are truly appreciative of everyone’s part in making our TV studio become a reality. Now that it’s a new year, we’re excited to focus on our TV studio and begin producing content. We’ll check back in within a few months to keep you all posted on our progress!
Posted: January 22, 2024 by Doug Seidel
JAG’s Annual Conference
by Bob Duthaler, Conference Committee Chair
The JAG Conference Committee has begun meeting. We have elected the officers of the committee: Bob Duthaler, Chair, Rick Gearhart, Secretary and Linda Besink, Treasurer. The first items discussed were establishing the costs to attend, developing a schedule of events, and creating a list of potential sessions. Panelists will include representatives from NATOA, the ACM and JAG’s Organizational Members.
Registration Costs:
Full Conference:
Members: $225.00 and Non-members $350.00
Conference Only:
Members: $175.00 and Non-members $300.00
Banquet Only:
Members: $75.00 and Non-members $110.00
Link to Register: https://jagconference.com/shop/
Event Schedule
8:00am- TelVue User Group Breakfast
9:00am- Exhibit Hall open
10:00am-11:30am- Sessions
11:30am- Keynote Lunch
1:30pm- 5:30pm- Sessions
6:00pm- Banquet
Sessions (Details to follow)
3 Legislative: Laws and Rules & Regulations that will affect delivery of video content.
2 Technology: New equipment that will enhance the quality of video production.
6 Management: Examine dealing with the hurdles facing the operation of a media facility.
Call for Vendors
Booth size and event sponsors
Link to Register: https://lp.constantcontactpages.com/ev/reg/889386h
Conference Sponsors
Diamond (Conference Partner)- TelVue Corporation
Hotel
Discount rate for attendees $119.00
Link to Crowne Plaza Room Reservation: TBA Conference details will be posted as they are finalized to: https://jagconference.com/
Posted: January 22, 2024 by Doug Seidel
Legislative Update January 2024: News from Washington DC
by Dave Garb, Legislative Committee Chair
Closed Captioning and Web Accessibility Requirements for Local Governments
Where it Currently Stands for PEG
The Americans with Disability Act has compliance obligations for local government accessibility for websites, video streaming, and even cable broadcasting.
While the FCC has long excluded community television from captioning requirements, the Department of Justice, state governments, and private citizens have renewed a push to require captioning for all types of video content, and particularly those found on the internet.
Last month, JAG held a special webinar that explored where the requirements currently stand for access television, along with thoughts on where it might be heading, when the DOJ might make a decision, and what should be done now to prepare for the immediate future.
Our guest speaker for this informative event was Brandon M. Dittman, a founder and partner of Wilson Williams Fellman and Dittman*, an expert on the ADA and Rehabilitation Act Captioning Requirements and FCC Regulations for Closed Captioning, as well as the DOJ and their rule-makings.
Brandon relayed the following facts to the participants:
• Since 1998 the FCC has stated under its regulations that local government content is categorically exempted from captioning on television. Other government agencies such as the DOJ who are responsible for enforcing the Americans with Disabilities Act, will say otherwise. And even the FCC takes the position that video programming may be subject to captioning requirements even if they don’t require it.
• The American with Disabilities Act – Title 2 regulates public entities and regulates governments. If you’re a government entity of any kind, you fall under Title 2
• DOJ Requires Web Content Accessibility Guidelines (WCAG) 2.1 https://www.w3.org/WAI/standards-guidelines/wcag/docs/ or https://www.w3.org/WAI/WCAG22/quickref/?versions=2.1 for all web content, and captioning for video content, whether live or prerecorded is required.
• Different parts of the Rehabilitation Act which needs to also be considered include:
• Section 508 – “Electronic information and information technology must be accessible for
people with disabilities”.
(You could potentially become subject to this if you receive federal funding. Such funding could come with a requirement that you comply with the Rehabilitation Act.)
One of the most eye-opening moments of the webinar was when Brandon stated that “Any person can bring what’s called a citizen suit where they can act as their own private attorney general. Especially on the website side. A private citizen can ask for an injunction and can demand that you change your practice or stop doing the discriminatory practice.” They can recover all their attorney’s fees, and in most cases, they can get monetary damages of some kind.
So what should a PEG Channel do to prepare when the DOJ comes down with more changes about Closed Captioning?
Brandon offers the following suggestions:
• Basically you should just start budgeting for it now. And I would start with the things that are used most by the public, whatever those may be. So your websites, your public meetings, those sorts of things.
• Most of you have Video-On-Demand Channels, so whatever goes on there should have the ability to be captioned somehow. If for whatever reason you have an exception or whatever else you still may be under, you actually are still under the ADA’s broader requirement for effective communication. And just so you know, that’s always kind of lurking in the background. There still is the effective communication piece to this.
• Look towards the future to ensure that your servers have the ability to create automatic closed captioning. It’s a lot harder to prove the case that captioning is not good enough versus you didn’t have anything. It is going to deter all but the most determined from filing a lawsuit against you because again, it’s a lot easier to prove that you have nothing.
JAG works exclusively with vendors that can help you prepare for the possible future of adding closed captioning into your programs.
There have been no final rulings at this time by the DOJ. But what is being considered when the effective date is decided, is to implement a delayed implementation based on population size. For example, if you’re a government below 50,000 people, you may get three years to comply, with larger municipalities having perhaps two years.
Don’t panic about it just yet, but start to budget! We cannot ignore it forever! This seems like something we might have to face whether we want to or not.
If you would like to view this special webinar in its entirety with our guest Brandon M. Dittman. please go to:
JAG: ADA and Closed Captioning Webinar 12-21-23
Still in Play: HR 3557
The American Broadband Deployment Act
Reminder everyone: This bill imposes new restrictions on local authorities regarding their ability to regulate a variety of state and local land use and zoning issues that pertain to the deployment of telecommunications infrastructure, including wireless and wireline deployment, as well as new limits on requirements and renewals of cable franchise agreements.
Please watch our informative video on HR 3557 and hear what might happen if it is passed at: https://www.youtube.com/watch?v=fzP_t_SPzGk . And please pass this link around to all of those who can stop this harmful bill. JAG constantly advocates, analyzes and addresses emerging issues in areas such as: Local Government Communications and Internet Policy, New Technology Initiatives and Advancements, Cable Franchising and, the Operation of Public, Education and Government Media Facilities.
Posted: January 22, 2024 by Doug Seidel
Enhancing Public Access to Government Meetings with SRT Streaming
by Dana Healy, Vice President, Sales, Cablecast
In the dynamic sphere of local government, transparency and accessibility are paramount. Ensuring the public has real-time access to government meetings is a critical function of communication teams and video specialists. The challenges of network streaming video are magnified in this setting, where reliability and security are non-negotiable. This is where Secure Reliable Transport (SRT) streaming becomes an invaluable tool.
SRT Streaming: A Boon for Government Communications
SRT, a cutting-edge video transport protocol developed by Haivision, is revolutionizing the way government entities stream and distribute video content. It is specifically designed to operate over less-than-ideal networks like the public internet, providing high-quality video and audio streaming, essential for broadcasting government meetings.
The Technical Edge of SRT in Government Use
SRT stands out for its ability to deliver low-latency, high-quality video streams, even over congested networks. This ensures that live streams of council meetings, public hearings, and other government events are broadcasted smoothly, with minimal disruptions. The secure encryption of SRT also guarantees the confidentiality and integrity of the streamed content, a critical aspect for government communications.
Comparing Protocols: Why SRT for Government Streaming?
Unlike traditional protocols such as RTMP or HLS, SRT is designed to thrive in unstable network environments, making it ideal for government entities that often rely on public internet connections for streaming. SRT’s robustness against packet loss and its low-latency capabilities make it superior for live streaming important meetings, ensuring real-time public access and interaction.
Practical Applications in Local Government
Many local governments have already adopted SRT for streaming council meetings and other events. This adoption has enabled uninterrupted, high-quality broadcasts to the public, ensuring transparency and fostering civic engagement. These successful implementations serve as a model for other government entities looking to improve their streaming capabilities.
SRT and Video Servers: A Synergistic Relationship
For government communications teams, integrating SRT with their existing video servers enhances their ability to manage and distribute live and on-demand content efficiently. Video servers supporting SRT enable seamless delivery of meeting streams, both live and archived, to the public.
Accessibility for All: SRT in Low-Budget Government Setups
SRT’s compatibility with various broadcasting software like OBS Studio, vMix, and Wirecast makes it accessible even for government entities with limited budgets. This ensures that all levels of government can provide high-quality streaming of their meetings, promoting inclusivity and accessibility.
Looking Ahead: SRT in Government Video Streaming
As we advance, SRT’s role in government video streaming is poised to grow. Its adaptability to emerging technologies and evolving network conditions will continue to make it a staple in government communications strategies.
For local government communications teams and video specialists, SRT Streaming is not just a technology choice; it’s a commitment to transparency and public engagement. By leveraging SRT, governments can ensure that their meetings are accessible, secure, and of high quality, regardless of the challenges posed by network streaming video. This commitment to accessible government is central to a thriving, engaged community.
For the many community media and city cable operations using Cablecast version 7.5, native support for live SRT stream playback and recording makes it easy (and affordable) for stations to send live meetings, events, and other programming back to master control using the public internet. Cablecast VIO servers also support several network streaming protocols – including RTMP, HLS and NDI, among others – but SRT is a great option for cost-effective, reliable IP transport. Just pair your Cablecast VIO with an encoder on location and you can playout SRT streams, with no additional hardware needed. Want to learn more about how SRT streaming can improve your channel playback workflow? Get started with Cablecast.
Posted: December 15, 2023 by Doug Seidel
Spotlight: Edison – Rising Above the Crowd in Edison
By Michael D’Amato, Station Manager, Edison TV
It seems these days we need to set our cameras higher and higher just to achieve a clear shot over a sea of raised cell phones – camera operators cannot be afraid of heights! More on that later.
Edison TV, one of the founding stations in the Jersey Access Group, has had a clear mission since I became the station manager in 2006 – to present the officials, organizations and residents of the Township of Edison in the best possible light, both figuratively and literally.
Did the mayor stumble on a word? Fix it! The singer cracked on the national anthem? Edit it out!!
At Edison TV, we face the same challenges as other access stations – keeping up with ever changing technology. We moved from 4:3 to widescreen in 2012. A grant in 2013 resulted in studio LED lighting. We started shooting in high definition in 2014 and launched social media pages that same year. In 2015 we began broadcasting with Cablecast, which included videos on demand on the township website and live streaming of Channel 15. The year 2017 included our one viral social media video, a Toys for Tots PSA featuring the Grinch – 4.1 million views on YouTube and more than 800 subscribers added because of one silly video! A Grinch video produced the next year, which I feel was a superior effort, has garnered a paltry 5,000+ views – go figure!
And then there was the Pandemic. I was at the station throughout the pandemic and had to find programming wherever possible, including every state COVID briefing, religious services and re-airing and re-packaging videos from our past. That first spring and summer no one was allowed in the studio – well, almost no one. I did give Ron MacCloskey permission to record a “Classic Movies with Ron MacCloskey” episode at the station as long as there were no guests. The result was he interviewed himself – strange days indeed.
Eventually meetings returned via zoom, closed captioning was added in September 2020, PTZ cameras were installed in the council chambers in 2021 and meetings were broadcast live on YouTube – all of this leading to a much deeper relationship with our IT Department, as you can imagine.
Social media reigns supreme, which leads me back to my earlier talk of cell phones and high camera placement – I’m pretty sure all of us are dealing with more and more members of the public recording events with their cell phones – they step in front of us and we have to ask them to move. We move from camera to camera afraid we’re interfering with their shots! In the photo, I’m standing atop a picnic table with 10-20,000 people around me – many of them recording with cell phones. How do we stay relevant?
Maybe we stay relevant by offering creative and professional video and sound recordings, we insert graphics and lower thirds that support the stories we are trying to tell (and what official doesn’t like to see his or her name and title flashed on the screen?) and we involve the public: I often like to have what I call an “audience cam” at the front of the room or stage; you’re having a good time dancing and waving your arms? You’re on television! (and the audience cam also keeps people in the audience on their toes – they tend to at least look more attentive if they think they are being recorded). Most importantly, we post content to social media and the township website – I steer viewers away from our SD cable channel to our HD content. In conclusion, Edison TV has been producing hyper-local content since 1991. I’m in my 20th and final year at the station with no idea who the mantle will be passed on to. Hopefully it will be someone with fresh ideas and the same commitment to consistently producing professional content for an ever-evolving Edison community; hopefully someone who will rise to the occasion. Happy Holidays!
Posted: December 15, 2023 by Doug Seidel
Happy “JAGmas” Season!
by George Fairfield, JAG Awards Committee, Chair
Tis the season to begin getting your JAG Award entries ready for submission…even more so than in prior years, because there are several changes that will affect your registration and submission.
First, your registration: The registration will still open on January 1, 2024 but the deadline to have all your entries registered is January 31, 2024.
Second, your submissions: All entry submissions must be uploaded by February 15, 2024 and your video highlights will need to be uploaded by February 29, 2024.
Be sure to mark these dates on your calendar.
And speaking of your entry submissions, there are changes to what you will need to submit. After listening to our judges and members of JAG, it has been decided that each upload is not to be any longer than 10 minutes.
If the entry is 10 minutes or less, you will simply submit the entire video/program.
If the program is over 10 minutes, you will submit a video consisting of the opening of the program, a portion from the middle of the program, and the closing of the program, minus any credits unless they are part of the closing, with the entire run time not to exceed 10 minutes.
Each section of the “Over 10 Minute” entry must be clearly separated as follows:
1. begin with the Opening Section: at a time of your choosing, fade to black
2. followed by 10 seconds of black
3. then fade up into the middle section; at a time of your choosing, fade to black
4. followed by 10 seconds of black
5. then fade up into the ending section: at a time of your choosing, fade to black
6. the entire entry (all three sections) is not to exceed 10 minutes
How long each section will be is up to you but the committee suggests that you show your program in its best light possible.
The goal of this change is to help bridge the gap between the diverse programming produced by the member stations of JAG while leveling the judging plane plus help the judges have a better understanding of your entry.
You still must not re-edit the program sections themselves; the sections must appear as they were originally produced and cablecast. The JAG Awards committee is excited about the coming season and look forward to seeing everyone’s submissions. For a complete list of rules, please visit the JAG Website at jagonline.org. If you have any questions, please feel free to reach out to the JAG Awards Committee Chair at gfairfield@piscatawaynj.org.
Posted: December 15, 2023 by Doug Seidel
Legislative Update December 2023: News from Washington DC
by Dave Garb, Legislative Committee Chair
Closed Captioning / ADA Requirements
Where it Currently Stands for PEG
Recently, there has been concern regarding the Closed Captioning of PEG programming, and if the PEG community will be mandated to offer captioning.
Our partners at the Alliance for Community Media have some thoughts to ponder about where things currently stand on this issue.
From Mike Wassenaar, President, ACM:
Your cable channel is probably exempt from the FCC’s Captioning Rules – if revenue for the channel is less than $2M per year per the FCC’s self-implementing exemptions go into effect. We expect the FCC will implement a registry of video channels and distributors to handle captioning complaints in the coming year. We’ll keep our partners posted on when this is likely to happen, and what we’ll be required to provide – which will most likely be a contact address and email for questions about captioning.
As a reminder, all local governments and non-profits are subject to the Americans with Disabilities Act, which requires that organizations use the effective communication standard with local residents
( https://www.ada.gov/topics/effective-communication/ )
1. Are you a local government? You have an ADA requirement separate from the FCC requirement to implement effective communication – or have a publicly responsible official state that it isn’t economically feasible. This means every local government should have a plan to know the cost of implementing and providing captions, even if they don’t implement them.
2. Content that is exempt on cable is exempt online per implementation of the CVAA from 2011.
If video content is online only, there is no exemption (so I suggest online only content have a captioning solution) – This includes VOD delivered via Internet.
The DOJ will state new guidelines regarding accessibility and quality standards for all online content delivered by state and local governments in early 2024. Governments will have to meet WCAG2 standards https://www.w3.org/WAI/standards-guidelines/wcag/docs/ or https://www.w3.org/WAI/WCAG22/quickref/?versions=2.1. This specifies online video needs for captions.
The DOJ proposal is for jurisdictions over 50K people. Jurisdictions would have two years to implement these standards, and those under 50K would have three years. Please note there is no change to the Effective Communication standards suggested.
This is not a final rule – So don’t panic! It would probably take effect 60 days after publication in the Federal Register, so we don’t have target dates at this time.
The key issue here is to plan when a timeline occurs, and work with vendors for best solutions (and budget accordingly in advance).
The ACM is monitoring this situation and will have materials to consider in 2024 – but talks with equipment vendors have already begun to ensure they meet WCAG2 standards in future products and upgrades. So all… don’t worry about it just yet. However, as Mike stated, start budgeting now. We are all doing VOD, it seems like this is something we will have to face head on whether we want to or not.