Notes from Consumer Group

NOTES ON SUBMISSION BY HOYTS, VILLAGE, GREATER UNION AND READING CINEMAS TO THE AHRC FOR A TEMPORARY EXEMPTION FROM COMPLAINTS IN RELATION TO THE PROVISION OF ACCESS FEATURES.

MAA Comment: The locations are in keeping with previous discussions and have taken into account the relatively recent rollouts of Parramatta and Erina cinemas.

No major changes to previous drafts of the schedule have been made in relation to captioned locations. Although retrofitting the existing captioned locations with audio description may be considered a priority by some groups, on account of this exemption application being made in relation to previous negotiations that have not considered this point, MAA will not be commenting on this.

Submission Point: Availability of Access Features
The applicants will continue to use best endeavours to locate and show a wide range of films with both captions and audio description where available. Open captions will continue to be shown at a minimum of three scheduled sessions each week, with audio description also available at the same sessions at the designated screens for the open caption films with audio description.

MAA Comment: The cinemas should be encouraged to work with Screen Australia to ensure that all Australian features made accessible via Screen Australia’s captioning policy are scheduled into their accessible programs.
It should be noted that audio description can be played during any session of the accessible film’s season on the accessible screen. As audio description is a personal service received via headphones, its transmission does not potentially lessen the enjoyment of other cinema patrons who do not require the service. Therefore, audio description should be made available at all sessions of the accessible film on the accessible screen.

Submission Point: Accessible information on Film Schedules
The applicants will work with representatives of disability organisations to ensure the availability of accessible information on captioned and audio described films within 6 months of the granting of the Temporary Exemption.

MAA Comment: The recent independent accessible cinema program has demonstrated that the use of localised, targeted marketing can play a key role in cinemas taking ownership of their accessible program and in making a connection with their local audiences. Besides a coordinated national approach from cinema head offices, each location manager should seek out local groups (seniors, disability, education, language) to notify of the new program. A personal approach from the local cinema manager will assist in establishing a link and increase the possibility of attendances from these groups, as opposed to online or standard newspaper advertisements of accessible sessions. Early establishment of such links will assist the cinema in ironing out any information availability issues by way of feedback from the users.

Submission Point: Review
The applicants will undertake a review of the cinema access program in consultation with representatives from key stakeholders starting 9 months before the end of the Temporary Exemption.

MAA Comment: Discussions concerning the expansion of accessible cinema over the last few years have extended beyond just extra locations. Any issues that have been brought up in previous negotiations but not addressed in this exemption application should be addressed at this review time, if not beforehand. Such issues are:

1. Changes to session times - consumers have expressed concern over the lack of variety to session times, including the lack of access to cheap day tickets, which more often than not fall on a day outside the accessible schedule.

2. Marketing and promotion – the applicants make reference to working with representatives of disability organisations to ensure the availability of accessible movie information. This is a small part of the marketing and promotion discussions that have taken place.

The applicants have previously expressed concern over the lack of attendances, citing this as a reason to delay investing resources to promote captioned screenings. Foremost, it should be noted that attendance numbers should not come into play as this is about a fundamental right to equal access. Accessible sessions should be treated as another service the cinema offers, similar to seniors, babies and carers and other specialist sessions. Accessible sessions could be tied into the marketing that is done for these specialist sessions: for example seniors often have hearing or vision that has deteriorated; and carers may require the captions to read the soundtrack when babies are crying.

Relying on consumer organisations to promote accessible sessions is avoiding responsibility for their own programs. Consumer organisations are happy to support accessible sessions, but they are not advertising mediums. Although these organisations more often than not have regular newsletters that are sent out, it should be recognised that only a small proportion of people with a vision or hearing impairment are members of these organisations.

3. Inclusion of specific locations – to a certain degree, specifically requested locations (that is, locations that may have been subject to formal complaints) have been addressed in this schedule. Consumers who have formally complained against local Hoyts, Village, Greater Union or Reading locations and are not satisfied with the submitted schedule should make this point in their submission with regards to a review.

4. New builds and refurbishments – there has been no commitment to providing access in new and refurbished cinemas. By using universal design principles, cinemas should realise that the inclusion of accessible equipment from the start is a more cost effective and efficient method than installing it retrospectively. You would not build a new cinema without wheelchair access, and then add it six months later.

Summary
Whilst in support fundamentally of the application for an Exemption under section 55 of the Disability Discrimination Act, many elements of the discussions held in recent years regarding the expansion of captioned locations and the inclusion of audio description have been omitted from this application. It is imperative that these elements be appropriately addressed in the review process, if not beforehand.