HERI Committee Report

MAINTAINING A SINGLE SYSTEM

Chapter 15
Accessibility

Section 3 of the Broadcasting Act states that "programming accessible by disabled persons should be provided within the Canadian broadcasting system as resources become available for the purpose."¹ This particular section was added in response to a recommendation made by the Standing Committee on Communications and Culture in 1987 in its report on the Canadian broadcasting system.²

For people who are hearing or visually impaired, this access is accommodated through several different formats. Closed captioning assists the deaf or hearing impaired. Audio description and descriptive video services (DVS), or described video programming as it is sometimes called, assist the blind or visually impaired, as does the National Broadcast Reading Service (VoicePrint) and La Magnétotèque.

The proliferation of channels and the presence of three distinct distribution mechanisms (conventional, cable, satellite), however, has raised important difficulties concerning delivery of services to persons with disabilities. This chapter reviews what the Committee heard concerning programming accessibility for the hearing and visually impaired. It also discusses another access issue, namely the expense of participation in broadcasting hearings.

A. Closed Captioning

Since at least 1995, the CRTC has made specific requirements for captioning as a condition of granting or renewing broadcast licences. These requirements differ according to the size of the broadcaster and the language of delivery.

English-language television stations are separated into three categories: large, medium and small. Large stations are defined as those earning more than $10 million in annual advertising revenues and network payments. This includes CBC, CTV and Global. These broadcasters have been required, since 1 September 1998, to caption at least 90% of all programming during the broadcast day, as well as all local news, including live segments.³ Medium-sized stations, (those earning between $5 and $10 million in annual advertising revenues and network payments) are expected to meet the same standards as large stations.⁴ Small stations (earning under $5 million in annual revenues and network payments) are encouraged to work towards large-station captioning standards as well.⁵

As for French-language television stations, since 1999, the CRTC has expected broadcasters to move towards achieving the same levels of captioning as English language broadcasters, and has been "exploring this with individual broadcasters at licence renewal time."⁶ Moreover, in 2001, the CRTC held that the largest French language private broadcaster, TVA, must, by September 2004, caption 100% of all news and, by 2007, 90% of all programming as a condition of its licence.⁷

What is Closed Captioning?

Captioning is a method used to make television broadcasting available to persons who are deaf or hard of hearing. This is achieved by the use of subtitles that appear on the television screen as a written transcript of dialogue and other meaningful sound effects on a television program. Captioning can be either "open" or "closed". Open captioning refers to that which is accessible to all viewers, and closed captioning refers to that which is accessible only to those viewers using a television equipped with a computer chip to decode the captioning signals embedded within the broadcast signal. Virtually all televisions manufactured within the past 10 years are equipped with such a decoding chip.⁸ Closed captioning may be toggled off or on, as the viewer wishes. It is estimated that about 15% of the Canadian population has some form of hearing loss.⁹

Pre-packaged captioning and real-time captioning

Captioning of television broadcasts may be prepared in advance of broadcast ("pre-packaged" captioning) or occur simultaneously with the broadcast images ("realtime" captioning).

The process for providing pre-packaged captioning is much like having a document translated from one language into another. A video copy of the material to be broadcast is provided to the captionist, who watches the tape, listens to the audio and inserts the captions. The tape may be stopped and replayed for clarity, and the positioning of the captions may be adjusted so as not to interfere with the images on the screen. The captions are then edited to correspond with the images by use of time signals and inserted into the broadcast signal and the audio and video signals are saved together for later broadcast. Pre-packaged captioning, which provides the greatest accuracy in the finished product, is the most time-consuming and costly method of captioning, costing approximately $1,000 for one hour of program captioning.¹⁰

Real-time captioning, on the other hand, occurs as the images are
broadcast live. Television news and live sporting event broadcasts are good examples of this; clearly, these are formats completely unsuitable for pre-packaged captioning.

In real-time captioning, a stenographer provides the captioning while the images unfold onscreen. This is a less expensive method than pre-programmed captioning, costing approximately $140 for one hour of programming.¹¹ However, as it does not have the benefit of time and editing, it sometimes suffers for accuracy, spelling errors, missed dialogue, loss of content as the images on the screen can sometimes outpace the captionist's speed and the possible interference of the captioning over the on-screen images, obscuring, for example, the speaker of the on-screen dialogue. Moreover, any technical problems either with the broadcast or captioning devices will necessarily compromise the ability to provide on-the-fly captioning, thus impeding viewers' ability to read what they cannot hear.

The Technology

Captioning technology has evolved over time and differs as between preprogrammed captioning and real-time captioning.

There are two systems that may be used for pre-programmed captioning, although one, Cheetah Systems captioning, is no longer in use in Canada. The other, the Rogers Canada system, is capable of captioning all pre-packaged content in Canada.¹²

Captionists providing real-time captioning use phonetic shorthand on a stenography keyboard, much like the machines used by court reporters. These machines are unique in that the keys correspond to sounds rather than individual letters.

French- and English-language captioning

Witnesses told the Committee that English language captioning tends to be superior to that of French language captioning, and there are significant differences between pre-programmed captioning and real-time captioning.¹³ Some of the reasons for this are market driven, and more particularly a function of the large presence the United States has in both the captioning of programs and the sheer number of English-language programs produced annually. Moreover, the U.S. federal Department of Education has provided much funding for captioning itself.¹⁴

Difficulty with French captioning lies in the technology used, which is based on an English-language model. In the case of real-time captioning, the hardware must be remapped with French phonology to accommodate accents and other characteristics of the French language not present in the English language. Currently, there are two different systems that can accomplish this on English language hardware. One system, co-developed by a Canadian at a captioning company, has every accent available in the caption decoder font.¹⁵ A competing system has been developed by la Société Radio-Canada and is, according to one witness, "technically inferior" to the other system in that the SRC system can only use the lower case accented character "é" despite it being technically possible to use many more accents than that.¹⁶

Linguistics presents another challenge with respect to French real-time captioning. The French language requires gender and number agreements which must be complied with and which may lead to errors in the captioning of live broadcasts. Additionally, as one witness explained, because the French language in general uses more words per sentence than does English, it sometimes compromises a captionist's ability to keep pace with live events as they unfold onscreen.¹⁷

Thus viewers who rely on French language real-time captioning are sometimes frustrated with the quality of the captioning.

Training captionists

The delivery of captioning, and particularly real-time captioning in French, suffers from a lack of trained captioners in Canada. The Committee heard witness testimony directly on this point:

There's a distinct shortage of trained real-time captioners in French around the world, because the system is new. It has been adapted to the English hardware, after all. There are some in France. There are some in Québec. There aren't enough.

There are no legitimate training programs for machine-aided stenography in the French language, as there are in English. Canada has a very good source for English-language-court-reporting training, but there are no such schools for French-language court reporting.¹⁸

This witness suggested that French language captioning would be improved by the creation and support of better training regimes for French real-time captioners.¹⁹

The Reality

Although both the Broadcasting Act and CRTC policies contain clear language expressing the need and desirability for the captioning of television programs broadcast in Canada, witness testimony before the Committee suggested that the reality is rather different.

The Committee heard that the language used by the CRTC in some instances lacks force and clear direction. For example, it "persist[s] in merely encouraging — as distinct from requiring — broadcasters to provide minimal amounts of captioning."²⁰ This may be readily seen in the case of smaller English and French language broadcast stations, as noted above.

In some instances, captioning is treated as an afterthought and as a marginal and unnecessary element of the broadcast as a whole. The Committee heard one witness who had been looking forward to viewing a movie that had been advertised as having captioning. However, when the movie was run, it was without the captioning. When this witnessed pressed the broadcaster for an explanation, he was told that the movie had been received with the wrong captioning track and that it was broadcast as scheduled but without the advertised captioning. He told the Committee:

Now I ask you, if it had been the audio track that was the wrong programming, would they have gone ahead and broadcast the movie with the wrong audio track? Would they? No, they wouldn't. But they didn't care about broadcasting without a captioning track.²¹

As mentioned above, the CRTC has made it a requirement of broadcast licences that a certain proportion of all programming during the broadcast day be captioned. The CRTC defines "broadcast day" as "the period of up to 18 consecutive hours, beginning each day not earlier than six o'clock in the morning and ending not later than one o'clock in the morning of the following day, as selected by the licensee."²²

The Committee heard that this 18-hour limitation of a broadcast day further marginalizes captioning and, by extension, those who rely on it:

Are all deaf people supposed to go to bed at midnight? We're not allowed to stay up and watch a late movie? Who made that decision? Who said deaf people only live 18-hour days? We live 24-hour days like everybody else. We want 24-hour regulation of captioning.²³

The Committee also heard that the CRTC does not adequately enforce its own policies and that broadcasters need not fear reprisal should they not adhere to the captioning requirements, expectations or encouragements²⁴ of their broadcast licences. One witness told the committee that:

Nothing untoward will happen to you if you're a broadcaster and do not meet requirements for captioning or description. There has never been a case in which any broadcaster has ever been meaningfully punished for failing to live up to captioning or description requirements. It simply doesn't happen.²⁵

This was echoed by another witness, who said that:

It's widely acknowledged that in its present incarnation, the CRTC is toothless and is unwilling to penalize licensees for their failure or refusal to meet licensing conditions. This kind of situation makes the CRTC bureaucratically pointless and ineffectual.²⁶

This gives the unfortunate appearance of indifference to the community which relies on captioning. This appearance is exacerbated by limitations of the definition of "broadcasting day" and policy language that "expects" or "encourages" captioning rather than requiring it. The remedy, according to one witness, is that the CRTC:

... be given the power and the political support to take aggressive action wherever necessary. That could include forcing broadcasters off the air, at least temporarily, if they violate the conditions of their licensing.²⁷

Absent such mandatory direction and punitive enforcement, there is evidence to suggest that some broadcasters will continue to resist full implementation of the captioning directives of their broadcast licence. In 2000, a complaint was heard before the Canadian Human Rights Tribunal alleging that the Canadian Broadcasting Corporation was failing to live up to the English-language captioning requirements under its broadcast licence.²⁸ As a large broadcaster, CBC is required to caption at least 90% of all programming during the broadcast day as well as all local news, including live segments.²⁹ It was alleged that the CBC's continuing failure to meet these requirements constituted discrimination on the basis of disability, an action contrary to the Canadian Human Rights Act.³⁰

After hearing evidence on the matter, the Tribunal held that, due to lack of captioning, some CBC English-language network broadcasts, as well as those by CBC Newsworld, were not accessible to deaf or hard of hearing viewers, thus constituting a prima facie case of discrimination on the basis of disability.³¹ The Tribunal also made note of evidence that the technology currently exists to caption everything broadcast on television:

The CBC claimed that providing the captioning they were obliged to provide as a condition of their licence would constitute an undue hardship and offered financial evidence to sustain this position. The Tribunal dismissed this claim, concluding from the CBC's own evidence that the estimated cost of full captioning would total less than1% of the CBC's annual budget — an amount insufficient to constitute an undue hardship on the [C]orporation.³²

Indeed, the Tribunal stated that:

... after considering all of the evidence adduced by the CBC in this case, I was left with the overwhelming impression that, although significant improvements to the level of captioning have been implemented in recent years, with a little corporate will and imagination, a good deal more could be done with respect to captioning without imposing an undue hardship on the CBC than has thus far taken place.³³

The Tribunal then ordered that the CBC English-language network and Newsworld "caption all of their television programming, including television shows, commercials, promos and unscheduled news flashes, from sign on until sign off. This must occur on the first reasonable occasion."³⁴ The Tribunal also "strongly encourage[d] the CBC to consult with representatives of the deaf and hard of hearing community on an ongoing basis with respect to the delivery of captioning services."³⁵

This decision was warmly received by the deaf and hard of hearing communities as a long-awaited vindication of their rights. The CBC has appealed the decision of the Canadian Human Rights Tribunal and the case is still in progress at the time of writing.

B. Services for the Visually Impaired

Audio Description for Visually Impaired Viewers

Audio description for blind or visually impaired viewers is a form of basic voice-over that describes the textual or graphic information that is displayed onscreen. This sort of service, for example, has someone reading aloud weather reports or sports scores as they appear on the television screen.

The CRTC has set regulations for the availability of this service. In its 1999 Policy Framework for Canadian Television, the CRTC stated that:

Licensees are strongly encouraged to adapt their programming to include audio description wherever it is appropriate and to take the necessary steps to ensure that their customer service responds to the needs of the visually impaired.³⁶

Building on this policy statement, beginning in 2001-02, CTV and Global were expected to provide audio description as part of their licence renewal agreements. In its licence renewal decision for television stations owned by CTV, the CRTC stated:

CTV indicated that it is committed to its general practice of providing audio description of important graphic information. It conveys all emergency information, such as weather warnings, in audio form as well as in video form. The Commission notes this commitment, and expects CTV to ensure that it provides audio description where appropriate. It further expects the licensee to take the necessary steps to ensure that its service responds to the needs of visually impaired audiences.³⁷

Global's licence contains a similar clause concerning the provision of descriptive audio and the CRTC's requirement for such service is identical, though specific to each network:

Global confirmed that its policy is to reinforce a program's textual and graphic elements, such as the presentation of regular weather forecasts, sports scores, addresses, and telephone numbers, with an oral description. The Commission notes this commitment, and expects Global to ensure that it provides audio description where appropriate. It further expects the licensee to take the necessary steps to ensure that its service responds to the needs of visually impaired audiences.³⁸

Thus, these networks are expected to provide audio description wherever it is appropriate. There are no specific requirements as to the number of broadcast hours expected to have the descriptive audio service available.

Descriptive Video Service for Visually Impaired Viewers

This service consists of a narrated description of key visual elements as they appear on screen. The purpose of this narrative is to give a visually impaired viewer a mental picture of what is happening on the screen. The description is timed so that it does not interfere with the on-screen dialogue. The descriptive video service is normally provided on the second audio program (SAP) channel. This second audio channel exists as an alternative to the standard audio that normally accompanies the video portion of the television program. Listeners can then choose to receive this second audio channel through either a special decoder or a television set or VCR equipped to receive SAP.

In a 1999 policy statement, the CRTC said that:

With respect to descriptive video services (DVS), the Commission concludes that it is premature to impose specific requirements on licensees at this time. The Commission encourages licensees and the National Broadcast Reading Service to continue to cooperate in order to effect the gradual implementation of DVS.

The Commission, at licence renewal, will explore with licensees the progress that has been made in meeting the needs of the visually impaired.

The Commission considered issues related to DVS during a proceeding concerning to the addition of a third national television network (PN 1998-8). The Commission's approach has been to support in principle, the gradual implementation of DVS.³⁹

This gradual implementation process is clearly seen in the 2000 renewal of CBC's English- and French-language licences, in which the statement that "it is premature to impose specific requirements on licencees" is repeated.⁴⁰ The CRTC then stated in the terms and conditions of both English and French language licences that it "encourages the Corporation to continue to develop the use of DVS, and to cooperate with the National Broadcast Reading Service in order to effect the gradual implementation of DVS."⁴¹

Following on this, the CRTC has begun to "require" descriptive video services as part of broadcast licence renewal applications. In CTV's 2001 licence renewal, the CRTC imposed specific conditions of licence:

... on each CTV station relating to the provision of described video. The condition requires CTV's largest stations (in Toronto, Ottawa and Vancouver) to broadcast, between 7 p.m. and 11 p.m., an average of two hours per week of described video programming during the first two years of the licence term. All of CTV's stations are required to provide three hours per week in year three, and four hours per week in year five. A minimum of 50% of the hours must be original broadcasts. This programming must be Canadian and be from categories 2(b) and 7. The licensee may, however, count toward fulfilment of this condition a maximum of one hour per week of described video programming that is directed to children and broadcast during an appropriate children's viewing time.

The Commission further expects CTV, wherever possible, to acquire and exhibit described versions of the Canadian and non-Canadian programming that its stations broadcast. It notes that some American programs already include descriptions in order to fulfil requirements in this area that are in effect in the United States. Finally, the Commission commends the licensee for making concrete proposals with respect to the broadcast of programming that includes described video. The Commission considers that the presence of such programming in the Canadian broadcasting system is an important contribution.⁴²

As part of its 2001 licence renewal, the CRTC imposed a similar

... condition of licence on each Global station relating to the provision of described video. The condition requires Global's largest stations (in Ontario, Vancouver and Quebec) to broadcast, between 7:00 p.m. and 11 p.m., an average of two hours per week of described video programming during the first two years of the licence term. All of Global's stations are required to provide three hours per week in year three, and four hours per week in year five. This programming must be Canadian and be from categories 2(b) and 7. A minimum of 50% of the hours must be original broadcasts. The licensee may, however, count toward fulfilment of this condition a maximum of one hour per week of described video programming that is directed to children and broadcast at an appropriate children's viewing time.⁴³

Global's licence also contains a statement of expectation that wherever possible the station should acquire and exhibit described versions of Canadian and non-Canadian programming.⁴⁴ Thus, both CTV and Global have specific requirements that must be met with respect to the provision of descriptive video services for visually impaired viewers.

TVA's licence renewal is slightly different. Here the CRTC stated that:

The Commission expects the large station groups to demonstrate leadership in establishing descriptive video. With regard to CFTM-TV's market, the Commission expects TVA to provide, during peak viewing hours, DVS in accordance with the following timetable: Years 1 and 2: 2 hours/week; · Years 3 and 4: 3 hours/week; · Year 5 and following years: 4 hours/week.⁴⁵

The Commission also "emphasizes that the number of hours allocated to DVS must not consist of more than 50% repeats."⁴⁶

National Broadcast Reading Service (VoicePrint) and La Magnétotèque

VoicePrint and La Magnétotèque are 24-hour a day newspaper reading services that are delivered over a secondary audio programming (SAP) service. They provide full text reading of news, information, features and stories published by a variety of newspapers, magazines and periodicals. These services are distributed by cable television licensees with more than 2,000 subscribers, direct-to-home satellite providers such as Bell ExpressVu and Star Choice, and multipoint distribution systems such as Look TV, SkyCable and Image Wireless.⁴⁷

C. Proposed Solutions

The Committee strongly believes that the present wording of section 3(p) of the Broadcasting Act, stating "programming accessible by disabled persons should be provided within the Canadian broadcasting system as resources become available for the purpose", is discriminatory. The qualifying phrase "as resources become available for the purpose" detracts from the statement of accessibility and leaves the impression that broadcasting that is accessible to disabled persons is of marginal importance. This erodes Canada's commitment to equality.

The Committee recognizes that closed captioning and descriptive video services are significant issues that must be addressed to give meaningful effect to the accessibility statement in section 3 of the Broadcasting Act. It is also aware that the Canadian Human Rights Tribunal in the case of Vlug v. CBC, stated that:

[Broadcasters] shall caption all of their television programming, including television shows, commercials, promos and unscheduled news flashes, from sign on until sign off. As required by Section 53(2)(b) of the Canadian Human Rights Act, this must occur on the first reasonable occasion.

As such, the Committee strongly supports television broadcasting that is accessible to the hearing and visually impaired and encourages the broadcasting industry to work towards the better provision of this access. In addition, the Committee urges broadcasters to fully comply with their broadcasting licence requirements as stipulated by the CRTC.

The Committee notes that it is a condition of some broadcast licences that accessibility be provided. The Committee is aware of the substantial costs of providing programming that is accessible to all. With respect to closed captioning, some costs are covered when Canadian broadcasters purchase pre-captioned programming. In addition, sponsorship agreements in which advertisers assist with the cost of captioning a program in exchange for certain advertising rights also helps ease the cost of providing this service.

Despite this, many programs are not pre-captioned and thus must have it added prior to broadcast. Moreover, as an increasing number of new television channels become available, there is a corresponding rise in the need for broadcast material for those channels, and a need for such material to be captioned, if necessary.

With respect to French-language programs, this situation is exacerbated by a shortage of trained captionists in Canada, particularly French-language captionists. Nevertheless, the Committee is not persuaded that the cost of complying with broadcast licencing requirements for captioning as stipulated by the CRTC is overly burdensome or constitutes an undue hardship for broadcast licence holders. Accordingly, the Committee makes the following recommendations:

This assistance should include training programs, in both official languages. Absent a program to train an adequate number of individuals in both official languages, support for broadcasters in providing captioning and descriptive video services is illusory, and thus the overall objective of more comprehensive accessibility will be even more difficult to reach.

The Committee also recognizes that oversight will be key if targets are to be met. For this reason:

D. Other Access Issues

The expense of participation in broadcasting hearings

The expense of participating in public hearings before boards and tribunals such as the Canadian Radio-television and Telecommunications Commission (CRTC) is a barrier to full and equal access to the process. Many of those who wish to appear before a board to express a viewpoint or make an intervention are deterred by the expense of doing so. This is contrary to the notion of public participation in a democratic society. It is particularly problematic when such barriers restrict full citizen involvement in public issues such as matters relating to broadcasting and local and national television. It is more troubling still given the Commission's role under section 3(d)(i) of the Broadcasting Act to "safeguard, enrich and strengthen the cultural, political, social and economic fabric of Canada." Public input is thus a crucial element of the process and barriers and financial disincentives to it especially disturbing.

At present, the Broadcasting Act does not provide for the recovery of costs by individuals or organizations who participate in public hearings before the CRTC. This is in contrast to the CRTC's powers under the Telecommunications Act to provide such relief. The same tribunal has differing powers under differing legislation to award costs to those who, in exercise of their democratic rights, appear before it. In the one case participants may be compensated for their costs and in the other they may not.

"Costs" in this context refers to a specified list of recoverable expenses that have been incurred by interveners who participate in a CRTC hearing. The CRTC has established guidelines for these expenses, which include the kind of fees and disbursements recoverable and at what rate. For example, fees paid for legal counsel, expert witnesses, consultants and analysts may be recovered at specified hourly rates. In addition, disbursements for travel, accommodation, meals and photocopying may also be recovered at specific rates. Other reasonable expenses may also be recovered at the Commission's discretion.⁴⁸

Under the power given to it by the Telecommunications Act, the CRTC may order one party, typically a telecommunications company, to pay the costs of another party, typically an intervener representing a public interest in the matter under review. The underlying principle of paying costs is to compensate deserving interveners for the cost incurred by their intervention, based on the fair market value of the work performed. The funds come from budget of key industry interveners.

For the CRTC to require that a company pay another party's costs, the company must meet three criteria: it must come under the jurisdiction of the CRTC; it must have taken part in the process, and it must have been affected by the outcome.

In addition to the guidelines setting out the kinds of costs that can be recovered and the applicable rates, the CRTC has established Rules of Procedure with respect to the awarding of costs under the Telecommunications Act. For example, not every participant who appears before the CRTC on a telecommunications matter is entitled to a cost award. To qualify for recovery of costs, participants must demonstrate that they are representative of a group of citizens, that they have participated in the proceedings in a responsible way, and that they have contributed substantially to a better understanding of the issues in question.⁴⁹ Once each of these tests have been passed, the CRTC then has the discretion to award all costs, some costs or none at all.

The Committee believes that amending the Broadcasting Act will further enhance the democratic process by helping to remove financial barriers to full participation. This is particularly significant when the Commission is considering such broadcasting and television issues as rate increases, licencing conditions of broadcasters, channel packaging, pricing, service and content matters that affect consumers directly. Impediments to consumer input and participation on these important issues must be removed.

Moreover, this balanced access is important given the imbalance between large media companies and individual consumers in terms of the resources each has to spend at hearings before the Commission. This gives an appearance of inequality of access that is inconsistent with the democratic process. Assisting interveners to recover some of their costs would help remedy this.

Reducing financial barriers also helps ensure equal representation between the various interested parties, thus providing the Commission with a clearer picture of the effect of the proposed decisions. Finally, removing barriers to greater citizen access will foster a more open, impartial and transparent process at hearings and lead to more informed decisions.

For these reasons, an amendment proposing that the Broadcasting Act include a provision for the awarding of costs to participants in hearings before the CRTC on broadcasting matters, and that the CRTC be given the power to create criteria in this respect, has been considered in the Senate of Canada as Bill S-8. This proposed amendment was given third reading and passed by the Senate on 2 April 2003 with the following text:

1. The Broadcasting Act is amended by adding the following after section 9:

9.1 (1) The Commission may award interim or final costs of and incidental to proceedings before it and may fix the amount of the costs or direct that the amount be taxed.

   (2) The Commission may order by whom and to whom any costs are to be paid and by whom they are to be taxed, and may establish a scale for the taxation of costs.

2. Subsection 10(1) of the Act is amended by deleting the word "and" at the end of paragraph (j) and by adding the following paragraph:

   (j.1) establishing the criteria for the awarding of costs; and

The Committee looks forward to receiving this bill. It recognizes the barriers restricting full citizen participation in public hearings due to the cost of access and supports the proposed amendment to the Broadcasting Act passed by the Senate of Canada on 2 April 2003 allowing for the recovery of intervener costs. It further notes that established guidelines already exist for this purpose for hearings before the CRTC on telecommunications matters. Therefore:

Endnotes