Broadcast Writer

For this program, the captions were in the standard position of the bottom of the screen. Unfortunately, those closed captions block a lower-third.
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Prior to early 2015, broadcasters were not required to reposition closed captions to avoid blocking on-screen text (nor to avoid covering people’s faces so viewers can lip-read.)

In February 2015, the FCC has rolled out several new requirements for broadcast captions, including that if a broadcaster’s closed captions block text or faces, then the captions must be moved to someplace where they don’t block text or faces. (FCC CFR › Title 47 › Chapter I › Subchapter C › Part 79 › Subpart A › Section 79.1 … (J)… 2… (iv)Placement)

Certain TV stations that fall below the FCC’s income or market threshold for caption quality rules may have applied for an FCC caption exemption.

If your station does not have an FCC caption quality exemption, you are required to re-position your captions to avoid covering on-screen text (usually a lower-third) and to avoid covering the speaker’s face.

During the QC Tech Check, a conscientous engineer may reject a program if a caption(s) accidentally block on-screen text or a person’s face.
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For ATSC 1.0 and for the EIA 608/708 caption standard, the caption safe area of the screen is divided into 15 vertical lines.

By default, most captions are positioned on lines 14 -15 at the bottom of the screen. But when the captions block text or a person’s face, the captioner is supposed to temporarily move the captions to a place where they won’t block text or faces. Typically, off-line captioners move the captions to vertical lines 1-2 at the top of the screen. But, captioners are also allowed to move the captions up a few lines to vertical lines 11 – 13, if the captions avoid blocking text or faces in that vertical position.

For live captioning, captioners usually move the captions up a few lines from the bottom to avoid covering any lower-third text that could be keyed in during the program.

Some live-captioned programs move their live captions up to vertical lines 12 and 13 so captions are above the lower-third and don’t block people’s names.

PBS Newshour, for example, moves their captions up to vertical lines 11-12. Their captions are placed on such a high vertical line to avoid blocking lower-thirds that their news desk captions appear at the host’s chest or belly level instead of the traditional position of at the level of the host’s hand.

By default, most captions are 2 vertical lines containing up to 32 characters/line), and are placed at the bottom of the screen on vertical lines 14 and 15. Technically, captions can be up to 3 or 4 vertical lines, but 2 vertical lines are most common.

If I were captioning a program like Native Report here, I would re-position the captions on vertical lines 11-12 (which would be host’s collar area.) If it weren’t for the program graphic at the top of the screen, vertical lines 1-2 would be acceptable.
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https://www.nab.org/xert/scitech/pdfs/tv031510.pdf Television Safe Areas: Caption Safe Area*

*In this case, Vertical Lines 1- 4 aren’t a compliant caption position because captions on lines 1-4 would block this text:
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 FCC-compliant Caption Vertical Placement on Vertical Lines 11-12 
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If you use REV.com or any CaptionMax, the captioner should automatically re-position your captions to avoid covering text or faces. With other online captioning services, you are likely to be charged an extra fee per minute of video in order to have them reposition the captions to avoid covering lower-thirds.