For Television Stations Going All Digital on February 17 - Remember that Consumer Education Efforts Do Not End With the Change
Many television stations are making the conversion to all-digital operations today (see our post here for details). These stations should remember that the DTV Consumer Education efforts that are currently in place apply to both the analog channel and the primary digital channel, and thus will continue after the conversion. Based on the current rules, the obligation to continue the education efforts extend through March 31st. So even if stations shut off their analog signal today, the digital station should continue airing the 16 PSAs per week, 16 crawls per week, the 30 minute long format program, etc., on their primary digital channel. Similarly, under the current rules, the stations all still need to file a Form 388 on April 10th reporting on the First Quarter efforts. Our memo detailing these efforts can be found here.
Presumably, the FCC will be providing further guidance on the consumer education rules, but given that the existing rules contemplate that DTV stations will continue these general consumer education efforts past the hard date transition, with the transition deadline now extended through June 12, these rules may well be changed to require that the education efforts extend beyond the current quarter through June or perhaps beyond. So watch for further information.
I was wondering why stations are still required to broadcast crawls and PSAs on their primary digital channel. I am not sure whether folks who made the successful switch to digital want to be annoyed with transition messages after they have gone digital.