With the obligation of television stations to file the quarterly Children’s Television Reports on FCC Form 398 by Monday (as the usual January 10 date is on a weekend) and the simultaneous requirement to place into their online public file documentation of compliance with the commercial limits in Children’s programming, it is worth reminding stations of the seriousness with which the FCC continues to view its children’s television rules. There have been a number of fines and enforcement actions against TV stations in recent weeks, highlighting the need for stations to be vigilant about compliance with all aspects of the children’s television rules. While the license renewal cycle, during which most of these issues come to light, is coming to an end in 2015 and stations that have already been renewed won’t face renewal scrutiny for at least another 5 years, issues that arise even this far out from the renewal window can haunt the station at the next renewal. Moreover, with the public inspection files of stations now online, the FCC or other interested parties can view station’s compliance with these obligations at anytime from anywhere, and can easily file FCC complaints. So TV stations cannot let down their guard simply because their license renewal has been granted.
In the past week, we saw one interesting case, where the FCC proposed to fine a station $3000 for failing to include the “E/I” symbol in the educational and informational programming directed to children on two of its multicast channels. The FCC rejected arguments by the licensee that the programming on those channels was in Korean, and thus the E/I symbol would not make sense to the Korean viewers of the programing. The Commission reasoned that, if the station wanted an exemption to the rules, where it could identify the programming as educational and informational in Korean text, the station should have asked for a waiver of the rules.
Continue Reading Remember Children’s Television Compliance Obligations – The FCC Does Not Forget