Kid

Kids Liaison

Last Updated Oct 6, 2008 07:09 PM

Public File Proposals

61. Our rules currently require commercial licensees to compile reports, containing information about the children's programming they air, including the time, date, duration, and description of the programs. Licensees maintain these reports in the station's public inspection file.(149) We sought comment in the NPRM on changing the existing requirements to enhance public access to and use of the information in these reports.(150) We identify several ways, discussed below, that such enhancements can be made without materially increasing any burden on the licensee.

i. Children's liaison

62. In the NPRM, we proposed that stations identify the person at the station responsible for collecting comments on the station's compliance with the CTA, and asked how such a requirement could be implemented without being burdensome.(151) Some broadcast parties disagreed with this proposal,(152) but the major networks, other broadcasters, and other commenters supported it.(153) We believe it is reasonable to require licensees to designate a liaison for children's programming and to include the name and method of contacting that individual in the station's children's programming reports, since someone at each station must, as a practical matter, be responsible for carrying out the broadcaster's responsibilities under the CTA. We agree with CME that there is value in identifying for the public an individual to contact with concerns or complaints about the broadcaster's children's programming.(154)

This requirement also will facilitate public access to information on stations' educational programming efforts, and assist stations in responding to comments and complaints from the public. Moreover, because licensees are currently required to maintain children's programming reports(155) and letters received from the public in their public inspection file,(156) this requirement should not impose a significant additional burden on licensees.

ii. Explanation of how programming meets definition of core programming

63. We will adopt the proposal in the NPRM that licensees provide a brief explanation in their children's programming reports of how particular programs meet the definition of "core" programming.(157) A few broadcast parties were opposed,(158) but most, including most of the major networks, supported the proposal.(159) Although NAB initially opposed this proposal,(160) it filed supplemental comments setting forth its support for requiring broadcasters to explain how programs they identify as "core" meet that definition.(161) Such descriptions assist parents and others who wish to monitor station performance in complying with the CTA. Having a broadcaster identify those programs it relies upon to meet its CTA obligation on an ongoing basis, rather than the end of the term, will increase broadcaster accountability.

64. ABC argued that licensees should have broad discretion in the manner and detail of these descriptions. For example, ABC contended that, "for a qualifying regular series, licensees should not be required to describe each weekly or daily episode; a general description of the series format, subject matter, and other overall qualities should be sufficient...."(162) We agree that such a general description of a series should be sufficient so long as the description is adequate to provide the public with enough information about how the series is specifically designed to meet the educational and informational needs of children.

iii. Physically separate reports

65. In the NPRM, we proposed separating the children's programming reports from the rest of the public inspection file.(163) This would enable interested parties to review the information without having to search through unrelated materials. This is our current practice with a licensee's political file.(164) A few broadcasters commented that this requirement is unnecessary as the children's programming reports are easily accessible,(165) but most broadcasters and other commenters supported this proposal.(166) Facilitating access to children's programming reports will facilitate public monitoring and increase broadcaster accountability under the CTA; requiring broadcasters to keep their children's programming reports separate from other portions of their public inspection files will ensure such ease of access. We therefore conclude that broadcasters should separate children's programming reports from other reports they maintain in their public files.

iv. Publicizing children's programming reports

66. In the NPRM, we proposed that licensees publicize the children's programming reports by, for example, announcing their existence and location periodically over the air.(167) Some broadcasters opposed this proposal, arguing that members of the public rarely review information in the public files, and those interested in children's programming are likely to be aware of the stations' reports.(168)

See also Kid 620 1 - 7