Deadline Approaching for 2020 Children’s TV Report and Commercial Limits Public File Certification

January 30, 2021 is the deadline for commercial full power and Class A television stations to take two actions.  The first is to upload materials to the station online public file necessary to show compliance with the FCC’s rules on commercial limits in children’s television programming for all of 2020.  This requirement was previously completed quarterly by the 10^th day of the first month of the quarter, but switched to an annual requirement due by the 30^th day of January each year.

The second required action by January 30, 2021 is to complete and file the station’s children’s television report covering the period from January 1 to December 31, 2020.  That report is available in LMS for completion now, and can be filed as early as January 1, 2021.  Once logged in, select the facilities tab, and then select the station facility id, which will produce the “Applications” button with a pull-down menu that includes the children’s television report.

The form enables the reporting of compliance based on certain flexible categories/options set forth in the rule, and requires the reporting of core programming hours aired by quarter on the main channel and digital multicast channels (if any).  For example, stations selecting Category A, Option 1 would need to report a total of at least 156 hours for the year on the station main channel, with at least 39 per quarter to be in full compliance.  The FCC eliminated the requirement for stations to air at least 3 hours per week of children’s core programming on 24/7 digital multicast channels, but allowed stations to shift some core programming from the main to the subchannels by choosing a different compliance category.  As a result, a Category A, Option 1 station with at least 156 hours on the main channel would be fully compliant reporting zeros in the quarterly blocks for digital subchannels in the form, but stations choosing Category A, Option 2, Category B, or Category C compliance would need to report the correct number of hours of their core programming that was shifted off of the main channel to the subchannels.

Remember that the reporting is for total hours in each quarter, not the number of average weekly hours as in the old form.

Also remember that there were changes to the definition of “core programming” for purposes of computing the number of hours.  A “core” program is one that:

(a) has serving the educational and informational needs of children ages 16 and under as a significant purpose,

(b) is aired between the hours of 6:00 a.m. and 10:00 p.m.,

(c) is a regularly scheduled weekly program (though there are some exceptions),

(d) is at least 30 minutes in length (though there are some exceptions),

(e) for commercial broadcast stations only, the program is identified as specifically designed to educate and inform children by the display on the television screen throughout the program of the symbol E/I,

(f) the target child audience is specified in writing in the licensee’s children’s TV report, and

(g) instructions for listing the program as educational/informational are provided by the licensee to publishers of program guides.