March 30th Deadline For Revised Annual Children’s Television Report

All commercial full power and Class A digital television stations have until March 30, 2020 to file the new Children’s Television Report in LMS.

This first annual report will only cover the period from September 16 – December 31, 2019, but when stations log in, they will note that the form asks for information for all four quarters of 2019.  No worries.  The FCC staff has advised that stations should place a “zero” in the appropriate blocks for Q1 and Q2 of 2019, report only the number of core programming hours aired from September 16-30 in the Q3 2019 block, and then report all of Q4 2019 programming in the Q4 block.  Stations must select the compliance option they used during each quarterly period.  For the September 16 – December 31, 2019 period, at least 45 hours of core programming (prorated from the annual 156-hour requirement) must have aired to meet the FCC requirements.

If you’re confused about the compliance “options” under the new rule, here’s how that works.  Stations have two options to satisfy their children’s core programming obligations:

• Broadcast an average of 3 hours/week of children’s core programming, all of which must be regularly scheduled weekly programming OR
• Broadcast a total of 156 hours of core programming annually, with a minimum of 26 hours per quarter of regularly scheduled weekly programming plus up to 52 hours annually of core programs at least 30 minutes long that are not regularly scheduled on a weekly basis. The 52-hour portion could also be deemed satisfied with some shorter-form programming and interstitials that are not 30 minutes long.

Regardless of which of the two approaches a station chooses, those stations that multicast will be permitted to air up to 13 hours per quarter of regularly scheduled weekly core programming on a multicast stream in lieu of the main channel, and still count it toward the total core programming aired under either of the options above.

Remember, stations are no longer required to air three hours per week of children’s educational and informational programming on each multicast channel, so that significantly reduces the number of core children’s programming overall.  The only time such programming will occur on multicast channels is if a station decides to shift up to 13 hours per quarter of such programming from its main to a multicast channel.

As a general reminder, the definition of “core” children’s programming changed under the new rules now must meet the following criteria: (a) air between 6 a.m. and 10 p.m., (b) serve the educational and informational needs of children ages 16 and under as a significant purpose, (c) be regularly scheduled, except as allowed in compliance option 2, (d) be at least 30 minutes long, except as allowed under compliance option 2, (e) display the E/I symbol throughout the program (now for commercial stations only), (f) target child audience is specified in writing in the Form 398, and (g) instructions for listing the program as E/I are provided by the station to publishers of program guides (though such info will not have to include the specific age group any longer).