The FCC just adopted additional regulations for broadcasting children's programming on digital channels. Needless to say, the commission placed more bureaucratic demands on the backs of broadcasters. Now, the FCC is deciding how much kiddy-focused programming you have to broadcast to keep your license.
Don't you just love it when the government claims to know what's best for us? There's always some bureaucrat who has never worked in broadcasting telling us what needs to be done — this time under the guise of serving children.
The key change regarding digital operation is that, as stations increase the total number of broadcast hours, they must increase the amount of children's programming as well, in proportion to the total core hours broadcast.
If you effectively double the number of hours you broadcast by dividing your channel into two parts, you have to provide six hours of kiddy shows. If you split your operational channel into four parts over the core period, you have to provide a total of 12 hours of children shows.
This all works out to three percent. The magic number is obtained by dividing the current three-hour guideline by 105, or the total number of hours/week available for core programming during the 7 a.m. to 10 p.m. broadcast window. At 15 hours/day times seven days/week, this equals 105 hours per week. Therefore, to calculate the total number of tot shows you'll have to broadcast, multiply the total number of core digital (non-subscription) broadcast hours per week by three percent and round up to the nearest one-half percent.
Okay, maybe that's not too bad. But don't think you can start an all-kid channel and have it count toward your requirement. You still have to transmit three hours of tot shows on your main channel. This means you can't offload all the kid shows to one digital multiplex. Gee, wouldn't it be awful if a station devoted one of its digital channels entirely to children's programming? Given Uncle FCC's I-know-better-than-you attitude, the station would still have to broadcast three hours of tot tidbits on the main channel.
Finally, stations will have to transmit the educational/instructional (E/I) bug throughout any children's programming. I suppose if the program is about Barney the purple dinosaur, viewers need the E/I bug to know it's okay for kids to watch it, as opposed to a sitcom with Barney Fife.
The new rules also address commercials within the kid shows. The order specifies a limitation of 10.5 minutes per hour on weekends and 12 minutes per hour on weekdays. The FCC says that leaves 49.5 minutes for actual program material. Yes the math is right, but it's not real world. Stations still need room for two IDs and two bumpers, and programming will want a couple of promos (which, by the way, count as commercials). All this ought to leave the local station with about three minutes of spot time — if it's lucky.
Don't get me wrong; I'm not complaining about having kid shows. But the new rules represent just another in a long list of mandates on broadcasters, justified by the excuse that we are “using the public's spectrum.” Okay, then I want my neighbor to pay $10 a month to use his garage door opener because I open mine by hand!
What's next, a charge to breath the air?