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In three separate actions the FCC has moved to standardize or expand reporting requirements relating to the public interest obligations of TV broadcasters. Here is a summary of the three initiatives:

DTV stations' obligations to children. The FCC is seeking comments on the following issues related to children's TV in the digital age:

- How the children's core educational programming processing guideline should be applied to DTV broadcasters;

- Whether the guideline should apply only to free broadcast services or also to pay services, and whether a three-hour guideline is sufficient in light of the additional program capacity made available by digital technology;

- Whether the Commission's policies regarding pre-emption of core programs should be revised in view of the greater programming flexibility available to DTV broadcasters;

- Whether children's programming advertising limits and policies should apply to both free and pay program streams;

- How these rules and policies should be interpreted in light of DTV's interactive capabilities;

- Whether the Commission should revise its definition of "commercial matter" to include interruptions such as certain program promotions; and

- How to address the issue of airing promotions for age-inappropriate movies or TV shows in programs viewed by children.

Comments on these issues will be due in late November or early December.

Quarterly reports on children's programming. The FCC has amended its rules to permanently require commercial television broadcasters to file with the FCC Children's Television Programming Reports describing their children's educational and informational programming as they are prepared. Under the Commission's 1996 order implementing the Children's Television Act, commercial TV stations were required to prepare and place in their public inspection files quarterly reports on their children's educational programming, but the four quarterly reports could be filed with the Commission jointly once a year.

These reports identify the educational and informational programs aired by the station over the previous quarter and the days and times these programs were regularly scheduled, the age of the target audience for each program, the average number of hours per week of core children's programming broadcast, and plans for the next quarter.

In its recent order, the Commission made a number of revisions to the quarterly report to make the information contained in the form clearer and more useful. The FCC also asked whether broadcasters should be required to make their quarterly reports accessible through their websites.

Standardized quarterly reports. In a notice adopted in September, the FCC tentatively concluded that television broadcasters should provide information on how they serve the public interest in a new standardized format on a quarterly basis. The disclosure form would be maintained in the station's public inspection file in place of the currently required issues/programs lists and be placed on the station's or a state broadcasters' association's website.

- Types of disclosures. The FCC is seeking comment on what program categories should be included on the standardized form. The FCC proposes including a "catch-all" category to ensure that the form enables broadcasters to reflect any public interest programming they aired that does not fit into one of the specified categories. The Commission also is seeking comment on how licensees should inform the public about their provision of closed-captioned and video described programming.

- Ascertainment revisited. The FCC invited comment on whether a licensee should provide a narrative description on the standardized form of the actions taken in the normal course of business to identify its community's programming needs and interests. The Commission also sought comment on whether activities such as organizing community events or awareness campaigns should be listed on an attachment to the form and considered in assessing whether the licensee has served the public interest under the Communications Act.

- Public inspection file. The FCC tentatively concluded that licensees must place a paper copy of the standardized disclosure form in their public inspection files each quarter and retain those forms until final action has been taken on the next renewal application.

Comments on these proposals also will be due in late November or early December.

Annual EEO Public File Reports must be placed in the public files and on the websites of stations in the following states on or before Dec. 1: Alabama, Colorado, Connecticut, Georgia, Maine, Massachusetts, Minnesota, Montana, New Hampshire, North Dakota, Rhode Island, South Dakota and Vermont.

All commercial TV stations must complete construction of their DTV facilities by May 1, 2002. For NCE-TV stations, the deadline is May 1, 2003.