Station Compliance›Field Notes

Most FCC rules are written in standards — reasonable diligence, as soon as possible, comparable practice. Children's programming is written in numbers, which makes it easier to comply with and easier to fail measurably.

The Core Programming numbers

From § 73.671, a commercial television station's Core Programming must meet all of these at once:

Each is a separate way to miss. A station can air ample children's programming and still fall short because it ran at 5:30 a.m., or because the blocks were 15 minutes, or because the E/I bug was not on screen.

The E/I symbol is the one to check first

§ 73.671(c)(5) requires, for commercial stations, that the programme be identified as specifically designed to educate and inform children by the display on the television screen throughout the programme of the symbol E/I.

Throughout. Not at the top of the hour, not in the corner during the open.

This is worth checking because it is a plumbing failure rather than a programming one. The bug is inserted by the same graphics or master control path that handles everything else on screen, and it stops for the same reasons anything else stops — a router change, a firmware update, a switch to a different playout path, an automation event that was edited and never re-tested.

What has to be filed and kept

Children's programming reporting lives in the public file, and the obligation is quarterly. § 73.3526(e)(11) covers the children's television programming reports alongside the issues/programs list, which means the same calendar dates you already keep for the quarterly list are the dates that matter here.

Two practical consequences:

• The reports and the programming are separately checkable. A station that aired everything correctly and filed late has a documented violation with no programming defect behind it.
• The retention runs to the next renewal, like the rest of the file. A gap does not age out; it sits there for the whole licence term.

The commercial limits, briefly

§ 73.673 limits commercial matter in children's programming — 10.5 minutes per hour on weekends and 12 minutes per hour on weekdays, for programming directed to children 12 and under.

The failure mode here is not usually greed. It is an automation log built for adult dayparts running into a children's block, or a promo counted as programme content when it should have counted as commercial matter. Website addresses displayed during children's programming have their own restrictions worth reading if you run any.

The audit

1. Pull your last two quarters of children's programming reports. Do they exist, are they complete, were they filed by the tenth?
2. Add up the hours. Three per week averaged over six months, and at least 26 in each quarter.
3. Check the clock. Everything counted must have aired between 6:00 a.m. and 10:00 p.m.
4. Watch a block on a real receiver and confirm the E/I bug is present throughout, not just at the open. This is the check nobody does.
5. Spot-check commercial minutes in one children's hour against the limit.
6. Confirm the blocks are regularly scheduled weekly programmes, not floating.

Why it belongs on this site

Because it fails the same way everything else here fails.

Children's programming compliance is a task with no daily symptom, owned by nobody in particular at a small station, and dependent on equipment nobody monitors. The E/I bug and the EAS crawl run through the same graphics path. The quarterly report shares a deadline with the issues/programs list. The renewal that reviews one reviews the other.

That is also the opportunity. September 29 forces somebody into the plant with a checklist — the program chain security rule sees to that. A station already standing in front of master control can confirm the E/I insertion in ten minutes, and the alternative is discovering it at renewal.

The compliance calendar covers what else runs on the quarterly rhythm.