Form for substance?


The FCC’s "Standardized Television Disclosure Form" is officially available, and it’s a doozy. We clock it in at eight pages. It asks for all kind of information. What market are you in? Are you a network affiliate? Publicly owned? Independent? Commercial/noncommercial?

It asks for information on primary and non-primary programming streams, the amount of time weekly for different types of programming, and how much is in high-definition. It wants total time for national news, locally news produced by the station, local news from elsewhere, total time spend on local civic affairs and local electoral affairs. It also asks for total programming that is independently produced, total PSAs, total paid PSAs and total closed captioned programming.

It then provides space to go into more depth on the news, public affairs and PSA areas. It asks it you run programs aimed and under-served communities in your license area, and it asks about religious programming. It asks how your station goes about meeting community needs and serving the disable. It seeks information of performance during emergencies, and whether the station participates in an LMA, JSA or similar agreement.

Then it asks for a signature.

TVBR/RBR observation: This form is going to be a great deal of fun to keep up to date. And we can see where it would be fun to go to a station’s public file and dig into this stuff, especially for the watchdog community. It may not be a bad thing for every station, either. As Capitol Broadcasting’s Jim Goodmon has pointed out, it gives strong full-service stations a chance to shine.

The obvious question is on the flip side. Take a 24/7 syndicated home shopper in an LMA. It’s perfectly legal, but it’s going to result in a lot of zeros on the program tally page. Should it just go ahead and turn in the license now?

We have to believe that the FCC would have no authority to revoke a license based on program content, because of the First Amendment, and more to the point, because if somebody is tuning in, the station is in fact serving somebody in the local community. And if there is nothing the FCC can do, short of wagging a finger and shaming a particular station, then this whole thing becomes an essentially pointless exercise.

Click on the pdf link below for the full FCC form.