Child Advocates to FCC: Rules Were Not Made to Be Broken

A coalition of organizations told the Federal Communications Commission that the FCC should retain its children's programming rules. The Center for Digital Democracy, Campaign for a Commercial-Free Childhood, Common Sense Kids Action, Color of Change, Dr. Jenny Radesky, and the Benton Foundation wrote:

Having now reviewed the comments, Child Advocates believe that the record supports retention of the current guidelines. The record does not show that non-broadcast platforms provide significant educational programming for children. In addition, many families continue to rely on over-the-air broadcasting and cannot afford the alternatives. And despite changes in viewing habits, large numbers of children still watch broadcast television.

The coalition says it is not against updating the Children's TV Act (which the FCC rules enforce) to reflect marketplace changes, but revamping the FCC rules first would be putting the kiddie cart before the pony. The main asks and critiques: 

1. Non-broadcast children’s programming is generally not designed to educate or inform children
2. Many families continue to watch and rely on over-the-air broadcasting
3. Many families are unable to afford non-broadcast alternatives 
4. Many children watch broadcast television 
5. Adopting the NAB safe harbor would reduce the amount, viewership and advertising revenues from children’s educational programming, making production uneconomical
6. There is no merit to NAB’s claims about the benefits of putting all children’s educational programming on multicast channels
7. Broadcasters, cable and DBS operators must maintain publicly accessible records sufficient to verify compliance 
8. The commission should not eliminate the Children’s Television Program Reports
9. Cable and satellite operators must continue to provide documentation showing compliance with advertising guidelines in their online public inspection files.