Broadcasters, Children's Advocates at Odds Over Kidvid

informative] content, even in OTA [over-the-air] homes.” The association responded to comments from a collection of children’s media groups, including Campaign for a Commercial-Free Childhood, Center for Digital Democracy and Common Sense Kids Action. The record doesn’t show that nonbroadcast platforms provide “significant educational programming for children,” those groups replied. “Despite changes in viewing habits, large numbers of children still watch broadcast television.” The National Hispanic Media Coalition said the FCC should “pause” the proceeding to gather more information or risk not complying with the Administrative Procedure Act: “Neither the NPRM nor the comments filed in the record meaningfully evaluate the potential unintended effects of deregulation.” Others also urged the FCC to reset the proceeding and gather more information. “A doctor should not prescribe a litany of prescriptions before carefully examining a patient and diagnosing an illness; and neither should the FCC prescribe a litany of prescriptive remedies without a more thorough examination of what ails the Kid Vid issue,” said the Parents Television Council. Continue requiring broadcaster kids' TV reports, the children’s media groups said: “Neither broadcasters nor MVPDs should be allowed to simply certify compliance with the [Children’s Television Act] when there is no viable way to verify their compliance.” Current filing rules are a burden on small cable companies and broadcasters, said the American Cable Association and every broadcast commenter. Some content companies, such as Litton Entertainment, argued allowing broadcasters to satisfy requirements with children’s shows aired only on multicast channels will discourage production of new kid content. Lower ad revenue on multicast channels would destroy the market for new educational children’s shows, Litton said. “Allowing broadcasters to move all E/I programming to lesser-watched multicast streams would mean lower-quality (i.e., standard definition, not closed-captioned or video-described) programming and significantly fewer viewers,” said Hearst. Ion and broadcast network affiliate associations praised the FCC’s efforts, saying the media landscape “more than justifies the rule changes proposed by the Commission, and supported by most of the comments, because they will serve the public interest.”