[grc] FCC reg re "call to action"

[Tim Požar]

Ug.  This is the most abused and changed section of the FCC's rules.

Noncommercial radio stations originally had a requirement for 
Underwriting Announcements.  The purpose was to disclose who is paying 
for the production and airing of a show.  For example, if you are airing 
a show on the development of oil production, you should know that it was 
sponsored by Exxon.  Any monies coming in from an underwriter can be 
only applied for the cost of production and playback of the program. 
This was not designed to be a profit source for the station.

The FCC came out with BC Docket 21136[1] that is heavily referenced in 
§73.4163 "Noncommercial nature of educational broadcast stations."[2] 
that eased the restrictions of underwriting announcements.

As lifted from "NPR Underwriting Guidelines"[3]...

	On April 23, 1981, the FCC adopted the Second Report and Order
	(BC Docket No. 21136) with new policy concerning the non-
	commercial nature of public broadcasting. While on-air
	acknowledgment of the funding sources is still necessary
	(according to Section 317(a)(1) of the Communications Act of
	1934, as amended), the 1981 FCC policy relaxed the restrictions
	associated with the acknowledgments and placed the burden on the
	good faith of public broadcasters to prevent abuses and to
	maintain the essential character of the noncommercial service.

	Subsequently, in 1982[4] and 1984[5][6], the FCC issued
	reconsideration decisions which supplement the 1981 order. These
	decisions further clarify the underwriting policies of the
	Commission while reiterating its basic reliance upon licensee
	discretion in
	making judgments on permissible credit content and language. In
	1986, the FCC issued a Public Notice addressing several specific
	underwriting issues, including use of telephone numbers. In
	addition, there has been a series of cases, arising out of	
	listener complaints, in which FCC staff have interpreted and
	applied the underwriting policies in the context of specific on-
	air credits.

The FCC has redefined these regulations several times, loosing up the 
rules as the years go on. To get a "clear" picture you have to refer to 
these dockets.  Using the "NPR Underwriting Guidelines" would be a good 
place to see what and what you can't do as they did most of the heavy 
lifting for you.

[1] https://docs.fcc.gov/public/attachments/FCC-82-327A1.pdf
[2] 
https://www.ecfr.gov/current/title-47/chapter-I/subchapter-C/part-73/subpart-H/section-73.4163
[3] http://www.nprstations.org/handbook/36underwriting.pdf
[4] https://docs.fcc.gov/public/attachments/FCC-82-327A1.pdf
[5] 
https://archives.federalregister.gov/issue_slice/1984/4/5/13526-13538.pdf#page=9
[6] https://docs.fcc.gov/public/attachments/FCC-84-105A1.pdf




On 2/5/22 2:40 PM, Kim Kaufman via grc wrote:
> Hi all -
> 
> My understanding is that NCE's can't do "call to action" things, especially around fed legislation. Does anyone know the FCC reg for this or where to find it?
> 
> Thank you.
> 
> Kim Kaufman
> KPFK LSB Treasurer
> 
> 
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