Recently, the Federal Communications Commission posted three enforcement actions for non-commercial educational radio stations regarding impermissible underwriting announcements. Two of these cases reinforce the responsibility of the station licensee for everything it broadcasts--even if another organization created the programming.
In the Jones College notice of apparent liability, a program called "Swing Time" was provided by an outside programmer. Although the station received no monetary compensation from the programmer or the underwriters, only the program. The FCC deems the programming itself as compensation (think 'barter syndication') and the announcements must then comport to the regulations. Simply put: the FCC holds the station responsible for compliance with every announcement--regardless where the program was produced.
The program included eight underwriting announcements that are clearly out-of-bounds. Some of the the announcements were 60 seconds long. The commission noted:
"Although the C ...Read more »