PBS stations need specific information identifying any potentially problematic content (content considered sensitive, objectionable, or adult in nature/content at a higher risk for drawing FCC complaints) to be communicated at least 8 weeks prior to air in order for stations to make local scheduling decisions in a timely manner and prepare for possible feedback from their viewers. Late notice of problematic content creates unnecessary schedule disruptions and community relations challenges for stations and often results in last minute edits, schedule changes, and, in some instances, program cancellations. PBS cannot wait until tapes have been delivered to have these discussions.
To assist in addressing these issues, PBS is requesting that producers:
- Inform PBS program management as soon as possible of known content concerns -- but no later than 12 weeks before air -- and to provide PBS with an unpackaged copy of the program and a definitive list of problematic or “flagged” content along with that notification.
- Include a complete flag/content disclosure on the Program Acceptance Agreement.
- Alert PBS producer management of any previously unknown flags found during final editing process prior to delivery. NOTE: Producers are expected to complete a full screening of the final version of any program for content/flag issues prior to delivery. Far too often, PBS is receiving tapes with previously undisclosed flags.
- Deliver on time – 30 business days prior to scheduled broadcast and, lacking that, provide timely notification of late or potentially late delivery.
- Producers should provide the content team a copy (DVD) of final on-air version of their program.
Timely submission and notification of content flags is critically important to both producers and PBS by allowing:
- Early and more effective review of content to assure compliance with FCC regulations while allowing time for discussion and mutual agreement on edits or other treatment of a program.
- Cooperative approach to addressing potentially problematic content while maintaining editorial integrity.
- Avoidance of last minute content concerns and editing decisions.
- Timely and comprehensive communication with station programmers and management assuring fact-based scheduling decisions and effective viewer relations.
Failure to provide early submission and notification results in rushed decision-making that errs on the side of caution. Shortened review time also means that producers will have little time to make edits in a manner that preserves their artistic vision. Content edits occurring after program delivery will result in fees for which the producer is responsible.
Thank you for your consideration and cooperation.