The FCC has released 16 Show Cause Orders threatening to deprive a number of low power television (LPTV) stations of their Class A status for failure to file Children's Television Programming Reports.  These orders appear to be implementing a long-rumored get-tough policy on Class A TV stations, as the FCC prepares to clear portions of the TV spectrum to auction it for use by wireless broadband providers, in accordance with the authorizing legislation we wrote about last week. Class A stations are protected from interference like full power TV stations, while other LPTV licensees can be displaced from their current channels by new primary users - potentially including future wireless broadband auction winners. Therefore, if these Class A stations are downgraded to LPTV status, the FCC could displace them as needed for spectrum auctions.  If they retain their Class A status, they are protected like full-power TV stations, and the FCC must attempt to replicate their coverage in any repacking of the spectrum that may occur.

These 16 Show Cause Orders all have essentially the same set of facts as this one.  Specifically, all of the stations failed to file multiple Children's Television Programming Reports and failed to respond to FCC letters cautioning the stations that failure to file these reports could result in loss of Class A status.  As the FCC notes in all of the Show Cause Orders, Class A licensees are required to comply with many full power TV requirements, including the need to maintain a main studio and a public inspection file, to comply with children's programming requirements, political programming requirements, station identification requirements and Emergency Alert System rules. Failure to comply with any of these requirements could result in loss of Class A status.

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