The question has recently arisen as to when underwriting announcements can be aired on noncommercial radio and TV stations. The New York Times recently quoted me on the subject in an article discussing the plans of PBS to experiment with putting underwriting announcements in programming, rather than merely in the breaks between the end of one program and the beginning of the next. The FCC rules for both radio and TV state, in italics, that the scheduling of underwriting announcements "may not interrupt regular programming." What does that mean?

In 1982, in adopting the rules as to the timing of sponsorship announcements and the acknowledgment of donations, the FCC relied on what was then a recently-enacted statute addressing the sponsorship of public broadcasting programming. The House of Representatives report adopting that legislation contained language interpreting the meaning of the prohibition against these announcements interrupting regular programming. The FCC relied on that language in adopting the rules currently on the book. There, Congress said that announcements could be run "at the beginning and end of programs,...between identifiable segments of a longer program" or, in the absence of identifiable segments, during "station breaks" where the flow of programming was "not unduly disrupted." For radio, this seems like a much easier test to meet, as there are always breaks in programs, e.g. between stories on a news program like Morning Edition, between guests on a program like Fresh Air, or between music sets on a noncommercial music-oriented station. For TV, the issue is somewhat more complicated, thus the questions that the Times wrote about in connection with the PBS tests.