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PROGRAM UNDERWRITING GUIDELINES

PREAMBLE

Corporate sponsorship is an ever-growing source of operating revenue for public radio station WMOT. These Underwriting Guidelines present a style and standard for the on-air acknowledgment of corporate support for programs broadcast on WMOT. In formulating these Guidelines, WMOT has endeavored to balance listener expectations for a noncommercial radio service with the legitimate interest that corporate supporters may have in being adequately identified on the air.

The Public Broadcasting Act of 1967 and subsequent amendments define public broadcasting as being noncommercial in nature. Public radio is able to produce programs in isolation from the demands of the commercial marketplace. A public radio station may accept gifts, grants, donations, and contributions for the production, acquisition, and promotion of its programs and operation. It is the solicitation of those contributions and the recognition given them that is addressed in these Guidelines.

The Guidelines for underwriting programs on WMOT are presented in two parts: Principles and Procedures.

• The Principles involve broad concepts that reflect the philosophy and standards for underwriting. 

• The Procedures are the specific rules associated with underwriting programs on WMOT.

The Mandate of Public Radio

Of course, these principles and procedures fall within statutory framework (47 U.S.C. 399) and the policies established by the Federal Communications Commission (FCC). On April 23, 1981, the FCC adopted the Second Report & Order (BC Docket No. 21136) with a new policy concerning the noncommercial nature of public broadcasting.  

• While on-air acknowledgment of 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 acknowledgements 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, 1984, and 1986 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.      

• All of these FCC materials have been used in developing the WMOT Guidelines.