public policy and children's...

Public Policy and Children's Television Aletha C. Huston

Bruce A. Watkins

Dale Kunkel

Department of Human Development University of Kansas Department of Sports Management and Communication University of Michigan Department of Communication Studies University of California, Santa Barbara

ABSTRACT." Television occupies a large part of children's time from an early age. Among its many functions, education, social learning (prosocial as well as antisocial), and selling products are well documented by research evidence. Commercial programming for children in the United States consists primarily of cartoons and entertainment shows; educational and informative programs are supplied by public broadcasting and, to some degree, by a few cable channels emphasizing the child audience. The structural organization and revenue sources for children's television have a direct effect on program and commercial content.

We propose two principal goals for public policy in this domain: to promote programming that serves the diverse needs of children for education, entertainment, aesthetic appreciation, and knowledge about the world, and to protect children from television content and advertising practices that exploit their special vulnerability. In recent years the Federal Communications Commission has followed a philosophy of deregulation, based on the assumption that market forces would generate diverse programming and limit commercialization. The data, as applied to the programming marketplace for children, contradict that assumption. We recommend a requirement for a minimum amount of informational and educational programming for children on every station, and we propose strengthening public broadcasting, currently the only source of such programming for many children. Cable and alternative technologies cannot carry the burden of serving children's needs unless they become universally available. Regulation is also needed to protect children from commercial exploitation. The long-range policy goal should be to eliminate advertising to children; short-range goals include reinstatement of time limits on advertising and restrictions on product-related programs.

Television is ubiquitous in the United States and most other industrialized societies. Because most American children are born into homes in which the television set is turned on several hours a day, it enters their lives long before most other socializing agents such as schools, peers, or religious institutions.

Our purpose in this article is to review and evaluate public policies affecting children's television. There is

ample evidence that television affects children's knowledge, beliefs, attitudes, and behavior, for good or ill. Al- though the negative effects of television often occupy the spotlight of public controversy, the potential of the medium for positive contributions to development is at least as important. We take the position here that the goals of public policy ought to be twofold: (a) to promote programming that serves the diverse needs of children for information, entertainment, aesthetic appreciation, and knowledge about the world, and (b) to protect children from television content and advertising practices that exploit their special vulnerability.

The fact that this children's public policy issue in- volves a private-sector, profit-making industry makes it an especially complex one. Most television programming is designed to attract audiences for advertised products; the welfare of child viewers is secondary to merchandising goals. As a result, polieymakers typically ask to what ex- tent the government should police or supplement the private marketplace to assure services to children, rather than asking directly what role government should play. Proposals for government intervention meet not only the usual barriers of scarce dollars and conflicting priorities but also opposition from a powerful industry with huge economic stakes to protect.

In this essay, we review briefly what is known about children's uses of television and some of its major influences on their lives. We then examine what kinds of television fare are available for children in the United States and how the content of programs is related to the structural organization of broadcasting and production. Law and public policies affecting children's television programming and advertising are reviewed and evaluated, and proposals for feasible and effective policy changes are presented.

H o w Children U s e Television

Although estimates of children's viewing time vary widely (from 11 to 28 hours a week), they all indicate that Amer- ican children spend more time watching television than in any other activity except sleep (A. C. Nielsen Co., 1988; Anderson, Field, Collins, Lorch, & Nathan, 1985; Car- penter, Huston, & Spera, in press; Comstock, Chaffee, Katzman, McCombs, & Roberts, 1978; Huston, Wright, Rice, Kerkman, & St. Peters, 1987; Timmer, Eccles, &

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O'Brien, 1985). Home observations show that, by age four, children look at the set more than half the time it is on; attention peaks at around 80% in late childhood (ages 10-12), the age at which total viewing time also reaches a peak (Anderson, Lorch, Field, Collins, & Na- than, 1986; Comstock et al., 1978).

These averages obscure wide individual and group differences. Children and adults from families with low education and/or low incomes use television more heavily than their more educated and affluent counterparts (Greenberg, 1986; Medrich, 1979). Black children and adults watch more television than Whites, even with social class controlled (Berry & Mitchell-Kernan, 1982). Poor and minority children not only watch a great deal of television, but they rely on it heavily as a source of news and social information (Greenberg, 1986).

In short, television occupies a great deal of children's time and attention. It is particularly central to the lives of low-income and minority children who lack the finan- cial resources to obtain alternative media or, in some in- stances, alternative activities.

Influences of Television on Children

In this section we summarize television's influences on children under three rubrics describing the roles of television in children's lives: education, social learning, and selling, x

Television as Educator

Because of its appeal and widespread availability, television has enormous potential for teaching academic, cognitive, and social skills. Planned programs designed to teach began to be widely noticed in the late 1960s with pioneers such as Mister Rogers' Neighborhood and Ses- ame Street. Others followed.

Careful evaluations have demonstrated that such programs are often (though not always) effective (Watkins, Huston-Stein, & Wright, !981). Field experiments demonstrated that viewing Mister Rogers' Neighborhood leads to increased prosocial behavior, task persistence, and imaginative play (Stein & Friedr!ch, 1975). In two large- scale evaluations of Sesame Street, the target audience of preschool children learned many of the skills and concepts taught on the program (Ball & Bogatz, 1970; Bogatz & Ball, 1971). Even a skeptical interpretation of the data concluded that children learned letter and number skills from unaided viewing (Cook et al., 1975). Viewing at ages 3 and 4 is associated with improved vocabulary and prereading skills at age 5 (Rice, Huston, Truglio, & Wright, 1987; Truglio, Huston, & Wright, 1986). After broadcasts of Reading Rainbow, a program designed to encourage reading, sales and library use of the featured books rise dramatically. Freestyle, a series designed for 9-to 12-year-olds, succeeds in expanding this age group's concepts about gender roles and careers (Johnston & Et- tema, 1982; F. Williams, LaRose, & Frost, 1981).

Although many of these findings have substantive and theoretical value, they also provide important evidence for policymakers. Clear evidence of effectiveness is

critical for persuading guardians of public or private funds to invest in the very expensive business of television production. When compared with other forms of education, broadcast television is extraordinarily cost effective because it reaches such a large number of children. For example, Sesame Street cost between $1.00 and $2.00 per viewer per year in its first 2 years of broadcasting (Cook et al., 1975).

Television as a Source of Social Learning

Whether intended to or not, television can and does teach about social behavior and social groups. Programs designed for children and for adults often convey a highly stereotyped and distorted social world in which being male, youthful, beautiful, and White are valued, and being female, old, handicapped, dark-skinned, or foreign are not valued (Greenberg, 1986; Liebert & Sprafkin, 1988; U.S. Commission on Civil Rights, 1977). When positive counterstereotyped models are available, nonstereotypical role learning occurs (Johnston & Ettema, 1982; Wrob- lewski & Huston, 1988).

Violence also abounds on television, particularly on commercial programs designed for children (Signorielli, Gross, & Morgan, 1982). The effects of television violence have been investigated more thoroughly than any other issue in the field. Experts have repeatedly concluded that there is a small, but reliable, causal effect of television violence on aggressive behavior (Friedrich-Cofer & Hus- ton, 1986; Huesmann & Eron, 1986; Pearl, Bouthilet, & Lazar, 1982; Surgeon General's Scientific Advisory Com- mittee on Television and Social Behavior, 1972). The American Psychological Association (APA, 1985) and many other professional organizations have endorsed that conclusion. Industry representatives (e.g., American Broadcasting Companies, 1983; Milavsky, Stipp, Kessler, & Rubens, 1982) and a few academics (e.g., Freedman, 1984, 1986) continue to dispute the conclusion that television violence causes aggression. Yet small but statisti- cally significant findings have occurred in the research literature across a variety of research methods and subject populations. In addition, even if one grants the minority view that the scientific proof is tenuous, the social sig- nificance of the negative effects of televised violence on a nation of children is sufficiently strong to warrant concern and action by policymakers.

The same mechanisms that generate adverse effects are also capable of producing positive outcomes. Prosocial

We are grateful to John C. Wright for his comments and suggestions. Funding from National Institute of Mental Health Grant MH-34703 provided assistance for preparation of the manuscript.

Correspondence concerning this article should be addressed to AI- etha C. Huston, Department of Human Development and Family Life, University of Kansas, Lawrence, KS 66045.

1 Several comprehensive reviews of the television literature are available. They include Comstock et al. (1978), Dorr (1986), Liebert and Spratkin (1988), Pearl, Bouthilet, and ~ (1982), and Stein and Friedrich (1975). A thorough bibfiography of research through the 1970s is also available (Murray, 1980).

February 1989 • American Psychologist 425

interactions such as altruism and sympathy are also por- trayed in many commercial television programs (Harvey, Sprafldn, & Rubinstein, 1979). Both experimental and correlational evidence indicate that prosocial content in commercial entertainment programming can provide an effective model for social learning (Collins & Getz, 1976; Sprafkin, Liebert, & Poulos, 1975; Spratkin & Rubinstein, 1979).

Television for Selling Products

Children are a targeted "market" for advertising toys, cereals, candy, and other foods (Barcus, 1977; Melody, 1973). A convincing body of research accumulated during the 1970s demonstrated that preschool children typically fail to distinguish program material from advertising. Children below about age 8 do not understand the persuasive intent of advertising and are, therefore, particularly vulnerable to its appeals (Adler et al., 1980; Federal Trade Commission, 1978; Wartella & Hunter, 1983). Children older than 8 are more aware of the purposes of advertising, but they are still apt to be persuaded by appeals that are subtly deceptive or misleading (Kunkel, 1988a; Ross, Campbell, Huston-Stein, & Wright, 1981; Ross et al., 1984). Both data and the continuing invest- ment in advertising to children by food and toy companies provide ample evidence that advertising is effective in its Ultimate goal--selling products.

What Television Fare Is Available to Children and Why In the early days of television, a substantial amount of high-quality children's programming was available at popular viewing times on the major networks. For instance, in 1951, 27 hours per week of children's programming were broadcast by the networks on weekdays between 6 and 8 p.m. (Melody, 1973). By the 1960s, however, programming for children had been relegated to time slots that were least successful in attracting audiences of adults, particularly Saturday morning. Low-cost ani- marion replaced productions using live actors, and children were increasingly targeted as a market for advertising (Melody, 1973).

As commercial television's service to the child audience declined, alternatives were sought to provide more and better children's programming. In 1967, the Public Broadcasting Act created a system of noncommercial television stations to provide diverse cultural and educational programming, including imaginative instruc- tional programming for children (Carnegie Commission on Educational Television, 1967). Starting in the late 1970s, cable television grew rapidly; its greater channel capacity permitted "narrow-casting," providing programs designed to meet the needs of specialized audiences, including children. Cable transmission is supported by a combination of advertising and user fees. Just over half the homes in the country now subscribe to cable (A. C. Nielsen Co., 1988). However, cable avmlability to children is skewed toward the affluent because of cost and because many rural and low-income urban areas are not served

by any cable company. Most recently, home videotape recorders have enjoyed rapid diffusion; 53% of U.S. households owned a videotape recorder at the end of 1987 (A. C. Nielsen Co., 1988).

Program Content

Commercial television, public television, cable, and videotape distribution have different structural organizations, revenue sources, and goals that lead to very different types of program content. In this discussion we concentrate on children's programs, those designed primarily for a child audience. They are classified as informative if they are designed to educate, teach a skill, present moral or social messages (Kerkman, Huston, Wright, & Eakins, 1987), or convey information about "history, science, literature, the environment, drama, music, fine arts, human rela- tions, other cultures and languages" (Federal Commu- nications Commission, 1974). Of course, such programs are often also intended to be entertaining.

Programs on Commercial Television

Commercial broadcasters are generally driven by a need to reach the largest possible audiences. Thus commercial stations devote relatively little broadcast time to programs for children and even less time to informative programs. Commercial network alffliates averaged less than one hour per week of children's informative programming in 1983; there were seven programs per week on the three commercial networks combined (Kerkman et al., 1987; Phil- lips, Williams, & Travis, 1986). Independent commercial channels--those not receiving their programs from one of the three commercial networks--broadcast syndicated children's programs, primarily noninformational cartoons. In one sample in 1983, two independent channels averaged four hours per week of informative children's programs (Kerkman et al., 1987). Few programs are age- specific; most are aimed broadly at the 2-12-year-old audience, given the need for the largest audiences. Because most channels schedule children's programs during the same time slots, availability is even more limited than the numbers of programs might suggest.

Although informative programs on commercial television are rare, the exceptions are notable. Each network has occasional after-school special programs (about once a month). There have also been creative efforts on Saturday morning such as Pee Wee's Playhouse, Fat Al- bert and the Cosby Kids, and Pryor's Place.

In the past five years, commercialism in children's television has increased dramatically with the advent of product-related programs (Kunkel, 1988b). In earlier years, toys were often developed from program characters and themes as an afterthought. The new wrinkle in product-related programs is that the programs are created as an integral part of the design and merchandising of a toy. The latest extension of this trend is interactive programming, for which a toy can be purchased to interact with a signal from the program. Although interactive tech- nology could be used for prosocial or educational purposes, its first commercial incarnation was high-tech

426 February 1989 * American Psychologist

weaponry that allowed the viewer to shoot and be shot at by the figures on the television set.

Advertising on Commercial Stations

Advertising directed to children promotes toys and foods; the majority of the foods advertised contain large quan- tifies of sugar and/or fat. On Saturday morning network programming, commercials and program promotions occupy about 15% of each hour (Barcus, 1977; Condry, Bence, & Scheibe, 1987). Weekday children's programs on independent channels have typically included about 12 minutes per hour (20%) of nonprogram content, including commercials (Barcus, 1977), and recent data suggest an increase above this level (Condry et al., 1987; Kunkel, 1987).

Programs on Public Television

Public television devotes a large proportion of its broadcast time to children's programs, and virtually all of those programs are informative. In one analysis, there were 84 children's programs (42% of those broadcast) on public television (Phillips et al., 1986). Children's informative programs were available 27 hours per week from 1981 to 1983 (Kerkman et al., 1987). Because funding for public broadcasting is not dependent on program ratings or audience size, public broadcasters are able to pursue programming targeted at more narrowly defined segments of the population, such as children of specific age groups. Mister Rogers' Neighborhood and Sesame Street are for preschool children; 3-2-1 Contact, Square One, Reading Rainbow, and Voyage of the Mimi are primarily for children in middle childhood; De Grassi Junior High, Up. and Coming, Freestyle, and Wonderworks are designed for early adolescents.

Programs on Cable

Nickelodeon and the Disney Channel broadcast a consid- erable amount of children's programming, some of it informative. For example, in 1983, Disney carried 22 hours of children's informational programs and over 50 hours of noninformational children's programs per week (Kerkman et al., 1987); other cable channels, such as Home Box Office and Showtime, provide children's programming in addition to their offerings targeted toward adults (Siemicki, Atkin, Greenberg, & Baldwin, 1986). The entertainment programs are more diverse than those from broadcast television and include game shows, movie reviews, and children's dramas. However, Nickelodeon and Disney are available only in homes subscribing to cable services that include these channels among their offerings, and Disney requires an additional fee beyond that for basic cable.

Summary

The structural organization and revenue sources for children's television have a direct impact on program content. Cross-national data support the conclusion derived from comparing American television outlets: Noncommercial sources of funding lead to more informational and edu-

cational programs. Profit-oriented, advertiser-supported TV is heavily oriented to entertainment (Murray & Kip- pax, 1981; T. M. Williams, 1986).

Public Policy We stated initially two goals of public policy in this domain: to promote programming that serves the diverse needs of children for education, entertainment, aesthetic appreciation, and knowledge about the world, and to protect children from content and advertising practices that exploit their special vulnerability. At the federal level, both regulatory decisions and public policies designed to stimulate production and distribution of diverse programs can be important.

The principal legal basis for federal regulation is the Communications Act of 1934, establishing that the airwaves belong to the public. Although a broadcaster (i.e., station) is granted "free and exclusive use" of a particular frequency for a fixed period of time---currently 5 years-- the broadcaster is required in return to serve in the "public interest, convenience, and necessity" (Communications Act of 1934, p. 51). The Federal Communications Com- mission (FCC) is the agency charged with overseeing broadcasters.

Policies to Promote Diverse and Beneficial Content

In 1960, the FCC identified children's programs as one of 14 program types usually necessary in order for broadcasters to meet their public interest obligation (FCC, 1960). In 1974, the Commission further elaborated its policy, saying that each broadcaster was required to make a "meaningful effort" to provide programming for "both preschool and school-aged children" (FCC, 1974, pp. 39397-39398) and that programs were to air during both weekday and weekend periods when children were likely to view.

In 1979, the FCC Children's Television Task Force evaluated compliance with that 1974 policy statement. The task force addressed three areas of concern about program content, finding that (a) the total time devoted to children's programs was insufficient, (b) there was too tittle educational, informational, or age-specific programming, and (c) children's programs were concentrated in a few time periods. Several possible solutions were proposed for consideration. One of these was a requirement for a minimum amount of educational and informative children's programming (FCC, 1980).

Marketplace solutions. The FCC ultimately declined to take any action, arguing that expanded children's programming would be provided by cable and other new communication technologies (FCC, 1984a). The Com- mission's reasoning was that with a greatly increased number of broadcast outlets, competition would lead to specialized programming for particular audiences, in- ciuding children. In recent years, the FCC's policies have relied consistently on marketplace competition rather than government regulation as the appropriate method to promote content diversity (Fowler & Brenner, 1982). Therefore, no action was taken on the 1980 proposal that


the FCC engage in a rulemaking procedure for children's programming until pressure was brought through the courts. In 1983, the FCC formally closed the children's television docket (FCC, 1984a).

The deregulatory posture of the FCC was carried further in 1984 with a comprehensive deregulation order removing virtually all guidelines on general program content and eliminating guidelines limiting the amount of advertising on programs for children and adults (FCC, 1984b). Although this order had wide-ranging implications for children's programming, it included no consideration or evaluation of its potential impact on the child audience.

These rulings included a major change in defining the public interest obligations of broadcasters to children. The FCC declared that although it expected the child audience to be served by broadcasters, stations might take into account other sources of children's content in their markets. The responsibility to serve children's interests was to be shared by all broadcasters in a particular market rather than required of each individual licensee. Content available on public television, cable, pay television, sat- ellite, and even on commercial videocassettes could relieve individual stations of any responsibility to program for children.

This decision raises significant issues of equity. Ac- cess to many of these alternative sources is much greater for the affluent than for lower income urban and rural families. We noted earlier that low-income and minority children are particularly heavy users of television and that they rely on it for information and education as well as for entertainment. Yet these are the viewers most likely to be limited to a narrow and inadequate set of programming options if commercial broadcasters are not required to meet their needs.

Program content requirements. A second major policy option is to establish requirements for program content diversity. Several proposals have suggested requirements for a minimum amount of educational/informational programming, usually with some requirement that such programs be scheduled at times when children are likely to be viewing. For example, bills in- troduced in the House and Senate in 1983, 1985, and 1986 sought to require broadcasters to air a minimum daily or weekly amount of educational and informational programming for children. In 1988, both houses passed a watered-down version of these bills that required broadcasters to meet the educational needs of children with their overall programming. However, the President subjected it to a pocket veto.

The major purpose of such proposals to require educational and informational content is to guarantee broadcast space for innovative programs. If every broadcaster was required to carry a certain amount of educational or informative programming, no one station would be at a competitive disadvantage for doing so. Good quality programming is often more expensive to produce than commercial fare. The production process usually includes identifying learning goals and interactions among research

and production staff on the best ways to achieve these goals. Concurrent with program creation and production is formative evaluation--assessing how comprehensible (as well as entertaining) the programs are to the targeted age groups. Whenever possible, summative evaluation also occurs, assessing the program's effectiveness in achieving the initial goals. Consequently, it usually costs more for broadcasters to purchase informational programming. This is particularly true currently, when such programming competes with product-related programs subsidized by toy companies and bartered by them to stations (Kun- kel & Watkins, 1987). Thus, without regulation the "free market" provides little or no space for diverse and innovative children's programming.

Government funding. One critical element in any policy solution is finding ways to finance high-quality, diverse television productions for children. Program content requirements might stimulate commercial production of such programs, but the record thus far indicates that most educational and informative programs are produced outside the advertiser-supported, commercial system. Therefore, significant attempts to increase the diversity of children's programs have focused on increasing funds for public television.

Government monies have financed a large number of educational programs for children. Through the Cor- poration for Public Broadcasting, federal funds help to support public television broadcasts and production. However, for the responsibilities it assumes, public broadcasting is significantly underfunded. Only about 15% of the funds for public broadcasting come from the

,federal government; the rest is provided by state and local governments and by viewer and corporate contributions (Watkins, 1987). Public broadcasting receives less than half of the $590 million recommended as a minimum annual federal contribution in a 1979 evaluation (Car- negie Commission on the Future of Public Broadcasting, 1979). Despite strong bipartisan Congressional support for public broadcasting, the Reagan administration sys- tematically cut funds through minimal budget recommendations and vetoes of funding legislation and at- tempted rescission of monies already approved.

Agencies in the government, including the National Science Foundation, the National Endowment for the Arts, the Bureau of the Handicapped, and the Office of Education, have funded production of many of the educational programs produced in the 1970s and 1980s (e.g., 3-2-1 Contact, Sesame Street, Freestyle). Again, the funding activity in these agencies declined significantly after the mid-1970s (FCC, 1979).

Most European countries fund television production and broadcasting at least partly by user fees imposed on television sets (Murray & Kippax, 1981). In this country, taxes specifically designed to produce revenue for television production have been periodically proposed but not adopted ("NAB Suggests Tax," 1987). Recently, a proposal was defeated in the Senate that would have levied a tax on the sale of commercial broadcast properties; the resulting funds were to have supported public broad-

428 February 1989 • American Psychologist

casting ("Transfer Tax," 1987). Tax incentives for corporate contributions to production have also been proposed.

Removing barriers to formation of programming codes. Before 1982, broadcasters had a voluntary set of codes governing both programming content and advertising practices. However, any industry-wide guidelines can be interpreted as violations of federal antitrust laws. In 1982, a consent decree eliminated the National As- sociation of Broadcasters' (NAB) self-regulatory advertising guidelines; the voluntary programming guidelines were subsequently abandoned. For the past several years, bills have been considered in the Congress that would exempt broadcasters and cable companies from antitrust restrictions that prevent them from developing industry codes to regulate programming and advertising to children. However, this legislation has not yet been adopted by both houses of Congress.

Generating and publicizing information about children's television. Government agencies play an important policy role by generating knowledge and publicizing important issues about children's television through funding research, issuing reports, holding Congressional hearings, and the like. The 1972 report to the U.S. Sur- geon General (Surgeon General's Scientific Advisory Committee on Television and Social Behavior, 1972), the hearings to examine this research (U.S. Congress, 1972), and the 1982 National Institute of Mental Health update (Pearl et al., 1982) have generated important knowledge and have served to keep the issue on the public agenda (Rowland, 1983). Since 1952, at least 20 Congressional hearings have focused on children and television, and countless others, such as the FCC oversight hearings, have raised significant aspects of the issue (Watldns, 1988). Hearings and reports generate knowledge, publicity, and debatemthey also alert the broadcasting industry to at- tend to its responsibilities to the public interest.

For the most part, government attention to children's television has lacked continuity over time. i-Iearings and reports often occur on a one-shot basis, usv ally generated by public pressure and/or particular officials who are concerned about the topic. More effective and consistent action might result if some structure like a National Cen- ter for Children's Television (Rubiustein, 1981) or a Na- tional Endowment for Children's Television (Heinz, 1983) was established. Such a center could serve as a research clearinghouse; it could stimulate, evaluate, and fund proposals for creative children's programming; and it could serve as a policy arm or advocate for quality children's television.

Policies to Protect Ckildren Against Harmful Effects of Television

Although there has been much public concern about the negative effects of violence, explicit sex, and social ste- reotyping, public policy solutions to these problems are difficult to imagine in the United States. Hearings and dissemination of information are the major public activ-

ities designed to limit harmful television content. It is difficult if not impossible to devise more active or coercive governmental actions that do not conflict directly with the First Amendment guarantee of free speech.

Advertising to children is another matter. There have been active research and policy initiatives concerning children's advertising since 1970. Research on advertising to children has been closely tied to appfied concerns with obvious implications for public policy. Policymakers moved relatively swiftly in the early 1970s to enact reg- ulations restricting television advertising to children on the basis of two primary types of findings.

Discriminating programs from commercials. Once evidence became clear that most children up to about age 4 to 5 experience great difficulty in discriminating program from commercial content, the FCC (1974) established what it called the "separation principle." The Commission held that broadcasters must maintain a clear separation between these two types of content in order to simplify the task of recognizing commercial messages. Three specific applications of the separation principle were established: (a) separation devices (e.g., "We'll be right back after these messages") were required before and after all commercial breaks in children's programs; (b) host-selling was prohibited--characters appearing in children's programs could not also appear in commercials placed within or adjacent to their programs; and (c) the promotion of products incorporated within the body of the children's program content was prohibited. 2

Understanding persuasive intent. Research evidence also indicated that most children up to the age of about 7 to 8 years failed to recognize the persuasive intent that necessarily underlies all television advertising and thus were uniquely susceptible to its influence. Accordingly, the FCC (1974) implemented restrictions on the amount of advertising during children's programs, limiting such messages to 12 minutes per hour on weekdays and 91/2 minutes per hour on weekends. 3 Given the evidence at hand, the most effective means of protecting children's welfare would have been to ban advertising directed to them entirely. This option has been dismissed by the FCC on the grounds that such a prohibition of advertising to children would lead to the disappearance of all children's programming because there would be no sources of revenue available to support program production costs (FCC, 1986).

Soon aRer these 1974 policies were implemented,

2 These policies are not FCC rules, which require absolute broadcaster compliance, but are instead guidelines, which inform broadcasters of the criteria that will be used to evaluate their performance when applying for license renewal. Stations that do not comply with guidelines must show cause during their renewal proceeding as to why they have failed to do so. Though they do not carry the same legal standing, guidelines tend to be treated by broadcasters with the same degree of respect afforded to rules.

3 The limitations were phased in gradually, and the figures cited here reflect only the fully implemented criteria. Like the policies arising from the separation principle, the ceilings on content of advertising to children were implemented as guidelines rather than rules.


the Federal Trade Commission (FTC, 1978) launched a thorough, intensive investigation of advertising to children. The FTC proposed banning or severely restricting television advertising to children too young to recognize its persuasive intent (below age 8) on the grounds that advertising is inherently "unfair" to children. It also recommended limiting advertising directed to the 8-11-year- old audience. However, in 1980, the Congress effectively terminated the FTC proceeding by eliminating the power of the FTC to rule on "unfair" advertising practices. In 1981, the FTC ended its proceeding with the conclusion that no workable strategy was available to remedy the problems involved in television advertising to children (FTC, 1981; Liebert & Spratkin, 1988).

In the last few years, the FCC has dismantled several protections for child viewers. As noted earlier, the 1984 deregulation order eliminated the FCC's ceiling on the amount of commercial time during all programs, including, by default, programs for children. Without comment or justification, the FCC also cast aside its restriction on product-related programs, which it later praised as an "innovative technique to fund children's programming" (FCC, 1985, p. 713). Because the deregulation order seemed to give little or no thought to the impact on the child viewer, a 1987 U.S. Court of Appeals order directed the FCC to reconsider its decisions lifting these two reg- ulations. As this article went to press, the Commission was still reviewing the evidence it has gathered in a formal Notice of Inquiry (FCC, 1987) to help determine its re- sponse to the court order.

Evaluation of policy. Several years of deregulation have demonstrated that the marketplace does not effectively regulate advertising to children. Quite the opposite. In lifting its restrictions on the amount of advertising, the FCC argued that stations would lose audiences if they aired too many commercials; the number of commercials would be limited to maintain a competitive advantage. With marketplace mechanisms operating effectively, there would be no need for governmental interference to limit commercial content.

One hardly needs to be a child development expert, however, to recognize that such logic does not apply to children. Children enjoy watching commercials, at least partly because of sophisticated production techniques. And even if child viewers rebel against a glut of commercialism, what choices exist when they change the channel?

Since the FCC recently legitimized product-related programming for children--the so-called "program- length commercials"--this genre has quickly moved to dominate the marketplace of children's television (En- glehardt, 1987; Kunkel, 1988b). These programs prolif- erate because they can offer broadcasters more attractive economic arrangements (e.g., profit-sharing) than their non-product-related competition. Of course, the reason they can provide such incentives is that the shows them- selves are tantamount to commercials and generate huge sales of licensed products, sometimes in the neighborhood of hundreds of millions of dollars (Diamond, 1987; Pe-

cora, 1987). In effect, much of children's television now has 100% advertising.

Barriers to Effective Policymaking

Although policy efforts in children's television have produced some positive effects over the years, we have not fully achieved the goals of promoting diverse programming or protecting children from harm. The reasons for our nation's difficulty in formulating effective policies are complex, but two major issues stand out.

First Amendment issues. Any effort to control or regulate television content raises questions about violations of First Amendment rights. Broadcasters, journal- ists, and civil libertarians often congregate in opposition to any form of content regulation. However, the courts have generally viewed the First Amendment as a protection of citizens' access to diverse sources of information and have held that it does not prevent the government from requiring content-specific programming (Watkins, 1987). In fact, one could argue that control of content by a small number of commercial outlets violates other citizens' First Amendment rights.

In a similar vein, broadcasters argue that if they are required to program for children, similar requirements might be imposed for other audiences. Yet there are many areas in which society has singled out children for their special needs or for special protection: child labor laws, restriction on purchasing alcohol and tobacco, mandatory education, seat-belt and child-restraint laws, and many others. Most of these policies are based on the recognition that children have special needs and vulnerabilities; the society must afford them ample protection and oppor- tunity for growth. Such regulation has not expanded to encompass other groups.

lndustry opposition. The major barrier to regulation has been opposition by broadcasters, who have developed a powerful and effective lobbying force. For example, they helped to raise a $30 million "war chest" to oppose the 1978 FTC efforts to regulate children's advertising (Lie- bert & Spratkin, 1988).

Broadcasters have been less consistently opposed to policies based on alternative funding than to regulation. At one point, the NAB contemplated efforts to raise money for public television in order to supply needed children's programming ("Closed Circuit," 1985).

The problem will not be solved by blaming broadcasters. They are behaving rationally within the context of a profit-oriented system. They are caught in a difficult bind. Their principal goal is profit in a competitive industry. Many of them care about the quality of their products and about their effects on children, but high- quality children's programming is expensive and risky. The most profitable form of children's programming is geared to the goals of the advertisers to whom broadcasters sell their audiences.

The problem is the commercial system by which most American television is produced and distributed. Our analysis of programming in the United States and abroad makes it clear that diverse, educational, infor-

430 February 1989 • American Psychologist

mational programming is not easily generated in an advertiser-supported system. Other sources of funding are needed that permit the needs of the audience rather than the needs of the advertiser to come first.

Policy Recommendations

Program content. The most promising policy to ensure diversity and quality is some quantifiable requirement for educational and informational children's programming on every broadcast outlet. Such a requirement could stimulate production and experimentation among commercial broadcasters. It could provide broadcast outlets for many creative producers who complain that they cannot sell good children's programs in a market occupied largely by product-oriented cartoons. Proposals for such a requirement have been discussed since the early 1960s; it is time that we tried it.

Policies are needed to generate funds for production and broadcasting outside the advertiser-supported system. We need a strong, well-funded public broadcasting system that has a consistent, predictable source of revenues allowing for long-term planning. Some of those funds must be provided directly by the government, but we should continue to explore other avenues for generating revenues for public television. If cable and videoeassettes are to supply diversity, then some methods need to be found to make these alternative media sources available to lower- income children, perhaps through public libraries and schools. Ways must also be found to make creative educational videos comparable in cost to those currently subsidized by toy companies.

Advertising. The most sound policy for our nation's children would be to ban advertising from children's programs altogether. If such a ban was combined with a requirement for broadcasting a minimum amount of children's programs, then children's programs would not disappear. In all likelihood, the resulting programs would be more diverse because they would not be oriented to product sales. Requiring programs and not allowing advertising can be justified as "'the price of doing business" for those fortunate enough to be awarded use of the scarce and profitable public resource, the television airwaves.

Several more immediate first steps are recommended. The FCC should reinstate the long-standing policy limiting the amount of commercial content directed at children. It should also return to its previous proscription of product-related programming for children, which originated as one application of the separation principle. It makes little sense to rescind one application of this principle while continuing to uphold the others (e.g., requiring separators, prohibiting host-selling).

Once these actions are taken, the protection afforded to children will return to the level established in the 1970s, not exactly a major step forward. More can and should be done. For example, program/commercial separation devices often are not used by broadcasters (Fontes, 1979) or are ineffective (e.g., Palmer & McDowell, 1979). The FCC should require more carefully crafted separators with demonstrated effectiveness (Ballard-Campbell, 1983).

Second, a limit on the use of popular children's program characters in television advertising should be considered. Children's trust and affection for popular characters should not be used for commercial exploitation.

Research and information. Finally, continued government support is needed for research examining children and television advertising. The 1982 NIMH update volumes expanded the research agenda beyond the narrow confines of television violence and aggression and made clear the need for more knowledge about a wider range of issues and content. The National Science Foundation's 1977 overview of the children and television advertising literature should be revisited and supplemented with additional empirical work. Studies in the realm of advertising to children are often rejected by traditional funding channels as atheoretical, but there are plenty of research questions in this area still to be resolved. For instance, there is almost no direct evidence on the impact of product-related programming on child viewers. Policymakers at the FCC have offered this lack of knowledge as an explanation for their failure to regulate such content (FCC, 1985), although the plethora of research evidence in other areas of television's impact on children has not always moved the Commission to action, either.

For the Future Throughout this essay, we have discussed the actions of government agencies as though they occurred in a social vacuum. Most of the actions of the FCC and the courts regarding children's programs have resulted at least partly from initiatives taken by citizen action groups, most no- tably Action for Children's Television, professional organizations, and others. In part, the policy dilemmas sur- rounding children's television have resulted from the fact that a new medium, television, was rapidly disseminated without time for adequate planning or public debate about its role in the society. Television simply adopted the commercial, advertiscr-supported system already in place for radio. Cable channels, because they do not use the public airwaves, are not under the same obligation to serve the public interest as broadcast television. Other technological changes have occurred and will continue to occur. Citizens and policymakers should begin to be proactive rather than reactive. If we plan ahead, and if we continue to encourage public involvement in the policy process, more effective policies serving the needs of the public can be formulated and implemented before rather than after problems arise. Initiative, oversight, publicity, and legal actions by citizens are essential to any policy debate and action on the future of children's television.

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