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Editor: Harry Jessell's column ("Commercial Overload," Nov. 6) cited the work of an assistant professor at Salem State College, Judi Cook, who made claims about the frequency of children's underwriting on PBS member station WGBH-TV Boston. The column also quoted the researcher's disparaging conclusions about public television.

Unfortunately Ms. Cook's research is based on faulty methodology and her conclusions are not supported by either the data she gathered, or by the laws and regulations governing underwriting on public television. Her observations were based upon only one "composite" day of programming, which was not representative of WGBH-TVS schedule. It did not include the
News Hour With Jim Lehrer
,
NOVA
,
Masterpiece Theatre

and other pillars of the PBS schedule.

Ms. Cook does acknowledge that "the total amount of time attributed to underwriting appears small (2%)" and "roughly half.of the underwriting spots included statements of support of PBS or learning in general." Such findings would seem to contradict her dire conclusions relating to public television's approach to children.

Underwriting on PBS member stations is fundamentally different from advertising on commercial television. Federal law and regulations prohibit underwriting messages on public television that contain a specific call to action, superlative descriptions, qualitative claims, price information or inducements to buy, all of which are staples of commercial advertising. PBS' guidelines for children's underwriting are even more strict, limiting messages to those which support public television or promote learning and education. In addition, national underwriting credits on PBS may not exceed 15 seconds and do not interrupt programs.

We are proud of our service to children, with a distinctive lineup of award-winning educational programs that kids love and parents trust. We would like nothing more than for noncommercial sources of funding to grow so that corporate support became less essential in paying for this unique and important service to children. Until that day arrives, however, we must and will continue to seek support for our children's programs from public-spirited corporations, and we will acknowledge their contributions in an appropriate manner as required by law.-
Tom Epstein, VP, communications, PBS, and Jeanne Hopkins, VP, communications,
WGBH-tv


Cook responds:


PBS may be following the rules governing public television, but that does not negate the fact that these underwriting spots look and feel very much like real commercials. Gone are the days of static images of


underwriters' logos. I challenge your readers to watch a few hours of children's television on PBS and draw their own conclusions as to whether or not children are being targeted as consumers.

Editor: I just finished reading ["Commercial Overload"]. I must take exception to your comparison of the underwriting spots on PBS children's programs to the type of advertising spots found around commercial children's fare. I would be astonished if you could find any public station in this country that aired 12 minutes of spots per hour as commercial stations are allowed to.

Judi Cook's assertion that "this appears to be the wave of the future," is, unfortunately, partially correct. Programming is expensive to produce. In an ideal world, we would find funding mechanisms to provide the dollars to produce quality children's entertainment that could run without annoying commercials.or disturbing underwriting spots.

Commercial broadcasters pay for their children's programming by selling commercials. At least public broadcasters have specific guidelines that limit the amount of time that may be devoted to underwriting spots in a program (usually 60 seconds for an one hour period), and some local stations sell additional underwriting around programs to defray their costs of acquiring that show. To compare that attempt to cover costs as the equivalent of the endless stream of commercials for ridiculously priced toys that children are encouraged to "need, want and demand" is ludicrous
.
-
Guy Serumgard, production manager,

WTVP(tv)
Peoria, Ill.

Editor: Harry Jessell's column raised some provocative questions about the state of U.S. children's media including, "Isn't there something creepy about grown-ups who go to work each day to study children so that they can better sell them stuff?" With all due respect, the answer is a qualified yes.

What really is creepy is that despite years of research examining young children's inability to distinguish programmatic from commercial content, we still have no significant national funding in place to provide our most vulnerable audiences with regularly scheduled educational programming. Public broadcasting stations, via their TV and online services, do yeoman's work on limited budgets-work that both crosses the screens and extends beyond them into the daily lives of children, parents, caregivers and teachers. To blithely damn public media's commitment to not only noncommercial distribution, but also noncommercial development, without acknowledging the economic realities of production and distribution is counterproductive.

At the end of his column, Jessell tells children's marketers to "get a real job." Here's a thought: With all the influence BROADCASTING CABLE and Cahners publications have in the industry, why not dedicate a regular feature to the research and information that could both drive noncommercial, creative development and attract the financing to produce and distribute it? Now, that's what I would call a real job.
-Alice Cahn, managing director, Interactive Media for Children, The Markle Foundation

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