The GAB recommends that members talk to their own counsel about any specific application of the FCC’s Public Notice and their own situations. The following is not a replacement for seeking your own counsel for your specific situation.
Georgia Primary Election- Tuesday, May 24th
- Rates apply April 9th through May 24th
Georgia Primary Run-Off- Tuesday, June 21st
- Rates apply the whole period
Georgia Election Day- Tuesday, November 8th
- 60 days prior to the election (Rates apply September 9th through November 8th)
Georgia Run-Off- Tuesday, December 6th
- Rates apply the whole period
*Day 45/60 is the day before election day
Stations have the choice of running or not running political spots on election day…BUT if spots are aired on election day the political rate applies.
Stations are reminded to have a Political Disclosure Statement on file that explains the station’s policies regarding political advertisements, such as election day inventory.
- For more information please reference the Political Broadcasting Guide from Wilkinson, Barker, Knauer, LLP.
- Is one of your on-air employees running for office? Here is everything David Oxenford says that you need to know. Equal Opportunities With On-Air Employees Running For Political Office
- Lowest Unit Rate Windows for Alabama, Georgia, and South Carolina.
To be exempt from Lowest Unit Charge calculations, any no-charge spots should not be added to any existing advertising package, nor should they be used as a direct incentive to buy a new package, e.g., no promises should be made to give 20 no-charge spots to an advertiser if they buy a paid schedule of 20 spots. The whole idea is that these spots are gifts to the advertiser to help them through the crisis, separate and apart from any commercial advertising transaction – while at the same time building goodwill for the station and helping the station fill holes in their inventory that have resulted from cancelled advertising. These gifts should be viewed as a temporary measure to get through the crisis. Because these no-charge spots cannot be tied to paid packages, stations should be careful on how they promote them to advertisers. Here are some ideas:
- Don’t call them “bonus spots” in any communications. Call them “goodwill spots” or “covid-19 spots” or something else, but you do not want to imply that they are a bonus associated with another package.
- Don’t give them in strict proportion to any existing contract, e.g., don’t give an advertiser 10% of its paid schedule in “goodwill spots.” That also makes it look too much like they are part of a paid schedule.
- Don’t list them on the same invoice or affidavit of performance that you provide to an advertiser showing its paid spots. There is no requirement that you provide specific documentation to advertisers of what you run, but if you do, keep it apart from the documentation of paid schedules.
- The spots should be preemptible. Don’t make any promises or guarantees of any specific number of spots that will be provided and remind advertisers that this situation is temporary and simply an expression of good will on your station’s part during these difficult times for everyone. You also should not guarantee any particular audience size or reach or frequency.
- While not required, having a unique message relating to the pandemic, or packaging multiple advertisers together in spots to promote local businesses, can help differentiate these spots from normal paid schedules that are still subject to LUC consideration.
Please click the link below to read the FCC’s Public Notice.