I never realized the tremendous educational value of "G.I. Joe," the television cartoon in which a battalion of soldiers heeds the battle-cry "Yo Joe!" to fight against an evil enemy.

I certainly never considered that the heroes in this cartoon "fight against an evil that has the capabilities of mass destruction of society," in a situation which shows "social consciousness and responsibility." At least that's a description of the show according to a broadcaster explaining the educational value of its children's programming.

Why, you may ask, would anyone attempt to assign educational value to "G.I. Joe," a perfectly friendly but educationally uninspiring cartoon hero?

The answer is that broadcasters' Federal Communications Commission (FCC) licenses are due for renewal, and according to a federal law passed in October 1990, known as the Children's Television Act, broadcasters must document on their renewal forms their efforts to meet some minimum standards for children's programming.

The standards are very minimal. According to the law, there may be no more than 12 minutes of commercials per hour of children's shows, and no more than 10 and a half minutes of commercials per hour on weekends.

Additionally, "as part of their obligation to serve the public interest, television station operators and licensees should provide programming that serves the special needs of children." Such programming may either serve the "cognitive/intellectual" or "social/emotional" needs of children. The law cites programs such as "The Smurfs" as examples of appropriate children's programming.

"The Children's Television Act has a long history. As early as 1960, the FCC identified children as one of its special interest groups, Ten years later, a group called Action for Children's Television (ACT) was formed to petition the FCC for higher programming standards.

In 1974, as a result of this petitioning, the FCC released a report concluding that broadcasters had a "special obligation" to serve children as a "substantive and important" group.

The report concluded that broadcasters needed better scheduling, elimination of host-selling and product tie-ins and a separation to delineate programs from commercials. The report also set the voluntary advertising and programming guidelines which were eventually adopted by the Children's Television Act.

The only check that the FCC enacted to regulate broadcasters was a space on the FCC license renewal form for broadcasters to describe their efforts to comply with the voluntary guidelines. In 1979 an FCC task force issued a Notice of Proposed Rulemaking that suggested that broadcasters were complying with the advertising guidelines but not with the voluntary guidelines.

All of these legislative efforts to protest children suffered a setback in the era of Reagan deregulation. In 1984, the FCC suddenly dropped its advertising time limits and, two years later, it removed its commercial guidelines.

When forced to reconcile its new position with past policies before a U.S. Court of Appeals, the FCC claimed that it had never set any firm guidelines and that broadcasters should regulate themselves.

The thinking behind this sort of deregulation was that "the market" would regulate television ads and programming. The idea was that if there were too many commercials or too many low-quality shows, the viewers would complain and effect a change.

The problem with this thinking is that children don't have the same voice to complain as adults do, and in fact they may not know what to complain about. Children have a hard time distinguishing between commercials and cartoons featuring the toys sold in commercials, and they often put faith in celebrities who, for example, tell them to "be like Mike."

More important, it is absurd to expect captains of industry to be concerned about the rights of children. In light of their history of the exploitation of children--for example, child labor during the Industrial Revolution--their is no reason to expect the television industry will stop exploiting children.