issued a joint filing to the FCC in September 2005 to urge against the "far-reaching, burdensome and expensive" advertising rules, with Disney also suing over the regulations as being a violation of freedom of speech. On December 16, 2005, the FCC chose to delay the new regulation to March 6, 2006, in order to allow time for further discussion. They were implemented in September 2006. 2019 changes FCC commissioner Michael O'Rielly has considered the educational programming regulations to be outdated. Citing the wider variety of platforms available (including cable networks and digital platforms), he stated that "with today's dynamic media marketplace there are very little, if any, additional benefits provided by the Kid Vid rules". O'Rielly also argued that the "onerous" nature of the regulations were also making stations reluctant to air other, more viable programs on Saturday mornings, such as newscasts and sports. In July 2018, the FCC issued proposals regarding changes to the rules, including removing the requirement that a program must be regularly scheduled and at least 30 minutes in length, providing the option for all of a station's E/I programming to air on a subchannel rather than the main signal, allowing stations to organize or sponsor "non-broadcast" initiatives in lieu of airing educational programming, and replacing the quarterly report with an annual report. O'Rielly felt that the 30-minute minimum length "killed off shorter, high-quality programs that were once popular and educational", and does not reflect current viewing habits. A group in favor of maintaining the existing policies, which included the Benton Foundation, Campaign for a Commercial-Free Childhood, and Common Sense Kids Action, among others, issued a letter of opposition to the FCC. They disagreed with O'Rielly's assessment that non-broadcast platforms "provide significant educational programming for children", and argued that broadcast television was still widely viewed by children, and that not all families have access to non-broadcast media. On June 19, 2019, the FCC issued its proposed rule changes: while the basic minimum will remain intact, the earliest time allowed for E/I programming was moved up to 6:00 a.m. local time. Furthermore, a limited amount of public service announcements and short-form programming will be allowed to count as E/I, and stations will be allowed to schedule up to a third of the required programming on its digital subchannels. As a consequence of the latter aspect of the rule changes, the requirement to place E/I programming on every