With the Martin Luther King Day holiday just passed, it seems appropriate to review the FCC’s EEO rules, which look to promote broad access to broadcast employment opportunities.  The FCC’s EEO rules no longer seek exclusively to promote minority employment, but instead seek to have stations reach out to all groups within the area they serve to try to attract people from diverse sources into broadcasting – rather than allowing stations to simply recruit through word-of-mouth and traditional broadcast sources (e.g. referrals from consultants and friends).  We have written about the FCC audit process by which it will review the EEO performance of approximately 5% of all broadcast stations each year (see, e.g. our articles here and here) and also about recent fines for stations that did not comply with the FCC requirements in specific areas.  With EEO review also expanding this year through the filing of FCC Form 397 Mid-Term Reports by radio station clusters with 11 or more full-time employees located in certain states (see the list of states on our Broadcasters’ Regulatory Calendar), it might be good to review the basics of the FCC’s EEO requirements.

The FCC requirements, beyond forbidding any station from engaging in overt discrimination, also requires broad outreach to a station’s community to recruit for open employment positions at any station, as well as efforts to educate the community about the duties of and qualifications for  positions at broadcast stations, whether or not a station has any job openings.  These requirements apply to any station employment unit (a group of commonly-owned stations serving the same general geographic area and having one or more common employees) with 5 or more full-time (30 hours per week or more) employees.  What do the outreach rules require of stations?
Continue Reading Reminder: A Broadcaster’s FCC EEO Obligations

The FCC has announced another round of EEO audits – looking at the compliance with the FCC’s EEO rules and policies of several hundred radio and TV stations across the country.  Those stations selected for the audit (see the list here) must provide the FCC with the last two year’s public inspection file reports, plus

I conducted a webinar on the FCC’s EEO rules for the Texas Association of Broadcasters on November 30, 2010.  In conducting the webinar, I reminded broadcasters of the many ways that their EEO compliance can be monitored by the FCC – either through EEO random audits, through mid-term EEO Reports on FCC Form 397 (which were filed