Just a reminder to broadcast stations in certain states of several upcoming October obligations.  First up, October 3rd is the deadline for Radio Stations in Florida, Puerto Rico, and the U.S. Virgin Islands to file their FCC Form 303-S license renewal applications seeking a renewal of their broadcast licenses.  (See our earlier license renewal advisory here.)  Accordingly

The FCC has issued Notices of Apparent Liability against two radio licensees for apparent EEO violations at their respective station clusters. These NALs, issued on the next to last day of the FCC’s business year, are the first to address EEO violations in a year and a half. The common thread in both NALs was the licensee’s failure to properly recruit for new hires, relying primarily on "walk-ins" or referrals in lieu of the "wide dissemination" required for information about job openings.  In one case, where the licensee failed to widely disseminate information about 28 job openings, the FCC proposed a fine of $20,000.  In the other case, where the station owner was able to document recruitment efforts for some of its openings, the FCC proposed a fine of $8000 for the six jobs where the required recruitment efforts were found lacking. 

In the first NAL, the $20,000 proposed forfeiture was based on a finding that the licensee failed to properly recruit for 28 of the 29 full-time vacancies filled over a six year period.  Instead, the licensee relied on "walk-ins" and referrals for six vacancies, and used the Internet or on-air ads for 22 vacancies.  These methods alone do not constitute sufficient dissemination of job vacancies under FCC rules.  In a post last year, we explained that the FCC does not consider Internet advertising alone to be sufficient for recruitment purposes, and questioned whether that policy is appropriate in this day and age.

Continue Reading FCC Imposes Fines Up to $20,000 for EEO Violations

June 1st marks the deadline for two FCC EEO requirements.  First, by June 1st, radio and television stations located in Arizona, the District of Columbia, Idaho, Maryland, Michigan, Nevada, New Mexico, Ohio, Utah, Virginia, West Virginia, and Wyoming, must prepare their Annual EEO Public File Reports.  Specifically, stations or Station Employment