- Special Counsel
December 3, 2012 FCC EEO Deadlines
Certain radio and television stations face an upcoming Federal Communications Commission (FCC or Commission) Equal Employment Opportunity (EEO) annual reporting deadline on Monday, December 3, 2012:
Annual EEO Public File Report
Radio and television station employment units (SEUs) located in Alabama, Georgia, Colorado, Minnesota, Montana, North Dakota, South Dakota, Connecticut, Maine, Massachusetts, New Hampshire, Rhode Island and Vermont with five or more full-time employees must prepare and place in their public inspection file(s) and post on their website(s) belonging to each station in the SEU by Monday, December 3, 2012 an annual EEO Public File Report (PFR). (All full-power and Class A television stations must also upload the PFR to the station's online public inspection file hosted by the FCC.)
The PFR should summarize the SEU's recruitment activity from December 1, 2011 through November 30, 2012, including full-time positions filled, the recruitment sources used to advertise those job openings and the total number of interviewees and hirees produced by each recruitment source. The PFR must also include a summary of the SEU's recruitment initiatives.
The next round of broadcast license renewal applications are due by December 3, 2012 as well, which requires the filing of this key EEO report for certain radio and television stations:
FCC Form 396 Broadcast EEO Program Report
Radio stations in Colorado, Minnesota, Montana, North Dakota and South Dakota as well as television stations in Alabama and Georgia must apply for license renewal on or before Monday, December 3, 2012. A critical component of the Commission's license renewal process is the Form 396 Broadcast Equal Employment Opportunity Program Report, which must be submitted to the FCC, electronically, prior to the filing of the Form 303-S Application for Renewal of Broadcast Station License. The Form 396 requires applicants to report discrimination complaints and, for SEUs with five or more full-time employees, to submit PFRs for 2011 (covering December 1, 2010-November 30, 2011) and 2012 (covering December 1, 2011-November 30, 2012). Once filed with the FCC, the Form 396 must be placed in the public inspection file(s) belonging to each station in the SEU. (In the case of full-power and Class A television stations, the Form 396 must be uploaded to the station's online public inspection file hosted by the FCC.)
If you would like a copy of our renewal primer, including information on the EEO component of the application, or should you have any questions about FCC EEO compliance, please contact the Wiley Rein attorneys listed below.