- Special Counsel
June 2, 2014 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, June 2, 2014:
Annual EEO Public File Report
Radio and television station employment units (SEUs) located in Arizona, Idaho, Maryland, Michigan, Nevada, New Mexico, Ohio, Utah, Virginia, West Virginia, Wyoming, and the District of Columbia with five or more full-time employees must prepare by Monday, June 2, 2014 an annual EEO Public File Report (PFR). The report must be placed in the public inspection file of each station in the SEU. For full-power and Class A television stations, this means the PFR must be uploaded to the station's online public inspection file hosted by the FCC. The PFR must also be posted on the website belonging to each station in the SEU.
The PFR should summarize the SEU's recruitment activity from June 1, 2013 through May 31, 2014, including full-time positions filled, the recruitment sources used to advertise those job openings, and the total number of interviewees and hires produced by each recruitment source. The PFR must also include a summary of the SEU's recruitment initiatives.
Certain broadcast license renewal applications are due on June 2, 2014. The license renewal process includes the filing of an FCC Form 396 Broadcast EEO Program Report, as described below:
FCC Form 396 Broadcast EEO Program Report
Television stations in Arizona, Idaho, Nevada, New Mexico, Utah, and Wyoming must apply for license renewal on or before June 2, 2014. A critical component of the Commission's license renewal process is the Form 396 Broadcast EEO 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 2013 (covering June 1, 2012-May 31, 2013) and 2014 (covering June 1, 2013-May 31, 2014).
Once filed with the FCC, the Form 396 must be placed in the public inspection file of each station in the SEU. For full-power and Class A television stations, the FCC will automatically place the electronically filed Form 396 in the station's online public inspection file. Stations should check their online public files to make sure the Form 396 is there.