License Renewal Notes

You may remember that when your station files for license renewal, it must also file an EEO program report to certify (i) that there have been no judicial/administrative proceedings instituted against the station for employment discrimination, and (ii) whether the station has fewer than five full-time employees.  If a station has five or more full-time employees, then the last two annual EEO public file reports must be uploaded, a person responsible for EEO compliance must be specified, and a narrative statement provided that describes how the station has carried out its EEO obligations.

So, in essence, stations with five or more full-timers are undergoing an EEO audit of sorts at license renewal time.  Of course, stations should always have their EEO house in order, but the two EEO public file reports that have to be submitted at license renewal time should be carefully scrutinized to be sure they do not create an issue.  If you have an EEO public file report uploaded to your station’s public file now, and it has issues, don’t delete it and upload a new one.  That will cause the original report to appear as though it were uploaded after the required deadline.  Instead, create an addendum and upload that separately.