North and South Carolina Radio Stations Up Next for EEO Mid-Term Reviews

The FCC has begun EEO reviews at the mid-point of station license terms, starting with radio stations.  In a public notice marking the start of the process, the FCC previewed how the process will work and the schedule for these reviews over the next four years.  Radio stations in North and South Carolina are up next, with reviews occurring on or about August 1^st.

Mid-term EEO reviews are required by the Communications Act and Section 73.2080(f)(2) of the FCC’s rules for TV station employment units with five or more full time employees, and for radio station employment units with eleven or more full time employees.  Reviews are matched to the date four years after the deadline for stations to file their license renewal applications.

EEO mid-term reviews are much like the reviews that the FCC’s Enforcement Bureau conducts during the license renewal process, where they review a station employment unit’s last two EEO public file reports (the current one and the one prior), and can request additional information from licensees as necessary.  The public notice indicates that FCC Enforcement Bureau staff will “inform licensees of any necessary improvements in recruitment practices to ensure that they are in compliance with the Commission’s EEO rules, and take other enforcement action as appropriate.”

Stations will not know when the staff is conducting the review, so being sure that the required EEO public file reports are uploaded timely is important.  If all is well, a station will not hear anything from the staff.  If there are issues, and the staff reaches out, responding completely and timely is critical.

For radio station employment units with five or more full-timers, the station online public file contains a “yes/no” question under a “Mid-Term Review” tab to disclose whether the employment unit has 11 or more full-timers.  That question should be answered when the annual EEO public file report is uploaded at the license mid-term point (i.e., fourth anniversary of the license renewal application filing deadline).  Those who answer yes will be subject to review. Those who answer no will not be.