DA 22-854
Released: August 19, 2022
ENFORCEMENT BUREAU CONTINUES 2022 EEO AUDITS
On August 19, 2022, the Enforcement Bureau issued the second set of Equal Employment
Opportunity (EEO) audit letters for 2022 to randomly selected radio and television stations.
1
In accordance with section 73.2080(f)(4) of the Commission’s EEO rules,
2
the Enforcement
Bureau annually audits the EEO programs of randomly selected broadcast licensees. Each
year, approximately five percent of all radio and television stations are selected for EEO
audits.
A list of the radio and television stations included in this audit as well as the text of the
August 19, 2022 audit letter appears on the following pages, which are also located at the
Enforcement Bureau’s EEO headline page on the FCC website at:
https://www.fcc.gov/enforcement/eb-eeo/equal-employment-opportunity-headlines. The
deadline for stations to upload responses to their FCC-hosted online public inspection files is
October 7, 2022.
Please be advised that, in contrast with past practice, the Enforcement Bureau will no longer
issue letters to licensees upon completion of our review of audit responses. If questions arise
during staff review, the Enforcement Bureau will contact the licensee.
Enforcement Bureau Contact: [email protected] or 202-418-1450
1
On March 21, 2022, the Enforcement Bureau sent the first broadcast EEO audit letters for 2022. See
Enforcement Bureau Commences 2022 Broadcast EEO Audits, Public Notice, 2022 WL 850337 (EB 2022).
2
47 CFR § 73.2080(f)(4)
Federal Communications Commission
Washington, D.C. 20554
August 19, 2022
Dear Licensee:
1. In accordance with 47 CFR § 73.2080(f)(4), [Station call sign] (the Station) and all other
stations, if any, in the same station employment unit (defined by 73.2080(e)(2) as commonly
owned stations in the same market that share employees) (the Unit) has been randomly selected
for an audit of its Equal Employment Opportunity (EEO) program. A copy of section 73.2080 of
the Federal Communications Commission (FCC or Commission) rules can be found here:
https://www.fcc.gov/enforcement/eb-eeo/equal-employment-opportunity-rules.
2. Audit Data Requested.
(a) If the Unit has fewer than five full-time employees (defined by section 73.2080(e)(1) as
employees regularly assigned to work 30 hours a week or more), submit a response listing the
Unit’s full-time employees identified by job title (no personal names should be provided), the
number of hours each is regularly assigned to work per week, and a response to Question
2(b)(vi) below. Please also see Questions 3 and 4 below for guidance regarding brokers and
brokered stations.
(b) If the Unit employs five or more full-time employees, provide the following information:
(i) Copies of the Unit’s two most recent EEO Public File Reports, described in section
73.2080(c)(6).
(ii) For each station in the Unit that maintains a website, the website address. If the
Unit’s most recent EEO Public File Report is not posted on each website as required by
section 73.2080(c)(6), identify that website and explain why the report is not so posted.
If the Unit does not maintain a website, but its corporate site contains a link to a site
pertaining to the Unit, identify the corporate website address where the Unit’s most
recent EEO Public File Report is linked pursuant to section 73.2080(c)(6).
(iii) For each of the Unit’s full-time positions filled during the period covered by the
EEO Public File Reports noted above, or since acquisition of the Unit (if during that
period), the date of hire as required by section 73.2080(c)(5)(vi) as well as dated copies
of all advertisements, bulletins, letters, faxes, e-mails or other communications
announcing the position, as described in section 73.2080(c)(5)(iii). However, to reduce
the burden of responding to this audit, if a job notice was sent to multiple sources, the
Unit may include in its response: (1) documentation showing one such notice was sent,
(2) a list of the additional sources to which the notice was distributed, and (3) a statement
confirming notices to all additional sources used to announce the vacancy were retained,
2
as required by section 73.2080(c)(5)(iii).
3
Include, however, copies of all job
announcements sent to any organization (identified separately from other recruitment
sources) that has notified the Unit that it wants to be notified of the Unit’s job openings,
as described in section 73.2080(c)(1)(ii).
(iv) As required by section 73.2080(c)(5)(v), the total number of interviewees for each
vacancy and the referral source for each interviewee for all the Unit’s full-time vacancies
filled during the period covered by the above-noted EEO Public File Reports.
(v) Dated documentation demonstrating performance of the Unit’s recruitment initiatives
described in section 73.2080(c)(2) during the period covered by the above-noted EEO
Public File Reports, such as participation in job fairs, events with educational institutions,
and mentoring or training programs for staff. Specify the Unit personnel involved in
each recruitment initiative. In addition, provide the Unit’s total number of full-time
employees and state whether the population of the market in which any of the Unit’s
stations operates is 250,000 or more. Based upon these two factors and as required by
sections 73.2080(c)(2) and (e)(3) of the Commission’s rules, state whether the Unit is
required to perform two or four points worth of initiative activities within a two-year
period (measured from the date the stations in the Unit file their renewal applications and
the second, fourth, sixth and eighth anniversaries of that date). If the Unit performed
more than the required number of initiative activities, it may provide documentation for
only the required amount in its response, i.e., two or four points worth. If any
documentation provided appears inadequate, e.g., it is not dated or does not clearly prove
the Unit’s participation, the Commission may ask for additional verification.
(vi) Any pending or resolved complaints involving the Unit filed during the Unit’s
current license term(s) before any body having competent jurisdiction under federal,
state, territorial or local law, alleging unlawful discrimination in the employment
practices of the Unit on the basis of race, color, religion, national origin, or sex. For each
such complaint, provide: (1) a brief description of the allegations and issues involved;
(2) the names of the complainant and other persons involved; (3) the date the complaint
was filed; (4) the court or agency before which it is pending or by which it was resolved;
(5) the file or case number; and (6) the disposition and date thereof or current status.
Note that the Unit must report all complaints, regardless of their status or disposition.
(vii) In accordance with section 73.2080(b), during the Unit’s current license term(s) (or
since acquisition of the Unit (if during that period)), a description of the responsibilities
of each level of Unit management responsible for implementing Unit EEO policies and
how the Unit has informed employees and job applicants of its EEO policies and
program.
3
For on-air announcements that aired multiple times to advertise the position, you may send a traffic log summary
documenting the timeframe during which the announcements aired (in lieu of the log in its entirety). The log
showing all air dates and times may be required for additional verification, but the Unit need not provide with its
initial response.
3
(viii) In accordance with section 73.2080(c)(3), during the Unit’s current license term(s)
(or since acquisition of the Unit (if during that period)), a description of the Unit’s efforts
to analyze its EEO recruitment program to ensure that it is effective and to address any
problems found as a result of such analysis.
(ix) As required by section 73.2080(c)(4), during the Unit’s current license term(s) (or
since acquisition of the Unit (if during that period)), a description of the Unit’s efforts to
analyze periodically its measures taken to examine pay, benefits, seniority practices,
promotions, and selection techniques and tests to ensure that they provide equal
opportunity and do not have a discriminatory effect. If the Unit has one or more union
agreements, describe how the Unit cooperates with each union to ensure EEO policies are
followed for the Unit’s union-member employees and job applicants.
(x) If your entity is a religious broadcaster and any of the Unit’s full-time employees are
subject to a religious qualification as described in section 73.2080(a) of the rules, the Unit
should indicate that status in its response and provide data as applicable to its EEO
program. For example, for those full-time hires subject to a religious qualification, you
must provide only a record of the hire listed by job title and date filled, the recruitment
sources used for the opening, and the source that referred the person hired. No other
records are required for those hires. If five or more full-time positions are not subject to a
religious qualification, the licensee must maintain and provide all records for such hires
and complete the initiatives required under section 73.2080(c)(2). Otherwise, a religious
broadcaster is not required to perform these initiatives.
(c) Resumes, company training manuals, posters, employee handbooks, and corporate
guidebooks are not required to be submitted. If any of the information in these or similar
materials is relevant to any part of this audit letter, the Unit may provide a summary of any
content if it so wishes. If this audit requires an unusually burdensome volume of documentation,
the Unit may contact EEO staff at (202) 418-1450 prior to the response deadline to discuss
alternative ways of condensing the information.
3. Time Brokerage—Licensee of brokered station(s) receives audit letter.
If any station included in the Unit is subject to a time brokerage agreement, the licensee must
immediately forward a copy of this letter to the broker under each such agreement. Additionally,
if the Unit employs fewer than five full-time employees, the licensee must respond by providing
a list of the Unit’s full-time employees listed by job title, the number of hours each employee is
assigned to work, and a response to Question 2(b)(vi) above. If the Unit employs five or more
full-time employees, the licensee must respond fully to paragraph 2(b).
4. Time Brokerage—Broker receives audit letter.
(a) Broker receives audit letter from brokered station licensee. The broker must submit
information requested in 2(b) above concerning information relating only to its own full-time
4
employees working on behalf of the brokered station, as required by section 73.2080(f)(3) of the
Commission’s rules. If recruitment activity for those brokered station employees is maintained
with that of other stations licensed to you, and you lack the ability to separate the information,
submit information pertaining to both.
(b) Broker receives audit letter directly from Commission. If any station in the Unit is
licensed to you, submit information requested in 2(b) above for the Unit’s EEO program. If
recruitment activity pertaining to full-time employees working on behalf of another station you
broker is maintained with that of the Unit, and you lack the ability to separate the information,
submit information pertaining to both.
(c) Broker described in 4(a) or 4(b). If full-time employees at the station you broker,
combined with full-time employees at the Station (or Unit), total fewer than five, you need only
respond to this letter by submitting a list of full-time employees (identified by job title and
number of hours regularly assigned to work per week) for both the brokered station(s) and
subject Station as well as a response to Question 2(b)(vi).
5. Procedures.
(a) The response to this audit letter must be uploaded to the FCC-hosted online public
inspection file (https://publicfiles.fcc.gov/) belonging to each station in the Unit by no later
than October 7, 2022. The response should be placed in the EEO Audits, Investigations, and
Complaints subfolder in the online public file (found at EEO Records>>Additional
Documents>> EEO Audits, Investigations, and Complaints). Include in the response the
Station's Facility ID Number and an e-mail address of a Station representative.
(b) Any extension of time must be requested at least five days prior to aforementioned deadline
(via email to [email protected]), indicate the additional time the Unit believes it needs to
complete its response (not to exceed 45 days) and will be granted only upon a showing of good
cause. Unless and until an extension is granted, the original deadline remains in effect.
(c) If the Unit submitted an EEO audit response in 2020 or 2021 and/or the most recent license
renewal application(s) applicable to the Unit were granted after August 1, 2020, send an email to
[email protected] for additional guidance on whether a response is required. In the email,
provide a reference to the relevant filings/applications before the Commission.
(d) The accuracy and completeness of the response must be certified by an officer, partner or
other principal of the Station licensee or broker (as appropriate) or, in the case of a
noncommercial educational station, by an officer, member or other principal of the licensee.
(See 47 CFR § 1.16.). To knowingly and willfully make any false statement or conceal any
material fact in response to this audit is punishable by fine or imprisonment (see 18 U.S.C. §
1001; 47 CFR § 1.17), revocation of any station license or construction permit (47 U.S.C. §
312(a)(1)), and/or forfeiture (47 U.S.C. § 503). Failure to respond to this audit letter by the
deadline is punishable by sanctions in accordance with section 73.2080(g).
5
(e) As required by sections 73.3526(e)(10) (commercial stations) and 73.3527(e)(11)
(noncommercial educational stations), a copy of this letter and the response must be placed in the
FCC-hosted online public inspection file belonging to each station in the Unit. Consequently,
the response should not include personal information about individuals, such as social security
numbers, home addresses, or other personally identifiable information. The FCC does not require
that employment units retain such information in their records, or that such information be
provided in response to this letter.
(f) Upon receipt, audit responses will be reviewed for completeness. If any questions arise or
there are missing materials, EEO staff will contact you. The Enforcement Bureau no longer
issues letters to licensees upon completion of our review of audit responses.
Should you have any questions, please contact EEO Staff at [email protected] or (202) 418-
1450. Thank you for your cooperation.
Sincerely,
/s/ Elizabeth Goldin
Elizabeth E. Goldin
Assistant Chief, Investigations & Hearings Division
Enforcement Bureau
AUGUST 19, 2022 BROADCAST EEO AUDIT
RADIO & TELEVISION STATIONS
CALL SIGN
SERVICE
CITY OF LICENSE
STATE
FACILITY ID
KBVU
DTV
EUREKA
CA
58618
KCAT
AM
PINE BLUFF
AR
30138
KCRA-TV
DTV
SACRAMENTO
CA
33875
KEYT-TV
DTV
SANTA BARBARA
CA
60637
KGMD-TV
DTV
HILO
HI
36914
KHXT
FM
ERATH
LA
54650
KJEF
AM
JENNINGS
LA
8168
KJMH
FM
LAKE ARTHUR
LA
22962
KKPX-TV
DTV
SAN JOSE
CA
22644
KLLN
FM
NEWARK
AR
48700
KMTC
FM
RUSSELLVILLE
AR
58266
KMTR
DTV
EUGENE
OR
35189
KMVX
FM
MONROE
LA
48976
KNBC
DTV
LOS ANGELES
CA
47906
KOPB-TV
DTV
PORTLAND
OR
50589
KTLN
FM
THIBODAUX
LA
4219
KUAP
FM
PINE BLUFF
AR
6113
KVLO
FM
HUMNOKE
AR
28114
KVMA-FM
FM
SHREVEPORT
LA
53030
KZBL
FM
NATCHITOCHES
LA
7824
WAHP
FM
BELTON
SC
67212
WAKL
FM
GAINESVILLE
GA
48727
WANS
AM
ANDERSON
SC
21829
WASG
AM
DAPHNE
AL
51141
WAXS
FM
OAK HILL
WV
52789
WAYM
FM
SPRING HILL
TN
58421
WBAD
FM
LELAND
MS
28876
AUGUST 19, 2022 BROADCAST EEO AUDIT
RADIO & TELEVISION STATIONS
2
CALL SIGN
SERVICE
CITY OF LICENSE
STATE
FACILITY ID
WBEL-FM
FM
CAIRO
IL
87567
WBIN-TV
DTV
DERRY
NH
14682
WBMH
FM
GROVE HILL
AL
8607
WBNO-FM
FM
BRYAN
OH
72782
WBRI
AM
INDIANAPOLIS
IN
54706
WCFL
FM
MORRIS
IL
28304
WCNC
AM
ELIZABETH CITY
NC
49438
WCNR
FM
KESWICK
VA
52394
WCOG
AM
GREENSBORO
NC
74203
WCSR-FM
FM
HILLSDALE
MI
71298
WCSZ
AM
SANS SOUCI
SC
25235
WCYN
AM
CYNTHIANA
KY
71307
WCYN-FM
FM
CYNTHIANA
KY
71308
WDGG
FM
ASHLAND
KY
21436
WDLR
AM
MARYSVILLE
OH
29636
WDUR
AM
DURHAM
NC
36943
WEAA
FM
BALTIMORE
MD
43794
WEBK
FM
SOCIETY HILL
SC
175269
WEDH
DTV
HARTFORD
CT
13602
WEMM-
FM
FM
HUNTINGTON
WV
43860
WERC-FM
FM
HOOVER
AL
62278
WERM
AM
FAIRHOPE
AL
32848
WESP
FM
DOTHAN
AL
6891
WFCM
AM
SMYRNA
TN
58737
WFSQ
FM
TALLAHASSEE
FL
21803
WGLU
FM
WARNER ROBINS
GA
29129
AUGUST 19, 2022 BROADCAST EEO AUDIT
RADIO & TELEVISION STATIONS
3
CALL SIGN
SERVICE
CITY OF LICENSE
STATE
FACILITY ID
WGPL
AM
PORTSMOUTH
VA
69560
WGUO
FM
RESERVE
LA
70279
WHBC-FM
FM
CANTON
OH
4488
WHRP
FM
GURLEY
AL
22264
WHTH
AM
HEATH
OH
57937
WHTX
AM
WARREN
OH
70531
WIBL
FM
FAIRBURY
IL
86178
WIGO
AM
MORROW
GA
60918
WINW
AM
CANTON
OH
8549
WIRO
AM
IRONTON
OH
61685
WIVT
DTV
BINGHAMTON
NY
11260
WJCF
AM
MUNCIE
IN
1724
WJCK
FM
PIEDMONT
AL
28334
WJER
AM
DOVER-NEW
PHILADELPHIA
OH
73134
WJZ-FM
FM
CATONSVILLE
MD
1916
WKAT
AM
MIAMI
FL
43034
WKBH
AM
HOLMEN
WI
56617
WKCL
FM
LADSON
SC
10340
WKEY
AM
COVINGTON
VA
73157
WKFN
AM
CLARKSVILLE
TN
65202
WKGL-FM
FM
LOVES PARK
IL
38638
WKJN
FM
CENTREVILLE
MS
53025
WKKI
FM
CELINA
OH
60848
WKNK
FM
CALLAWAY
FL
42371
WLFL
DTV
RALEIGH
NC
73205
WLIJ
AM
SHELBYVILLE
TN
27632
AUGUST 19, 2022 BROADCAST EEO AUDIT
RADIO & TELEVISION STATIONS
4
CALL SIGN
SERVICE
CITY OF LICENSE
STATE
FACILITY ID
WLJN
AM
ELMWOOD
TOWNSHIP
MI
24603
WLKD
AM
MINOCQUA
WI
55210
WLKT
FM
LEXINGTON-FAYETTE
KY
29575
WLLX
FM
LAWRENCEBURG
TN
53664
WLRO
AM
DENHAM SPRINGS
LA
37815
WLYF
FM
MIAMI
FL
30827
WMMJ
FM
BETHESDA
MD
54712
WMOR-FM
FM
MOREHEAD
KY
73279
WMOV
AM
RAVENSWOOD
WV
24585
WMQM
AM
LAKELAND
TN
42369
WMRY
FM
CROZET
VA
6130
WMTD
AM
HINTON
WV
6013
WMVG
AM
MILLEDGEVILLE
GA
73302
WMVM
FM
GOODMAN
WI
59353
WMYM
AM
MIAMI
FL
12833
WNIA
FM
TARBORO
NC
172953
WNKW
AM
NEON
KY
37154
WNVM
FM
CIDRA
PR
1891
WNYI
DTV
ITHACA
NY
34329
WONC
FM
NAPERVILLE
IL
49179
WOVV
FM
OCRACOKE
NC
173549
WOWB
FM
BREWTON
AL
40428
WOWL
FM
BURNSVILLE
MS
79355
WPFC
AM
BATON ROUGE
LA
31172
WPNA-FM
FM
HIGHLAND PARK
IL
74177
WPNT
DTV
PITTSBURGH
PA
73907
WPRH
FM
PARIS
TN
93121
AUGUST 19, 2022 BROADCAST EEO AUDIT
RADIO & TELEVISION STATIONS
5
CALL SIGN
SERVICE
CITY OF LICENSE
STATE
FACILITY ID
WPXI
DTV
PITTSBURGH
PA
73910
WQAL
FM
CLEVELAND
OH
72889
WQKV
FM
WARSAW
IN
89586
WQNS
FM
WAYNESVILLE
NC
41008
WQOS
AM
CORAL GABLES
FL
74165
WQQB
FM
RANTOUL
IL
73229
WQSI
FM
UNION SPRINGS
AL
9782
WQXB
FM
GRENADA
MS
10672
WRAZ-FM
FM
LEISURE CITY
FL
61646
WREO-FM
FM
ASHTABULA
OH
54566
WRHD
FM
FARMVILLE
NC
26020
WROX
AM
CLARKSDALE
MS
11611
WRRG
FM
RIVER GROVE
IL
68153
WRSW
AM
WARSAW
IN
73968
WRUO
FM
MAYAGUEZ
PR
69434
WRVL
FM
LYNCHBURG
VA
37249
WSMR
FM
SARASOTA
FL
64255
WSRT
FM
GAYLORD
MI
1159
WTIL
AM
MAYAGUEZ
PR
40780
WTRT
FM
BENTON
KY
88122
WTVR-TV
DTV
RICHMOND
VA
57832
WUAT
AM
PIKEVILLE
TN
10397
WUMP
AM
MADISON
AL
39590
WUNL-TV
DTV
WINSTON-SALEM
NC
69360
WVEK-FM
FM
WEBER CITY
VA
14721
WVFL
FM
FOND DU LAC
WI
91710
WVIT
DTV
NEW BRITAIN
CT
74170
AUGUST 19, 2022 BROADCAST EEO AUDIT
RADIO & TELEVISION STATIONS
6
CALL SIGN
SERVICE
CITY OF LICENSE
STATE
FACILITY ID
WVJZ
FM
CHARLOTTE AMALIE
VI
62113
WWDC
FM
WASHINGTON
DC
8682
WWOG
FM
COOKEVILLE
TN
60780
WXGO
AM
MADISON
IN
17624
WYAL
AM
SCOTLAND NECK
NC
74223
WYCD
FM
DETROIT
MI
1089
WYCE
FM
WYOMING
MI
24773
WYPX-TV
DTV
AMSTERDAM
NY
13933
WYSU
FM
YOUNGSTOWN
OH
74434
WYXE
AM
GALLATIN
TN
3424
WZAP
AM
BRISTOL
VA
55004
WZEE
FM
MADISON
WI
41980
WZLA-FM
FM
ABBEVILLE
SC
60101
WZME
DTV
BRIDGEPORT
CT
70493
WZSR
FM
WOODSTOCK
IL
53505
WZWP
FM
WEST UNION
OH
74301
WZYQ
FM
MOUND BAYOU
MS
191535