Throughout the year, NYSBA receives a lot of questions regarding EEO obligations. The FCC’s obligations apply to stations with 5 or more full-time employees. They go beyond traditional nondiscrimination laws and require stations to take affirmative steps to reach out to the community. Noted FCC attorney David Oxenford has provided a basic outline describing local station’s EEO obligations. He states:
“Beyond the general requirement that all broadcasters (and all other businesses) avoid discrimination in hiring, promotion, and all other employment practices, the FCC imposes additional obligations on radio and TV stations that are part of “employment units” with 5 or more full-time employees. An employment unit is defined as a station or commonly controlled cluster of stations serving the same general geographic area that share at least one employee. Full-time employees, for FCC purposes, are employees who work at least 30 hours per week.”
Remember, due to technical issues on the FCC’s web portal, New York stations must file their annual EEO Public File reports by February 28, 2023.
You can see David Oxenford’s analysis of the basic EEO obligations here.