John Garziglia Working with Broadcasters on FCC Equal Employment Opportunity (EEO) Improvement Proposal

WASHINGTON, DC—A coalition of 82 broadcasters is asking the Federal Communications Commission (FCC) to streamline certain Equal Employment Opportunity (EEO) rules to reduce what they call “burdensome paperwork” and create a more equitable playing field. Womble Bond Dickinson telecom attorney John Garziglia is working with the group of mostly small broadcasters. Inside Radio recently discussed their proposals.

Inside Radio said the broadcasters are proposing three EEO-related reforms:

• Require wide outreach for every fulltime broadcast station job, no matter how few employees the company has. The broadcasters’ group says this would help even the smallest stations cast a wider net in recruiting new employees, particularly for entry-level positions that may serve as a first step to a career in broadcasting.
• Examine a broadcast company as an entire entity, not on a station or cluster basis. The group of broadcasters notes that many radio stations are operated by out-of-market staff. So examining a company in its entirety, rather than on a station or market basis, gives the FCC more accurate information on radio station staffing.
• Reset the FCC’s small station exemption for EEO rules to reflect the number of employees that work at a company, not a specific station it owns. Current FCC rules require EEO filings for any broadcaster with five or more full-time employees. But the broadcasters’ group says this is a burden for small stations. Instead, they ask the FCC to raise the threshold to 50 employees, noting that, among other metrics, this is the same threshold the federal government uses to require companies to offer employee health insurance under the Affordable Care Act.

“There is nothing more sapping to a small broadcaster than EEO paperwork and documentation that it is not staffed to handle, knowing that its larger competition has an HR department handling such record-keeping,” the group writes in its July 18, 2019 Comments to the FCC .

Garziglia is quoted in Inside Radio as hoping the proposal will serve as a “starting point for a frank discussion for what works and doesn’t work in attracting a diversity of employees to broadcasting”.

Click here to read “Small Broadcasters Offer FCC Proposals To Improve EEO Enforcement” in Inside Radio.

John Garziglia represents radio and television broadcasters, offering personalized assistance in all areas of communications and telecommunications law including transactional and contract negotiations for broadcast station mergers and acquisitions, the securing of financing, governmental auctions of new frequencies, license renewals, new stations applications, facility changes, facility upgrades, licensing, and compliance with FCC rules, regulations and policies.

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