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FCC, 857  X -  F.2d 1556 (D.C. Cir. 1988) (Astroline); Dubuque T.V. Limited Partnership, 4 FCC Rcd 1999   (1989). The allegations, except for those of which official notice may be taken, must be   /supported by the affidavit of a person with knowledge of the facts alleged. 47 U.S.C.  309 (d)(1).  X-  4.` ` Submitted with the petition was a statement under penalty of perjury from the   kPresident of the Bloomington County, Illinois, branch of the NAACP. He states that he is a   -regular listener of WJBC(AM)/WBNQ(FM). We find that the declaration meets our requirements   for standing. Accordingly, we hold that the NAACP has petitioner status against stations  X4-  lWJBC(AM)/WBNQ(FM). See American Legal Foundation v. FCC, 808 F.2d 84 (D.C. Cir.  X-  1987); see also Petition for Rule Making to Establish Standards for Determining the Standing of  X-  a Party to Petition to Deny a Broadcast Application, 82 FCC 2d 89 (1980)(citing Warth v. Seldin, 422 U.S. 490, 511 (1975)).  X-   5.` ` Prima Facie Case. The NAACP derived its factual allegations from the licensee's   =EEO program and annual employment reports. Review of its allegations led us to conclude, as  X-  a threshold matter, that the NAACP presented a prima facie case demonstrating that unconditional  X|-  grant of the renewal applications would have been inconsistent with the public interest. See  Xe-  [Section 309(d)(1) of the Communications Act of 1934, 47 U.S.C.  309(d)(1); See also Astroline.  XN-  X7-  6.` ` Review of the NAACP's EEO allegations as well as the licensee's renewal   yapplications, opposition and inquiry response, however, leads us to conclude that there are no   Zsubstantial and material questions of fact warranting designation for hearing. In addition, we find   no evidence that the licensee engaged in discrimination. Thus, a grant of the renewal applications  X-  will serve the public interest. 47 U.S.C.  309(d)(2). See Astroline. However, we will impose appropriate remedies.  X"- 3III. DISCUSSION  X#-  Xh$-  7.` ` Section 73.2080 of the Commission's Rules requires that a broadcast licensee"h$0*%%(#"   refrain from employment discrimination and establish and maintain a program reflecting positive   and continuing efforts to recruit and promote qualified women and minorities. When evaluating   EEO performance, the Commission focuses on the licensee's efforts to recruit and promote   qualified women and minorities and the licensee's ongoing assessment of its EEO efforts. Such   <an assessment enables the licensee to take corrective action if qualified women and minorities are   "not present in the applicant pool. The Commission also focuses on any evidence of  Xv-discrimination by the licensee. See Sections 73.2080(b) and 73.2080(c).  XH-  8.` ` Review of the licensee's renewal applications, opposition and inquiry responses  X1-  reveals that the stations had 23 fulltime hiring opportunities, including 18 for upperlevel  X -  positions, from August 1, 1986, through August 1, 1989.eX  yO - j#X\  P6G;IP#эThe BloomingtonNormal, Illinois Metropolitan Statistical Area ("MSA") is 5.1% minority (3.6% Black and   1.5% other). The stations' 1983 through 1989 Annual Employment Reports list no minorities on fulltime staffs ranging from 43 to 51.e In its renewal applications,'  yO- #X\  P6G;IP#эIn its renewal applications, the licensee listed the number of hires occurring during the reporting year as   three. In an amendment filed January 10, 1990, the licensee changed that number to 27 total hires, of which 23 were   fulltime. We sent a second inquiry letter to the licensee requesting an explanation for this discrepancy. In its   response, the licensee contends that the inaccuracy was due to its misinterpretation of the information requested. The   -licensee believed that the form requested only the number of women and minorities hired for fulltime positions during the reporting year, not all individuals hired. ' the   xlicensee indicated contacting the following minority and general sources: the Illinois Broadcasters  X -  Association Minority Internship Program, the United Private Industry Council, the Pantagraph,  X -  Radio and Records Magazine, Illinois State University, Illinois Wesleyan University, Eastern   Illinois University, the Bloomington Human Relations Commission, the Illinois Department of   Job Services, the RadioTV News Directors Association and employee referrals. The licensee   jindicated that it received the following number of minority referrals from the following sources:  Xy-  Lthe Illinois Broadcasters Association Minority Internship Program (3), Illinois State University (1), the RadioTV News Directors Association (1) and employee referrals (1).  X4-  9.` ` In response to letters of inquiry requesting recruitment efforts data, the licensee   was unable to provide such information. It indicated that, prior to November 1988, it did not   keep any records of actual sources contacted for each vacancy. However, the licensee claims that  X-  <it contacted six recruitment sources on a regular basis, but not for every opening.q`  yO - /#X\  P6G;IP#эThe six sources included the Bloomington Human Relations Commission, the Illinois Department of Job   Services, the Illinois Department of Rehabilitation Services, the United Private Industry Council, the Occupational   JDevelopment Center and the Bloomington Chapter of the NAACP. Additionally, the licensee states that beginning  yOX"- / in November 1988, it sent job vacancy announcements to all six sources listed above. q Moreover, for   the period prior to August 1989, the licensee was unable to provide the number, gender and race  X-  >or national origin of those who applied or were interviewed for each position. The licensee"0*%%5"   -maintains that it was unaware of the recordkeeping requirements resulting from the Commission's  X-  adoption of Amendment of Part 73 of the Commission's Rule Concerning Equal Employment  X-  Opportunity in the Broadcast Radio and Television Services, 2 FCC Rcd 3967 (1987) (Broadcast  X-  jEEO).   yO4-  #X\  P6G;IP#эThe licensee contends that such detailed recordkeeping was not required by the Commission until August  yO-  of 1987, in Broadcast EEO. However, as we stated in NAB Report and Order, 4 FCC Rcd 1715 (request for  yO-  clarification of Broadcast EEO by the National Association of Broadcasters): "[T]he data we are asking licensees   to report should have been kept by licensees at least since 1976 to fulfill their reporting obligations as to recruitment  yOT-as well as their selfassessment obligations." Id. at 1716.  Nevertheless, the licensee was able to provide the referral sources for 12 of the 16 hires   that it made prior to November 1988. The following referral sources were used for these 12   Lhires: a general newspaper (7), employee referrals (4) and Illinois Job Service (1). Additionally,   \the licensee indicates that it knew the exact number of minority applicants for each position   <during the period under review. The licensee states that two Blacks applied for a clerical position   and one Black applicant was hired for an upperlevel position in the news department.   Furthermore, the licensee claims that for all of its news positions, including five of the 23 full  time vacancies, it contacted minorities who had placed advertisements with the RadioTelevision   \News Directors Association. The licensee also asserts that it met with minority students at   Illinois State University and wrote letters to minority degree candidates from Southern Illinois   University, encouraging them to apply for positions at WJBC(AM)/WBNQ(FM). However, the licensee did not receive any applications from these contacts.  X-  &10.` ` The NAACP contends that neither the licensee's 1982 nor 1989 renewal   applications reflect whether the licensee undertook an effective EEO program. Neither the 1982   nor 1989 EEO programs listed any minority organizations or schools as recruitment sources. The   NAACP argues that three of the six minority referrals listed in the 1989 renewal application may   =not have been referrals for fulltime positions because they were connected with an internship   program. According to the NAACP, most of the stations' referrals came from a daily newspaper   which generated 59 female referrals. The NAACP theorizes that if those 59 referrals represented   [half the applicants during the renewal year, then the licensee had approximately 120 applicants   and did little to diversify its applicant pool. The NAACP quotes the stations' 1975 through 1989   <Annual Employment Reports and surmises that the licensee's longstanding underemployment of   Mminorities may be due to the licensee's belief that it need not employ minorities on a regular   -basis. The NAACP argues that the licensee should have known that aggressive corrective steps   Zwere required based on its previous license renewals. Yet this is at least the second renewal term, according to the NAACP, in which the licensee has neither shown nor proposed any such steps.  XN-  X7-  11.` ` In response, the licensee first argues that the Commission should consider only the   Minformation quoted by the NAACP relating to the December 1, 1982, through November 30,   L1989, license term. It contends that precedent clearly indicates that when reviewing a station's   >record at renewal time the Commission will consider only the record during the license term"x0*%%"  X-  immediately preceding the filing of a renewal application. United Broadcasting Co., 100 FCC  X-  2d 1574, 1577 (1985); TeleBroadcasters of California, Inc., 58 RR 2d 223, 225 (Rev. Bd. 1985).   Second, the licensee contends that the facts quoted in the petition are incomplete and fail to   Lprovide an accurate reflection of its EEO practices. It states that it has employed minorities on   at least a parttime basis during each year of the license term and has undertaken efforts to   =recruit, employ and promote minorities even though the stations' applicable labor force is only   5.1% minority and few identifiable minority organizations exist in the BloomingtonNormal MSA.  X1-  }12.` ` The NAACP states that Bloomington Broadcasting Corporation (BBC), the parent   <company of the licensee, also owns three stations in Tennessee and Michigan against which the   <NAACP also has petitions pending. The NAACP requests that because BBC "displays a pattern   of systematic EEO noncompliance at its various stations" the Commission should consider when   .analyzing these stations' EEO records whether BBC has engaged in intentional discrimination.   In response, the licensee argues that the NAACP has failed to allege any facts showing intentional   jdiscrimination. In addition, the licensee contends that the inquiry responses it provided for its   \three stations in Tennessee and Michigan contained information establishing that no racial   discrimination had occurred at the stations. The licensee argues that because the NAACP's   allegations of discrimination are unsupported, "there is no reason for the Commission to depart   from its casebycase consideration of renewal applications filed by the BBC subsidiaries." We agree.  X-  _13.` ` There are no substantial and material questions of fact warranting designation for  X-  hearing. See Astroline. In this regard, we find no indication of employment discrimination   [because the licensee attracted, interviewed and hired minorities during its tenure. Under these circumstances, grant of renewal is appropriate.  X-  o14.` ` The record in this case indicates that the licensee recruited for only 12 of its 23   hires. As a result, it reported only three minority applicants. In addition, the licensee did not  Xe-  begin recruitment efforts with minority specific sources until the final year of its license term.Xe yO- M#X\  P6G;IP#эThe licensee is reminded that under our EEO Rule, 47 C.F.R. 73.2080, it has an obligation to recruit for   females and minorities for each vacancy. Inasmuch as WJBC(AM)/WBNQ(FM) neglected to recruit for 11 vacancies, female, as well as minority, employment was affected.   During the inquiry period, the licensee failed to gather information necessary for adequate self  assessment of its EEO efforts. The licensee was unable to provide the number, gender and race   or national origin of those who applied or were interviewed for each position until the end of the license term.  X-  215.` ` The sanction which we would ordinarily impose for the sort of deficiencies noted   Lhere is the issuance of a Notice of Apparent Liability ("NAL"). However, an NAL is barred by" 0*%%"   the applicable statute of limitations provisions of former Section 503(b)(6) of the   \Communications Act, as amended, 47 U.S.C.  503(b)(6), and by former Section 1.80(c)(1) of   the Commission's Rules, 47 C.F.R.  1.80(c)(1). Although the statute of limitations period was   yextended to cover the entire license term by an amendment enacted on October 27, 1992, in this  X-  case the thenapplicable threeyear statute of limitations period expired two months prior to the  X-  statutory extension, i.e., in August 1992, three years after the last evidence of violations in   iAugust 1989. Nevertheless, to ensure that the licensee conducts meaningful selfassessment and   Lmaintains an adequate EEO program, we will grant renewal and impose reporting conditions as  XH-set forth below.H yO -  #X\  P6G;IP#эIn order to facilitate the disposition of cases raising similar statute of limitations issues, the Commission   hereby delegates to the Chief, Mass Media Bureau, the authority to rule on cases in which the statute of limitations   of former Section 503(b)(6) of the Communications Act precludes the imposition of a forfeiture, notwithstanding   a finding of EEO noncompliance or Sections 0.283(a)(4) and (b)(1) of the Commission's Rules. Similarly, the   hBureau may rule on petitions for reconsideration of Commission actions where a petitioner correctly argues that the  yO -former statute of limitations precluded the imposition of a forfeiture for EEO noncompliance.#x6X@`7>FX@#р  X - }/IV. CONCLUSION ă  X -  216.` ` Upon review of the record, we find that grant of the renewal applications is in the   public interest. However, we will grant the renewal applications of WJBC(AM)/WBNQ(FM) subject to reporting conditions.  X- 6V. ORDERING CLAUSES ă  Xb-  17.` ` Accordingly, IT IS ORDERED that the Petition to Deny filed by the Illinois State   [Conference of Branches of the NAACP and its Bloomington County Branch (NAACP) against  X4-WJBC(AM)/WBNQ(FM) IS DENIED .V  X-  18.` ` IT IS FURTHER ORDERED that the license renewal applications for  X-WJBC(AM)/WBNQ(FM) ARE GRANTED subject to the reporting conditions specified herein. " X-  Q" 19.` ` IT IS FURTHER ORDERED that the licensee of WJBC(AM)/WBNQ(FM),   submit to the Commission an original and one copy of the following information on August 1, 1996: " Xe-  #6"   (a)` ` Two lists divided by fulltime and parttime job vacancies during the  XN-  #twelve months preceding July 1, 1996, indicating the job title and FCC job   #Tcategory, date of hire, the race or national origin, sex, and the referral   #source of each applicant for each job, and the race or national origin and   #sex of the person hired. The list should also note which recruitment" @0*%%"  X-sources were contacted;v`  yOy-#X\  P6G;IP#э Such a list might start: ` ` 1) News Director: Officials and Managers; Fulltime.  yO-3 Applicants:` ` 1 White female American Women in Radio and Television  yOa-` ` 1 Hispanic maleNational Hispanic Media Coalition  yO)-` ` 1 Black femaleNAACP   Sources contacted Local newspaper, American Women in Radio and Television, National Hispanic Media Coalition and NAACP. Selected Hispanic male (08/19/95)v `  X-  #(b)` ` A list of all employees as of the July 1, 1996, payroll period by job title   #and FCC job category, indicating fulltime or parttime status (ranked from   #Shighest paid classification), date of hire, sex, and race or national origin; and `  X_-  #(c)` ` Details concerning the station's efforts to recruit minorities for each   #8position filled during the 12month period specified, including   #Ridentification of sources used and indicating whether any of the applicants   #4declined actual offers of employment. In addition, the licensee may submit   #any information it believes relevant regarding the station's EEO performance and its efforts thereunder. `  X -  #20.` ` IT IS FURTHER ORDERED , that the Mass Media Bureau send by  X - -Certified Mail Return Receipt Requested one copy of this Memorandum Opinion and  X-Order to all parties.  Xb-  #q21.` ` The report is to be filed with the Acting Secretary of the Commission for the attention of the Mass Media Bureau's EEO Branch.  X-` `  hh, FEDERAL COMMUNICATIONS COMMISSION ` `  hh,William F. Caton ` `  hh,Acting SecretaryV  X- V ă