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LThis consisted of offering jobs to minorities lacking in the usual qualifications for employment   at the stations whom the stations' staff encountered and felt showed the potential to succeed in   broadcasting careers with some training. As examples of this approach, Prism cited one fulltime   .and two parttime hires. Prism indicated that it hired a salesman who worked for a client of the   [stations for a fulltime sales position. This person was hired on March 20, 1996. On March 22,   j1995, it hired an individual who worked as an attendant in the parking lot next to the station for   ia parttime lowerlevel position as Engineering Assistant. Thereafter, this individual's duties were   0expanded to include some engineering training. Finally, on March 4, 1996, Prism hired a   university student who had applied for a sales position for a parttime lowerlevel position as   Promotions Assistant. Prism did not modify its standard list of recruitment sources during the review period.  X-  _7.` ` There are no substantial and material questions of fact warranting designation for  X-  Mhearing. Astroline Communications, Inc., 857 F. 2d 1556 (D.C. Cir. 1988). Moreover, there is   no evidence of employment discrimination. Prism recruited, attracted and hired minorities during the license term. Accordingly, renewal of the stations licenses is in the public interest.  X-  8.` ` We find, however, that Prisms overall recruitment efforts with respect to   minorities were deficient because the stations failed to recruit for 23 (38.3%) of the 60 fulltime   vacancies during the review period. Further, Prism contacted only a single general source for   kan additional 10 (16.7%) of the 60 vacancies, which was not a sufficient recruitment effort in   view of the stations' difficulty in attracting minority applicants. Thus, it was able to attract only   18 minorities (3.4%) out of 529 applicants during the review period, and had only 13 minorities   (7.5%) out of 173 interviewees. Moreover, minorities were present in only 12 (24%) of the   stations' 51 hiring pools. Additionally, we find that Prism failed to adequately selfassess the   effectiveness of its EEO Program. The licensee concedes that its efforts were inadequate.   Despite its inadequate performance, the licensee did not reassess its standard list of recruitment   sources. Moreover, it continued to fill vacancies without meaningful recruitment. In fact, there   is no evidence that Prism engaged in any selfassessment until shortly prior to the filing of its   renewal applications on March 28, 1996. It is reported that Prism's General Manager met with   za representative of the local NAACP in January 1996. Nonetheless, even after that meeting,   Prism continued to fill vacancies without recruitment and made no reported changes in its   standard list of recruitment sources. Prism contends that its ability to selfassess the effectiveness   .of its EEO program was impaired since many applications received by mail did not indicate the   =applicant's racial or ethnic identity. However, there is no indication that Prism made any effort" (,))qq&"   ito address this problem. Our EEO Rule requires that licensees address any problems encountered  X-in the implementation of their EEO program. See 47 C.F.R.  73.2080(c)(5).  X-  9.` ` It also appears that, although it had not previously engaged in serious recruitment   or selfassessment efforts, Prism concluded as a result of its lateterm selfassessment that it was   in fact unable to successfully recruit by what it characterizes as "traditional" channels. It   proposed to rely instead on the occasional hiring of minorities as a result of random encounters.   However, while we encourage broadcasters to be creative in their outreach efforts, this process   could, at best, serve as a supplement to the ongoing efforts to attract minority and female   applicants for all vacancies required by our EEO Rule. Moreover, it would be difficult to assess   the adequacy of recruitment through random, informal encounters of uncertain frequency.   Finally, we emphasize that our EEO Rule is based on efforts to recruit minority and female applicants and does not establish a hiring quota or goal.  n10. After carefully reviewing the facts of this case, we find that the record in the  X -  @instant case is similar to that of KUTR(AM)/KCPXFM, Salt Lake City, Utah, in Price  X-  Broadcasting Company, 11 FCC Rcd 3620 (1996).<V X -  Ѝ #C\  P6QP#KUTR(AM)/KCPXFM were located in the Salt Lake CityOgden, Utah, Metropolitan Statistical Area. The labor force was 7.5% minority (0.8% Black, 4.5% Hispanic, 1.7% Asian/Pacific Islander and 0.5% American Indian).< KUTR(AM)/KCPXFM failed to recruit for   .30 (73%) of 41 vacancies. Further, we found that the licensee of KUTR(AM)/KCPXFM failed   to adequately selfassess the effectiveness of its EEO program, since it failed to maintain   adequate records. Finally, we found that the licensee's deficient EEO performance was   -aggravated by the submission of inconsistent information in its filings. We renewed the licenses   >of KUTR(AM)/KCPXFM subject to reporting conditions and issued a Notice of Apparent Liability to the licensee for $16,500.  X-  R11.` ` In the instant case, we find that Prism's EEO record is comparable to that of   KUTR(AM)/KCPXFM, except that the aggravating factor of inconsistent submissions is not   present here. Prism failed to adequately recruit for 33 (55%) of its 60 vacancies. While   >KUTR(AM)/KCPXFM failed to recruit for a greater percentage of its hires, Prism had more   jhiring opportunities and its labor force included a higher percentage of minorities. Further, the   licensee of KUTR(AM)/KCPXFM claimed that the stations had recruited, but was unable to   document those efforts due to a lack of records. Prism's records are more complete, but they   nevertheless affirmatively establish its recruiting failures. Moreover, Prism failed to utilize its   EEO program for five vacancies at the end of the review period, even though it was aware of its   previous inadequate results. Accordingly, we find Prism's continuing failure to recruit of   comparable seriousness to that of KUTR(AM)/KCPXFM. Prism also failed to adequately self  assess the effectiveness of its EEO efforts, as did the licensee of KUTR(AM)/KCPXFM. As   [noted, Prism, for the most part, maintained adequate records. However, it failed to use them as   part of ongoing, meaningful selfassessment efforts throughout the review period. Accordingly,   we conclude that the issuance of a Notice of Apparent Liability in the amount of $16,000 is appropriate. "h$A,))qqF#"Ԍ X-3, III. CONCLUSION   X-  Q12.` ` Upon review of the record, we find that no hearing is warranted. Accordingly,   {finding the licensee to be otherwise qualified, we will grant Prism's renewal applications.    However, because we find that Prism failed to recruit and selfassess the effectiveness of its EEO   kefforts as required by our EEO Rule, we will issue a Notice of Apparent Liability for $16,000.   Further, we will impose reporting conditions to monitor the stations prospective EEO performance.  X1- IV. ORDERING CLAUSES ă   X -  ~13.` ` Accordingly, IT IS ORDERED that the license renewal applications of Prism  X -  Radio Partners, L.P., for Stations WWKY(AM), WVEZ(FM) and WTFX(FM) ARE GRANTED   X -  Zsubject to the reporting conditions specified herein, and pursuant to Section 503, a NOTICE OF  X -APPARENT LIABILITY FOR FORFEITURE in the amount of $16,000. V X7-  xЍ #C\  P6QP# The Commission has consented to the assignment of the licenses for all three stations to SFX Acquisitions,   JInc., contingent upon the stations licenses being renewed. SFX Acquisitions, Inc., has, in turn, filed applications for   iconsent to assign the licenses for WWKY and WVEZ(FM) to Clear Channel Communications, Inc. and to assign   the license for WTFX(FM) to Regent Broadcasting of Louisville, Inc. In the event that the licenses are assigned,  yOx-  Jthe reporting conditions will apply to the assignees of the stations upon consummation of the assignments. See San  yO@-  xLuis Obispo Limited Partnership, 9 FCC Rcd 894 (1994); Woolfson Broadcasting Corporation, 4 FCC Rcd 6160  yO-(1989). #C\  P6QP#  X-  14.` ` IT IS FURTHER ORDERED that the licensee of Stations WWKY(AM),   !WVEZ(FM) and WTFX(FM) submit to the Commission an original and one copy of the following information on April 1, 1997, April 1, 1998, and April 1, 1999:  X4- 6` ` (a) Two lists divided by fulltime and parttime job vacancies during the  twelve months preceding March 1, 1997, for the first report, March 1,  s1998, for the second report, and March 1, 1999 for the third report,  Eindicating the job title and FCC job category, 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  X-also note what recruitment sources were contacted;x)V yO -#C\  P6QP#э Such a list might start:  (1) News Director; Officials and Managers; Fulltime  yO"-3 Applicants:` `  1 White femalehh,VA.W.R.T.  yO"-` `  1 Hispanic malehh,VNational Hispanic Media Coalition(#  yO#-` ` 1 Black femalehh,VUrban League Sources contacted: Local newspaper, A.W.R.T., National Hispanic Media Coalition and Urban League. Selected: Hispanic male (10/19/96), National Hispanic Media Coalition.(#  X|-  ` ` (b) A list of employees as of the March 1, 1997, payroll period, for the first  report, the March 1, 1998, payroll period, for the second report, and the"ei ,))qq"  DMarch 1, 1999, payroll period, for the third report, by job title, indicating  fulltime or parttime status (ranked from highest 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   position filled during each respective 12month period specified, including  Ridentification of sources used and indicating whether any of the applicants  declined 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 -  15.` ` The reports are to be filed with the Secretary of the Commission for the attention of the Mass Media Bureau's EEO Branch.  X -  16.` ` IT IS FURTHER ORDERED , that the Mass Media Bureau send by Certified  X -  Mail Return Receipt Requested a copy of this Memorandum Opinion and Order and Notice  X-of Apparent Liability to Prism Radio Partners, L.P.  Xb-  17.` ` With respect to the forfeiture proceeding, the licensee may take any of the actions   \set forth in Section 1.80 of the Commission's Rules, 47 C.F.R. Section 1.80, as summarized in   the attachment to this Order. Any comments concerning the ability to pay should include those  X-financial items set forth in the attachment.  ` `  hh,FEDERAL COMMUNICATIONS COMMISSION ` `  hh,William F. Caton ` `  hh,Acting Secretary