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Given the significant minority population in Sussex County  x(18.2%), we are not persuaded by RBC's assertion that minorityoriented recruitment sources  X-(e.g., organizations, churches, publications, etc.) were nonexistent.  X- ` x 8.` ` As to the argument that comparison of WGMDFM's record to WNRWTV's is  xinappropriate because WNRWTV is in a larger and more "stable" market, in comparing stations  xwe look primarily to the composition of the area labor forces of the stations at issue, not market  XN- x.strength. See Walker County Communications, Inc., 11 FCC Rcd 17506, 17509 (1996) ("Walker  X7- xyCounty)." As we noted in our decision in Rehoboth Beach (at  1718), both WGMDFM and  xWNRWTV have comparable percentages of minorities in their respective labor forces (18.2%  xand 17.8%, respectively). Station WGMDFM had more hiring opportunities than Station  xWNRWTV and both stations recruited for a similar percentage of vacancies. In addition, both  xstations failed to maintain complete recruitment records and to selfassess adequately the  xproductivity of their recruitment efforts. These were the primary factors that determined the  xyappropriate sanctions. Moreover, we have assessed the same forfeiture amount on other radio  X"- x[stations with similar EEO deficiencies as here and used WNRWTV as a comparison case. See  X#- x=Walker County, 11 FCC Rcd at 17507, 1750917510 (Commission found that imposing a $15,000  xforfeiture on Stations KSAM(AM)/KSAMFM, Huntsville, Texas, was appropriate because the"h$0*&&uu(#"  xEEO record of these stations were comparable to that of Station WNRWTV, WinstonSalem, North Carolina).  X- ` $x9.` ` RBC further argues that the Commission should take into account that a small  xtown FM station cannot offer the salaries and benefits that a large market television station can  xoffer. This factor affects minorities and nonminorities alike, independent of the location of a  Xv- x-station, and is not a mitigating factor in determining the forfeiture amount. See Davidson County  X_- xBroadcasting Company, Inc., 12 FCC Rcd 3375, 3381 (1997), petition for recon. pending; Lotus  XH- xCommunications, Inc., 9 FCC Rcd 2117, 2120 & n.13 (1994). RBC also states that the  xCommission should take into account the size of the respective stations in comparing their EEO  xefforts. It points out that WNRWTV had between 30 and 36 fulltime employees during the  xperiod in question, and that, in contrast, WGMDFM only had between 16 and 21 fulltime  x!employees during the review period. In determining the forfeiture amount, we took into  xconsideration the difference in the size of the staff of these two stations and concluded that the  xdifference in staff size did not, by itself, serve as a mitigating factor in favor of a reduction in  xyforfeiture when, as here, there are other, more significant factors to offset the difference in staff  X- xjsize.x {O -  #C\  P6QP#ЍxCompare MyStar Communications Corporation, FCC 97148 (rel. May 2, 1997) with WCCBTV, Inc., 11  yO- xxFCC Rcd 19680 (1996), petition for recon. pending (reconsideration sought on grounds not related to staff size).  yO- xZDuring their respective review periods, the stations in MyStar Communications Corporation had a staff size that  yOc- xranged from 2454 fulltime employees, while the stations in WCCBTV, Inc. had a staff size that ranged from 1520  yO+- xemployees. Despite the difference in staff size, we imposed the same forfeiture amount (i.e., $12,000) because of other, more significant factors in common. x For example, WGMDFM had more hiring opportunities than did WNRWTV (52 and 29, respectively).  XK- `  x 10.` ` Finally, RBC states that the Commission should consider some of the  x"extraordinary steps which WGMD took in its efforts to recruit minority employees." As  xMexamples, it points out that one of the partners of the licensee, an experienced newsperson,  xjpersonally recruited minority employees from outside the area and personally trained one such  x]minority. RBC also points out that it advertised outside the local area to attract minority  x/applicants, while such outside recruitment would not be necessary in a large MSA such as  xWinston Salem. These examples of "extraordinary steps" that RBC states it took to recruit  X- xminority applicants were raised by RBC in the license renewal proceeding and have already been  X- xZconsidered. See Rehoboth Beach, at  19. In any event, the licensee's efforts were not consistent  x.in this regard and thus did not attract more minority candidates. Consequently, they were not sufficient.  X7- ` Ax 11.` ` Based on the foregoing, we deny RBC's request for rescission or reduction of the  X - xforfeiture amount specified in the NAL in Rehoboth Beach. Therefore, we issue a Forfeiture Order in the amount of $15,000 against RBC. "B0*&&uu"Ԍ X-ԙ IV. ORDERING CLAUSES  X- x` `  X- ` x 12.` ` ACCORDINGLY, IT IS ORDERED that Resort Broadcasting Company's request  xfor rescission or reduction of the forfeiture amount specified in the Notice of Apparent Liability  X-in Rehoboth Beach, 11 FCC Rcd 18214 (1996), is DENIED .  Xv- ` x 13.` ` IT IS FURTHER ORDERED , pursuant to Section 503(b) of the Communications  xzAct of 1934, as amended, 47 U.S.C.  503(b), that Resort Broadcasting Company, licensee of  XH- x{Station WGMDFM, FORFEIT to the United States the sum of fifteen thousand dollars  xz($15,000) for violations of Section 73.2080 of the Commissions Rules, 47 C.F.R.  73.2080. In  x/regard to this forfeiture proceeding, the licensee may take appropriate action as set forth in  xPSection 1.80 of the Commission's Rules, 47 C.F.R.  1.80, and Section 504(a) of the  xCommunications Act, as amended, 47 U.S.C.  504(a), as summarized in the attachment to this  X -Memorandum Opinion and Order and Forfeiture Order.  X - ` `x 14.` ` IT IS FURTHER ORDERED that copies of this Memorandum Opinion and  X- xOrder and Forfeiture Order be sent to Resort Broadcasting Company by Certified Mail Return Receipt Requested.  X-x` `  hh FEDERAL COMMUNICATIONS COMMISSION (#(#Xx` `  hh x` `  hhWilliam F. Caton x` `  hhActing Secretary