Federal Communications Commission
Washington, D.C. 20554
August 11, 2009
 
Dear Licensee: 
1.  In accordance with 47 C.F.R. § 73.2080(f)(4) of the Commission’s rules, the station employment unit 
(the “Unit”) that includes your above-referenced station (the “Station”) has been randomly selected for an 
audit of its Equal Employment Opportunity (“EEO”) program.  (A copy of Section 73.2080 of the 
Commission’s rules is enclosed for your reference.)
2.  If the Unit is not required under our rules to have an EEO recruitment program due to the nature of its 
full-time workforce (having fewer than five full-time employees, defined as employees regularly assigned 
to work 30 hours a week or more), you must still respond to this audit letter.  However, in your response, 
you must provide only a list of the Unit’s full-time employees, each noted by job title and the number of 
hours each is regularly assigned to work per week, and a response to Question 3(e) below.  Also, in 
formulating your response, please see Questions 4(a) and (b) below regarding brokers and brokered 
stations, for instructions for situations in which the applicable employment unit has fewer than five full-
time employees.  
3.  Audit Data Requested.  If the Unit employs five or more full-time employees, provide the following 
information in your response to this letter, including an explanation regarding any requested information 
that you are unable to provide:
(a) Copies of the Unit’s two most recent EEO public file reports, described in 47 C.F.R. 
§ 73.2080(c)(6).  For any stations in the Unit that have websites, provide each web address.  If the Unit’s 
most recent EEO public file report is not included on or linked to each of these websites, in violation of 
that subsection, indicate each station involved and provide an explanation of why the report is not so 
posted or linked.  In accordance with 47 C.F.R. § 73.2080(c)(5)(vi), provide the date of each full-time hire 
listed in each report provided.
(b)  For each Unit full-time position filled during the period covered by the above EEO public file 
reports, or since your acquisition of the Station, if after that period, dated copies of all advertisements, 
bulletins, letters, faxes, e-mails, or other communications announcing the position, as described in 47 
C.F.R. § 73.2080(c)(5)(iii).  Include copies of all job announcements sent to any organization (identified 
separately from other sources) that has notified the Unit that it wants to be notified of Unit job openings, 
as described in 47 C.F.R. § 73.2080(c)(1)(ii).  
(c)  In accordance with 47 C.F.R. § 73.2080(c)(5)(v), the total number of interviewees for each 
vacancy and the referral source for each interviewee for all full-time Unit vacancies filled during the 
period covered by the above-noted EEO public file reports. 
(d)  Documentation demonstrating performance of Unit recruitment initiatives described in 47 
C.F.R. § 73.2080(c)(2) during the periods covered by the above-noted EEO public file reports, such as 
participation at job fairs, mentoring programs, and training for staff.  Specify the Unit personnel involved 
in each such recruitment initiative.  Also, provide the total number of full-time employees of the Unit and 
state whether the population of the market in which any station included in the Unit operates is 250,000 or 
more.  Based upon these two factors, determine and state whether the Unit is required to perform two or 
four initiatives within a two-year period, pursuant to 47 C.F.R. §§ 73.2080(c)(2) and (e)(3).   
(e)  Disclose any pending or resolved complaints involving the Station filed during the Station’s 
current license term before any body having competent jurisdiction under federal, state, territorial or local 
law, alleging unlawful discrimination in the employment practices of the Unit on the basis of race, color, 
religion, national origin, or sex.  For each such complaint, provide: (1) a brief description of the 
allegations and issues involved; (2) the complainant and other persons involved; (3) the date of the 
complaint’s filing; (4) the court or agency before which it is pending or was resolved; (5) the file or case 
number; and (6) the disposition and date thereof or current status.  Note that all complaints must be 
reported, regardless of their status or disposition.
(f)  In accordance with 47 C.F.R. § 73.2080(b), for the period from March 10, 2003 (or from the 
first day of the Station’s current license term, if after that date) until the date of this letter, describe the 
responsibilities of each level of Unit management to ensure enforcement of Unit EEO policies and 
describe how the Unit has informed employees and job applicants of its EEO policies and program.
(g)  In accordance with 47 C.F.R. § 73.2080(c)(3), for the period from March 10, 2003 (or from 
the first day of the Station’s current license term, if after that date) until the date of this letter, describe the 
Unit’s efforts to analyze its EEO recruitment program to ensure that it is effective and address any 
problems found as a result of such analysis.
(h)  In accordance with 47 C.F.R. § 73.2080(c)(4), for the period from March 10, 2003 (or from 
the first day of the Station’s current license term, if after that date) until the date of this letter, describe the 
Unit’s efforts to analyze periodically its measures taken to examine pay, benefits, seniority practices, 
promotions, and selection techniques and tests to ensure that they provide equal opportunity and do not 
have a discriminatory effect, and if the Unit has one or more union agreements, describe how the Unit 
cooperates with each union to ensure EEO policies are followed for the Unit’s union-member employees 
and job applicants.   
(i)  If your entity is a religious broadcaster and any of its full-time employees are subject to a 
religious qualification as described in 47 C.F.R. § 73.2080(a) of the rules, so indicate in your response to 
this letter and provide data as applicable to the Unit’s EEO program.   For example, for full-time hires 
subject to a religious qualification, only a record of the hire listed by job title and date filled, the 
recruitment sources used for the opening, and the source of the hiree must be maintained.  No other 
records are required for those hires.  If five or more full-time positions are not subject to a religious 
qualification, the licensee must maintain all records for such hires and complete the initiatives required 
under 47 C.F.R. § 73.2080(c)(2).  Otherwise, a religious broadcaster is not required to perform these 
initiatives.   
4.  Time Brokerage.  
(a)  Brokered station(s).  If the Unit employs fewer than five full-time employees and any station 
included in it is subject to a time brokerage agreement, in addition to responding to this letter and 
providing us a list of the Unit’s full-time employees listed by job title (and the number of hours each 
employee is assigned to work) and a response to Question 3(e) above, you must immediately forward a 
copy of this letter to the broker under each such agreement, which must also respond to Question 4(b) 
below.   
(b)  Brokers.  The broker of any Unit station referenced above must supply the Commission with 
the information requested herein regarding the broker’s full-time employees who work at each such 
brokered station.  If this letter is addressed to you requesting data about a station licensed to you, and you 
also broker a station in another employment unit, you must submit the information requested herein for 
each of your stations and your full-time employees at each brokered employment unit, if the recruitment 
data for any such brokered unit is included with that for your own station referenced above.  See 47 C.F.R. 
§ 73.2080(f)(3).  If your employees at your own station(s), combined with your employees at the station(s) 
that you are brokering, total fewer than five full-time employees, however, you need not provide such 
information.  Instead, you must respond to this letter by the deadline described below by submitting a list 
of your Unit’s full-time employees (listed by job title and number of hours regularly assigned to work per 
week) and the same type of list for the full-time employees you employ at the brokered station(s), and a 
response to Question 3(e) above 
5.  Procedures. Direct your response to EEO Staff, Policy Division, Media Bureau, Federal 
Communications Commission, 445 12th Street, S.W., Washington, DC  20554.  The response must be 
received by the Commission by September 21, 2009. The accuracy and completeness of the response 
must be certified to by an officer, partner or other principal of the Station licensee or broker (as 
appropriate) or, in the case of a noncommercial educational station, by an officer, member or other 
principal of the licensee.  (See 47 C.F.R. § 1.16.)  The response may be in the form of a CD or other 
electronic medium, as long as the certification provided refers to the material submitted and is on paper 
with an original signature.  To knowingly and willfully make any false statement or conceal any material 
fact in response to this audit is punishable by fine or imprisonment (see 18 U.S.C. § 1001; see also 47 
C.F.R. § 1.17), revocation of any station license or construction permit (47 U.S.C. § 312(a)(1)), and/or 
forfeiture (47 U.S.C. § 503).  Absent an extension of time, failure to respond to this audit letter by the 
deadline noted above is also punishable by sanctions in accordance with 47 C.F.R. § 73.2080(g).  
Extensions of time must be requested in writing (or e-mail sent to lewis.pulley@fcc.gov) and will be 
granted only upon a showing of extraordinary circumstances.
6.  In accordance with 47 C.F.R. § 73.3526(e)(10) (for commercial stations ) and 47 C.F.R. 
§ 73.3527(e)(11) (for noncommercial educational stations), copies of which are also enclosed, you must 
place a copy of this letter and your response in the public inspection file of each affected station.  
Consequently, your response should not include personal information about individuals, such as social 
security numbers, home addresses, or other personally identifiable information.  We do not require that 
employment units retain such information in their records, or that such information be provided in 
response to this letter.  
7.  If our EEO random audits sent in 2007 or 2008 included the Station, or if the Station’s most recent 
license renewal application was granted, by final order, within the past 18 months, you may not have to 
provide a response to this letter.  If you believe that the Station falls within one of these categories, before 
responding to this letter, please so state in an e-mail, providing the specifics of the audit or renewal, sent 
to the undersigned at lewis.pulley@fcc.gov.  Upon receipt of this information, we will advise you if a 
response is necessary under the circumstances.  Should you have any questions regarding this matter, 
please contact the EEO Staff at (202) 418-1450.  Thank you for your cooperation.
Sincerely,
Lewis C. Pulley
Assistant Chief, Policy Division
Media Bureau
Enclosures