The Multicultural Media, Telecom and Internet Council (MMTC) this week filed reply comments with the FCC to its “modernization of media regulation initiative.” Co-authored by President/CEO Kim Keenan and President Emeritus and Senior Advisor David Honig, MMTC outlines seven priorities the Commission should take when proceeding with its plans.
First on MMTC’s list is ensuring that the update of certain EEO Rules will not interfere with the Commission’s goals of preventing and proscribing discrimination. To that end, MMTC does not object to the elimination of Form 397 in the EEO midterm reports, as it is “seldom, if ever,” used for EEO enforcement or citizen review of EEO performance.
Furthermore, MMTC says the EEO Public Inspection File website posting requirement is duplicative and may be eliminated.
But one rule that MMTC says should not be eliminated is the requirement that broadcasters send job vacancy notifications to “entitlement sources.”
It says, “E-mailing job notices to a handful of sources that want such notices requires almost no effort. Organizations that request these vacancy notifications typically include colleges (particularly community colleges and HBCUs), Urban League chapters, LULAC councils, and job training centers. These job notices help the community institutions encourage clients, students, and others to consider the broadcast company favorably when planning a career.”
MMTC said some commenters contend that these entitlement sources are no longer needed because they produce few job referrals in the short term.
MMTC disagrees. “These commenters misunderstand the purpose of entitlement sources,” it says. “An entitlement source is an integral part of a broadcaster’s promotion of its equal employment opportunity policy — the broadcaster’s open door to all who might wish to work there someday. This is the same kind of multi-source outreach every broadcaster does when promoting its brand as part of its advertising campaign.”
Meanwhile, MMTC takes no position in the shift to annually, from quarterly, of producing a list of programs that have provided the most significant treatment of community issues during the preceding three-month period and placing it in its public file.
For the MMTC, “The reporting requirement, whether annually or quarterly, should be retained because it serves an important purpose.”
Furthermore, MMTC argues that the FCC’s rural radio policy should be repealed.
“If the Commission wishes to eliminate unnecessary, outdated and unduly burdensome regulations, this policy should be a priority for elimination,” MMTC says. “Many minority owners and small broadcasters entered the business when the only stations available or affordable were in outlying areas, but their intended audiences were located in central urban locations. Although the spectrum would allow movement of transmitters to reach these areas, FCC policies stood in the way. Rather than allowing the station owner to determine what type of programming would serve its audience, the FCC arbitrarily placed barriers in his way.”
