April 24, 1996

KLAW Broadcasting, Inc. 626 DAve. SW ,William F. Caton, Acting Secretary Lawton, OK 73501 405-581-3600 ~. Fax 357-2880 Federal Communications Commission E-Mail @sirinet.net

1919 M Street, N. W

Washington, DC 20554

OOC~tT f\LE COP~ OR\G\N~L 'Re: MM Docket No. 96-16

Members of the Commission:

As General Manager of K-LAW - KZCD in Lawton, OK, I am writing you today to

ask for consideration of small market broadcasters like myself as you examine

possible changes with the current .EEO rules.

Our market has a population of less than 100,000. Our station currently employs

10 full-time and 6 part-time employees. With this small of a staff, we don't have

specialists, we all wear several hats. When the EEO rules were changed so that

at least a half dozen reports had to be completed on every job opening, this

meant an additional work load for present employees. We're small enough that

there is no Human Resources position.

No. of Copies rec'd 0 c}...~ List ABCOE Comments on MM Docket No. 96-16 Page 2

The Front Desk ReceptionisUSwitchboard OperatorlTraffic Manager must add

"EEO Officer" to her duties to fill out government paperwork.

While the framers of the current plan had good intentions of trying to make sure

a cultural mix is represented in the on-air signals and programming, it is not the way it works in the real world. I would put our public service, community

involvement, goodwill with minority communities or any other scale up against

any radio station. But this did not come about because of the great mix of

minorities we have on our staff. Radio stations are either committed to their

community or they are not.

Current rules state that we should periodically examine what sources we are

attracting minority applications from. We use EVERY source we can find to try

and attract any minorities. The truth of the matter is, it is next to impossible to

try and induce minorities to play cowboy music in a very small market in

Oklahoma. The close proximity of Fort Sill and the many minority young

soldiers that are part of the post also inflates the minority population of our

market. These individuals are not available for full-time employment. While

they are here they work for the government. And for the most part, once they

don't work for the government anymore, they go back "home" - wherever that

might have been before they entered the service. Comments on MM Docket No. 96-16 Page 3

I would like to ask that you consider the following points:

* Possibly increasing the minimum requirements for hiring guidelines to

kick-in. Staff size can get up to near 20 in very small markets where

minority recruitment, much less radio recruitment at all, is very

challenging.

* An even better way might be to start the guidelines based on Market Size.

The larger population base, the larger the available pool of qualified

candidates.

* Take into consideration items such as military bases that unduly inflate

some sectors of the popUlation, but does not increase the available work

force.

While you are taking time to look at possible changes, lets look outside of the box for once. Stay with me on this idea, it is on the edge.

Because the commission's EEO policy was really started to ensure

diversification of programming, should there be some leveling off of

minority expectations if the minority audience is being served by

one or more stations? This would be along the lines of watching

for "reverse discrimination". Most stations that serve a minority

audience hire almost exclusively from that particular minority Comments on MM Docket No. 96-16 Page 4

population. So if a market has a large Hispanic audience, and

there are stations programming just to that segment of the

audience, all other broadcasters would be able to cut (say in half)

the number of staff expected to be Hispanic.

The population is served by diversification of programming and minority employees are being recruited (the mostly exclusive numbers at one station would out-weigh the possible openings at other stations).

Thank you for your consideration.

Robert W. Payton ~

Vice President/General Manager