c
-14-
WOPo-FH, Valdosta, GA
~OPo-FM has been owned and operated by Hetro Media Broadcasting. Inc. einee Feb~uary. 1981. The atation's record of fulltl~e minorIty employment eince 19~3 is reflected in the following table. Table 11. Minority Eaployment at VQPo-FH. 1982-1988
Month , Min8.I#E~p1s., , H1na./iEmple., I of %of and fOP 4 Categs. total Fulltillle Parity. Parity. Year top 4 Total - Categ•• Fulltime
1988 O/lS 0/19 O~ 0% 1987 0/15 0/17 OX 0% 1986 1/13 l/lS 27% 24% 1985 1/12 1/14 30% 26% 1984 0/12 0/14 0% 0% 1983 1/7 1/10 51% 36t 1982 1/9 1/10 40% 36%
WOPQ'. Btati.tlcal record could Dot be .ore dIsmal: none of .~ the 19 ful1time employees reported on the 1988 Form 395 were minor1tlea. Not evan any of the eight parttlme employees vere lIlinodtiu.
The EEO progra~ •••oclated with the currently pending renewal appl1eattona ~ake. reference to no minority .chools, minority organ1zations, or minorlty eedla. One minority organization (Black Community Action Organ1z4eion) ~., proposed in the 1982 renewal application; it was not mentioned In the current application.
Therefore, a Bilingual investigation should be conducted to deter~lne vhether the near total absence oI minority e~ployees during the licente ter~ resulted from inadvertence, from a de11berlte violation of the EEO rule. or fro~ discrimination.
1'1 -15-
CONCLUSION
~ For the foregoing reasons, the foregoing applications should be made the subject of Bilingual investigations and, if the evidence so warrants, should thereafter be denied. 7/
Respectfully submitted, aAC~!d~ Charles Carter Associate General Counsel NAACP 4805 Mt. Rope Drive Baltimore, Maryland 21215 (301) 358-8900
Dav! Honig 1800 N.W. l87th Miami, Florida (305) 628-3600
Counsel for Petitioners , March I, 1989 '''-.-/
~I Eight of the 13 declarations Petitioners had hoped to append hereto are appended hereto. Petitioners hope to transmit the remaining five shortly. So that the licensees will have notice of their contents, Petitioners note that the form of the additional declarations will be similar to the form of the declarations appended hereto. Petitioners note with some pride that this represents substantial progress, with very limited resouces, toward full participation of the petitioning individuals at the time the petition Is filed, as the Commission prefers•
. ''''--.../ Georgia/Alabama Radio Renewals
STADKEMT OF PLOUA ll. HAKSHALL
Pluria W. Marshall states as follows:
I am the Chairman of the National Black Media Coalition.
I have reviewed, and I subscribe to the NBMC/NAACP Petition to
Deny. The facts stated therein are true" to my personal knowledge
except where identified as having been based upon official records such
as statistical data and material on file with. the Federal
Communications Commission.
I would be seriously aggrieved if the Petition to Deny is not
granted, since those members of the National Black Media Coalition who
reside in the communities in Alabama and Georgia whose stations are
included in the petition would be deprived of job opportunities and
program service in the public interest.
This statement 1s true to my personal knowledge and is made
under penalty of perjury under the laws of the United States of
America. ~j{W Pluria W. Harshall Chairman National Black Media Coalition 38 New York Avenue N.E. Washington, D.C. 20002
Dated: U:d-~/m
Ib DI!C1.A.UIION
RE: Radio Station WQPQ-FM. Valdosta. Georgia
1 hereby subscribe to the NBMC/NAACP Petition to Deny. The facts stated therein are true to .y pe~.onal knowledge except where identified as having bee~ based upon official records such a•
• tatistical data and asterial on file with the Federal Coamunications
CO.lIi.ston.
I am a regular listener Co the station.
I would be seriously aggrieved if the Petition to Deny 18 not granted. since members of the NAACP. including ayself, would be deprived of job opportunities and program service in the public interest.
This statement is true to my personal knowledge and is made under penalty of perjury under the law6 of the United States of America.
Lewis Gordon President Lowndes-Valdosta Branch, NAACP P.O. Box 1324 Valdosta, GA 31601
•
17 , R£: Rad io Station WBBQ-AM-FM, Augusta, Georgia
1 hereby subscribe to the NBKC/NAACP Petition to Deny. The
facts atated therein are true to .y personal knowledge except where
identified as having been based upon official recorda auch a8
statistical data and aaterial on file with the Federal Communications
Co••ission.
I am a regular listener to the 8tatlon.
I would be seriously aggrieved if the Petition to Deny is not
granted, since members of the NAACP, including myself, would be deprived of job opportunities and program service in the public
interest.
This statement is true to my personal knowledge and is made under penalty of perjury under the laws of the United States of
America.
Dennis Williams President Augusta Branch of the NAACP 1301 Laney-Walker Blvd. Augusta, GA 30901
• DI!:C1..A1lA1'lOH , IE: Radio Station UHBB-AM. Selma, Alabama
I hereby subscribe to the NBKC/NAACP Petition to Deny. The
facts stated therein are true to .y perso~al knowledge except where
identified as having been b4sed upon official records luch a.
statistical data and material on file with the Federal Communications
Camilli s &1 0 n •
1 am a regular listener to the station.
I would be seriously aggrieved 1f the Petition to Deny is not granted, since members of the NAACP, including myself. would be deprived of job opportunities and program service in the public
{nteres:.
this statement is true to my personal knowledge and 1s made und~r penalty of perjury under the laws of the United States of
America.
President Dated: 02-:;-'/- 1'9 Selma-Dallas County Branch. NAACP f _ 8 Edgewood Drive Selma, AL 36701
• . • "',
/9 ! DI!CL.A1lAl'IOH , RE: Radio Station WLWI-AM-FM. Montgomery. Alabama
I hereby subscribe to the NaMC/NAACP Petition co Deny. The
facts stated cherein are true to .y personal knowledge except where
identified as having been based upon official recorda such a8 statistical data and asterial on file Vith the Federal Coamufticacions
Commission.
1 am a regular listener to the 8tation.
I would be seriously aggrieved if the Petition to Deny 1s not granted, since members of the NAACP, including myself, would be deprived of job opportunities and program service in the public interest.
This statement is true to my personal knowledge and is made under penalty of perjury under the laws of the United States of
America. qjj;:fi.~k~~' President Dated: Metro Montgomery Branch. NAACP P.O. Box 1788 Montgomery. AL 36102 DeC~ION
, RE: Radio Station WAPI-~l-FM. Birmingham. Alaba~
I hereby subscribe to the NBMC/NAACP Petition to Deny. The facts stated therein are true to .y personal knowledge except where identified as having been based upon official record. 8uch a. statistical data and IUte'rial on f1le wtth the Federal CoaulUnl~at10ns
Commission.
I am a regular listener to the station.
1 would be seriously aggrieved if the Petition to Deny 18 not granted. since members of the NAACP, including myself, would'be deprived of job opportunities and program service 1n the public interest.
This statement 15 true to my personal knowledge and 1s made und~r penalty of perjury under the laws of the United States of
America.
William J. President Dated: OJ ... 2"'-- 8"1 Birmingham Branch of the NAACP 209 So. 61st St• • Birmingham. AI. 35212 , RE: Radio Station WVlIN/WZYl'. Athens, Alabama
I hereby subscribe to the NBMC/NAACP Petition to Deny. The
facts stated therein are true to .y perlonal knowledge except where
identified as having been based upon official record. auch .s
statistical data and material on file 'with the federal Co.munlcatlons
I am a regular listener to the stacton.
I would be seriously aggrieved 1f the ~ecttion to Deny is not graneed, since .embers of the NAACP. including myself, would be· deprived of job opportunities and program service 1n the public
interest.
This statement is true to my personal knowledge and is made under penalty of perjury under the laws of the United States of
America.
Dated:~4 .;7~ /9fl Barbara Clemons President
# Limestone County Branch. NAACP Rt. 11, Box 108 Athens. AL 35611
• DECLARATION OF EARL SllUBOSTER
BE: Georgia and Alabama Station License Renewals
I am the Director of Region V of the NAACP.
I hereby subscribe to the NAACP Georgia/Alabama Petition to
Deny. The facts stated therein are true to my personal knowledge except where identified as having been based upon official records such as statistical data and material on file with the Federal
Communications Commission.
Many NAACP members residing in Region V of the NAACP. which includes the States of Georgia and Alabama. are regular listeners to the stations subject to the Petition to Deny.
I would be seriously aggrieved if the Petition to Deny is not granted. since members of the NAACP would be deprived of job opportunities and program service in the public interest.
This statement is true to my personal knowledge and is made under penalty of perjury under the laws of the United States of
America.
Regional Director NAACP 970 Martin Luther King Drive S.W. Suite 203 Atlanta. Georgia 30314 Dated: z- 25"- ~1 ·. I ..
CERTIPICATE OF SERVICE
I, David Honig, hereby ce~tify that 1 have this lit d~y of Hareh, 1989 eauaed a copy of the foregoing "PeUUon to Deny" to be delivered via U.S. Firat C1SA' Mail. po.tage prepaid, to the 10110\ling: ~/
M. Scott John8on. Esq. WHBB/WTUN Cardner Carton , Douglas P.O. Box 10S5 1001 Pennsylvania Ave. N.Y. Selma, At 36702 Welhington, D.C. 20004 Counsel for WVNN/WZYP \1API-!M-FH, WLWI-AM-FH, and WVNA-AM-FM
WOS/WORM WBRP-AM 401 14th St. S.E. 2101 Covernors Drive S.W. Decatur, AL 35602 Huntsville, At 35805
Stanley Neustadt, Esq. WBBQ-AM-FM Cohn & Mark. P.O. Box 2066 1333 New Hampshire Ave. H.Y. ·Augusta. GA 30913 Washington, D.C. 20036 Counsel for WAGQ-FM
WWGS!WSGY WQPQ-FM 1434 Tift Ave P.O. Box 1327 ~ifton, CA 31794 Valdosta, GA 31603
!/ Liefn,e!s are being served directly where no lawyer 18 listed 1n the FCC files for the stattons. fY7 rn 6 £ X. :3
Disposition r------'-" MMB Ex. 3 r~:::;!.~r:l1 r tI.n·p~ t.~ re.IV t'.. :. ,"_ .• \r \. '...... '. 4 JUL ~; - E,:·j
Si£ned By Mailed By
J. Mac~ Bramlett, VICe President ~ Dixie' Broodcast1ng, Inc. 401 14th Street, SE Decatur, AI.. 35602
Dear Mr. Bramlett:
This refers to the E&l program subntttEd as put of the application for renewal of license of the above-zeferenoEd stat:ion(s) •
.Beca.~ ~ is i.nsuffJ.oient infonnat:.I.On to nake a de~t:i.On that. emn·ls were undert.aken to at.t.mct Jtd.norlty ~aant:s ~r there were jd> ~~ we are request:.i.ng the fallowi.n.1 JnfonxatiDn.
For each position filled dw:ing the ~perkd fran NJvenber l~ 1985,to Novenber 1, 1988 or smce your a.cquisitioo. of the sta.ti~ provide the jcb' .' title, 395-B jd:> cJ.as<;.jffcatian, the full or part-time status of the positiDn, the date the position was filled, the refen:a1. SCJUJ:036 CXJl1ta=tai, the nmber . of perscns interviewed (indicating tb:lse that -were minority and feoale), am the referral source, gender and ra::e or na.tional odgin (e.g., H1spmfc) of . , t;he succ~ candidate. y~ may provide aIr;;{ a:X1itiooal ~tion to show , :effOrtS Uiidertakeh 1:0 ~t~:tbeEED ·piO;;JLaiU.:· yoUr rE!spome "IitSt·!ie,,:,.···· ',' received by us within thirty (30) dal'S of the d3.te of this letter. Also, please send a copy of the infome.d.on to David lbnig, coume1. for NBMe et ale They will have twenty (20) days in which to cament on }OJr subn:iss:ion~--
Should ~ have any quest:i.c03 regar:djng this matter, please' cont:a::t Ms. Pan'era D. Hairston at (.202) 632-7069.
Sincerely,
Glenn A. Wa1£e Chief, EEX> Branch Enforcement Division l'-1ass Hedia Bureau
cc: Daniel Van fbm, Ea1tJlre David E. Honig, aquire
I ~ m Tn 8 E x. 4
Federal~9El£I1unications Commission
Dockm No. /2--~ Exhibit NO~____ ' Presented by ft ~_~ I-t~Ltr _ (Ida""f,ed ,;zlrL_, _ Di:>position ) Relei VGd a[i'7 _ { ReJected - _
Repaller!Jft1{-.-01}(l-A-'-"La Date ~6(2- MMB Ex. 4
Arent, Fox, Kinmer, Pl ;.J _:',
Washington Square 1050 Connecticut Avenue. N.W. ( Washington. D.C. 20036-5339
Daniel F. Van Horn (202) 857-6030 July 28, 1989
Donna R. Searcy Secretary Federal Communications Commission 1919 M Street, N.W. Washington, D.C. 20554 Re: Stations WHOS(AM) and WDRM(FM),. Decatur I Alabama
Dear Ms. Searcy: .: . ' ..... ::. '; Submitted herewith, on behalf of D~xie:Broadcasting, Inc., Debtor-In-Possession, licensee of Stations WHOS(AM) a41 WDRM(FM), Decatur, Alabama, is a report ,relative to the recent employment practices of the stations. This report is being submitted in response to a letter from Glenn A. Wolfe, Chief, EEO Branch of the FCC's Mass Media Bureau, dated July 3, 1989. The deadline for submitting the' report is August 2, 1989. The .report is submitted in the form of an Opposition which was filed .with the FCC on -April 14,,' 1989 in response to Petition to Deny filed against the renewal applications of the stations. The information requested by Mr. Wolfe's office is contained.in the text of the Opposition. Please call me if you have any questions concerning the report. Sincerely,
-~- ../" .. , 'f "_. --- I .' -.... - - Daniel F. Van Horn Counsel for Dixie Broadcasting, Inc., Debtor-In-Possession Enclosure Courtesy copy: Pamera Hairston
Telephone (202) 857-6000 Cable ARFOX TeleK WU 892672 tIT 440266 TelecoOlCr: (202) 857-6395 I Arr·fl' ... ,'.lIer PiotkJ'1 } ... : ~'- f \':'1 In fILE COpy
BEFORE THE FEDERAL COMMUNICATIONS COMMISSION WASHINGTON, D.C. 20554
In re Appl'ication of ) ) nIXIE BROADCASTINC, INC~ ) File Nos. BR-B8l201wO DEBTOR-IN-POSSESSION" . ) and BRH-B81201w~ ) For Renewal of Licenses for ) Stations WHOS(AM) and WDRM(FM), ) Decatur, Alabama )
TO: Chief, Mass Media Bureau
OPPOSITION TO PETITION TO DENY ~ iI· A ~.L' ~ "~ '-/'h' "j/c / «'0 o~.~~ ~ ~'" ~~. /~ 0/ ~ .T~ ~ "~o. cT.J1 \ ....~ ".1' l'~ tO~ ( ~~ ~Ji, Il;-a Daniel F. Van Horn, Esquire" Susan A. Marshall, Esquire Arent, FQx, Kintner, Plotkin & Kahn' 1050 Conne~ticut Avenue, NW Washington, D.C. 20036-5339 (202) B57-6030
Counsel for Dixie Broadcasting, Inc., Debtor-In-Possession
Date: April 14, 19B9 TABLE OF CONTENTS
SUMMARY ...... '" ... '" ...... ii
I. INTRODUCTION ·· · ·· · ··· · . · . . 1
II. DISCUSSION . · · · ·· · ·· · ·· · ·· · · 3 A. 1988 Reporting Period ·· · · · ·· 3 B. 1982-1987 Reporting Periods · · ·· · · . . 7 III. CONCLUSION . · · · · ·· ··· · · ··· ·· . . 11
\ (
- i -
3 SUMMARY
Dixie Broadcasting, Inc., Debtor-In-Possession
("Dixie"), licensee of Stations WHOS(AM) and WDRM(FM),
Decatur, Alabama, opposes the Petition to Deny ("petition~) .. filed by Region V of the NAACP," 'i:h~respE:ctive branches of
the NAACP operating within the service areas of certain
referenced Alabama and Georgia radio stations, and the
National Black Media Coalition (collectively, the
·Pe~itioners") with respect to the abov~~captioned application for renewal of licenses for Stations waos and WORM. Petitioners have failed to raise any substantial or
material questi?ns of fact or law with respect to Dixie's
. ~ operation of the stations during the last renewal term, or
with respect to Dixie's employment practices. Therefore,
their Petition should be dismissed .
.Petitioners allege that Stations waP$IWDRMdo not
appear to be operating under a "meaningful" EEO program and
that the licensee's self-analysis of its·program contains
nothing to indicate that it is aware that its program has
allegedly failed to produce meaningful results. Petitioners,
however, have failed to prove discrimination or any violation
of the Commission's EEO rules or policies. Petitioners
cannot, and do not, provide any actual claim of
discrimination. Furthermore, based on the lack of minority
population in the relevant civilian work force, the
Petitioners have failed to prove that a substantial
""'--...-/ ii statistical disparity exists between the available minority
labor force and the station's minority employment.
During the course of the seven-year license term, the
licensee has employed and/or considered for employment a
... _?E:b~tc3._nt:.ial number of minority candidates -- all but one 'o·f- .
whom Wd~ for an upper-level job position -- by virtue of its
contact with local Black broadcasters, colleges and other
institutions. Consequently, Dixie's record demonstrates a -. continuing ef'fort 't.o ~eek';:out minorities and women for
available positions an4 to improve the representation of
minorities, a:t:,-,the s~-ations.
Inlight'.'of the licensee's efforts, when .evaluated in ~. . - the context of the Commission~s Equal Employment Opportunity
( Rules and the decisions applying them, it is clear tha't .'--../' neither the designation of its renewal applications for
hearing, nor any other EEO sanction, is appropriate.
iii BEFORE THE FEDERAL COMMUNICATIONS COMMISSION WASHINGTON, D.C. 20554
In re Application of ) . ) DIXIE BROADCASTING, INC. ) File Nos. BR-881201WO DEBTOR-IN-POSSESSION ) and BRH-881201WN ) ···Por ~'Renewal of -Licenses for ) Stations WHOS(AM) and WDRM(FM), ) Decatur, Alabama )
TO: Chief, Mass Media Bureau -'.
OPPOSITION TO PETITION TO DENY
I. INTRODUCTION
1. Dixie Broadcasting, Inc., Debtor-In-Possession
("Dixie"), hereby opposesll the Petition to" Deny ("Petition")
filed by Region V of the NAACP, the respective branches of
the NAACP operqting within the service areas of certain
referenced Alabama and Georgia radio statio~s., a.nef the
National ·Black Media Coalition (collectively, "Petitioners"),
with respect to the license renewal applications of various
radio stations located in Alabama and Georgia, two of which
named in the Petition are Stations WHOS(AM) and WORM(FM),
Decatur, Alabama, which are licensed to Dixie. The
Petitioners have failed to raise any substantial or material
questions of fact or law with respect to Dixie's operation of
II On March 30, 1989, Dixie filed a Motion for Extension of Time, until April 14, 1989, within which to respond to the above-referenced Petition to Deny. The Commission granted Dixie's request. Thus, this Opposition is timely. the stations during the last renewal term or with respect to
Dixie's employment practices. The Petition, therefore,
should be dismissed. 2 /
2. Specific~~LY, the Petitioners allege that
Stations WHOS and WORM do not a!?!?ear to _h~LOpp.r<3.ting under a
"meaningful" EEO program -and that the licet1see-~s·-5erf
analysis of its program contains nothing to indicate that it is aware that its EEO program has allegedly failed to produce
meaningful results during the license term. See__ .".PetItion4 at:. pages 2 and 6. The Petitioners' ch~racterization of Dixie's
program and efforts is totally faulty. Although- no -:. - .
minorities have been reflected in the WHOS/WDRM ',.Annual- . Employment Reports (FCC Form 395-B) during\the license term,
the record indicates, as set forth more fully below, that the
-~ stations have been aware of the need to recruit and hire
qualified minority and female employees and have demonstrated
2/ Dixie also submits that both the NBMC and the-NAACP lack ;~tanding to bring the Petition and that, therefore, the Petition should be treated as an informal objection. Section 309(d)(l) of the Communications Act of 1934 states that a petition to deny must allege specific allegations of fact sufficient to show that the petitioner is a party in interest as supported by affidavits or statements under penalty of perjury. 47 U.S~C. S 309(d)(1). See also American Legal Foundation v. FCC, 808 F.2d 84, 90-91 (D.C. Cir. 1987) and Mississippi Broadcast Renewals, 59 FCC2d, 1335, 1336 (1976). Neither the Statement submitted by Pluria W. Marshall, Chairman of the NBMC, nor the Declaration submitted by Earl Shinhoster, Director of Region V of the NAACP, establish that Mr. Marshall or Mr. Shinhoster are listeners or residents within the listening area of Stations WHOS/WDRM. Therefore, neither the NBMC nor the NAACP demonstrate the required nexus between them and the challenged stations. Consequently neither should be treated as a party in interest.
- 2 -
7 positive and continuing efforts to do so. When the stations' efforts are evaluated in the context of the FCC's rules and the Commission's decisions applying them, it is clear that the denial of Dixie's renewal applications or the bmposition of any other sanction ~0~1~ b~ II. DISCUSSION 3. Contrary to the Petitioners' allegations,
Dixie's record indicates that during the November 1, 1987 to
November 2, 1988 reporting period, as well as during the other six years of the stations' license term, the licensee has demonstrated a continuous effort to seek out minority and " .~ . female employees for available positions and to improve the representation of minorities on the statio~s' staff.
A. 1988 Reporting Period
4. During the. 1988 reporting period, Dixie's EEO .- program (FCC Form 396) reflects the licensee's contact with a substanti~l number of recruitment sources. The licensee placed ·advertisements for job openings in Broadcasting
Magazine and Radio and Records, recruited prospective employees from the National Career College and the University
3/ The factual matters represented herein which are not the subject of official notice by the Commission are verified by Nat Tate, a current employee of WHOS/WDRM and by J. Mack Bramlett, the licensee's Vice President and General Manager of Stations WHOS and WORM, in Statements under penalty of perjury which are attached hereto as Exhibits A, and C, respectively. Unexecuted copies of the Statements are being submitted at this time. The executed Statements will be submitted to the Commission shortly as a Supplement to this Opposition.
-J- of Alabama -- both with substantial mi~ority enrollments, and
encouraged current station employees to refer qualified job
candidates for openings.~/ From these sources, the licensee
received two female referrals ... In addition, the licensee
",1$("I-J~0!:yj!.!<:;tedan int:.ernship program with the University of , . Alabama. . During the summer of 1988 (as well as during the
summer of 1987), two students, one female and one male,
received training in promotion and on-air positions. The
licensee anticipates continuing the internship program in the . future. In addition, in 1988, two women were promoted in
upper-level job positions. With respect to new hires, the
licensee hired 12 new employee~,51 including six.women, of
whom two were for upper-level job positions. (
41 The Petitioners (at p. 6 of the Petition) attack the licensee because'no community organizations were contacted during the 1988 reporting period. In fac~, the licensee has, .- at various times during the license term,' contacted community organizations; however, because such organizations' have not bee~ ~ successful recruitment source, the licensee has chosen not to rely on these organizations. Instead, the licensee has lOOked to other sources which have been more responsive, including local educational institutions" and newspapers. Such a procedure is exactly what the Commission expects licensees to do when recruitment sources prove unresponsive. Therefore, contrary to the Petitioners' allegations, the licensee has been aware of which recruitment sources produce meaningful results and which do not, and has relied on the sources that have proven to be most responsive.
51 Although 16 new hires were reflected in the stations' 1988 EEO Program, there were actually 12 new hires during the reporting period. Four individuals, who had been paid talent fees for production work they performed on a one-time basis as independent contractors but who never actually worked as station employees, were incorrectly included in the "new hire" total.
- 4 - 5. Stations WHOS/WDRM are licensed to Decatur,
Alabama, which is located in Morgan county and is not part of
any MSA.~/ Consequently, the relevant work force in
evaluating the stations' emplo~ent profile is Morgan County. According to 1980 Unit.ed States Census data,?-I the civilian labor f(n.·ce in Morgan· Count.y' is 39.8% female and 7.4% Black,
with other racial minorities represented in statistically
insignificant numbers. 8 / The stations' 1988 Annual
Employment Report indicates that the licensee employed 20
fulJ.-time employees, of" whom eight (or 40%) were women, a~d
18 upper-level employees, of whom six (or. 33.3%) were
61 In 1988, a new MSA was created by Congress consisting of Morgan County and part of adjacent Lawrence County. However, this new MSA was not created by the U.S. Census Bureau and therefore is not reflected in U.S. Census ( data. Since the FCC relies on the U.S. Census as the source of its labor force data, the licensee has also relied on U.S. Census data, and, thus, has utilized Morgan County as its frame of reference for local civilian wor~ force data.
LI . See 1980 Census Data Summary Report -- State and County Total Percentage for Total Employed Civilian Labor Force:.--- Morgan County, Alabama.
81 Other racial minorities are represented in Morgan County as follows: 0.5% Hispanics; 0.2% Asians or Pacific Islanders; and 0.1% American Indians or Alaskan Natives. rd. The Petitioners claim (at p. 3 of the Petition) that minorities represent 8.7% of the Decatur, Alabama market, not 8.2% (i.e., 7.4% Blacks, plus 0.5% Hispanics, 0.2% Asians, and 0.1% American Indians) as reflected in the 1980 Census data. The Petitioners' data, the source of which is not identified, cannot be relied upon as representative of the Decatur civilian labor force.
- 5 -
/0 women. 9/ Although no minorities are reflected in the
stations' 1988 Annual Report, the licensee did undertake
.~' substantial attempts to hire minorities, and, in fact, in
February 1989, before the filing of the Petition, hired Kathy
E. Jordan, a Black woman, for the full-time position of
." P~.~~lic ·.!<..ffairs Director and afternoon drive-time news
announcer. Dixie requested referrals for that position from
the National Career College in August and September 1988.
.'. However, the College had sent none. Ms. Jordan, who had
worked at another local radio station, heard about the job by:
.- .. > word-of-mouth. She was hired on February 17 and is still
working at the stations.
6. In October 1988, the stations interviewed Carol
\ ( Washington, a Black woman, for the Public Affairs Director posLtion. Ms. Washington had owned a dress shop located near
the stations and had become friendly with ~any of the women
on the stations' staff. When Ms .. Washington . decided to sell
her business t she had approached Mr. Bramlett, the stations'
General Manager, about working at the stations. In December,
Mr. Bramlett offer~d her the position. However, due to
family problems and commitments, Ms. washington was unable to
accept the offer at that time. When she subsequently
~I See Exhibit B for charts of the year-by-year employment statistics for WHOS!WDRM, as well as for other stations licensed to Decatur for 1982-1988, as reflected in their FCC Annual Employment Reports (FCC Form 395-B) for their overall work force and top-four job categories.
- 6 -
I(