In the Matter of Review of EEO Compliance and Enforcement in Broadcast and Multichannel Video Programming Industries, MB Docket No. 19-177.  the Massachusetts Broadcasters Association, in combination with the state broadcasters associations of all 50 states, the District of Columbia, and Puerto Rico, filed extensive Reply Comments in this proceeding noting the questions raised by federal appellate courts as to the constitutionality of the FCC’s EEO Rule, and the corresponding need for the Commission to more narrowly tailor the rule to meet constitutional requirements and thereby lessen the burden on broadcasters.

Additionally, the Reply Comments advocated eliminating the FCC’s program of random annual EEO audits of broadcasters, as such audits are costly, burdensome, and have proven unproductive for both the FCC and broadcasters, as they have merely confirmed what is already known—that broadcasters have an excellent record of compliance with the EEO Rule despite the extensive paperwork burdens that entails.  The Reply Comments also opposed numerous proposals submitted in the proceeding that would have only served to make the EEO Rule more burdensome without any countervailing need or benefit.

Thanks to the incredible work by Pillsbury Law’s Scott Flick and Lauren Lynch Flick in this matter.

Read the full reply comments using the link below.

The State Broadcasters EEO Reply Comments 11 4 2019