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Media Bureau Mails MVPD EEO Audit Letters

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Released: October 25, 2013


News Media Information 202 / 418-0500

Federal Communications Commission

Fax-On-Demand 202 / 418-2830
445 12th St., S.W.
TTY 202 / 418-2555

Washington, D.C. 20554

DA 13-2072

Released: October 25, 2013


On October 23, 2013, the Federal Communications Commission mailed the third set of its Equal
Employment Opportunity (EEO) audit letters for 2013. This mailing was sent to randomly
selected multi-channel video programming distributors (MVPDs). In accordance with the
provisions of Sections 73.2080(f)(4) and 76.77(d) of the Commission's Rules, 47 C.F.R.
73.2080(f)(4), 76.77(d), the FCC annually audits the EEO programs of randomly selected
broadcast licensees and MVPDs. Each year, approximately five percent of all broadcast stations
and MVPDs are selected for these random EEO audits. By Public Notice DA 13-301, released
February 28, 2013, and Public Notice DA 13-1443, released June 28, 2013, the Media Bureau
announced its mailing of similar audit letters to the broadcast stations listed in the attachments to
those Public Notices.
A list of the MVPD units to which these October 3, 2013 audit letters were sent is attached, along
with a copy of the audit letter.
Media Bureau Contact: EEO Staff at 202-418-1450.

Employment Unit ID MSO/OPR Name County State
599970 Ace Telephone Association Houston MN
Advance Newhouse Partnership LLC Kern CA
Atlantic Broadband Queen Anne MD
Atlantic Telephone Membership Corp. Brunswick NC
10857 Cable One, Inc. Twin Falls ID
12310 Charter Communications Fairfield CT
12365 Charter Communications Olmsted MN
12378 Charter Communications Butte CA
12465 Charter Communications Los Angeles CA
Charter Communications
Gwinnett GA
Charter Communications Genesee MI
Charter Communications
Pettis MO
Charter Communications
Greenville SC
Charter Communications
Charter Communications
Clark WA
Comcast Cable Communications, LLC Hinds MS
Comcast Cable Communications, LLC Lancaster PA
Comcast Cable Communications, LLC Wayne MI
Comcast Cable Communications, LLC Hartford CT
Comcast Cable Communications, LLC Cook IL
Comcast Cable Communications, LLC New Castle DE
Comcast Cable Communications, LLC Hartford CT
Comcast Cable Communications, LLC Miami Dade FL
Comcast Cable Communications, LLC Kent DE
Comcast Cable Communications, LLC Washtenow MI
Cox Communications, Inc.
Santa Barbara CA
Cox Communications, Inc.
Kent RI
EPB Fiber Optics
Hamilton TN
Fibernet Monticello
Wright MN
Knology, Inc.
Richmond GA
Mediacom Communications Corporation Marshall KY
Mediacom Communications Corporation Greene MO
Mediacom Communications Corporation Dougherty GA
Mid Coast Cablevision, LP
Wharton TX
Northland Communications Corporation Bonner ID
Pencor Services, Inc.
Wyoming PA
Suddenlink Communications
Pope AR
Suddenlink Communications
Midland TX
Suddenlink Communications

Evangeline LA
Suddenlink Communications
Smith TX
Telecommunications Management, LLC Dunklin MO
Time Warner
Time Warner
Outagamie WI
Time Warner
Erie PA
Time Warner
Mecklenburg NC
Wideopenwest Networks, LLC
Windjammer Communications LLC
Anderson TX
Wire Tele-View Corporation
Schuylkill PA
Zito Media, L.P.
Potter PA

October 23, 2013
Dear Manager:
1. In accordance with the provisions of 47 C.F.R. 76.77(d) of the Commission's Equal
Employment Opportunity ("EEO") rules, your employment unit has been randomly selected for an
audit of its EEO program. (A copy of 47 C.F.R. 76.77 and the other rules referred to in this letter
are enclosed for your reference.)
2. If the unit is not required under our rules to have an EEO recruitment program due to the size of its
full-time workforce (having fewer than six full-time employees, defined as employees regularly
assigned to work 30 hours a week or more), you still must respond to this audit letter. In your
response, however, you must provide only a list of the unit's full-time employees, identified only by
job title (no names should be provided) and the number of hours each is regularly assigned to work
per week, and a response to question 3(e) below.

Audit Data Requested.

If the unit employs six or more full-time employees (as defined above),
provide the following information in your response to this letter, including an explanation regarding
any requested information that you are unable to provide:
(a) The employment unit's most recent EEO program information, described in 47 C.F.R.
76.1702(b), which should have been placed in the unit's public file by October 1, 2013. If the unit
has a website, provide its web address. If the unit's most recent (2012) EEO public file report is not
included on or linked to by the website, in violation of 47 C.F.R. 76.1702(b), provide an
explanation of why the report is not so posted or linked to. If the unit does not have its own
website, but its corporate site contains a link to a site pertaining to the unit, then the unit's most recent
EEO public file report must be linked to either the unit's site or the general corporate site, pursuant to
47 C.F.R. 76.1702(b).
(b) For each full-time position filled during the period covered by the above EEO program
information, or since your acquisition of the unit, 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. 76.75(c)(3). 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. 76.75(b)(1)(ii). Also include the date that
each position was filled and the recruitment source that referred the hiree, as described in 47 C.F.R.
(c) In accordance with 47 C.F.R. 76.75(c)(5), 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 program information.
(d) Documentation demonstrating performance of unit recruitment initiatives described in 47
C.F.R. 76.75(b)(2) during the time period covered by the above-noted EEO program information,
such as participation at job fairs, engaging in mentoring programs, and providing 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 the
unit is located is 250,000 or more. Based upon these two factors, determine and state whether the unit
is required to perform one or two initiatives within a 12-month period, pursuant to 47 C.F.R.

(e) Disclose any pending or resolved complaints involving the unit filed during the past five
years 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, age, or sex. For each such complaint, provide: (1) a brief description of the
allegations and issues involved; (2) the name(s) of 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. 76.75(f), describe the unit's efforts to analyze its
recruitment program to ensure that it is effective in achieving broad outreach and how the unit has
addressed any problems found as a result of such analysis.
(g) In accordance with 47 C.F.R. 76.75(g), describe the unit's efforts to analyze its EEO
policies and employment practices to examine seniority, promotions, pay, benefits, 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.
Address any problems found as a result of this 47 C.F.R. 76.75(g) analysis and how the unit has
resolved them.


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 December 9, 2013. The accuracy and completeness of the response
must be certified to by an authorized officer, partner or other principal of the owner of the unit. 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), and/or forfeiture (47
U.S.C. 503). Absent an extension of time, failure to respond to this audit letter by the above
deadline is also punishable by sanctions in accordance with 47 C.F.R. 76.77(f) and may result in a
certification that the unit is not in compliance for 2013 with the Commission's EEO rules.
Extensions of time must be requested in writing (or e-mail sent to and will be
granted only upon a showing of extraordinary circumstances.
5. In accordance with 47 C.F.R. 76.79, a copy of this letter and your response will be placed in the
Commission's public file for the unit. Consequently, your response should not include personal data
about individuals, such as social security numbers, home addresses, or other personally identifiable
information. We do not require that units retain such information in their records, or that such
information be provided in response to this audit letter. Should you have any questions, please
contact the EEO Staff at (202) 418-1450. Thank you for your cooperation.
Lewis C. Pulley
Assistant Chief, Policy Division
Media Bureau

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