In January 2001, the United States Court of Appeals for the District of
Columbia Circuit vacated the FCC's EEO rules, which had been in effect only
since April 2000. The FCC suspended the EEO rules promptly after the court's
decision, pending further judicial review. Those rules, sometimes know as the
"Option A/B Rules," had been devised and put into place in response to
an April 1998, decision of the same court, which invalidated an earlier set of
EEO requirements. The EEO rules were applicable to broadcast stations and cable
television systems.
Background
For many years prior to 1998, the Commission's EEO rules had two primary
components, recruitment obligations and employment reporting which resembled a
"quota" system, with comparisons of station employment overall and in
its "top four" job categories to employment of minorities and women in
the local market. Both components included substantial record-keeping and
reporting requirements. In large measure, the court in
